Privacy Policy
Last updated: 08/03/2019
Highlights of this Privacy Policy
• What information do we collect?
• Who do we share your personal information with?
• How do we use personal information?
• How can you manage the information you have given us?
• How do we protect your information?
• How to contact us
Introduction
Trip Concierge Inc. (formerly Kxter, Inc.), a Delaware corporation, and its subsidiaries and corporate affiliates (“we,” “us,” “our,” and “Kxter”, “Trip Concierge”) respect your right to privacy and take your privacy seriously. Kxter is committed to taking appropriate steps to protect and secure any personal information you give us. This Privacy Policy explains how we collect, use and share personal information about you via our online services including our website, App and online booking APIs (i.e., online-booking tools used by our partners) ("Online Services") or give us in any other way (together, the “Services”). If any parts of our Online Services connect you with third party online services, those services do not operate under this Privacy Policy. Please review the privacy policies posted on those other online areas to understand their procedures for collecting, using, and disclosing personal information.
Key things you should know about how we use your information:
• We may use your information (and the information of those travelling with you) for purpose of completing travel bookings.
• This includes sharing your booking information with other parties to fulfil your booking.
• We also may engage other third-party vendors who provide services or functions on our behalf.
• Where you choose to receive marketing information, we will let you know about any special offers that may be of interest to you, including our loyalty programs. You are able to opt-out at any time.
• You can contact us about updating or accessing your information through our contact information within the Contact Us section at the bottom of this Privacy Policy.
• We may use information like cookies for purposes including, but not limited to: improving your experience on Online Services; improving our services generally; and to display ads and offers that are more relevant to you.
• From time to time and usually following an interaction with us, we may ask you for your feedback to provide you and others with better service.
• If you are using our Services outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. Please rest assured that we take appropriate steps to protect your privacy and security.
We recommend that you read this Privacy Policy in full to ensure you are completely informed. If you have any questions or concerns about our use of your personal information, then please contact us through information found in the “Contact Us” section at the bottom of this policy.
What personal information do we collect and why?
The personal information that we may collect about you broadly falls into the following categories:• Information that you provide directly to usWe may ask you to provide personal information directly to us. For example, we may ask you to provide your contact details such as full name, street address, telephone number, email address, and date of birth as necessary, in order to, for example:- enable your travel booking;- create or register an account with us;- provide the services and information you request such as details about your booking;- have an emergency contact number for you;- update frequent flyer or loyalty program information;- subscribe you to our marketing communications; and/or- submit enquiries to us. You will also need to provide your billing information (such as credit card number, cardholder name and expiration date) to make a payment. You may also be required to provide information about any other travelers on your booking, your marketing preferences, and additional information if you participate in a survey or competition. When creating an account, you will provide a login name/member ID as well as a password. Your personal information may also be linked to Cookies to enable the proper operation of our Online Services, store your travel searches on our Online Services, and collect information on how you used our Online Services. For more information, please see the “Cookies and similar tracking technology” section below. If you’re an employee of a corporate account, a vendor or other type of business partner such as a property owner, property manager, travel agent, other information collected can include employer, employee identification number, or other relevant details. We may also use your personal information for other purposes described in the “How we use your information” section below.
• Special Categories of Personal Information
Certain types of personal information, such as some government-issued identification numbers, religion, health or sexuality, are considered sensitive and require additional protection under applicable laws. We take appropriate steps to limit the circumstances under which we may collect sensitive personal information; examples of this information include the following:- Health-related information may be needed to provide appropriate travel accommodation and accessibility or facility requirements.- Government-issued identification numbers like passport or driver’s license number may be required for flights, vehicle rental or other travel reservation.- Other information that you can specify at your option and which may imply or suggest information like religion, health or other information, such as dietary needs.
• Information Voluntarily Provided About Your Travel Companion(s)When you make a reservation for someone else through our Online Services, we will request personal information and travel preferences about that individual. You should obtain the consent of any other individual(s) prior to providing us with their personal information and travel preferences. Your travel companion's information will only be available to view and amend through your account. Should your travel companion want to amend or delete their information themselves they can contact us directly at the information in the “Contact Us” section at the bottom of this policy.
• Information that we collect automatically When you visit us on our Online Services, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws. Specifically, the information we collect automatically may include, but is not limited to, information like your IP address, device type, unique device identification numbers, browser-type (such as Firefox, Safari, or Internet Explorer), your Internet Service Provider (ISP), your operating system and carrier. For website users, details of any referring website or exit pages as well as broad geographic location (e.g., country or city-level location) may also be collected. We may also collect other technical information such as how your device has interacted with our Online Services, including the pages accessed and links clicked, for example, trips viewed and the time and date of these. Collecting this information enables us to better understand the visitors who come to our Online Services, where they come from, and what content on our Online Services is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Online Services for our visitors, for example, to customize your user experience, tailor your searches and show you advertisements that may be of interest. We may also use this automatic information to prevent and detect fraud.Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology.”
• Information we collect when you use AppsWhen you use one of your smart phone app, tablet app, or applications for other platforms (collectively “App” or “Apps” as applicable), we may also collect, for example:- Information about the functionality of the Apps you access and use. This allows us to identify those areas of the Apps that are of interest to our customers so that we can refine and continuously improve the Apps.- Your device’s unique device identifier (“UID”). Each App sends us the device's UID, a sequence of numbers or characters that are unique to your device. We use this on the first opening of the App so that we can confirm to our advertising networks the number of downloads resulting from clicks on their respective ad banners and other marketing tools. When an email address is provided, we associate this with your current UID/cookie ID for the purposes of providing a seamless experience across your devices.- Information about your current location. When you use an App’s ‘find hotels near your current location’ or similar features that suggest relevant content based on location, or otherwise provide location-based services, we use information about your current location – provided by your device using GPS or similar technologies – to show relevant content or other localized information. We do not collect location data unless you expressly use a location-based feature, and you can switch off location data collection at any time through your phone settings menu.- Error reporting information. This enables us to investigate the error and to improve the stability of the App for future releases. As part of these error reports, the App sends us information about the mobile device type and version, the UID, the time the error occurred, the feature being used and the state of the application when the error occurred. We may use this information to investigate and remediate the error and to assist you in completing an impacted booking.You have the ability to control what information an App sends to us. You can exercise this control either by changing the settings of the App under its setting menu or changing the settings of your mobile device. Alternatively, you can remove the App from your device entirely and access our services through our website.
• Information that we obtain from third party sourcesPeriodically, we lawfully obtain personal information about you from affiliated entities, business partners and other independent third-party sources and add it to our account information. Examples of information we may receive includes updated contact information like email, purchase history, and demographic information.
• Information we collect when you communicate with us via the following methodsSocial Media: If you make use of any of our social media features on our Online Services or otherwise through a social media provider, we may access information about you via that social media provider in accordance with their privacy policy. For example, we offer the option to register with our website via the “Facebook Connect” feature, enabling you to register with our website using your Facebook account data without entering the required data manually on our webpage.When using a social media feature, if you have chosen to include personal information in your social media account, we may access information such as your name, profile picture, gender, birthday, email address, town or district and any other information you have chosen to make available. Subject to your privacy settings, we access information that you provide to a social media provider regarding your respective locations (“Location Data”) to provide you with relevant content. We do not store or use any data related to the friends you are connected with on a social media site.We may also access information from social media providers about your use of an App that we run on their website. Therefore, we encourage you to review the privacy policy of any social media provider you use.Call Monitoring and Recording: Calls to and from our customer service teams may be recorded or monitored for quality control purposes, analytics, to protect us in the event of a legal dispute and for staff training. Call recordings will be maintained consistent with this Privacy Policy. Any personal information obtained from you during the call will be treated in accordance with the provisions of this Privacy Policy.Other Online Communications: Any interactions you have with us through our Online Services, such as chat, will be recorded and monitored for quality control purposes, to protect us in the event of a legal dispute and for staff training. This information will be processed and maintained consistent with this Privacy Policy.
• Cookies and similar tracking technologyCookies are small data text files and can be stored on your computer's hard drive (if your Web browser permits). This website may use cookies for the following general purposes, including but not limited to:- To help us recognize you as a previous visitor and save and remember any preferences that may have been set while your browser was visiting our site.- To help us customize the content and advertisements provided to you on this website and on other sites across the Internet. For example, when you access a page on our website, a cookie is automatically set by us, our service providers, or our partners to recognize you as you navigate on the Internet and to present you with information and advertising based on your apparent interests. See “Display of Tailored Advertising” section below for more information about our online advertising practices and your choices.- To help measure and research the effectiveness of website features and offerings, advertisements, and email communications (by determining which emails you open and act upon).The Help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to request to disable cookies. Please note that if you refuse to accept cookies, you may not be able to access many of the travel tools offered on our sites.In addition to the above cookies, we may use Local Shared Objects, also referred to as "flash cookies," on our web site. These are used to enhance your user experience, for example, by storing your user preferences and settings, such as your volume/mute settings, and in connection with animated content on our website. Local Shared Objects are similar to browser cookies but can store data more complex than simple text. To find out more about flash cookies or how to disable them, please visit: Flash Player Help site.This site may also use Web beacons (also known as clear gifs, pixel tags or Web bugs), which are tiny graphics with a unique identifier, similar in function to cookies, that are placed in the code of a Web page. We use Web beacons to monitor the traffic patterns of users from one page within our sites to another, to deliver or read cookies, to understand whether you have come to our site from an online advertisement displayed on a third-party website, and to improve site performance. We also may allow our service providers to use Web beacons to, for example, help us understand which emails have been opened by recipients and to track the visitor traffic and actions on our site. This helps us measure the effectiveness of our content and other offerings.We may combine the information you give us with information related to your transactions and information we receive about you from third parties who carry out services on our behalf. The information received via Cookies and similar technologies may allow us to track your activities across devices and users' clickstream data associated with the Cookies.In general, we will use the personal information we collect from you only for the purposes described in this Privacy Policy or for purposes that we explain to you at the time we collect your personal information.Who do we share your personal information with?
• Our group companies at times may share your personal information with our affiliated companies within the Kxter group of companies. This sharing enables us, for example, to enhance the products and services we offer, as well as potentially provide you with information about products and services, both travel-related and other, which we believe might interest you. Also, if you inquire about booking a vacation rental stay through another Kxter brand, such as Skweel, we may on occasion share, for example, the number of your prior trips and any status level you have with an Kxter brand with the tour operator, air carrier, hotel or rental provider so they may have additional reassurance in approving your stay. To the extent that our parent company and corporate affiliates have access to your information, they will follow practices that are at least as restrictive as the practices described in this Privacy Policy. They will also take appropriate steps to comply with applicable laws governing the transmission of promotional communications and, at a minimum, give you an opportunity in any promotional email they send to choose not to receive such email messages in the future.
• Third party services providers who provide data processing services to us (for example, to support the delivery of; provide functionality on; or help to enhance the security of our Online Services), or who otherwise process personal information for purposes such as credit card processing, business analytics, customer service, marketing, distribution of surveys or sweepstakes programs, and fraud prevention. Where third-party service providers have access to data they will only collect information as needed to perform their functions. They are not permitted to share or use the information for any other purpose.
• Business partners with whom we may jointly offer products or services, or whose products or services may be offered on our Online Services. You can tell when a third-party business partner is involved in a product or service you have requested because their name will appear, either alone or with ours. If you choose to access these optional services, we will on occasions share information about you, including your personal information, with those partners. An example of a business partner would be a third-party loyalty program that you will earn points for, through a booking.
• Travel suppliers such as hotel, airline, car rental, insurance, property owners, and, where available, activity providers, rail and cruise lines, who fulfil your travel reservations. Services provided by a third-party supplier are generally described as such. Please note that these suppliers also may contact you as necessary to obtain additional information about you, facilitate your travel reservation, or respond to a review you may submit in accordance with their own independent Privacy Policy. From time to time we may share anonymous reviews with our hotel suppliers. On such occasions we do not share reviewer names or contact information unless you have explicitly told us that we may. We are not responsible for the hotel deducing your identity from the content of your review and contacting you directly.
• Social media providers when you access certain social media features through our Online Services, you will share information with the social media provider (such as Facebook). The information you share will be governed by the social media provider's privacy policy (including any data we may access via the social media provider). Social media providers should inform you about how you can modify your privacy settings on their site. If you connect your Kxter group account to a social media provider, such as through “Facebook Connect,” we may make available to that social media provider the information related to your use of our Services, such as our rewards and loyalty program or the reviews you post on our Online Services. Social media providers may provide settings that allow you to request that the social media provider disable such sharing of information and other privacy choices.
• Any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your interests or those of any other person;• When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company or this website, our customers, or others; and in connection with our Terms of Service and other agreements;
• In connection with a corporate transaction, such as a divestiture, merger, consolidation, 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 Policy; or• Any others with your consent to the disclosure. On occasion, we may share aggregate or anonymous information with third parties, including advertisers and investors. For example, we may tell our advertisers the number of visitors our website receives or the most popular hotels and vacation destinations.
How do we use your information?
We use the information we collect for a variety of purposes supporting you and our business uses, including to:
• fulfill the transactions that you make, such as booking a hotel;• provide you with travel confirmations and important travel updates for your upcoming trip (via channels such as email, SMS, and/or push messages);
• verify your identity for fraud prevention purposes;
• manage your account, including processing payments;
• communicate with you in general, particularly if there is a change to your booking;
• provide customer services related to your booking or to respond to any inquiry you make;• measure interest in and improve our products, services, and website functionality;
• notify you about special offers, coupons, sweepstakes and travel-related products and services that may be of interest to you. You may receive these through various channels, including by email, SMS, push messages, post mail, or telephone, or via advertisements on third-party sites, including through social media;• otherwise customize your experience with this website or App;
• reward you as part of any reward and recognition program you choose to join (whether this is our program or that of a third party);• obtain information from you, including through feedback you give or surveys you complete;
• carry out statistical analysis about the use of our website and Apps and the services we offer to improve each aspect of what we do;• protect our rights as a company, including as to our intellectual property, for example;
• resolve disputes, collect fees, or troubleshoot problems;
• prevent potentially prohibited or illegal activities;
• enforce our Terms of Use and other agreements; and
• as otherwise described to you at the point of collection. If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at the information provided at the bottom of this Privacy Policy.
How do we protect your personal information?
We want you to feel confident about using our Online Services to make travel arrangements, and we are committed to taking appropriate steps designed to protect the information we collect. While no Online Services can guarantee absolute security, we have implemented appropriate technical and organizational measures to protect the personal information that we collect and process about you.
International data transfers
The personal information we collect, or is collected on our behalf, may be transferred to, and processed in, countries other than the country in which you reside. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective). While such information is outside of your country of residence, it is subject to laws of such other countries, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. Specifically, the servers of our Online Services are located in the US, and our group companies and third-party service providers operate around the world. This means that when we collect your personal information, we may process it in any of these countries. Your information choices: You can access or update certain contact information in the Account section of our Online Services. You can request to de-activate your account at any time by contacting us through the contact information listed at the bottom of this policy. After you de-activate an account, you will not be able to sign in or access any of your personal information. However, you can open a new account at any time. If you have other questions about your information, please contact us at the information listed at the bottom of this Privacy Policy. Display of Tailored Advertising Data collected by us on this website to serve you with relevant advertising. We are committed to providing you with relevant content and information. To do this, we may, through cookies and other technologies used on this website, collect information about you, such as your travel related searches and whether you are looking for flights or hotels. We may use this information, together with other information we have collected about you from other sources, to serve you with more relevant ads on our website, across the internet, and on other devices that you may use. So, for example, if you search for a property in London on this site, you may see an ad for a London travel package on this site or on another website you visit.You can choose not to receive tailored online advertising from us on other websites, based on your activities on this website and learn more about many of the ways you can opt out of having your information used for tailored advertising purposes by accessing one of the following resources:•http://www.youronlinechoices•http://youradchoices.ca/choices/•http://www.aboutads.info/choices/•http://optout.networkadvertising.org/
Note that if you choose not to receive tailored ads, you will still see online advertisements, but they will be more general and less relevant to you. Data collected by business partners and ad networks to serve you with relevant advertising. We may allow third parties to collect information about your online activities through cookies and other technologies. These third parties include (1) business partners, who collect information when you view or interact with one of their advertisements on our sites; and (2) advertising networks, which collect information about your interests when you view or interact with one of the advertisements or tracking mechanisms they place on many different websites on the Internet. The information gathered by these third parties is used for example to make predictions about your characteristics, interests or preferences and to display advertisements on our sites and across the Internet tailored to your apparent interests.Please note that we do not have access to or control over cookies or other technologies these third parties may use to collect information about your interests, and the information practices of these third parties are not covered by this Privacy Policy. Some of these companies are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies. To learn more, please click here and here.Do-Not-Track Signals and Similar Mechanisms. Some web browsers may transmit "do-not-track" signals to websites 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 they even are 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, websites 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 how to respond to these signals.
