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Privacy Policy

1. Categories of Personal Information We Collect

When you use our platform, mobile application (“App”), or associated tools or services, we may collect the following kinds of personal information from you as needed:

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

  • Government issued Identification required for booking or identity verification, such as passport, driver’s license, government redress numbers, and country of residence

  • 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

  • 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 App

  • 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 and App

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

  • Information we receive about you from other Apogee Travel companies and third parties such as our business and affiliate partners and authorized service providers which may include updated contact information, demographic information, interests, and purchase history, which we may add to your account or profile and use for market research and analysis

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We collect sensitive personal information either with consent or in accordance with local law. This may include information which could reveal your racial or ethnic origin, religious or philosophical beliefs, sexual orientation, and health or disability information.

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When you install our App or use our platform, we automatically collect the following types of information from your device (“Automatically Collected Information”):

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  • 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)

2. Mobile App

When you download and use our mobile App, we collect certain technical information from your device to enable the App to work properly and as otherwise described in this Privacy Statement. That technical information includes:

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  • Device and telephone connectivity information such as your carrier, network type, network operator, subscriber identity module ("SIM") operator, and SIM country

  • Operating system and version

  • Device model

  • Performance and data usage

  • Usage data, such as dates and times the app accesses our servers, the features and links clicked in the App, searches, transactions, and the data and files downloaded to the App

  • Device settings selected or enabled, such as Wi-Fi, Global Positioning System ("GPS"), and Bluetooth (which may be used for location services, subject to your permission as explained below)

  • Mobile device settings

  • Other technical information such as app name, type, and version as needed to provide you with services

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Permissions for Location-Based Services

 

Depending on your device’s settings and permissions and your choice to participate in certain programs, we may collect the location of your device by using GPS signals, cell phone towers, Wi-Fi signals, Bluetooth or other technologies. We will collect this information, if you opt in through the App or other program (either during your initial login or later) to enable certain location-based services available within the App (for example, locating available lodging closest to you). To disable location capabilities of the App, you can log off or change your mobile device’s settings.

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Mobile App Analytics

 

Depending on your device’s settings and permissions and your choice to participate in certain programs, we may use technology to track where you chose to download our App and to measure advertising effectiveness. When we use this kind of technology, we will use privacy enhancing technologies such as de-identification, pseudonymization, encryption and improved notice where possible.

3. 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. 

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Your Use of Online Sites, Apps, and Services

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  • 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

  • Maintain your search and travel history, accommodation and travel preferences, and similar information about your use of Apogee Travel’s platform and services, and as otherwise described in this Privacy Statement

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

  • Collect and enable booking-related reviews

  • Help you to use our services faster and easier through features like the ability to sign-in using your account within the online services and sites of some of the Apogee Travel companies

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Communications and Marketing

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  • 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

  • Analyze information such as browsing and/or purchase history and use the result to optimize advertising in accordance with your interests and preferences

  • Measure and analyze the effectiveness of our marketing and promotions

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Other Business Purposes and Compliance

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  • 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

  • Create aggregated or otherwise anonymized or deidentified data, which we may use and disclose without restriction where permissible

  • 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

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Clickstream data
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In certain instances, we may use clickstream data to render an illustration of your usage of our site. Clickstream data is the collection of a sequence of events that represent visitor actions on a website. We may reconstruct your site journey modeled on the timing and location of your actions. This data is primarily used for customer service purposes, to verify the legitimacy of a claim, or to defend ourselves. This data may also be used for other internal purposes such as improving the user experience on our website and identifying website malfunctions.

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Sensitive Personal Information

 

We will only use your sensitive personal information for the purposes for which it was collected.

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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.

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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. 

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We may use artificial intelligence, machine learning, and other automated decision-making to enhance your user experience and keep our site safe.

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For example, we may use it in relation to:

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  • the sort order you see on our site

  • destinations, property or activity recommendations

  • the content you upload on our site (e.g., images of your properties) to ensure they meet our quality or formatting requirements, and to identify relevant amenities included in your listing

  • the reviews you share with us to ensure they do not contain identifiable personal information or to assess customer satisfaction

  • the prevention and detection of breach of our terms and conditions or other fraudulent activities to keep our site safe

  • our language and dialects within our virtual agents’ experience

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Automated decisions may be made by putting your personal information into a system and the decision is calculated using automatic processes.

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We will not engage in automated decision-making that involves a decision with legal or similarly significant effects solely based on automated processing of personal information, unless you: (1) explicitly consented to the processing, (2) the processing is necessary for entering into a contract, or (3) when otherwise authorized by applicable law.

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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.

4. Sharing of Personal Information

We share your personal information as described below and in this Privacy Statement, and as permitted by applicable law.

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  • Third-party service providers. We share personal information with third-parties in connection with the delivery of services to you and the operation of our business (for example, to provide credit card processing, customer service, business analytics, and fraud prevention and compliance services, and to serve you with advertising tailored to your interests). These third-party service providers are required to protect personal information we share with them and may not use any directly identifying personal information other than to provide services we contracted them for. They are not allowed to use the personal information we share for purposes of their own direct marketing (unless you have separately consented with the third-party under the terms provided by the third-party).

  • Travel suppliers. We share personal information with travel-related suppliers such as hotels, vacation-rental property owners and managers who fulfill your booking. Please note that travel suppliers may contact you to obtain additional information if and as required to facilitate your booking or to otherwise provide the travel or associated services.

  • Business partners and offers. If we promote a program or offer a service or product in conjunction with a third-party business partner, we will share your information with that partner to assist in marketing or to provide the associated product or service.  In most of those cases, the program or offer will include the name of the third-party business partner, either alone or with ours, or you will be redirected to the website of that business with notice. An example of such a business-partner relationship would be a third-party loyalty program for which you could earn points by completing a booking on our platform.

  • Targeted Advertising. We may disclose your Automatically Collected Information to our third-party marketing partners for targeted advertising. This may be considered “sharing” data under California law. Subject to certain limitations, some US residents have the right to opt out of having their personal information shared for this purpose. You should note that by opting out of these types of disclosures, you may limit our ability to customize your experience with content that may be of interest to you or to provide you with a better travel experience.

  • Legal rights and obligations. We may disclose your personal information and associated records to enforce our policies;  as necessary to satisfy our tax or other regulatory reporting requirements, including the remission of certain taxes in the course of processing payments; or where we are permitted (or believe in good faith that we are required) to do so by applicable law, such as in response to a subpoena or other legal request, in connection with actual or proposed litigation, or to protect and defend our property, people and other rights or interests.

  • Corporate transactions. We may share your personal information in connection with a corporate transaction, such as a divestiture, merger, consolidation, assignments or asset sale, or in the unlikely event of bankruptcy. In the case of any acquisition, we will inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Statement.

5. International Data Transfer

The personal information we process may be accessed from, processed or transferred to countries other than the country in which you reside. Those countries may have data protection laws that are different from the laws of your country.

 

The servers for our platform are located in the United States, and the Apogee Travel companies and third-party service providers operate in many countries around the world. When we collect your personal information, we may process it in any of those countries. Our employees may access your personal information from various countries around the world. The transferees of your personal data may also be located in countries other than the country in which you reside.

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We have taken appropriate steps and put safeguards in place to help ensure that any access, processing and/or transfer of your personal information remains protected in accordance with this Privacy Statement and in compliance with applicable data protection law. Such measures provide your personal information with a standard of protection that is at least comparable to that under the equivalent local law in your country, no matter where your data is accessed from, processed and/or transferred to.

6. 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.  

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Our cybersecurity team develops and deploys technical security controls and measures to ensure responsible data collection, storage, and sharing that is proportionate to the data’s level of confidentiality or sensitivity. We take efforts to continuously implement and update security measures to protect your information from unauthorized access, loss, destruction, or alteration. We hold our data-handling partners to equally high standards.

7. 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.

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When we delete your personal information, we use industry standard methods to ensure that any recovery or retrieval of your information is impossible. We may keep residual copies of your personal information in backup systems to protect our systems from malicious loss. This data is inaccessible unless restored, and all unnecessary information will be deleted upon restoration.

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The criteria we use to determine our retention periods include:

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  • The duration of our relationship with you, including any open accounts you may have with Apogee Travel companies, 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​​

  • Whether your information is needed for secure backups of our systems

8. Cookie Statement

What are 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.

 

Apogee Travel’s use of cookies

 

At Apogee Travel, 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 of 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

  • Analyze how well our sites are performing

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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

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Types and functions of cookies

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  1. 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.
       

  2. Other Types of Cookies

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We also use other types of cookies to make our site engaging and useful to you:

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  • Functional Cookies. We want to make sure when you visit our site, your preferences (such as your preferred language), settings, and previous searches are remembered. Functional cookies enhance your experience on any Apogee Travel company’s site.

  • Performance Cookies. We use performance cookies to: 

    • Understand our site’s performance and how it is used, including the number of visitors, how long you stay on the site, and which parts of the site you visit. We can see details about how visitors interacted with the site, like the number of clicks visitors made on a given page, their mouse movements and scrolling activity, the search words visitors used, and the text visitors enter into various fields

    • Test different designs and features for our site

    • Monitor how our visitors reach our sites

    • Determine effectiveness of our advertising

    • Improve our services, including your experience on our site

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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.

9. Your Rights

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

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  • If you have an account with us, you may change your communication preferences by logging in and updating the information in your account.

  • You can access, amend, inquire about deletion of, or update the accuracy of your information at any time by logging into your account.

  • If you no longer wish to receive marketing and promotional emails, you may unsubscribe by clicking the ‘unsubscribe’ link in the email. You can also log into your account to change communication settings. Please note that if you choose to unsubscribe from or opt out of marketing emails, we may still send you important transactional and account-related messages from which you will not be able to unsubscribe.

  • For our mobile App, 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

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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:

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  • 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

Updated May 25, 2023

Contact Us

If you have any questions or concerns about our use of your personal information, or wish to inquire about our personal information handling practices, and exercise your rights to access, correct or inquire about deletion of personal information, please contact us.

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