Privacy Policy

lastupdated: May 2018

1. Introduction

Weprovide travel reservation services for corporate, membership, group, andleisure travellers through technology provided by ARN.  The privacy andsecurity of our customers, respondents, and visitors are of paramountimportance.  We are committed to protecting the data shared with us. Thisprivacy policy explains how we process information that can be used to directlyor indirectly identify an individual (“Personal Data”) collected through use ofour website and platform.

Forthe purposes of this policy, we define the term “User” as an entity with whichwe have an established relationship, and the term “Visitor” as an individualthat visits any of our travel booking engine websites.

Anyinformation stored on our platform is treated as confidential. All informationis stored securely and is accessed by authorized personnel only. We implementand maintain appropriate technical, security, and organisational measures toprotect Personal Data against unauthorized or unlawful processing and use, andagainst accidental loss, destruction, damage, theft, or disclosure.

2. Collection and use

2.1 General

Thefollowing sections cover the specifics of each of the two groups from whichdata is collected: website Visitors and Users.

2.2 Website Visitors

Ifyou are a Visitor to our website only, and not a User of our platform, thenthis section is relevant for you.

Byvisiting this website, you consent to the collection and use of your PersonalData as described herein. If you do not agree with the terms set out herein,please do not visit this website. If required by applicable law, we will seekyour explicit consent to process Personal Data collected on this website orvolunteered by you. Kindly note that any consent will be entirely voluntary.However, if you do not grant the requested consent to the processing of yourPersonal Data, the use of this website may not be possible.

Wemay collect, record and analyze information of Visitors to our website. We mayrecord your IP address and use cookies. We may add information collected by wayof pageview activity. Furthermore, we may collect and process any Personal Datathat you volunteer to us in our website’s forms, such as when you register forevents or sign up for information and newsletters. If you provide us with yoursocial media details, we may retrieve publicly available information about youfrom social media.

SuchPersonal Data may comprise your IP address, first and last name, your postaland email address, your telephone number, your job title, data for socialnetworks, your areas of interest, interest in our products, and certaininformation about the company you are working for (company name and address),as well as information as to the type of relationship that exists between us.

Wegather data about visits to the website, including numbers of Visitors andvisits, Geo-location data, length of time spent on the site, pages clicked onor where Visitors have come from.

2.2.1 Purpose of processing personal data

Weuse the collected data to communicate with Visitors, to customize content forVisitors to improve our website by analyzing how Visitors navigate our website.

Wemay use the information that you provide to tailor our experience to you andyour needs so that our service becomes inherently more useful over time. We may use your email address to give you updates on your futurereservations, prior reservations and how our service is evolving, as well asprovide you with promotional materials and offers such as for travel-relatedinsurance.  It is our goal to have our promotions be useful and relevantto you, and we want them to become increasingly so over time.

2.2.2 Sharing personal data

Wemay also share such information with service vendors or contractors in order toprovide a requested service or transaction or in order to analyze the Visitorbehavior on our website.

2.2.3 Cookies

Cookiesare small pieces of information sent by a website to a Visitor’s hard disk.Cookies cannot be used to run programs or deliver viruses to your computer. Bycontinuing to visit the website, you agree to the placement of cookies on yourdevice. If you choose not to accept our cookies, we cannot guarantee that yourexperience will be as fulfilling as it would otherwise be. We may also placecookies from third parties for functional and marketing purposes. The use ofcookies is widespread and benefits the surfer.

2.2.4 Links to other sites

Pleasebe aware that while visiting our site, Visitors can follow links to other sitesthat are beyond our sphere of influence. We are not responsible for the contentor privacy policy of these other sites.

2.3 Users

2.3.1. General

Inorder to provide services to our Users, we collect certain types of data fromthem. This section will describe how this data is collected and used by us aswell as geographical differences that affect this policy. Data entered ortransferred into us by Users such as texts, questions, contacts, media files,etc., remains the property of the User and may not be shared with a third partyby us without the express consent from the User.

2.3.2 Collection of User data

Duringa registration/booking reservation process a User must provide information suchas name, company name, email, address, telephone, credit-card number and otherrelevant data. This information is used by us to identify the User and providethem with support, services, mailings, sales and marketing actions, billing andto meet contractual obligations.

Userscan at any time access and edit, update or delete their contact details bylogging in with their username and password to our travel platform; or, byemailing customer support at [email protected] or [email protected] with requestedchanges. Users may create more Users with different privilege levels withintheir account. It is the responsibility of the User that creates other Useraccounts to choose the level of access each User should have. Once these newUsers log into our technology, they meet the definition of User in this policy.We will not retain User data longer than is necessary to fulfill the purposesfor which it was collected or as required by applicable laws or regulations.

Wemay use the information that you provide to tailor our experience to you andyour needs so that our service becomes inherently more useful over time. We may use your email address to give you updates on your futurereservations, prior reservations and how our service is evolving, as well asprovide you with promotional materials and offers such as for travel-relatedinsurance.  It is our goal to have our promotions be useful and relevantto you, and we want them to become increasingly so over time.

2.3.3. Geographical location

ARNstores all User Data other than credit card data in our local database locatedin the United States of America. Credit card encrypted data is stored in athird party encrypted vault located in the United States of America in fullcompliance with PCI DSS regulations. As an international processor of travelreservations, we store User data from individuals located throughout the world. For Users with accounts located in our database with an address outsideof the United States of America, all personal data is processed in compliancewith the standards and regulations specific to their country or region.

2.3.3.1 Specific Processing for the European Economic Area (EEA)

ForUsers with a European address located in our User database, all processing ofpersonal data is performed in accordance with privacy rights and regulationsfollowing the EU Directive 95/46/EC of the European Parliament and of theCouncil of 24 October 1995 (the Directive), and the implementations of theDirective in local legislation. From May 25th, 2018, the Directive and locallegislation based on the Directive will be replaced by the Regulations (EU)2016/679 of the European Parliament and of the Council of 27 April 2016 on theprotection of natural persons with regard to the processing of personal dataand on the free movement of such data, known as the General Data ProtectionRegulation (GDPR), and our User data collection will take place in accordancewith the GDPR.

2.3.3.1.1 Controller

Weprocess personal data as a Controller, as defined in the Directive and theGDPR.

TheARN entity which you as a User entered an agreement with when using ourplatform, will be the Controller for User data, as outlined above in“Collection of User data” section.  Depending upon the particular contextand usage in this privacy policy, the terms “we,” “us,” “our” and similar termsmay refer to the owner of this web site or travel.win.

Weadhere to the Directive of 1995 and the GDPR from May 25th, 2018. Consequently,we process all data provided by our Users with accounts with addresses locatedin the European Economic Area (EEA) according to the GDPR guidelines.

3. Retention and deletion

Wewill not retain data longer than is necessary to fulfill the purposes for whichit was collected or as required by applicable laws or regulations. When auser’s account is terminated or expired, all personal data collected throughthe platform will be deleted, as required by applicable law.

4. Acceptance of these Conditions

Weassume that all Visitors of our travel booking engine website powered by ARNand users of our platform have carefully read this document and agree to itscontents. If someone does not agree with this privacy policy, they shouldrefrain from using our website and platform. We reserve the right to change ourprivacy policy as necessity dictates. Continued use of our website and platformafter having been informed of any such changes to these conditions implies acceptanceof the revised privacy policy.

5. Our Legal Obligation to Disclose Personal Information

Wewill reveal a user’s personal information without his/her prior permission onlywhen we have reason to believe that the disclosure of this information isrequired to establish the identity of, to contact or to initiate legalproceedings against a person or persons who are suspected of infringing rightsor property belonging to us or to others who could be harmed by the user’sactivities or of persons who could (deliberately or otherwise) transgress uponthese rights and property. We are permitted to disclose personal informationwhen we have good reason to believe that this is legally required.

6. For Further Information

Ifyou have any further questions regarding the data we collect, or how we use it,then please feel free to contact us by email at: [email protected][email protected] writing at:

travel.win

1500Cordova Road

Suite302

FortLauderdale, FL 33316