Updated on November 29, 2022

 

TRVLR, Inc., a Delaware corporation ("we," "us," "our," or "TRVLR") values you as a TRVLR user and recognizes that privacy is important to you. This Privacy Policy (this "Policy") explains: (i) how we collect, use, and disclose data when you use our website located at https://trvlrpay.com, any TRVLR mobile or tablet application, or any other feature or other TRVLR platform (collectively the "Platform"); (ii) your rights in determining what we do with the information that we collect or hold about you; and (iii) how you can contact us.

 

This Policy should be read in conjunction with our Terms of Service. Depending on how you interact with us or where you are located, different sections of this Policy may apply to you and include additional rights and information related to our data collection and use practices.

By submitting personal information to us and/or by using or accessing the Platform, you acknowledge that you have read and understood this Policy and thus agree to our collection, use and disclosure of your information as described herein. Therefore, please review this Policy carefully to understand what we do in regards to your information, and where applicable, the following sections:

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• California Users. If you are a California resident, please review this Privacy Policy and see the below titled "California Privacy Statement" for additional disclosures and a description of your rights under California law.

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• European and United Kingdom Users. If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”) and your Personal Data (as defined below) is subject to Regulation (EU) 2016/679 General Data Protection Regulation (“EU GDPR”) or the EU GDPR as it forms part of the laws of the United Kingdom by virtue of section 3 of the European Union (Withdrawal) Act 2018 and as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 (the “UK GDPR”, and, together with the EU GDPR, the “GDPR”), see the below section titled "EEA & UK Privacy Statement" for additional disclosures and a description of your rights under the GDPR.

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• Brazilian Users. If you are located in Brazil and your Personal Data is subject to the Law No. 13.709 of 14 August 2018, General Personal Data Protection Law (as amended by Law No. 13.853 of 8 July 2019) (“LGPD”), see the below section titled "Brazil Privacy Statement", for additional disclosures and a description of your rights under the LGPD.

 

This Policy describes:

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• Personal Data We Collect

• How We Use Your Personal Data

• How We Share Personal Data

• How We Protect Your Personal Data

• Personal Data Choices

• Personal Data Transfers

• Retention of Personal Data

• California Privacy Statement

• EEA & UK Privacy Statement

• Brazil Privacy Statement

• Changes to the Policy

• Contact Us

 

PERSONAL DATA WE COLLECT

 

TRVLR collects information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to any individual or a household (“Personal Data”). TRVLR may collect non-Personal Data that cannot be linked or associated with any individual person or household. When non-Personal Data is combined with other information so that it does identify an individual person, we treat that combination as Personal Data.

 

Depending on how you interact with us, you may provide us with the following categories of Personal Data:

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• Contact information, including name, phone number and postal and email addresses

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• Financial information such as credit card number, cardholder name, expiration date, authentication code, and billing address.

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• Profile information such as username, password, and loyalty program number.

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• Online activity, such as pages you have visited on the Platform.

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• Information about your travel plans and, if applicable, travel preferences

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• Marketing and communications information, such as marketing campaign data, Google Analytics ID, your preferences and consent in receiving marketing from us and Providers, and your communication preferences.

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• Inference data, including inferences drawn from the Personal Data identified above.

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We may also collect, in instances where you have provided it, information about other travelers, including their email address and other travel-related information. If you are sharing information with us about other individuals, you must obtain their consent before providing such Personal Data.

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If You Do Not Provide Personal Information. Where we need to collect Personal Data by law, or under the terms of a contract between you and a Provider, and you do not provide that data when requested, we may not be able to facilitate the payment you desire. In this case, we may not be able to facilitate the payment you request, but we will notify you if this is the case at the time.

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Information You Provide To A Third Party. The website may include links, plug-ins to websites operated by third parties (“Third-Party Sites”). TRVLR does not control any Third-Party Sites and is not responsible for any information they may collect. The information collection practices of a Third-Party Site are governed by its own privacy policy. It is your choice to enter any Third-Party Site. We recommend that you read the Third-Party Site's privacy policy if you choose to do so.

 

Children’s Privacy. The website is intended for adult use only and is not directed towards children, minors, or anyone under the age of 18. If you are under the age of 13, you are not authorized to provide us with any Personal Data. If the parent of guardian of a child under 13 believes that the child has provided us with any Personal Data, the parent or guardian of that child should contact us at the email address below and to have this Personal Data deleted from our files.

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HOW WE COLLECT PERSONAL DATA

 

Information You Provide to Us. TRVLR may collect Personal Data from you that you voluntarily provide to us in various ways, including, but not limited to:

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• Create an account with TRVLR

• Request the facilitation of a payment with a Provider

• Sign up to receive newsletters

• Response to marketing e-mails

• Call, e-mail, or otherwise communication with us and/or third parties contracted by TRVLR

• Otherwise interact with us or our Platform

 

Information We Collect From Third Parties. We collect Personal Data from various third parties, including those listed below. The collection, use, and disclosure of Personal Data received from third parties is governed by the privacy policies listed on the website where the information was submitted by the user. Third parties may send their own cookies and pixel tags to you, and may collect information and use it in a way inconsistent with this Policy. Please carefully review these third-party privacy policies to understand how your information may be collected, used and disclosed by these third parties.

 

Third Party Service Providers. We collect Personal Information from service providers including payment processors, website hosting providers, and email service providers.

 

Google Analytics. We use third party cookies provided by Google Analytics to assist us in better understanding our Platform visitors. These cookies collect usage data, such as the length of time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting our Platform. Based on this information, Google Analytics compiles data about website traffic and interactions, which we use to offer better user experiences and tools in the future. For more information on how to opt-out from Google Analytics, visit https://tools.google.com/dlpage/gaoptout.

 

HOW WE USE YOUR PERSONAL DATA

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We are committed to providing you with the services you request and respect the data privacy laws of the different jurisdictions in which we operate. We use information about you so we can help you enjoy and use the Platform, including in the following ways:

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• Register and manage your account, including to allow you access to and use of the Platform

• Notify you about special offers and products or services available from us or affiliated third parties such as hotels or travel companies (collectively, "Providers") that may be of interest to you, with your consent

• Facilitate your payment for bookings with Providers through the Platform

• Communicate with you about your use of or access to the Platform

• Enable communication between you and Providers (e.g. by providing up-to-date contact and profile information to Providers based on the information you provide on the Platform)

• Customize your experience on the Platform

• Make inferences about your interests or preferences

• Respond to your questions and comments about the Platform

• Resolve disputes or troubleshoot problems relating to the Platform

• Prevent potentially prohibited or unlawful activities

• Comply with legal obligations

• Enforce our Terms of Service and this Policy

• Measure interest in and improve the Platform through analytics

• Detect security incidents on the Platform

• Protect TRVLR and the Platform against malicious, deceptive, fraudulent, or illegal activity

• As otherwise permitted by law or described to you at the point of collection

 

Please note some information about you is required in order for us to provide you with relevant offerings from us and Providers, and to enable you to enjoy other benefits of being a registered user. Please review the paragraphs below with respect to your choices related to the collection and use of your information.

 

How We Share Personal Data

 

We share your Personal Information with third parties only in the ways that are described in this Policy and with our business partners and service providers in order to provide you with the Platform and perform any contract we enter into with them or you. We do not retain your Personal Data for a duration that is longer than reasonably necessary for the disclosed purpose.

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Information You Instruct Us to Share.  You may be presented with an option on the Platform to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Data and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties.

 

Service Providers.  We may use third-party service providers to perform certain business services and may disclose Personal Data to such service providers as needed for them to perform these business services.  Service providers are only allowed to use, disclose or retain the Personal Data to provide these services and are prohibited from selling Personal Data.  Business services provided include, but are not limited to, hosting services, communications services, website development services, payment processing services, compliance services, and analytics services.

 

Internal Third Parties. We may share Personal Information with our successors, assigns, licensees, affiliates, or business partners and others, including where disclosure of your Personal Data is needed to protect the employees, independent contractors, officers, directors, members, users, or stockholders of TRVLR who may use the Personal Data for the purposes described above.

 

Business Transactions. We may do business with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Policy.

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Legal Process. Subject to applicable law, we may disclose information about you (i) if we are required to do so by law, regulation or legal process, such as a subpoena; (ii) in response to requests by government entities, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) in connection with an investigation of suspected or actual unlawful activity.

 

HOW WE PROTECT YOUR PERSONAL INFORMATION

 

While no online platform can guarantee perfect security, we have implemented and maintain generally accepted industry standards to protect against the unauthorized access, use, modification, destruction or disclosure of your Personal Data both during transmission and once we receive it. For example, TRVLR transmits information via industry standard secure server (SSL). This SSL creates the secure and encrypted https://website address. When you see the https:// website address, you know the information you are in-putting is protected and secure.  However, no method of transmission over the Internet, or method of electronic storage, is 100% secure.

 

PERSONAL DATA CHOICES

 

Ability to Access, Update, and Correct Personal Data. TRVLR wants your Personal Data to be complete and accurate.  You represent and warrant that all information you provide in connection with your use of the Platform will be complete and accurate, and that you will update that information as necessary to maintain its completeness and accuracy.  To confirm the completeness and accuracy of, or make changes to, your Personal Information, please contact us at privacy@trvlrpay.com.

 

Communications Opt-Out. You may opt out of receiving marketing or other communications from us at any time by following the opt-out link or other unsubscribe instructions provided in any email message received, or by contacting us at privacy@trvlrpay.com. If you wish to opt out, please send us an email to the address provided below and include “Opt-Out” in the email’s subject line along with your name and the email address you used to sign up for communications in the body of the email. This opt out will not apply to operational or informational emails related to your account and purchases.  You may continue to receive promotional email messages for a short period while we process your request.

 

STORAGE OF PERSONAL DATA

 

Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your Personal Data, in the United States and other countries. If you live outside of the United States, you understand and agree that we may transfer your information to the United States. This site is subject to U.S. laws, which may not afford the same level of protection as those in your country. In the event of a transfer of your Personal Data, we will take steps reasonably designed to treat your Personal Information securely and in accordance with this Policy and applicable law.

 

RETENTION OF PERSONAL DATA

 

We will retain copies of your information for as long as you maintain your account or as necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. In addition, we may retain your information for the duration of any period necessary to establish, exercise or defend any legal rights.

 

CALIFORNIA PRIVACY STATEMENT

 

Shine the Light Law. California residents have the right to receive information that identifies any third party companies or individuals that TRVLR has shared your Personal Data with in the previous calendar year, as well as a description of the categories of Personal Data disclosed to that third party. You may obtain this information once a year and free of charge by contacting us at privacy@trvlrpay.com.

We do not disclose a user’s Personal Information to any third party for such third-party's direct marketing purposes nor do we sell, rent or lease your Personal Information except as disclosed in this Policy. California residents may opt-out of the sale of their Personal Data; however, we do not sell any such information at this time. In the event of TRVLR's sale of your Personal Data, you can opt-out of such sale by e-mail us at the address provided above.

 

‘Do Not Track’ Browser Setting. Some web browsers incorporate a Do Not Track (“DNT”) feature that signals to the websites that you visit that you do not want to have your online activity tracked. At this time, our Platform does not respond to DNT signals. Other third party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites.

 

EEA & UK PRIVACY STATEMENT

 

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 the Personal Data we collect on the Platform. The Providers to whom we may connect you to make reservations are also data controllers. To learn more about how a Provider may use your personal information, you should review its privacy notice.

 

Lawful Basis for Processing Your Personal Data. As described above in, “Personal Data We Collect," we process Personal Data. Our lawful bases for processing that Personal Data are:

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• Performance of a Contract. We may collect and use certain Personal Data in order to provide you with the services that you request (for example, if you use the Platform to pay for booking with a Provider, we will process your information in order to allow the relevant Provider complete and administer that booking).

 

• Legitimate Interests. We collect and use Personal Data to the extent necessary for our legitimate interests. For example, this may include collecting and using data to prevent and detect fraud, provide customer support, and conduct market research.

 

• Fulfill Legal Obligations. We are subject to various legal requirements in the jurisdictions that we operate that require us to collect, process, disclose and retain your Personal Data in order to comply with those laws. We may be required to retain your data for extended periods of time, and to provide copies of such data to law enforcement, governmental or other regulatory authorities, or third parties.

 

• Consent. To the extent that a legal ground described above would not apply to processing of your personal information by us, we will seek your consent for such specific purpose in accordance with applicable law (such as sending direct marketing messages by electronic means, like email, without an exception from the requirement to obtain consent). You may revoke your consent at any time by contacting us using the information at the bottom of this Policy.

 

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 at the bottom of this Policy 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 below.

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International Transfer of Personal Data. Our activities and the jurisdictions in which we are established are such that it may be necessary for Personal Data to be transferred and/or processed outside the EEA or UK, which may not offer the same level of protection with regard to Personal Data as required in the EEA or the UK and where there is no adequacy decision by the European Commission. In that case we will seek to ensure an adequate level of data protection by appropriate safeguards by way of the EU Standard Contractual Clauses.

 

If you would like further information on specific mechanisms we utilize for transferring Personal Data outside the EEA or the UK and the countries to which such transfer may be made, please contact us using the details set out at the bottom of this Policy.

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Your Rights with Regard to Your Personal Data

 

The GDPR provides you with certain rights related to the collection, processing, and transfer of your Personal Data, including:

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• Access. You have the right to know we collect certain Personal Data about you and to ask us for copies of your Personal Data.

• Rectification. You have the right to request that we correct information you think is inaccurate or incomplete.

• Object to Processing. You have the right to object to processing in some circumstances, including where we are using your Personal Data for our legitimate interests and for direct marketing purposes.

• Erasure. You have the right to request that we erase the Personal Data we have collected about you in certain circumstances.

• Restrict Processing. You have the right to ask us to restrict the processing of your Personal Data in certain circumstances.

• Data Portability. You have the right to receive the Personal Data you have provided to us in a structured, commonly used and machine-readable form and transmit those data it to another data controller.

• Withdraw Consent. You can withdraw your consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

• Lodge a Complaint with a Data Protection Authority (“DPA”). If you are concerned that we have not complied with your legal rights or applicable privacy laws, you have the right to lodge a complaint with the applicable DPA.

 

You can exercise these rights by contacting us using the information below. You may be asked to provide some proof of identification so that we can verify that it is you making the request

 

BRAZIL PRIVACY STATEMENT

 

If you, or the collection, use, storage, disclosure, or transfer (“processing”) of your Personal Data is subject to the LGPD, please review this section in addition to the entire Policy. This section of the Policy specifically summarizes our lawful basis for processing your Personal Data, your rights related to your Personal Data, how we may transfer your Personal Data, and how you can contact us.

 

Basis for Processing Your Personal Data. As described above in, “Personal Data We Collect," we process Personal Data. Our lawful bases for processing that Personal Data are:

 

• Consent. We may collect, use and share your Personal Data on the basis of your consent. You may revoke your consent at any time by contacting us using the information below in “How to Contact Us” or if you consented to our use of cookies, through the cookie management system available at the link on the bottom of the webpage.

 

• Compliance with a Legal or Regulatory Obligation. We are subject to various legal requirements in the jurisdictions that we operate that require us to collect, process, disclose and retain your Personal Data in order to comply with those laws. We may be required to retain your data for extended periods of time, and to provide copies of such data to law enforcement, governmental or other regulatory authorities, or third parties.

 

• Execution of a Contract or Preliminary Procedures Related to a Contract. We must collect and use certain Personal Data in order to provide you with the services that you request. This includes Personal Data used to provide you with the Platform and related services and related transaction information.

 

• Exercise of Our Rights. We may need to process certain Personal Data in order to exercise our legal rights in judicial, administrative, or arbitration procedures.

 

• Legitimate Interests. We collect and use Personal Data to the extent necessary for our legitimate interests. For example, this may include collecting and using data to prevent and detect fraud, provide customer support, and conduct market research.

 

International Transfer of Your Personal Data. The information that we collect may be transferred to, stored in, processed in or accessed from countries outside of Brazil. Some of the recipients of your Personal Data listed above may be located in countries outside Brazil that do not offer the same level of protection with regard to Personal Data as required in Brazil. In the event we transfer your Personal Data to countries, we will seek to ensure an adequate level of data protection data protection by appropriate safeguards or other methods permitted under applicable law. If you would like to obtain a copy of the safeguard that we use, please contact us using the information below.

 

Your Rights with Regard to Your Personal Data. The LGPD provides you with certain rights related to the collection, processing, and transfer of your Personal Data, including:

 

• Confirmation. You have the right to confirm that we are processing your Personal Data.

 

• Access. You have the right to request access to the Personal Data that we process about you.

 

• Correction. You have the right to request that we correct incomplete, inaccurate, or outdated data.

 

• Anonymization, Blocking or Deletion. You have the right to request that we anonymize, block, or delete excessive Personal Data that we have collected about your or Personal Data that is not being processed in compliance with the LGPD.

 

• Data Portability. You have the right to request that your data be provided to another service provider or product provider, subject to certain limitations under the LGPD.

 

• Deletion of Data Processed with Consent. Where we are processing your Personal Data on the basis of your consent, you have the right to request that we delete that Personal Data, subject to certain exceptions under the LGPD.

 

• Information About Public and Privacy Entities with Which We Shared Personal Data. You have the right to request information about the public and private entities with which we have shared your Personal Data.

 

• Information About Consent. You have the right to request that we provide you with information about your ability to deny your consent to certain processing activities and the consequences of such denial.

 

• Withdrawal of Consent. You have the right to revoke your consent at any time and free of charge. Where applicable, you also have the right to request the review of decisions made solely by automated processing of your Personal Data that affects our interests.

 

You can exercise these rights by contacting us using the information below. You may be asked to provide some proof of identification so that we can verify that it is you making the request

 

CHANGES TO THE POLICY

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We may modify or update this Policy from time to time. We encourage you to revisit this page often to remain fully informed of our Policy or you can contact us at any time to obtain the latest copy of this Policy.

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CONTACT US

 

Address

TRLVR, Inc.

5142 Hollister Avenue # 548

Santa Barbara, California 93111

 

E-Mail

contact@trvlrpay.com

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