EFFECTIVE DATE: May 15, 2023
1. WHAT PERSONAL INFORMATION IS COLLECTED BY TRAVELPRO OR ITS SERVICE PROVIDERS AND WHEN
We may receive and have received in the past 12 months Personal Information from other sources. For example, if you connect your social media account(s) to your account, the social media site may share information with us about your use of their services, including information about your profile, contacts, and viewed or liked content. We encourage you to read the applicable privacy policies for your social media accounts. We shall have no responsibility for the data collection and use practices of those social media sites.
If you use the Sites to make a payment, we collect Personal Information about the transaction. This includes the date of the transaction, payment information, such as your credit or debit card number and other card information, and other account and authentication information, as well as billing and contact details.
If you create an account, we may collect and have collected in the past 12 months email address, physical address, phone number. If you participate in a live product demonstration, we may record and have recorded in the past 12 months the conversations and related video and thus may collect your first name, image(s), and voice.
Travelpro and its service providers also collect certain non-personal information, data that does not identify you as an individual person. This information tells us about how people use the Sites so that we can analyze their effectiveness and provide you with a better web experience. We collect and use this information through a variety of technologies, including “cookies” and analysis applications, as discussed below.
You may elect to receive text messages from us. When you sign up to receive text messages, we will send you information about promotional offers and more. These messages may use information automatically collected based on your actions while on our sites and may prompt messaging such as cart abandon messages (i.e., Cookies). To the extent you voluntarily opt to have Text notifications sent directly to your mobile phone, we receive and store the information you provide, including your telephone number or when you read a text message. You may opt out of receiving text messages at any time by texting “STOP” to our text messages. For more information about text messages, see our Terms and Conditions."
(A) SERVER INFORMATION
Like every website, the Travelpro servers automatically and temporarily store the following information in the server log files. This information is provided by your browser, unless you have deactivated the function.
- IP address of the enquiring computer File query by the client
- The http response code
- The Internet page from which you visited us (referrer URL) The time of the server query
- The browser type and version
- The operating system used on the enquiring computer
(B) SITE VISIT TRACKING TECHNOLOGIES
Travelpro additionally may use web beacons or pixel tags, which are tiny invisible graphic images, in the Sites. Web beacons and pixel tags may be used by Travelpro to count users who have visited its webpages and for related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
(C) DIFFERENT DEVICES
If you use different devices (e.g., your smart phone, laptop, and/or home computer) to access the Sites, we may be provided with and collect device-specific information, including your hardware model, operating system version, unique device identifiers, phone number, location, and mobile network information. We may associate your device identifiers or phone number with your account information
(D) THIRD-PARTY ANALYTICS
We may use third-party service providers (e.g., Google Analytics) to collect and analyze information about use of the Sites. These service providers may utilize cookies and related technologies to collect personal information.
2. USE OF INFORMATION
Travelpro and its service providers may use your Personal Information to provide our services and to contact you in response to inquiries you submit. Travelpro and its service providers may retain and use your Personal Information for as long as needed for the following purposes:
to present our Sites and related content to you;
to provide you with information, products or services that you request from us;
to provide you with notices about your account;
in combination with other information for improvement of the Sites and marketing and promotional purposes;
to process orders and payments from you;
to provide more consistent and personalized services across the Sites, including to personalize our advertising, marketing, and promotional efforts;
to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
to comply with legal or regulatory obligations or in response to law enforcement requests;
to help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business;
to notify you about changes to the Sites or any products or services we offer or provide though it;
for our marketing purposes – to offer our Services to you, to improve and customize our Services for you and to understand how our Services are used;
to allow you to participate in interactive features on the Sites;
for our everyday business purposes – such as to process your transactions relating the Services we provide you, communicate with you, manage records, respond to court orders and legal investigations, and administer and provide services to you; and
in any other way we may describe when you provide the information;
for any other purpose with your consent.
3. WHEN TRAVELPRO DISCLOSES YOUR INFORMATION
We may disclose aggregated information about our users without restriction. This data cannot be attributed to any specific individual. Travelpro may disclose aggregated user data in order to describe our services to current and prospective affiliates, and to other third parties for lawful purposes.
Travelpro and its service providers may transfer information between them for business purposes. For example, our service providers may handle technical support, payment processing, marketing, advertising delivery and tracking, or information analysis. We furnish our service providers the information they need to perform these and other services, and we work with our service providers to respect and protect your information. We may also provide your information to our affiliates. The entities with which we share information may be located in the United States or other countries.
In the event that Travelpro or our business or assets are sold or transferred, the information collected on the Sites may be transferred or shared with third parties as part of that transaction. We may also provide information or provide access to information to any of our affiliated businesses or to our business partners.
With your consent, we may disclose information about you to third parties to market their products or services to you.
On rare occasions, we may disclose specific Personal Information without your consent and without notice to you as required to comply with laws and regulations, or to comply with court orders, subpoenas, or lawful discovery requests. Information collected from you may also be used to investigate security breaches or otherwise cooperate with authorities. We may also share information with companies assisting in fraud protection or investigation.
We may disclose information about you without your consent and without notice to you as required to enforce or apply the Terms and Conditions, or other agreements including for billing and collection purposes
We will only keep your personal data for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as business records, tax, accounting or other legal requirements).
When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymize it and we will make such determination based on applicable laws.
4. HOW YOUR INFORMATION IS PROTECTED
5. THIRD-PARTY SITES
The Sites may contain links to other websites. Please note that when you click on one of these links, you will leave the Sites and will be subject to the policies and privacy practices of those websites, which may differ significantly. You should review the policies of other websites you visit. Travelpro is not responsible for the content, technology, security, or practices of linked sites operated by others, or for your use of linked sites.
6. CHILDREN'S PRIVACY
We do not knowingly collect Personal Information from anyone under 13 years of age except as permitted by law. If you have knowledge that a child under the age of 13 has submitted Personal Information to us or if parents or guardians want to review or delete their child's registration information, please email us at Legal@Travelpro.com
7. YOUR RIGHTS IN RELATION TO PERSONAL DATA UNDER THE GDPR
Although Travelpro makes good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which Travelpro is unable to provide access, including but not limited to: where information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Travelpro determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Travelpro will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
8. CALIFORNIA PRIVACY RIGHTS
Travelpro will not discriminate against you for exercising any of these rights, for example, by charging a different price or denying goods or services.
(A) CALIFORNIA SHINE THE LIGHT
California Civil Code Section 1798.83 permits California residents who are users of the Sites to request from us once a year free of charge information about the Personal Information Travelpro disclosed to third parties for direct marketing purposes in the preceding calendar year (if any). If applicable, this information would include a list of the categories of Personal Information that was shared and the names and addresses of all third parties with which Travelpro shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us at the address provided below.
(B) CATEGORIES OF INFORMATION COLLECTED, DISCLOSED, AND SOLD
Since January 1, 2022, we have collected or received the following categories of personal information (the “Category” information corresponds to the categories in the California Consumer Privacy Act).
|Types of Information Collected
|Purpose for Collection
|Name, mailing address, Internet Protocol (IP) address, email address.
|- Account registration - Fulfilling customer orders for our services - Marketing our services - Customer service
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
|Name, address, telephone number, education, employment, employment history, credit card number, debit card number. (Some personal information included in this category may overlap with other categories.)
|- Account registration - Fulfilling customer orders for our services - Marketing our services - Customer service
|C. Characteristics of protected classifications under California or federal law.
|Age (40 years or older), race, color, national origin, citizenship, veteran or military status, union membership.
|- Potential employment opportunities
|D. Commercial information.
|Records of products or services purchased.
|- Fulfilling customer orders for our services - Marketing our services - Customer service
|F. Internet or other similar network activity.
|Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
|- Web site optimization - Marketing our services
|G. Geolocation data.
|- Web site localization - Order fulfillment
|I. Professional or employment-related information.
|Current or past job history or performance evaluations.
|- Employment opportunities
|J. Education information that is not publicly available
|Education records such as education history and degrees achieved.
|- Employment opportunities
|K. Inferences drawn from other personal information.
|Profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
|- Marketing our services - Analytics and improvement of our services
Sensitive Personal Information
Some types of personal information are subject to a heightened level of protection under data privacy laws. These types of personal information are called “sensitive personal information” and include social security numbers, driver’s license numbers, passport numbers, precise geolocation data, racial or ethnic origin information, and genetic data. If and to the extent we collect, receive, or process sensitive personal information of Site users, potential Site users, or website visitors, we apply security measures designed to protect such information. We do collect or receive certain sensitive personal information from job applicants and employees, which is addressed in a separate notice.
Categories of Information Disclosed
Since January 1, 2022, we have disclosed the following categories of personal information for a business purpose as described above:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected characteristics information.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category K: Inferences drawn from other personal information.
Categories of Information “Sold”
We do not sell your personal data for a monetary fee; however, some U.S. privacy laws define a “sale” very broadly such that it may include our sharing of your personal data with certain third parties if we receive anything of value in return. In that regard, we share your personal data with certain third-party marketing partners and in exchange we receive the ability to market or offer our products and services through their websites and applications. This may be considered a “sale” under some laws.
The personal data that may be shared or sold in this context is: your name; email address; other contact information; and information obtained through cookies about, for example, your location, the website that directed you to our Sites, how you navigate our sites, and what purchases you make.
Other than these third-party marketing partners, there are no other third parties to which we will sell your personal data.
(C) ADDITIONAL PRIVACY RIGHTS
Right to Information. Subject to certain limits, you may ask us to provide the following information:
- The categories of personal information we collected about you;
- The categories of sources from which the personal information was collected;
- The business or commercial purpose for collecting the personal information;
- The categories of third parties with whom we shared the personal information;
- The specific pieces of personal information we collected about you; and
- Whether your personal information was sold or shared (“shared” in this context means sharing for the specific purpose of cross-context behavioral advertising) and, if so, the categories of personal information that was sold or shared, the categories of third parties to which your personal information was sold or shared, and the business purpose for the sale or sharing.
Right to Delete. You also have the right to ask us to delete any personal information that we have collected about you, subject to certain limitations. We may deny your deletion request if the information is necessary for us or our service providers to, among other things, provide a service you requested, take actions reasonably anticipated in the context of our business relationship with you, perform a contract we have with you, detect and protect against security incidents or illegal activity, comply with a legal obligation, or exercise a right provided for by law.
Right to Opt Out of Sale or Sharing. Certain states provide residents with the right to opt out of the sale of personal information. If you are a resident of a state that provides such right, you have the right to opt out of the sale of your personal information. You may exercise this right by clicking on the “Do Not Sell My Personal Information” link located at the bottom of our homepage or by submitting a request as described in the “Submission of Requests” section below. In addition, if you are a California resident, you have the right to opt out of the sharing of your personal information with any third party for the purpose of targeted advertising. You may exercise this right by clicking on the “Do Not Sell My Personal Information – U.S.” link located at the bottom of our homepage or by submitting a request as described in the “How to Exercise Your Rights” section below.
(D) NOTICE CONCERNING DO NOT TRACK SIGNALS
“Do Not Track” or "DNT" is a privacy setting that you may set in your web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
(E) HOW TO EXERCISE YOUR RIGHTS
You can review your Personal Information by logging onto the Sites and visiting your account. You may also send us an email at Legal@Travelpro.com to delete any Personal Information that you have provided to us.
If you request that your account information be deleted or if you unsubscribe from communications, we may maintain information about your transactions or inquiries for future service and recordkeeping purposes, as permitted by law.
- How to Authorize an Agent.If you make a request to exercise your rights through an authorized agent, we will require written proof that the agent is authorized to act on your behalf and you have taken steps to verify your identity directly with us.
- How We Verify Your Request.To respond to your request, we must verify your identity or the authority of your authorized agent to make the request. We will only use the Personal Information provided in a verifiable consumer request to verify your identity or the authority of your authorized agent to make the request. Making a verifiable consumer request does not require you to create an account with us. To allow us to verify your request, we will require that you provide at least two pieces of Personal Information we already have in our possession. We will verify your consumer request by comparing the information you provide to information already in our possession, and take additional steps to minimize the risk of fraud. We will process your request within the time provided by applicable law.
(F) RESPONSES TO REQUESTS
We will confirm receipt of your request within 10 business days of receipt and generally will respond to your request within 45 days of receipt. If we need more time to respond, we will inform you of the reason and we may take up to an additional 45 days to respond.
(G) NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
(H) NOTICE OF FINANCIAL INCENTIVE
This Notice of Financial Incentive includes an explanation of financial incentives we may offer California residents when they provide us with Personal Information. Those incentives are reasonably related to the information’s value, as permitted by the CCPA. The material aspects of any financial incentive will be explained and described when you sign up.
Your participation in these programs is optional. If you choose to participate, you may withdraw at any time by contacting us at Legal@Travelpro.com.
The financial incentives offered by Travelpro from time to time in exchange for Personal Information are commonly percentage/promotional discount codes to be applied to a single purchase (typically in exchange for an email address or for joining a member rewards program). The discounts may result in a range of savings to the consumer, depending on the details of the purchase.
Incentives, including percentage/promotional discounts, are not directly tied to, or exclusively based upon, a set value of any individual element of consumer data, but are reasonably based in good faith on the following considerations:
- Some consumers first experience our brand online and offering an incentive provides a unique opportunity for them to explore our products.
- Some of Travelpro’s marketing and advertising activities are done online and email communications are a key part of reaching existing and potential consumers in a manner which they both expect and that allows for them to exercise choices about how or whether or not to be contacted. Discounts may also be affected by factors such as performance targets, geographic location, seasonality and market trends.
Discounts may also be affected by factors such as performance targets, geographic location, seasonality and market trends.
10. CONTACT US
Travelpro Products, Inc.
6500 Park of Commerce Blvd
Boca Raton, Florida 33487