PRIVACY STATEMENT AND COOKIE STATEMENT

Last Updated: December 12, 2022

Jetsetter Lux, LLC, values you as our customer and recognizes that privacy is important to you. This Privacy Statement explains how we collect, use, and disclose data when you use our platform and associated services, your rights in determining what we do with the information that we collect or hold about you and tells you how to contact us.

What does this Privacy Statement cover?

This Privacy Statement is designed to describe:

· How and what type of personal information we collect and use

· When and with whom we share your personal information

· What choices you can make about how we collect, use, and share your personal information

· How you can access and update your information.

What personal information do we collect and use, and how do we collect it?

We collect personal information when:

· You give us the information

· We collect it automatically

· We receive it from others

When you create an account on one of our sites, sign up to receive offers or information, or make a booking using our platform, you give us your personal information. We also collect such information through automated technology such as cookies placed on your browser, with your consent where applicable, and when you visit our sites.

How is your personal information shared?

Your personal information may be shared to help you book your travel and/or vacation, assist with your travel and/or vacation stay, communicate with you (including when we send information on products and services or enable you to communicate with travel providers and/or property owners), and comply with the law. The Privacy Statement below details how personal information is shared.

What are your rights and choices?

You can exercise your data protection rights in various ways. For example, you can opt out of marketing by clicking the “unsubscribe” link in the emails, in your account as applicable, or contacting our customer service. Our Privacy Statement has more information about the options and data protection rights and choices available to you.

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Privacy Statement

Categories of Personal Information We Collect

Use of Personal Information

Sharing of Personal Information

Your Rights and Choices

Privacy Shield

Security

Record Retention

Cookie Statement

Contact Us

Updates to Privacy Statement

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Categories of Personal Information We Collect

When you use our platform, Apps, or associated tools or services, we may collect the following kinds of personal information from you as needed:

· Name, username, email address, telephone number, and home, business, and billing addressees (including street and postal code)

· Government issued Identification required for booking or identity verification, such as driver’s license, government redress numbers, and country of residence (for travel insurance purposes), and for vacation property owners, tax identification number,

· Payment information such as payment card number, expiration date, billing address, and financial account number

· Travel-related preferences and requests such as favorite destination and accommodation types, and special dietary and accessibility needs, as available

· Loyalty program and membership information

· Birth date and gender

· Geolocation

· Images (including facial photographs), videos, and other recordings

· Social media account ID and other publicly available information

· Communications with us (such as recordings of calls with customer service representatives for quality assurance and training purposes)

· Searches you conduct, transactions, and other interactions with you on our online services and Apps

· Other communications that occur through the platform among partners and travelers, and in-group chat and traveler-collaboration tools

· The searches and transactions conducted through the platform

· Data you give us about other people, such as your travel companions or others for whom you are making a booking

When you install any of our apps or use our platform, we automatically collect the following types of information from your device:

· IP address

· Device type

· Unique device identification numbers

· Internet browser-type (such as Firefox, Safari, Chrome, and Internet Explorer)

· Internet Service Provider

· Operating System

· Mobile carrier

· How your device has interacted with our online services, including the pages accessed, links clicked, trips viewed, and features used, along with associated dates and times

· Details of any referring website or exit pages, as well as general geographic location (such as at the country or city-level)

Our Cookie Statement section, included below in this Privacy Statement, further explains how we use cookies and similar tracking technology.

Use of Personal Information

We use your personal information for various purposes described below, which depend on the site you visit or the app you use.

Your Use of Online Sites, Apps, and Services:

· Book the requested travel or enable vacation property booking

· Provide services related to the booking and/or account

· Create, maintain, and update user accounts on our platform and authenticate you as a user

· Enable and facilitate acceptance and processing of payments, coupons, and other transactions

· Administer loyalty and rewards programs

· Collect and enable booking-related reviews

Communications and Marketing:

· Respond to your questions, requests for information, and process information choices

· Enable communication between you and the travel supplier like hotels and vacation property owners

· Contact you (such as by text message, email, phone calls, mail, push notifications, or messages on other communication platforms) to provide information like travel booking confirmations and updates, for marketing purposes, or for other purposes as described in this Privacy Statement

· Market our products and services, optimize such marketing to be more relevant to you, and measure and analyze the effectiveness of our marketing and promotions

Other Business Purposes and Compliance

· Conduct surveys, market research, and data analytics

· Maintain, improve, research, and measure the effectiveness of our sites and apps, activities, tools, and services

· Monitor or record calls, chats, and other communications with our customer service team and other representatives, as well as platform communications between or among partners and travelers for quality control, training, dispute resolution, and as described in this Privacy Statement

· Promote security, verify identity of our customers, prevent and investigate fraud and unauthorized activities, defend against claims and other liabilities, and manage other risks

· Comply with applicable laws, protect our and our users’ rights and interest, defend ourselves, and respond to law enforcement, other legal authorities, and requests that are part of a legal process

· Comply with applicable security and anti-terrorism, anti-bribery, customs and immigration, and other such due diligence laws and requirements

· Operate our business using lawful business purposes and as permitted by law

Lawful bases for processing:

We will collect personal information from you only (i) where the personal information is necessary to perform a contract with you (e.g., manage your booking, process payments, or create an account at your request), (ii) where the processing is in our legitimate interests and not overridden by your rights (as explained below), or (iii) where we have your consent to do so (e.g., sending you marketing communications where consent is required). In some cases, we will have a legal obligation to collect personal information from you such as where it is necessary to use your transaction history to complete our financial and tax obligations under the law.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

Certain countries and regions allow us to process personal information on the basis of legitimate interests. If we collect and use your personal information in reliance on our legitimate interests (or the legitimate interests of any third-party), this interest will typically be to operate or improve our platform and communicate with you as necessary to provide our services to you, for security verification purposes when you contact us, to respond to your queries, undertaking marketing, or for the purposes of potentially detecting or preventing illegal activities.

We may in some cases use automated decision-making, for example, in relation to assessing fraudulent transactions or suspicious activity on our site. As part of this processing, automated decisions may be made by putting your personal information into a system and the decision is calculated using automatic processes. If you pose a fraud risk, this may affect your ability to book on our site. You may have rights in relation to automated decision making, including the ability to request a manual decision-making process instead or contest a decision based solely on automated processing. If you want to know more about your data protection rights, please see the Your Rights and Choices section below.

Sharing of Personal Information

We do not share your personal information.

Your Rights and Choices

You have certain rights and choices with respect to your personal information, as described below:

· You can control our use of certain cookies by following the guidance in our Cookie Statement included below in this Privacy Statement.

· You can access, amend, inquire about deletion, or update the accuracy of your information at any time by either logging into your account or contacting us

· For our mobile apps, you can view and manage notifications and preferences in the settings menus of the app and of your operating system

· If we are processing your personal information on the basis of consent, you may withdraw that consent at any time by contacting us. Withdrawing your consent will not affect the lawfulness of any processing that occurred before you withdrew consent and it will not affect our processing of your personal information that is conducted in reliance on a legal basis other than consent

Certain countries and regions provide their residents with additional rights relating to personal information. These additional rights vary by country and region and may include the ability to:

· Request a copy of your personal information

· Request information about the purpose of the processing activities

· Delete your personal information

· Object to our use or disclosure of your personal information

· Restrict the processing of your personal information

· Opt-out of the sale of your personal information

· Port your personal information

· Request information about the logic involved in our automated decision-making used in our fraud prevention practices and the result of such decisions

For more information on what data subject rights may be available to you, please click here.

For questions about privacy, your rights and choices, and in order to make a request to amend or update your information, or to inquire about deletion, please contact us via the options provided in the Contact Us section at the bottom of this Statement.

In addition to the above rights, you may have the right to complain to a data protection authority about our collection and use of your personal information. However, we encourage you to contact us first so we can do our best to resolve your concern. You may submit your request to us using the information in the Contact Us section, below. We respond to all requests we receive from individuals wanting to exercise their personal data protection rights in accordance with applicable data protection laws.

Security

We want you to feel confident about using our platform and all associated tools and services, and we are committed to taking appropriate steps to protect the information we collect. While no company can guarantee absolute security, we do take reasonable steps to implement appropriate physical, technical, and organizational measures to protect the personal information that we collect and process.

Record Retention

We will retain your personal information in accordance with all applicable laws, for as long as it may be relevant to fulfill the purposes set forth in this Privacy Statement, unless a longer retention period is required or permitted by law. We will deidentify, aggregate, or otherwise anonymize your personal information if we intend to use it for analytical purposes or trend analysis over longer periods of time.

The criteria we use to determine our retention periods include:

· The duration of our relationship with you, including any open accounts you may have with Jetsetter Lux, or recent bookings or other transactions you have made on our platform · Whether we have a legal obligation related to your personal information, such as laws requiring us to keep records of your transactions with us

· Whether there are any current and relevant legal obligations affecting how long we will keep your personal information, including contractual obligations, litigation holds, statutes of limitations, and regulatory investigations

COOKIE STATEMENT

Types of cookies and similar technologies

Cookies

Cookies are small pieces of text sent as files to your computer or mobile device when you visit most websites. Cookies may be delivered by us (first party cookies) or delivered by a third-party partner or supplier (third-party cookies). Cookies are either session cookies or persistent cookies. Session cookies enable sites to recognize and link the actions of a user during a browsing session and expire at the end of each session. Persistent cookies help us recognize you as an existing user and these cookies are stored on your system or device until they expire, although you can delete them before the expiration date.

Other similar technologies

· Web beacons, gifs, and clear gifs are tiny graphics, each with a unique identifier that are embedded invisibly on sites and in emails. Web beacons allow us to know if a certain page was visited or if ad banners on our sites and other sites are effective. We also use web beacons in our HTML-based emails to let us know whether our emails have been opened by recipients, which helps us to gauge the effectiveness of certain communications, promotions, and marketing campaigns.

· Proximity based beacons send one-way signals over very short distances, to communicate with associated mobile apps installed on your phone. They can notify you, for example, about experiences related to your trip and can alert you to related deals or promotions. Beacons communicate with your device only when you are in close proximity and only if you have given consent within the relevant mobile application.

· Pixels are small objects embedded into a web page that are not visible to the user. We use pixels to deliver cookies to your computer, facilitate the log-in process, monitor the activity on our sites, and deliver online advertising.

· Tags are small pieces of HTML code that tell your browser to request certain content generated by an ad server. We use tags to show you relevant advertising and promotions.

· Scripts are pieces of JavaScript code that launch automatically when certain webpages load, to determine whether users view associated advertisements.

· Local Storage Objects, such as HTML 5, are used to store content and preferences. Third-parties with whom we partner to provide certain features on our site to display advertising based upon your web browsing activity use Local Storage Objects to collect and store information.

All of the technologies described above will be collectively referred to in this Cookie Statement as “cookies”.

Jetsetter Lux’s use of cookies

At Jetsetter Lux, we use cookies for a number of reasons, including to:

· Help us improve your experience when visiting our sites

· Fulfill transactions and ensure our sites perform as intended

· Remember your preferences, such as language, region, or currency

· Provide you with relevant advertising and analyze performance of the ads

· Enable you to return to previous travel searches

· Identify errors on our sites

· Help with data protection and potentially detect and investigate malicious or fraudulent activity

· Help us understand traffic to our site, including time and date of the visit, time and date of the last visit, and other information

Types of information collected by cookies

The types of information that we collect through cookies include:

· IP address

· Device ID

· Viewed pages

· Browser type

· Browsing information

· Operating system

· Internet Service Provider

· Whether you have responded to, or interacted with, an advertisement

· Referring or referred links or URLs

· Features used and activities engaged in on our sites and in our apps

See the Categories of Personal Information We Collect section above for more information on what types of information are collected automatically.

TYPES AND FUNCTIONS OF COOKIES

Essential Cookies

Certain cookies are required or “essential” for our sites to function as intended. Essential cookies are necessary for you to navigate our site and use certain features like logging in to your account and managing your bookings. These cookies are also used to remember security settings that allow access to particular content. Lastly, we use essential cookies to collect information on which web pages visitors go to most, so we can improve our online services. You are not able to opt out of essential cookies.

How can you manage your cookies?

You can set or amend your web browser controls to accept or refuse cookies whenever you like, but please remember if you do choose to reject cookies, your access to some of the functionality and areas of our site may be restricted.

Do-Not-Track Signals and Similar Mechanisms

Some web browsers may transmit "do-not-track" signals to sites with which the browser communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether users are even aware of them. Participants in the leading Internet standards-setting organization that is addressing this issue are in the process of determining what, if anything, sites should do when they receive such signals. We currently do not take action in response to these signals. If and when a final standard is established and accepted, we will reassess our sites’ responses to these signals and make appropriate updates to this Cookie Statement.

Updates to Statement

We may update this Statement in response to changing laws or technical or business developments. If we propose to make any material changes, we will notify you by means of a notice on this page. You can see when this Privacy Statement was last updated by checking the last updated” date displayed at the top of this Statement.