Last Updated: [December 9, 2022]
Effective Date: [December 9, 2022]
This Privacy Policy describes how Universal Travel Concierge LLC (collectively, “Universal Travel Concierge,” “we,” “us,” or “our”) collects, uses, shares, and protects personal information. This Privacy Policy also tells you about your rights and choices with respect to your personal information, and how you can reach us to get answers to your questions. If you do not agree with any of the practices contained within this Privacy Policy, do not use Universal Travel Concierge sites and services.
How We Collect Information
We collect information about you in a variety of ways depending on how you interact with us and our websites and services, including:
- Directly from you when you provide it to us, such as when you sign up to open an account, subscribe or purchase a product or service, receive newsletters, updates, or other information from us or contact us by phone, e-mail, app or otherwise.
- Automatically when you interact with our websites, apps or emails through the use of cookies, server logs, and other similar technologies.
- From other sources, including, for example, third parties, business partners, our affiliates, or publicly available sources. For example, if you submit a job application, or become an employee, we may conduct a background check.
Use And Processing Of Information.
The following provides a non-exhaustive list of examples of how we might use some of the information that we collect.
| Context | Types of Data | Primary Purpose for Collection and Use of Data |
|---|---|---|
| Account Registration | We collect your name and contact information when you create an account. We also collect information relating to the actions that you perform while logged into your account. | We have a legitimate interest in providing account related functionalities to our users. Accounts can be used for easy checkout and to save your preferences and transaction history. |
| Cookies and first party tracking | We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed. | We have a legitimate interest in making our website operate efficiently. |
| Cookies and Third Party Tracking | We may place tracking technology on our website that collects analytics or allows us to participate in behavior-based advertising. This means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can report analytics to us or provide advertising about products and services tailored to your interests on our website, or on other websites. | We use cookies to understand the use of our website. |
| Demographic Information | We collect personal information, such as your age or location. | We have a legitimate interest in understanding our users and providing tailored services. |
| Email Interconnectivity | If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases. | We have a legitimate interest in understanding how you interact with our communications to you. |
| Employment | If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number. Providing this information is required for employment. | We use information about current employees to perform our obligations to employees. In some contexts, we are also required by law to collect information about employees or applicants. We also have a legitimate interest in using your information to have efficient staffing and work force operations. |
| Feedback/Support | If you provide us feedback or contact us for support we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply. | We have a legitimate interest in receiving, and acting upon, your feedback or issues. |
| Mobile Devices | We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our website or when visiting one of our stores. | We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices. |
| Order Reservation | We collect your name, billing address, shipping address, e-mail address, phone number, and credit card number when you reserve a service. | We use your information to perform our contract to provide you with products or services. |
| Public Health and Safety | In certain situations where a serious public health threat has been identified, we may collect information from employees, guests, and other individuals accessing our facilities. This may include medical and health information, such as body temperature, symptoms, and underlying health conditions. In some cases, we may also collect medical, health, and related information about an employee’s children, family member, or other individuals under the employee’s care. | We have a legitimate interest in protecting the health and safety of our employees and guests. In some jurisdictions we may be required by law, regulation, or governmental order to collect and retain information related to issues of public health and safety. We have a legitimate interest in complying with the laws in the jurisdictions in which we operate. |
| Website interactions | We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser. | We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud. |
| Web logs | We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors. | We have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our services is the most popular. |
In addition to the purposes and uses described above, we use information in the following ways:
- To identify you when you visit our website.
- To provide and improve services.
- To conduct the checkout process.
- To conduct analytics.
- To respond to inquiries related to support, employment opportunities, or other requests.
- To send marketing and promotional materials.
- For internal administrative purposes, as well as to manage our relationships.
To the extent we maintain and use personal information in a deidentified form, we will not attempt to reidentify the information, except for the purpose of determining whether our deidentification processes satisfy our legal obligations.
In addition to the specific situations discussed elsewhere in this policy, we may disclose personal information in the following situations.
- Affiliates and Acquisitions. We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage.
- Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
- Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third party intermediary.
- Service Providers. We may share your information with service providers. Among other things service providers may help us to administer our website, conduct surveys, provide technical support, process payments, and assist in the fulfillment of orders.
Some jurisdictions give you a right to make the following choices regarding your personal information:
- Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
- Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you service related communications.
How We Protect Personal Information
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Some of our websites permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.
The following additional information relates to our privacy practices:
- Transmission Of Information To Other Countries. As a company that may book international travel products, we may transmit your personal information to other jurisdictions. As a result your information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. By submitting your personal information to us you agree to the transfer, storage and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States.
- California Shine the Light. If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing please submit a written request to us using the information in the “Contact Information” section below.
- Third Party Applications/Websites. We have no control over the privacy practices of websites or applications that we do not own.
- Changes To This Privacy Policy. We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. Our privacy policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.
- Accessibility. If you are visually impaired, you may access this notice through your browser’s audio reader.
- Children. We do not knowingly sell the personal information of minors under 16 years of age.
If you have any questions, comments, or complaints concerning our privacy practices please contact us in writing at legal@universaltravelconcierge.com.