As the world’s leading travel club, TRAVEL SECRETS connects travelers with travel services and products offered by third parties, such as flights, accommodations, rental cars, packages, and travel insurance. This involves sharing personal information with third parties, including online travel agencies, hotels, rental car providers, airlines, and others (collectively, “Travel partners”).
For more information about the information we share with third parties and the recipients of such information, please refer to the How We Share Your Information section of this Policy. Please note that this Policy does not otherwise cover the use of personal information by third parties or their services, and we do not take responsibility for their privacy practices.
You may have certain rights or choices that relate to your personal information, including choices about how we share your personal information with others. For more information, please refer to the Your Choices and Rights section of this Policy.
|Information We Collect and Use||When you use or visit our Services, we collect information directly from you (e.g., when you make a booking or reservation). We may also generate information about you (e.g., information about your device while you use our mobile application). In some cases, we also obtain personal information from third parties (e.g., our group companies, business partners, third-party websites, applications, and services, and others).
Your TravelSecrets Travel Club membership includes your acceptance to receive the Travel Secrets email newsletter, to which you can opt to unsubscribe at any time with the unsubscribe link.
|How We Use Your Information||We use your information to provide our Services, tailor your experience, show you bookings and transactions made with our travel partners through TRAVEL SECRETS and our group companies, send you marketing communications, and provide you with more relevant advertising and offers that may be of interest to you, and for other purposes described below.|
|How We Share Your Information||We share your information with our travel partners; with our group companies; with other business partners (including advertisers); with social networking services; with third-party services or applications you use to log into your TRAVEL SECRETS account; with service providers (including payment card processors); and others as described below. We share information to provide and improve our Services, for our own marketing purposes, to facilitate offers and advertising from others that may interest you, and for other purposes as described below.|
|How We Store and Protect Your Information||We maintain technical, administrative, and physical security measures designed to protect your information. We may retain your information for as long as your account is active and for a period of time thereafter to allow you to re-activate your account without loss of information, and as necessary for purposes described below.|
|Your Choices and Rights||You have choices about your personal information, and in some circumstances, you may be able to opt out of receiving marketing communications, change your communication preferences, access and update your information, update location sharing options, exercise choices regarding cookies, and/or opt out of certain sharing of information with third parties (including our group companies, travel partners, and other business partners). These choices and other rights you may have are described in more detail below.|
|International Transfers of Information||We operate internationally, and information about you may be transferred to, or accessed by, entities located in countries outside of your home country. To protect your information, any such international transfers will be made in accordance with applicable law.|
|Links to Other Websites||Our Services may contain links to other websites or services that are not owned or controlled by TRAVEL SECRETS, including links to websites of our travel partners, our group companies, and other business partners (including advertisers).|
|Children||Our Services are not directed at or intended for use by children, nor do we knowingly collect information from children under 16 years of age.|
|Changes to This Policy||We update this Policy from time to time, and changes will be effective when posted (as identified in the Policy).|
|How to Contact Us||If you have any questions about this Policy or the way your personal information has been used, please contact us using our feedback form or at the contact details set out below.|
“Personal information” is data that identifies, relates to, describes, can be used to contact, or could reasonably be linked directly or indirectly to you. For purposes of this Policy, there is no meaningful distinction between the terms “Personal information” and “Personal data”
Personal Information We Collect Directly From You. As you visit or use our Services, we collect the following categories of personal information directly from you:
You may choose not to provide some of the personal information described above. Please note, however, that many of our Services require some personal information to operate, so if you choose not to provide the personal information necessary to operate and provide you with a particular Service or feature of that Service, you may not be able to use that Service or feature.
We do not proactively collect sensitive personal information, such as health-related information. However, our Services include text boxes that are designed for you to describe certain details about your travel preferences or special requests that you want us or our travel partners to know. Please be aware that information you freely submit in these boxes may reveal to us or to the travel partners or third parties with whom we share information (as detailed in the How We Share Your Information section below) certain information that may be considered sensitive personal information under applicable law (for example, information about dietary restrictions or disability accommodations). Sensitive personal information you voluntarily submit is processed on the basis of your consent, which you may revoke at any time by contacting us at the details set out in the How to Contact Us section below.
Personal Information Generated By Us. As you use our Services, we generate certain personal information about you, including through automatic data collection and by inferences based on the information we collect about you and your activity. We may automatically collect information about your interactions with the Services or communications you receive (such as email) using certain technologies, such as cookies, web beacons and other technologies (see our Cookies and Interest-Based Advertising Policy for more details). We generate the following categories of personal information about you:
Personal Information We Obtain from Third Parties. We may also receive certain categories of personal information from third parties, such as third-party websites, applications, social media networks, and services (each, a “third-party platform”), our group companies, travel partners, and other third parties, including individuals who have shared their travel itineraries with you through our Trips service. If you are an existing TRAVEL SECRETS user, we will combine this information with information we collect through our Services and use and share it for the purposes described below. The categories of personal information we may obtain from third parties includes:
We use your personal information for the following purposes (“Purposes”), to:
You have choices about your personal information, and in some circumstances, you may have the right to opt out or object to our uses of your personal information for these Purposes. For more information, or to exercise these or other rights (where available), see the Your Choices and Rights section below.
Trip Services. If you register for an account, send a booking confirmation to our Trips service or make a booking through our Services, you will have access to our Trips service, where we will collect your travel information to create and maintain your travel itineraries. If you directly send us booking confirmation emails, you authorize us to parse these emails automatically or manually and to add the information you provide to your Trips account, along with other information that we have collected (including saving a copy of the original email to your Trips account). If you sign up for the synchronization of your emails to our Trips service, you authorize us to access the emails in the email accounts you have connected to Trips, to regularly review these emails in order to identify those that are booking confirmations that we can import into our Trips service, to parse these emails automatically or manually and to add the information we have collected to your Trips account (including saving a copy of the original email to your Trips account). To the extent permissible by our email synchronization partners, we use the information in your Trips account to show you more relevant search results (e.g., accommodations you previously booked) or to provide you statistics about your travels, and we may use such information for marketing communications as described above. If you use or have itineraries as part of our Trips Service, you can send or grant access to your itinerary to anyone you choose. Your itinerary may contain enough details (e.g., booking reference codes) to allow the recipient to cancel or modify your booking, perform a check-in, etc. You should only share your itinerary with people you trust. Please also refer to our Getting Started with Trips page and the detailed Trips FAQ for answers to frequently asked questions, and visit your Account page to update your account settings and preferences. If you choose to display your itinerary on publicly-viewable web pages (Facebook, for instance), that information may be collected and used by others.
Electronic Communications. Consistent with the above Purposes and as permitted by applicable law, we may communicate with you via electronic messages, including email, text message, or mobile push notification to:
With your consent, where required, we may contact you at the mobile phone number that you provide to us by way of direct dial calls, autodialed and prerecorded message calls, and text messages in connection with the above Purposes.
Our Role as Data Controller. For purposes of European Union law and similar data protection regimes, we generally act as a data controller, meaning we determine the purposes and means of processing your personal information. Our travel partners to whom we may connect you to make reservations are also data controllers. To about how a travel partner may use your personal information, you should review its privacy notice.
Processing Bases and Consequences. When we process your personal information, we rely on the following legal bases:
When we use personal information to meet our legitimate interests, we take steps to ensure that your rights to your personal information are not infringed. You can contact us using the details set out in the How to Contact Us section below for more information about the steps we take to ensure these rights are not infringed. You also have the right to object to such processing as described in the Your Choices and Rights section below.
Aggregate Information. We aggregate personal information collected directly from you, information generated about you by us, and information obtained from third parties (with your consent, where required) with personal information collected about other users in order to produce general statistics that cannot be linked to you or any other specific user. Information that has been aggregated and de-identified is no longer considered “Personal information” and may be subsequently used for any purpose.
Anonymized Information. We may process information that cannot be linked to you or any other specific user using any means available to us, either because it was collected anonymously or has been subsequently anonymized. Information that is anonymous or has been anonymized is no longer considered “Personal information” and may be subsequently used for any purpose.
We disclose the personal information we collect (or otherwise generate or obtain) as follows:
In some circumstances, you may have the right to opt out or object to our sharing of your information with certain third parties. For more information, or to exercise these or other rights, see the Your Choices and Rights section below.
When you make a request, we also share with the travel partner additional information about you, such as information about your travel activity and history, and/or information that we collect from you and third parties. Travel partners use this information for their own purposes, which may include to improve their products or services and to provide you with targeted advertising and marketing communications, where permitted under law.
To about your choices related to how we share your information with our group companies (including our subsidiaries, our parent company, and its other subsidiaries), please see the Your Choices and Rights section below.
For example, if you frequently search for flights from Seattle to Paris around certain holidays, we may share that information with a particular airline partner so it can better understand which of our customers are interested in flights from Seattle to Paris on certain dates. The airline partner may then, for example, use this information to offer you a promotion.
To about your choices related to how we share your information with our business partners, please see the Your Choices and Rights section below.
TRAVEL SECRETS maintains commercially-reasonable technical, administrative, and physical security measures designed to protect your information from loss, misuse, unauthorized access, disclosure, alteration, and destruction.
When your payment information is being transmitted to our Services or through our Services, it will be protected by cryptographic protocols. To be clear, TRAVEL SECRETS only stores your payment information if you choose to save that information to your account. When you submit a booking or reservation, we transfer your payment information to the applicable travel partner to process the transaction. Our contracts with third parties that receive your payment information require them to keep it secure and confidential.
However, we cannot guarantee that transmissions of your payment information or your other information will always be secure or that unauthorized third parties will never be able to defeat the security measures taken by TRAVEL SECRETS or our third-party service providers. Except to the extent that liability cannot be excluded or limited due to applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control. You play an important role in keeping your information secure. You should not share your user name, password, or other security information for your TRAVEL SECRETS account with anyone. If we receive instructions using your user name and password, we will assume you have authorized the instructions. If you have reason to believe that your interaction with us is no longer secure (e.g., if you feel that the security of any account you might have with us has been compromised), please contact us immediately as detailed in the How to Contact Us section below.
Retention. We may retain your personal information for as long as your account is active and for a period of time thereafter to allow you to re-activate your account without loss of information. We may also retain your personal information as necessary to:
When you use or visit the Services, we collect information about your usage and activity using cookies, web beacons, and other technologies. Third parties may also view, edit, or set their own cookies. We and our third-party service providers, affiliates, and other business partners may also place web beacons for these third parties. The use of these technologies by third parties is subject to their own privacy policies and is not covered by this Policy, except as required by law. See our Cookies Policy for more details.
Email. If you no longer want to receive marketing and promotional emails from TRAVEL SECRETS, you may click on the “unsubscribe” link in such emails to opt out of future marketing email communications. If you have a TRAVEL SECRETS account, you may also opt out of marketing emails in your account settings. Please note that even if you opt out of receiving marketing communications from one or all of our Services, we will still send you service-related communications, such as confirmations of any future bookings you make.
Push Notifications (on Mobile Devices). You can use the settings on your mobile device to enable or turn off mobile push notifications from TRAVEL SECRETS.
Text Messages. If you no longer want to receive text messages from TRAVEL SECRETS, reply STOP (or as otherwise instructed) to the text message. If you have a TRAVEL SECRETS account, you may also adjust your account settings to opt out of text messages.
Cookies and Interest-Based Advertising. To exercise choices regarding cookies set through our websites or Services, as well as other types of online tracking and online advertising, see our Cookies and Interest-Based Advertising for more details. We currently do not employ technology that recognizes “do-not-track” signals from your browser.
Application Location. As explained in more detail in the Information We Collect and Use section above, we collect information about your location if you enable location services through the settings in your mobile device, or with your consent, as may be required by law. You can change the privacy settings of your device at any time to turn off the sharing of this location information with our Services. If you choose to turn off location services, this could affect certain features of our Services. If you have specific questions about the privacy settings of your device, we suggest you contact the manufacturer of your device or your mobile service provider for help.
Sharing with third parties. As described above in the How We Share Your Information section, we share your information with third parties for their own purposes or work with those partners to support their own marketing purposes. You can opt out of sharing your information with:
You can opt out of such sharing by changing your TRAVEL SECRETS account preferences. You may also send such opt-out requests to us as described in the How to Contact Us section below.
Access and Correction of Your Information. If you have created an online account with us and would like to update the information you have provided to us, you can access your account to view and update your information. You may also contact us as described in the How to Contact Us section below.
Legal Rights. Where applicable under local law, you may have the following rights regarding your personal information: the right to access personal information we hold, and in some situations, the right to have that personal information corrected or updated, erased, restricted, or delivered to you or a third party in a usable electronic format (the right to data portability). Where applicable, you may also object to how we use your personal information if the legal basis for processing that information is our legitimate interest. Where we are using your personal information on the basis of your consent, and where applicable under local law, you have the right to withdraw that consent at any time. Where you have granted consent to receive direct marketing communications from us, and where applicable under local law, you may withdraw that consent at any time.
If you wish to exercise the legal rights you may have under applicable law, please submit your request by using our feedback form. So that we can better process your request, please provide the email you use to log into your TRAVEL SECRETS account. If you do not have a TRAVEL SECRETS account, please provide the email you used to make requests or to use our Services.
Where applicable, you may also have the right to register a complaint to your local data protection authority. For residents of the EU and UK, contact the EU data protection authorities. For residents of Australia, if you are not satisfied with the outcome of your complaint after first contacting us, you may wish to contact the Office of the Australian Information Commissioner.
Information about you will be transferred to, or accessed by, entities located around the world as described in this Policy. Some of these entities may be located in countries that do not provide an equivalent level of protection for personal information as your home country.
We have put in place safeguards to provide adequate protection for transfers of certain information, in accordance with applicable legal requirements. For more information on the appropriate safeguards in place, or to request a copy of these safeguards, please contact us using the contact details listed in the How to Contact Us section below.
Our Services contain links to other websites or services that are not owned or controlled by TRAVEL SECRETS, including links to websites of travel partners and our advertisers, our group companies, and other business partners. This Policy only applies to information collected by our Services. We have no control over these third party websites, and your use of third party websites and features are subject to privacy policies posted on those websites. We are not responsible or liable for the privacy or business practices of any third party websites linked to our Services, including those of our group companies. Your use of third parties’ websites linked to our Services is at your own risk, so we encourage you to read the privacy policies of any linked third party websites when you leave one of our Services.
Our Services are not directed at or intended for use by children. We do not knowingly collect information from children under 16 years of age. If you become aware that your child or any child under your care has provided us with information without your consent, please contact us using the contact details listed in the How to Contact Us section below.
If you have any questions about this Policy or the way in which your personal information has been used, please contact us using our feedback form or by postal mail at:
TRAVEL SECRETS Attn: Data Protection Officer, 5042 Wilshire Blvd. #16955, Los Angeles, CA USA 90036
We use “first-party cookies,” i.e., those that are used solely by us or by third parties who act only on our instructions or on our behalf. These types of cookies are used for our own analysis of our own Sites, or to provide functionality such as remembering your language preference.
Other cookies on our Sites are used both by us for the purposes described in this policy and by third parties for purposes where those third parties may wish to combine information from our Sites with information from other sites to improve their services. For example, these types of cookies may be used for interest-based advertising purposes.
The cookies used on our Sites, by either us or by third parties, can be “session” cookies, or “persistent” cookies. “Session” cookies are deleted automatically when you close your browser, and are used for things like ensuring you are kept logged in as you navigate around our Sites. “Persistent” cookies remain stored on your device or browser even after you close it. These cookies are used, for example, to recognize you when you come back to our Sites.
We divide the cookies we use into three categories:
|Type of cookie||Description of how we use this type of cookie||What choices do you have?|
|Required||To provide a secure log-in to our Sites. To keep you logged in so that you do not have to log in repeatedly to access different pages of the Sites.||Required cookies are necessary for our Sites to operate. On some platforms, you can delete all cookies, but this may affect the basic functionality of the Sites.|
|Functional||To recognize you if you have visited previously, and remember your preferences from past visits, such as your language preference. To track when you make purchases or bookings on websites operated by our group companies (e.g., travel bookings on Booking.com, restaurant reservations on OpenTable, or car rentals on Rentalcars.com), so that we can display your bookings with our group companies on your account page. To improve our Sites and our offerings by helping us to understand how users use the Sites and to analyze trends which appear in that data. For example, we make changes to the user interface if we can see that certain pages are difficult for a large number of users to navigate. We also collect broad information about how our users use the Sites, for example, to understand which aspects of our Sites and our services are particularly popular, so that we can make improvements going forward. To personalize your experience of our Sites, for example, by showing you offers on our homepage or in emails that are most relevant to you based on your previous visits to our Sites or those operated by our group companies or by ranking certain types of options (e.g., only non-stop flights) higher in your search results.||Where required by law, functional cookies will only be used on the Sites where you have given your consent to their use.|
|Advertising (e.g., Google DoubleClick, Google Ads, Oath, Bing Ads)||To recognize you if you have used our services on another device. We combine information received from multiple devices to determine if you are using a new device, so that we can continue to provide you with a personalized experience on our Sites. To enable you to post to social media sites and other platforms, for example, to allow you to access a particular social media page to post a comment or a “like.” To collect information for use in advertising on our own Sites and on third party sites which you may visit. Such information is based on your preferences and your usage of our Sites. We have included more information about our use of advertising cookies below.||Where required by law, advertising cookies will be used only on the Sites where you have given your consent to their use. See the section entitled “Your Cookie Choices” below to about how to withdraw your consent to advertising cookies.|
We work with third parties that place cookies on our Sites to provide their services, including:
These companies may use information obtained through their cookies (which does not include your name, address, e-mail address or telephone number) about your visits to our Sites and other websites, in combination with information about your purchases and interests from other online sites in order to provide advertisements about goods and services of interest to you.
Mobile Devices, Anonymous Device Identifiers and Hashed IDs. We and/or third parties that we have engaged may collect and store a unique identifier matched to your mobile device, in order to deliver customized ads or content while you use applications or surf the internet, or to identify you in a unique manner across other devices or browsers. In order to customize these ads or content, we or a third party may collect de-identified usage data or other data about you which you have either voluntarily submitted to us, for example, your email address, or has been passively collected from you, such as your device identifier or IP address, where permitted. However, if we share your email address, we share it solely in hashed, non-human-readable form.
When you first visit our Sites, where required by law, you will have the option to give your consent to the advertising and functional cookies we use, or to refuse your consent to our use of those cookies by clicking on the [X] within that disclosure.
Browsers. Most browsers accept cookies by default. You may be able to change the settings to have your browser refuse certain cookies or notify you before accepting cookies. To do so, please follow the instructions provided by your browser which are usually located within the “Help”, “Tools” or “Edit” facility. Some third parties also provide the ability to refuse their cookies directly by clicking on an opt-out link, and we have tried to indicate where this is possible in the table above.
You can also find more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, at www.allaboutcookies.org and www.youronlinechoices.eu.
Mobile Devices. If you no longer wish to receive interest-based advertising on your mobile applications, please refer to your device’s operating system settings and follow instructions below.
If you no longer wish to receive interest-based advertising on your mobile device browser, you can follow the steps in relation to Browsers outlined above.
Do-Not-Track Signals. We currently do not employ technology that recognizes “do-not-track” signals from your browser.
Please keep in mind that, without cookies, you may not have access to certain features on our Sites, including access to your profile/account and certain personalized content. Removing all cookies from your computer could also affect your subsequent visits to certain websites, including our Sites, by requiring that, for example, you enter your login name when you return to that website. Please note that even if you exercise any of the choices described above, you will still see ads, but they will not be based upon the information collected through these tracking technologies, and therefore not necessarily relevant to your interests.
Policy Effective Date. March 31, 2022