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Who Are We?

2 Keys Travel LLC and its affiliates (“Company”) is a global travel services company that  serves individual client travel needs and offers other travel related services. In order to  deliver your services, it is necessary for us to collect and process your personal information.  We care about your privacy. This Privacy Policy explains the policies and practices we  follow to protect your personal information that we hold. This Privacy Policy applies to  information we collect about you either through your use of Company websites (“Site(s)”) or  through other means. The server(s) that make(s) this Site available may be located outside  the country from which you accessed this site, but we will collect, process and use personal  information only in accordance with this policy and as required by local law in the places in  which we operate.

If you have questions not answered in this policy, our Privacy Officer may be contacted  directly at [email protected].

What Personal Information Do We Collect?

We collect your personal information, and that of your travel companions, that is provided to  us either directly by you or through a travel sponsor as the case may be, in order to provide  you with the products and services you have requested. In most cases, it consists of • Full Legal Name

  • Email address
  • Postal address
  • Phone number
  • Credit card number or other payment information

We may collect other information to assist you with your travel plans including but not  limited to, passport number, driver’s license or other government-issued identification  number, date of birth, gender, arrival and departure locations and times, airline, hotel or car  rental frequent loyalty numbers, known traveler and global entry number, and other related  travel information.

Information We Collect Through Automatic Data Collection Technologies

We collect other information, such as your IP address, search terms, and site pages you  visit while on our Site, whenever you visit our Site, use our services, or view our online  advertisements. The technologies we use for this automatic data collection may include  cookies and log data.

You can learn more about how we use cookie data by reviewing our Cookie Policy which  can be found in the “Cookie Policy“ section of this document.

Whenever you use a website, mobile application, or other internet service, certain  information is created and retained by the website or application. This happens with our Site  as well. We collect technical information when you use our Site, or information that has  been made anonymous, such as:

• Log data: Our servers automatically record information when you use our Site, such  as your IP address, the type of browser you are using and its settings, the third party website  you visited immediately prior to accessing our Site, the operating system you are using, the  domain name of your Internet service provider, the search terms you use on our Site, the

specific Site pages you visit, type of product selected, the brand, order, and product  identifications, and the duration of your visits.

  • Cookie data: A “cookie” is data that a website server stores on your computer.  Cookies enable websites to recognize your computer and to “remember” your entries as you  move from page to page, or even when you revisit the site from time to time using the same  computer.

We may also collect information pertinent to the marketing of our products and services.  This information may include marketing channels, User Market IDs (CenterPoint, TNMP,  etc.), Site brands and product names, contract terms, financial information and other  information.

We collect and analyze this information to measure the number of visitors to the different  sections of our Site, to evaluate how visitors use our Site and to provide you with  advertisements that are relevant and useful to you, unless you have told us not to. We also  use the information we collect to understand customer needs and trends, to carry out  targeted promotional activities, and to generally help us make our Site more useful to  visitors.

We may use your Site data by itself or aggregate it with similar information we have  obtained from others. We may share your Site data with our affiliates and other third parties  to achieve these objectives. You may obtain a list of our affiliates and third parties with  whom we share your Site data by contacting us at the address below.

We reserve the right to use Internet Protocol (IP) addresses to identify a visitor when we  feel it is necessary to enforce compliance with our Site’s Terms and Conditions, or to: (a)  fulfill a government request; (b) conform with the requirements of the law or legal process;  (c) protect or defend our legal rights or property, our Site, or other users; or (d) in an  emergency to protect the health and safety of our Site’s users or the general public.

How We Use Your Information. 

If you are a customer, an agent, an employee, or a job applicant, the personal information  we hold and use is necessary for the performance of the services contract or independent  contractor or other agreement to which you are a party or to perform the services you have  otherwise requested.

If you are a prospective customer, the personal information we collect and use is necessary  for our legitimate interest in providing you with information about the services we offer, and  about which you have expressed an interest or that we believe will be of benefit to you.  Where appropriate, we will obtain your consent at the time we communicate with you. In some cases, our purpose for collecting the information is because you have expressly  consented to our collection and use of your personal information.

We collect your personal information for a variety of reasons. You may provide the  information to us directly, or through a tool or product provided by Company or another  organization to your employer in the case of our business clients. We collect your personal  information, such as name, address, email address, phone number, and credit  card information in order to provide the services you have requested. Other examples of  personal information that we collect include:

  • From employment applicants, we or our service provider will collect contact and  identification information, such as name, address, telephone number, e-mail address, date  and place of birth, driver’s license number and employment and salary information; • From travel customers, we may also request information such as your passport and  known traveler information, vendor loyalty programs, and other information as deemed  necessary by the service provider to fulfill your request, to permit us to provide other ancillary  travel services to you and to manage your travel experience.; and

Doing Business with You. We use the personal information we have collected to allow us to  evaluate your employment application, to provide the products and services you have  chosen, process payments, or to manage and develop our business and operations,  including:

  • Establishing, managing and terminating business relations with you; • Reviewing the products and services that we provide to you;
  • Informing you of our products and services other than those that you have  specifically requested;
  • Informing you of products and services carefully selected third parties may wish to  offer you;
  • Responding to your comments or requests for information;
  • Investigating and preventing fraudulent activities, unauthorized access to the  services and other illegal activities;
  • Protecting us against error, fraud, theft, and damage to our goods and property; • Enabling us to comply with applicable law or regulatory requirements; • For any other purposes about which we notify customers and users; and • For any other reasonable business purpose to which you consent.

Email communications: If you send us an email with questions or comments, we may use  your email address to respond to your questions or comments, and we may save your  questions or comments for future reference. We may email you when:

  • You have applied for employment with us;
  • You request information about our company;
  • It relates to purchases you have made from us (e.g., product updates, customer  support, etc.);
  • You consented to being contacted by email for a particular purpose. • We are sending you information about our other products and services, offers,  promotions and our newsletters, if this is in accordance with your marketing preferences.  However, you will always be able to opt out of such communications at any time. See the  ‘Your Choices’ section below.

How Do We Use Preference Based Advertising, Analytics, and Services? Disclosures As Required By Law 

We do not currently share your information that we collect for preference-based advertising  purposes and we do not currently have any plans to do so through this Site.

If we do in the future work with third parties for preference-based advertising, then we will  do so in accordance with this section and you can opt out as explained below. Such third  parties may include third party advertising networks and website analysis firms who

use cookies and web beacons to collect non-personally identifiable information when you  visit our Site and third-party sites. The information collected through cookies and/or web  beacons, including your IP address, web browser, pages viewed, time spent on pages, and  links clicked, is often used by these advertising networks to serve you with advertisements,  while you are on our Site and/or on third party sites, that better reflect your preferences and  needs. This information may be used by Company and these third parties to analyze and  track data, determine the popularity of certain content, deliver advertising and content  targeted to your interests on our products and services, and better understand your online  activity. For more information on how this type of advertising works, go  to

Who Else Do We Share Your Information with and Why? 

We may share your personal information with one or several of our business partners to  make an initial determination of the services you may need, to process your employment  application, or to otherwise facilitate our business operations. We also share your personal  information as necessary with airlines, hotels and other providers for whose services you  have requested our assistance. We may also share your information to protect and defend  the rights and property of Company.

Third Party Providers: We may use third parties to assist in processing your employment  applications, fulfilling your service requests, or providing other important information to you.  We require all such service providers to act in compliance with this Privacy Policy. We may  also share your personal information with third parties, including our affiliates, or with  employees, agents, consultants and other parties who require the information to assist us to  establish, maintain and manage our business relationship with you. Further, we may share  your personal information with our partners and affiliates to promote other services to you  that you might like or to show you ads in which you might be interested.

Email Communications: We may share your email contact information with our partners to  assist with marketing our products and services. You may unsubscribe from receiving future  commercial email communications from us by clicking the “unsubscribe” link included at the  bottom of any marketing emails we send, or by emailing us as provided in the “Contact Us”  section below. However, we reserve the right to send you transactional emails such as  customer service communications in connection with the products or services you have  purchased. For security reasons, we do not recommend that you send personal information,  such as passwords, social security numbers, or bank account information, to us by email.

Transfer of Assets: We do not sell or lease personal information or provide a list of our  customers to third parties. However, as we continue to develop our business, we may sell  or purchase assets. If another entity acquires us or all (or substantially all) of our assets, the  information we have about you will be transferred to and used by this acquiring entity. Also,  if any bankruptcy or reorganization proceeding is brought by or against us, all such  information may be considered an asset of ours and as such may be sold or transferred to  third parties.

Legal Necessity: Notwithstanding anything herein to the contrary, we reserve the right to  disclose any information about you if we are required to do so by law, with respect to

copyright and other intellectual property infringement claims, or if we believe that such  action is necessary to: (a) fulfill a government request; (b) conform with the requirements  of the law or legal process; (c) protect or defend our legal rights or property, or our Site; or  (d) in an emergency to protect the health and safety of our Site’s users or the general  public.

What Choices Do You Have About Our Use of Your Information? 

We strive to provide you with choices regarding the personal information you provide to us.  We have created mechanisms to provide you with the following control over your  information:

  • Cookies. You can set your browser to refuse all or some browser cookies, or to alert  you when cookies are being sent.
  • Your Contact Information. If you have previously emailed us and would like us to  delete your contact information from our files, please contact us at the email address below. • Other Information. If at any point you believe the personal information we hold about  you is incorrect, you want us to correct or delete that information, or you no longer want us to  hold that information or contact you, you can contact us at the email address below.

Accuracy of Personal Information: It is important that the personal information we hold  about you is accurate and current. Company requires you to keep us informed of changes to  your personal information. If your registration information changes, please send your  request to us at the email address below. We take reasonable steps to verify your identity  prior to honoring any such requests to help protect your privacy and security.

Accessing Your Personal Information: If you want to know what personal  information Company holds about you or wish to change personal information that is  inaccurate or out of date, or to withdraw your consent to our use of your personal  information, please contact us at the email address below. It may not always be possible to  completely remove or modify information in our databases, although we will make  reasonable efforts to do so upon your request. We do not control how our partners retain,  store and destroy data they have accessed in connection with assisting with providing our  services. You should check their websites for more information on their practices.

Do Not Track Disclosures: Certain browsers may offer you the option of providing notice to  websites that you do not wish for your online activities to be tracked for preference-based advertising purposes (“DNT Notice”). Some browsers are, by default, set to provide a DNT  Notice, whether or not that reflects your preference. Providing DNT Notice is often touted as  a means to ensure that cookies, web beacons and similar technology are not used for  preference-based advertising purposes – that is, to restrict the collection of information your  online activities for advertising purposes. Unfortunately, given how preference-based  advertising works, DNT Notices may not effectively accomplish this goal. For this and a  variety of other reasons, with respect to our Site, we do not take any particular action based  on browser based DNT Notices. However, we do not use third-party advertisers or engage  in behavioral marketing data collection for resale. Rather, if you do not wish to participate in  preference-based advertising activities, you should follow the opt-out process identified  above.

Your California Privacy Rights 

If you are a resident of the State of California, you have certain rights under California law to  request information concerning our data sharing activities with third parties.

Residents of the State of California, under certain provisions of the California Civil Code,  have the right to request from companies conducting business in California a list of all third  parties to which the company has disclosed certain personally identifiable information as  defined under California law during the preceding year for third party direct marketing  purposes. You may request the information in writing at the email address below. You may  learn more about your rights under California’s privacy laws at Safeguarding Personal Information

We take the security of your information very seriously. We have implemented industry standard security measures to protect against the loss, misuse and alteration of the  information under our control. To help ensure the confidentiality of your personal  information, it is important for you to protect against unauthorized access to your password  and to your computer. Be sure to sign off / log out when finished using a shared computer. Company will endeavor to safeguard personal information using methods that are  appropriate to the sensitivity of the information. We have implemented security measures  we consider reasonable and appropriate to protect against the loss, misuse and alteration of  the personal information under our control. However, we cannot guarantee or warrant the  security of any information you disclose or transmit to us online and are not responsible for  the theft, destruction, or inadvertent disclosure of your personal information. In the  unfortunate event that your information is compromised, we may notify you by e-mail or  U.S. mail to the last e-mail address or postal address you have provided us in the most  expedient time reasonable under the circumstances, or as otherwise required by applicable  law. We may delay notification as necessary while we take measures to determine the  scope of the breach and restore reasonable integrity to our system as well as for the  legitimate needs of law enforcement. From time to time we evaluate new technology for  protecting information, and when appropriate, we upgrade our information security  systems.

Privacy of Children’s Information 

Our Site is not directed to children. We do not sell products or services for purchase by  children. We will not knowingly collect personal information from children. If you are a  parent or guardian of a child under the age of 13 and believe he or she has disclosed  personally identifiable information to us, please contact us at the email address below. A  parent or guardian of a child under the age of 13 may review and request deletion of such  child’s personally identifiable information as well as prohibit the use of that information. Linked Sites

This Policy does not apply to your use of unaffiliated websites to which our Site is  linked. Company is not responsible for the privacy practices or the content on linked sites.  We recommend that you carefully read the privacy policies of each site you visit.

Sole Statement 

This Privacy Policy as posted on this Site is the sole statement of our privacy policy with  respect to this Site, and no summary, modification, restatement or other version thereof, or  other privacy statement or policy, in any form, is valid unless we post a new or revised  policy to the Site.

Contacting Us 

To get more information about Company’s privacy and information security practices, or if  you (a) have questions or comments about our Privacy Policy; (b) wish to make  corrections to any personal information you have provided; (c) want to opt-out from  receiving future commercial correspondence, including emails, from us or our affiliated  companies; or (d) wish to withdraw your consent to sharing your personal information with  others, contact us as follows:

By Email: [email protected]

Changes to This Policy 

Company may from time to time make changes to this Privacy Policy to reflect changes in  legal or regulatory obligations or changes in the manner in which we deal with personal  information. We will post any revised version of this Privacy Policy on our Site. Any changes  will be effective on the effective date stated in the revised Privacy Policy. If there are  significant changes we may provide more prominent notice or obtain your consent as  required by law. If you do not wish to accept the changes, you should cease using the Site.  Your continued use of the Site after we have posted a revised Privacy Policy indicates your  agreement to the revisions.

This Privacy Policy was last updated on April 15, 2020 and applies to 2 Keys Travel  LLC brands.