Columbus Travel Usa LLC owns and operates an online platform that provides users with information, recommendations and services related to travel and leisure, including tools for researching and/or booking hotels, rentals and other accommodations, attractions and experiences, restaurants, flights, and cruises, among other leisure-related services. In this Statement, we refer to these as our “Services”.

The information that you and others entrust us with enhances our ability to provide more relevant, personalized and helpful Services. We know that sharing your information with us is based on trust. We take your trust in us seriously and are committed to providing you helpful information, products and services, curated based on the information you have shared with us. Equally, and perhaps more importantly, we are committed to respecting your privacy when you visit our website or use our Services and being transparent about how we use the information you have entrusted to us.

This Statement describes how we obtain, use, and process your information. It informs you of the rights you have, how you can exercise them and how you can contact us. Please review this Statement carefully to learn about our practices with respect to information and privacy. By visiting our websites and related mobile applications, as well as other online platforms such as our affiliated partners’ websites, apps and social media, whether on a computer, phone, tablet, or similar device (each of these is referred to as a “Device”), you acknowledge and confirm that you have read this Statement.

We offer our Services to users in a number of countries and territories where the laws and customs differ. This Statement provides a general overview of our privacy practices. In addition, Sections 12 through 15 of this Statement provide specific information relevant to users residing in certain regions or countries.

1. Information Collected and Processed

When you access or use our Services, we collect and process information from and about you to provide the Services in a more personalized and relevant way. Some information we collect passively, for example, with our servers or with cookies or other similar tracking technologies. Some information we collect from different sources, including from you, affiliated entities, business partners, and other independent third-party sources. When you use our Services by “clicking-through” from a third-party website or when you visit third-party websites via our Services, those third-party websites may share information with us about your use of their service. Any information that we receive from third-party websites may be combined with the information provided by you.

2. Information Uses and Purposes

To the extent possible, we want to provide you with relevant content and a tailored experience when you use our Services, and we use information about you to do that, including in the following ways: Registration, membership, and other contracts Register and manage your account, including to allow you access to and use of our Services Facilitate your bookings Process payments or credits Offer you promotional programs that may include competitions, gift cards, rewards, cash back, and discounts Improve our Services Use your information for analytical purposes and to enable us to improve our Services Provide you with a tailored/optimized experience by grouping users based on, for example, usage, interests and demographics Send you survey, market research invitations, or panel interviews for analytics purposes Personalization and customization Notify you about special offers and products or services available from us, our affiliates, or our partners that may be of interest to you Tailor your experience, including by making inferences about your interests and preferences based on your activity and customize the ads shown to you both on and off our website Communication Communicate with you or facilitate communication between you and our partners and/or affiliates Conduct, monitor and record your calls or interactions with us; for example, your communications with our customer service or sales teams, or through our use of pixels and similar technologies to monitor how you interact with our emails to you, such as whether you open or click on content in our emails Host your reviews, forum posts, photos, videos, and other content Respond to your questions and comments Legal Compliance Resolve disputes or troubleshoot problems Prevent fraud and other potentially prohibited or unlawful activities Comply with relevant laws, respond to legal requests, prevent harm, and protect our rights Provide payment services, including to detect and prevent money laundering, fraud and security incidents, to comply with legal obligations, and to enforce any applicable terms of service Please note, if we use automated decision-making to process your personal information, we will implement appropriate measures required to safeguard your rights and freedoms including your right to obtain human intervention.

3. Information Sharing

In order to provide some of our Services and processing activities, we use service providers and may need to make available each category of information that we collect to these service providers, and certain other third parties, including our group of companies, in the following circumstances: Our Group of Companies. We may share information with certain companies in our corporate family so we can provide you with information about products and services, both travel-related and others, which might interest you and to provide payment services. This sharing also allows us to better understand how you interact with the websites, apps and services of our group companies. These companies will comply with this Statement and all applicable laws governing the transmission of promotional communications. Suppliers. We may share information with certain suppliers used to facilitate our Services, including where relevant to help with transactions. Business Partners. We may share information about you, your Devices and your use of our Services with our trusted business partners. For example, we may share information so that we can facilitate payment for products or services you may purchase on the websites of our partners. This sharing is generally pursuant to written agreements which include confidentiality, privacy, and security obligations; please note, however, that we do not control the privacy practices of these third-party business partners. Social Media Websites. When you use our Services and elect to share information with third-party social media websites, the information you share will be governed by the privacy policies of those social media websites and the privacy settings you have set with those social media websites. Advertising Networks. We sometimes collect and share information about your interests with advertising networks and data aggregators. Some of these companies are members of the Network Advertising Initiative or the Digital Advertising Alliance, which offer a single location to opt out of ad targeting from member companies. To learn more about the Digital Advertising Alliance, please click here. Fraud Detection Companies. Third parties may assist us by providing us with their fraud detection technologies. Trusted third parties. Third parties may also assist us in collecting information by, for example, operating features of our website or facilitating the delivery of online advertising tailored to your interests. We may share audience segments and other information, such as hashed email addresses, with third parties that use that information for tailored advertising to you. Other third parties may also provide us with their content and contract generation, management, and hosting tools. Third parties may only collect or access information as needed to perform their permitted functions. If and to the extent these third parties only assist us to perform our processing operations, we have bound them contractually to only act on our behalf as so-called data processors. Certain Device operating system versions permit you to opt out of certain types of information sharing, including to certain advertising networks. You can change the privacy settings of your Device at any time in order to turn off the functionality that collects and shares location information. Please check your Device settings if you want to limit such tracking. However, turning off location-sharing may affect certain features that we offer. If you have any questions about the privacy settings of your Device, we suggest you contact the manufacturer of your Device or your mobile service provider for help.

4. Information Choices

You have options with respect to the processing and use of your information by us. You can access, update, and even close your account by visiting the “Member Profile” section on our website or app. In addition, you can do the following: Choose the way we communicate with you. Choose not to provide us with certain information, although it may be needed to take advantage of certain features offered on our websites. Prevent the collection of certain geolocation information (e.g. by switching off location services for our app in the settings of your phone), but note that turning off location sharing may affect certain features of our Services. Close your account directly from within your Member Profile. Note that if you close your account, we will deactivate your account and remove your profile information from active view. We may retain some information associated with your account (including past transactions) for internal purposes including backups, fraud prevention, dispute resolution, investigations, our own legitimate business interests, and legal compliance for the period necessary to fulfil the purposes outlined in this Statement. As a registered member, you can modify your marketing subscriptions, including email subscription choices, at any time, within your member settings. Unsubscribe from promotional messages, including emails with travel-related opportunities, in any such email we send.

5. Information on Children

Our Services are not intended for children, which we consider to be: (i) individuals that are 13 years of age or under, or the age of privacy consent in your jurisdiction; or (ii) when processing data on the basis of a contract, the age of legal capacity to enter into the agreement. We will only collect or process information belonging to children under very limited circumstances. We might need to collect personal information belonging to children as part of our Service if, for example, the personal information is required as part of a travel-related reservation. We will only collect personal information belonging to children if it is provided by and with consent of a parent or guardian. If we become aware that we have processed the personal information of a child without the valid consent of a parent or guardian, we will delete the personal information.

6. Information Transfers

We offer our Services to users located in many different jurisdictions. If we transfer your information to other countries, we will use and protect that information as described in this Statement and in accordance with applicable law.

7. Information Security

We have implemented appropriate administrative, technical, and physical security procedures to help protect your information. We only authorize specific personnel to access personal information and they may do so only for permitted business functions. We use encryption when transmitting your information between your system and ours, and between our system and those of the parties with whom we share information. We also employ firewalls and intrusion detection systems to help prevent unauthorized access to your information. However, we cannot guarantee the security of information from unauthorized entry or use, hardware or software failure, or other circumstances outside of our control.

8. Information Deletion and Retention

We will retain copies of your information for as long as you maintain your account or as necessary in connection with the purposes set out in this Statement, unless applicable law requires a longer retention period. In addition, we may retain your information for the duration of any period necessary to establish, exercise, or defend any legal rights.

9. Information from Cookies

We want your access to our Services to be as easy, efficient, and useful as possible. To help us do this, we use cookies and similar technologies to improve your experience, to enhance website security, and to show you relevant advertising. Cookies are small text files that are automatically placed on your Device when you visit almost any website. They are stored by your internet browser and contain basic information about your internet use. Your browser sends the information from these cookies back to a website every time you revisit it, so it can recognize your Device and improve your experience by, among other things, providing you with personalized content. We also use other tracking technologies, such as pixel, SDKs, or server logs, that have a similar functionality. We also use cookies and tracking technologies to remember your login details, so you don’t have to re-enter them repeatedly when you use our Services or to help us understand your preferences. To give you control, we provide you with a Cookie Consent Tool which allows you to adjust and customize your cookie settings. You can access the Cookie Consent Tool by clicking the “Cookie consent” link at the bottom of every page and modify your preferences in our cookie banner. In addition, you can manage cookies through the settings of your internet browser. You have the right to withdraw your consent to cookies at any time by clicking on the “Cookie consent” link and modifying and saving your preferences. In the settings of your Internet browser, you can choose which cookies to accept and reject. We allow third parties to collect and use information obtained during your browsing activities in order to deliver tailored advertisements to you (from us and from third parties across the Internet), to analyze activity and engagement on our website or app, and to provide you with enhanced Services. These parties are listed in our Cookie Consent tool, where we provide you with their details and links to their privacy notices. When we disclose your information to these third parties, this may be considered a “sale” or “share” under the applicable U.S. state privacy laws. Details on how to exercise your legal rights with respect to such “sales” or “shares” can be found below in Section 13.

10. Information on Statement Changes

We may update this Statement in the future. If we believe any changes are material, we will let you know by doing one or more of the following: sending you a communication about the changes, placing a notice on the website and/or posting an updated Statement on the website. We will note at the top of this Statement when it was most recently updated. We encourage you to check back from time to time to review the most current version and to periodically review this Statement for the latest information on our privacy practices.