’s Privacy Policy

Last Modified: Nov. 10^th 2020 (“Effective Date”)

INTRODUCTION

This privacy policy (“Privacy Policy”) is designed to inform you about Inc. (“,” “we,” “us,” or “our”) policies and procedures for collecting, using, and disclosing your information in connection with your use of services. provides online travel agency services, (the “Services”) for our users (“Users”).

Users can access our Services through our website located at https://www.bookdirect.com (“Site”), through integrations via our API, and through our applications on their Devices. A “Device” is any computer used to access the Service, including without limitation a desktop, laptop, mobile phone, tablet, or other consumer electronic device.

SCOPE

This Privacy Policy governs your access of the Services, regardless of how you access it, and explains what data we collect when you use the Site and/or the Services, why we collect the data, how it is used, and your rights and choices. This policy applies to personal data and other information collected by us from or about: (i) visitors of our Site, (ii) Users, (iii) prospective clients, (iv) current clients, (v) job applicants.

By using our Site or the Services you consent to the collection, transfer, processing, storage, disclosure and other uses described in this Privacy Policy.

1. INFORMATION WE COLLECT

When you interact with the Site or the Services and in connection with our events, sales and marketing activities, we collect information that alone or in combination with other information could be used to identify you (“Personal Data”), as described below:

A. Information You Provide as a User
When you register an account as a User, you may be asked to provide Personal Data including without limitation, your name, phone number, email address, home address.

When using the Services, you may also provide us with your financial or banking information so that we are able to process your booking requests, for example to book a hotel for you.

You may also choose to submit Personal Data to us when you send us an email or use any interactive features that we may make available on the Services. For example, you may ask us to: (a) import your contacts by giving us access to your third party services (such as your email account) or (b) use your social networking information if you give us access to your account on social network connection services.

You may also provide us with your contacts’ email addresses if you invite them to join .

B. Events
We may also collect data from you including without limitation when you attend one of our events, during phone calls with sales representatives, or when you contact customer support.

C. Employment Applications
When you apply for employment through the Site, our provider of recruiting services will collect your resume and any additional information that you elect to provide to us, including but not limited to your employment history and education. In addition, where permitted by law, we may use a third party to carry out a background check to determine your suitability for a position.

D. Automatically Collected Information
i. Log Data.

When you use the Services, we automatically record information from your Device, its software, and your activity using the Services. This includes the Device’s Internet Protocol (IP) address, operating system, browser type, the web pages you visited before you came to the Site, the web pages you view immediately after leaving our Site, information you search for on the Site, locale preferences, identification numbers associated with your Devices, your mobile carrier, date and time stamps associated with transactions, system configuration information, metadata, and other interactions with the Services.

We collect this information in order to deliver the Services and to provide our Users with reporting and analytics relating to the use of the Services. This information is made available to Users via the Services (for example, we provide Users with information on the use of their custom replies) and may be associated with other information about the User.

ii. Other information collected via Cookies and Other Tracking Technologies.

We use “cookies” (small data files that we transfer to your Device) and other tracking technologies to operate and administer the Site and the Services, analyze trends and improve your access to, and use of, our Services. For more information about the cookies and similar technologies used on our Site and Services, please refer to our Cookie Policy annexed to this Privacy Policy.

2. HOW WE USE INFORMATION

A. Provide Information; Respond to Requests
When you ask for information about the Services (for example, when you request a demo or ask us to send you offers or price information), or register to a webinar or an event, we will use your contact information to respond to your request. Such use is necessary to respond to or implement your request.

B. Provide the Services to Users
We use data provided by Users in connection with the purchase, sign-up, use, or support of the User account (such as usernames, email address and billing information) to provide you with access to the Services and/or the Site, contact you regarding your use of the Services and/or the Site, or to notify you of important changes to the Services and/or the Site. Such use is necessary for the performance of the contract between you and us. To provide Users with our Services, we may share their data with third parties.

C. Sending Marketing Communications and Other Announcements
Where required by applicable law (for example, if you are an EU data subject), we will only send you marketing information by email or mail, or contact you by phone, if you consent to us doing so at the time you provide us with your Personal Data. When you provide us with your consent to be contacted for marketing purposes, you have the right to withdraw your consent at any time by following the instructions to “opt-out” of receiving marketing communication in each marketing email we send you. In addition, if at any time you do not wish to receive future marketing communications or wish to have your name deleted from our mailing or calling lists, please contact us at . Please note that if you opt out from marketing communications, we may still contact you regarding issues related to our Services and to respond to your requests.

D. For Legitimate Business Interests
We use data relating to your use of and interaction with the Site and the Services, including information that we receive through cookies and similar technologies, for certain legitimate business interests, which are the following:

to provide, administer, and support the Site and the Services;
to personalize and improve your access to and use of the Site and the Service (including to increase our Services’s functionality, product features, and user-friendliness);
to verify Users have the authorization needed for the Services to process their requests;
to inform our marketing strategy and personalize our communications with you (including providing or offering software updates, information on our features and other marketing and service-related announcements relevant to the content and features you engage with);
to conduct analytics and report on industry trends on content usage and performance;
to meet our corporate and social responsibility objectives;
if you ask us to delete your data or to be removed from our marketing lists and we are required to fulfil your request, we will keep basic data to identify you and prevent further unwanted processing; and
for internal business/technical operations, including troubleshooting, data analysis, testing, to prevent fraud or criminal activity, misuses of our products or services and ensure the security of our IT systems, architecture, and networks.

This use of your Personal Data is necessary for our legitimate interests in understanding how the Site and our Services are being used by you and to improve your experience on it.

3. INFORMATION SHARING AND DISCLOSURE

A. Your Use
We will display your Personal Data on your profile page and elsewhere on the Services according to the preferences you set in your account.

B. Our Travel Partners
We also disclose your Personal Data, if necessary, to process your request and deliver our Services, to our Travel Partners, so that we can book events, tickets, or hotel nights for you. We might also share sensitive information, only when required by our Travel Partners (such as special assistance needs to book a flight). These third parties have access to your Personal Data for the purpose of performing these specific tasks on our behalf and pursuant to our instructions.

C. Our AI assistant chatbot
To provide our Services to our Users and improve our Services for a better experience, we will share your data with LiveChat. However, we anonymize this data so that no identification is possible.

C. Employees, Services Providers, Business Partners, and Others
We will disclose your Personal Data to our employees as necessary to deliver the Services, and we may use certain third party companies and individuals to help us provide, support, analyze, and improve the Services (such as providers of data storage services, maintenance services, payment processing, database management,…). These third parties may have access to your Personal Data for the purpose of performing these tasks on our behalf and pursuant to our instructions.

As of the Effective Date, we use AWS storage service to store some of your information. You can find more information on Amazon’s data security on http://aws.amazon.com/security/.

We also share your Personal Data with our Fraud prevention partner Clearsale. You can access to their privacy policy here (https://www2.clear.sale/legal/privacypolicy).

C. Compliance with Laws and Law Enforcement Requests; Protection of ' Rights
We may disclose to parties outside files stored in your account and information about you that we collect when we have a good faith belief that disclosure is reasonably necessary to (a) comply with a law, regulation, or compulsory legal request; (b) protect the safety of any person from death or serious bodily injury; (c) prevent fraud or abuse of or its users; or (d) to protect ' property rights.

D. Business Transfers
If we are involved in a merger, acquisition, bankruptcy, or sale of all or a portion of our assets, your information may be transferred as part of that transaction, but we will notify you (for example, via email and/or a prominent notice on our Site) of any change in control or use of your Personal Data, or if either become subject to a different Privacy Policy. We will also notify you of choices you may have regarding the information.

4. CHANGING OR DELETING YOUR INFORMATION

If you are a registered User, you may review, update or correct the Personal Data provided in your registration or account profile by changing your account settings. If your Personal Data has been shared outside of our Services by other Users of third parties and not directly by us, we cannot change or delete this Personal Data out of our control.

5. DATA RETENTION

We will retain your Personal Data for as long as is necessary for the purposes set out in this Privacy Policy or for our Services, for as long as your account is active, or as needed to provide you the Services or for the duration required by law, whichever is the longer. If you wish to delete your account or request that we no longer use your information to provide you the Services, you may ask that we delete your account by emailing . We will then delete your Personal Data within 30 days.

We may retain, use or disclose your information (including Personal Data) as necessary to comply with our legal obligations, to resolve disputes or enforce our agreements, and a legitimate business interest (such as for analytics purposes, safety, and security). Consistent with and subject to these requirements, we will try to delete your information quickly upon request.

7. COMMUNITY

Our Services may offer publicly accessible community services such as blogs, forums, and wikis. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. Your posts may remain even after you cancel your account. For questions about your Personal Data on our Services, please contact .

8. EU DATA SUBJECTS’ RIGHTS

This section applies solely to EU data subjects (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, where applicable, Switzerland). is the data controller for processing of your Personal Data.

A. Your Rights
Subject to applicable EU law, you have the following rights in relation to your Personal Data:

Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
Right to erasure: You may ask us to delete or remove your Personal Data, such as where our legal basis for the processing is your consent and you withdraw consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly. We may continue processing Personal Data where this is necessary for a legitimate interest in doing so, as described in this Privacy Policy.
Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it. We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
Right to data portability: You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
- If we are relying on a legitimate interest to process your Personal Data — unless we demonstrate compelling legitimate grounds for the processing or
- If we are processing your Personal Data for direct marketing.
Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your data before we received notice that you wished to withdraw your consent.
Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.

You may exercise your rights by contacting us as indicated under “Contacting Us” section below.

B. Legitimate Interest
“Legitimate interests” means our interests in conducting our business, managing and delivering the best Services to you. This Privacy Policy describes when we process your Personal Data for our legitimate interests, what these interests are and your rights. We will not use your Personal Data for activities where the impact on you overrides our interests, unless we have your consent or those activities are otherwise required or permitted by law.

9. SECURITY

The security of your information is important to us. We follow generally accepted standards to protect the Personal Data submitted to us, both during transmission and once we receive it. No method of electronic transmission or storage is 100% secure, however. Therefore, we cannot guarantee its absolute security.

10. OUR POLICY TOWARD CHILDREN

Our Services is not directed to persons under 13. We do not knowingly collect Personal Data from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Data without their consent, he or she should contact us at and we will endeavor to delete it.

11. YOUR CALIFORNIA PRIVACY RIGHTS

Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year.

To obtain this information, please send an email message to with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response.

Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

12. CHANGES TO OUR PRIVACY POLICY

This Privacy Policy may change from time to time. If we make a material change to this privacy policy, we will provide you with notice. It is therefore important that you register with us and notify us if you change your email address. If you do not provide us with a current email address, you should regularly review this policy to ensure that you are informed of any changes.

13. CONTACTING US

If you have any questions about this Privacy Policy, please contact us at .

’s Cookie Policy

uses cookies and similar technologies on our Site and Services to operate and administer our Site and the Services, gather usage and performance data and give you a personalized experience with .

This Cookie Policy (“Cookie Policy”) provides information about how and when we use cookies and similar technologies for these purposes and the choices that you have. It forms part of ' Privacy Policy. Capitalized terms used in this Policy but not defined have the meaning set forth in our Privacy Policy.

1. COOKIES AND OTHER TECHNOLOGIES

A cookie is a piece of information sent to your browser from a website and stored on your computer’s hard drive. Cookies can help a website like ours recognize repeat users and allow a website to track web usage behavior. Cookies work by assigning a number to the user that has no meaning outside of the assigning website. For more details on cookies and similar technologies please visit All About Cookies.

Cookies can be stored on your computer for different periods of time. “Session cookies” only last for as long as the browser session and are deleted automatically once you close your browser. “Persistent cookies” cookies survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again. We use “persistent cookies” to save your registration ID and login password for future logins to the Services. We use “session ID cookies” to enable certain features of the Services, to better understand how you interact with the Services, and to monitor aggregate usage and web traffic routing on the Services.

We also use pixel tags (usually in combination with cookies), from the third parties described below, to get information about your usage of the Site and the Services and your interaction with email or other communications. Pixel tags are a technology similar to cookies that can be embedded in online content or within the body of an email for the purpose of tracking activity on websites (for example, to know when content has been shown to you), or to know when you have viewed particular content or a particular email message.

2. TECHNOLOGIES USED

We use cookies and similar technologies as described below:

*Type/Purpose*	*Who serve them*	*Opt-Out*
Strictly Necessary: Used to provide our Site and Services and use some of their features, such as the ability to log-in and access to secure areas. These cookies are essential for using the Site and the Services and without these cookies basic functionalities would not work.	Inc.	Because these cookies are strictly necessary to deliver the website and the services, you cannot refuse them.
Analytics: Used to recognize and count the number of Site visitors and see how they move around the Site (including number of page views, number of visitors, and time spent on each page). This helps us to improve the way our Site works, for example by making sure you can easily find what you need, and monitor the performance of our application in order to improve it.	Google Analytics: PrivacyPolicy. Google Tag Manager (a tag management system that allows you to quickly andeasily update tags and code snippets on a website): Privacy Policy	You can block or delete these cookies by changing the browser settings as explained under the “Your Choices” section below.Some providers offer direct opt- out tools.
Functionality: Used to Site and Services (such as collecting performance and error data, enabling customer support for users, for example offering live support chat). Some cookies may also allow us to conduct analytics.	LiveChat	You can block or delete these cookies by changing the browser settings as explained under the “Your Choices” section below.

3. YOUR CHOICES

On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:

You may also manage or opt-out of cookies by using the links provided by the third parties described above.

Please note that if you reject cookies or turn cookies off, you may be unable to access certain parts of the Site or the Services and you may not be able to benefit from the full functionality of the Site or the Services. You may not decline pixel tags. However, they may be rendered ineffective by declining all cookies or modifying your browser settings to notify you each time a cookie is tendered and permit you to accept or decline cookies on an individual basis.

To find out more about cookies and similar technologies, including how to see what cookies and similar technologies have been set and how to manage and delete them, visit http://preferences-mgr.truste.com in the United States, or the European Digital Advertising Alliance http://www.youronlinechoices.eu/ in Europe, or the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org, and follow the opt-out instructions there. If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.

4. CONTACT US

If you have any questions or concerns, please contact us at .