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Privacy Policy

Last Revised on April 15, 2023

Guest Max LLC, and our group of companies (“we” or “us”) are committed to protecting your privacy and using your personal data in accordance with applicable data privacy laws. This Privacy Statement explains how we collect, use, and disclose data when you use our platform and associated services, as well as your rights in regarding what we do with the information that we collect or hold about you. We provide this privacy notice in different languages. In case of any conflicts or inconsistencies between a non-English version of the privacy notice and the English version, the English version takes precedence.

Summary

What does this Privacy Statement cover?

This Privacy Statement is designed to provide answers to the following questions:

  • What is personal data?
  • What personal data do we collect and use?
  • How do we collect it?
  • Who does this apply to?
  • For what purposes do we collect personal data?
  • On what legal grounds do we collect personal data?
  • How do we share your personal data?
  • How long do we store your personal data?
  • What rights and choices do you have regarding your personal data?
  • How can you access and update your information?
  • How is your personal data secured?
  • Who is responsible for processing and securing your data?
  • How can you contact us?

What is personal data?

Personal data is any information that can be used, alone or together with other data, to uniquely identify any living human being, such as your name, ID number, nationality, or any email addresses or phone numbers related to you personally.

What personal data do we collect and use?

  • Name, email address, telephone number, and home, business, and billing addresses
  • Government issued identification required for booking or identity verification, such as passport, driver’s license, or national ID card
  • Payment information such as payment card number, expiration date, billing address, and financial account number
  • Travel related information, airline, hotel, room number, tour operator, travel agency
  • Travel-related preferences and requests
  • Loyalty program and membership information
  • Birth date and gender
  • Geolocation
  • Images (including facial photographs), videos, and other recordings
  • Social media account ID and other publicly available information
  • Communications with us (such as recordings of calls with customer service representatives for quality assurance and training purposes, emails, etc)
  • Other communications that occur through the platform among partners and travelers,
    and in-group chat and traveler-collaboration tools
  • The searches and transactions conducted through the platform
  • Data you give us about other people, such as your travel companions or others for whom you are making a booking
  • Information we receive about you from other Guest Max companies and third parties such as our business and affiliate partners and authorized service providers which may include updated contact information, demographic information, interests, and purchase history, which we may add to your account or profile and use for market research and analysis
  • Other data that you intentionally share. Information about you that you voluntarily submit to us in for example free text fields, web forms and other contexts.

When you install any of our apps or use our platform, we automatically collect the following types of information from your device:

  • IP address
  • Device type
  • Unique device identification numbers
  • Internet browser-type (such as Firefox, Safari, Chrome, and Internet Explorer)
  • Internet Service Provider
  • Operating system and version
  • Device model
  • Performance and data usage
  • Usage data, such as dates and times the app accesses our servers, the features and links clicked in the app, searches, transactions, and the data and files downloaded to the app
  • Device settings selected or enabled, such as Wi-Fi, Global Positioning System (“GPS”), and Bluetooth (which may be used for location services, subject to your permission as explained below)
  • Mobile device settings
  • Other technical information such as app name, type, and version as needed to provide
    you with services
  • Details of any referring website or exit pages, as well as general geographic location (such as at the country or city-level)
  • Device and telephone connectivity information such as your carrier, network type, network operator, subscriber identity module (“SIM”) operator, and SIM country
  • Other technical information such as app name, type, and version as needed to provide
    you with services

How do we collect it?

  • You give us the information
  • We collect it automatically
  • We receive it from others

When you sign in to one of our hotel sites, website, sign up to receive offers or information, or make a booking using our platform, you give us your personal information. We also collect such information through automated technology such as cookies placed on your browser, with your consent where applicable, when you visit our sites or download and use our Apps. In addition, we also receive information from affiliated companies within Guest Max, as well as business partners and other third parties.

Who does this apply to?

All persons accessing any of the virtualconcierge.net and virtualhotel.net sites, as well as any other site or service operated by the Guest Max.

For what purposes do we collect personal data?

We use your personal information for various purposes described below, which depend on the site you visit or the app you use.

Your Use of Online Sites, Apps, and Services:

  • Perform registration and ID validation with the Travel Partner (hotel, cruise, or other)
  • Request information and services from the associated Travel Partner
  • Book any requested product(s) or service(s)
  • Receive services related to the booking and/or account
  • Create, maintain, and update user accounts on our platform and authenticate you as a user
  • Maintain your search and travel history, accommodation and travel preferences, and similar information about your use of Guest Max ’s platform and services, and as otherwise described in this Privacy Statement
  • Enable and facilitate acceptance and processing of payments, coupons, and other transactions
  • Administer loyalty and rewards programs
  • Collect and enable booking-related reviews
  • Help you to use our services faster and easier through features like the ability to sign-in using your account within the online services and sites of some of the Guest Max companies

Communications and Marketing:

  • Respond to your questions, requests for information, and process information choices
  • Enable communication between you and the Travel Partner like hotels, tour operators, and excursion providers
  • Contact you (such as by text message, email, phone calls, mail, push notifications, or messages on other communication platforms) to provide information like booking
    confirmations and updates, for marketing purposes, or for other purposes as described in this Privacy Statement
  • Market our products and services, optimize such marketing to be more relevant to you, and measure and analyze the effectiveness of our marketing and promotions
  • Administer promotions like contests, sweepstakes, and similar giveaways

Other Business Purposes and Compliance

  • Conduct surveys, market research, and data analytics
  • Maintain, improve, research, and measure the effectiveness of our sites and apps, activities, tools, and services
  • Monitor or record calls, chats, and other communications with our customer service team and other representatives, as well as platform communications between or among partners and travelers for quality control, training, dispute resolution, and as described in this Privacy Statement
  • Create aggregated or otherwise anonymized or identified data, which we may use and disclose without restriction where permissible
  • Promote security, verify identity of our customers, prevent and investigate fraud and
    unauthorized activities, defend against claims and other liabilities, and manage other risks
  • Comply with applicable laws, protect our and our users’ rights and interest, defend ourselves, and respond to law enforcement, other legal authorities, and requests that are part of a legal process
  • Comply with applicable security and anti-terrorism, anti-bribery, customs and immigration, and other such due diligence laws and requirements
  • Operate our business using lawful business purposes and as permitted by law

On what legal grounds do we collect personal data?

  1. Legitimate Interest – If we collect and use your personal information in reliance on our legitimate interests (or the legitimate interests of any third-party), this interest will typically be to operate or improve our platform and communicate with you as necessary to provide our services and those of out Travel Partners to you, for security verification purposes when you contact us, to respond to your queries, or for the purposes of potentially detecting or preventing illegal activities.
  1. Explicit Consent – To provide you with marketing communications, where you have opted in to receive such communications (including information about us and our Travel Partners’ products, solutions and services, competitions and promotions). These can be shared via electronic means (Whatsapp, SMS, emails and online advertising) and via post.
  1. Legal Basis – In some cases, we will have a legal obligation to collect personal information from you such as where it is necessary to use your transaction history to complete our financial and tax obligations under the law. If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

How do we share your personal data?

Your personal information may be shared to help you book your travel and/or vacation, assist with your travel and/or vacation stay, communicate with you (including when we send information on products and services or enable you to communicate with travel partners and/or property owners), and comply with the law. Your personal data will only be shared with our mutual Travel Partners and their direct affiliates when applicable.

How long do we store your personal data?

We will retain your personal data in accordance with all applicable laws, for as long as it may be relevant to fulfill the purposes set forth in this Privacy Statement, unless a longer retention period is required or permitted by law. We will deidentify, aggregate, or otherwise anonymize your personal information if we intend to use it for analytical purposes or trend analysis over longer periods of time.

The criteria we use to determine our retention periods include:

  • The duration of our relationship with you, including any open accounts you may have with Guest Max companies, or recent bookings or other transactions you have made on our platform.
  • The duration of our Travel Partners relationship with you, including any open accounts you may have with them, or recent bookings or other transactions you have made on our platform.
  • Whether we or any of our Travel Partners have a legal obligation related to your personal information, such as laws requiring us or them to keep records of your transactions.
  • Whether there are any current and relevant legal obligations affecting how long we will keep your personal information, including contractual obligations, litigation holds, statutes of limitations, and regulatory investigations.

What rights and choices do you have regarding your personal data?

Guest Max LLC and the Guest Max value your rights and commit to allowing you to:

  • Request a copy of your personal information
  • Request information about the purpose of the processing activities
  • Delete your personal information
  • Object to our use or disclosure of your personal information
  • Restrict the processing of your personal information
  • Opt-out of the sale of your personal information
  • Port your personal information
  • Request information about the logic involved in our automated decision-making used in our fraud prevention practices and the result of such decisions

In addition to the above rights, you may have the right to complain to a data protection authority about our collection and use of your personal information. However, we encourage you to contact us first so we can do our best to resolve your concern. You may submit your request to us by contacting us here. We respond to all requests we receive from individuals wanting to exercise their personal data protection rights in accordance with applicable data protection laws.

How can you access and update your information?

  • You may change your communication preferences with us at any time by contacting us here.
  • You can control our use of certain cookies by following the guidance in our Cookie Policy.
  • You can access, amend or update the accuracy of your information at any time by contacting us here.
  • If you no longer wish to receive marketing and promotional emails, you may unsubscribe by clicking the ‘unsubscribe’ link in the email. You can also change communication settings (not available for all  Guest Max  companies) by contacting us here.
  • Please note that if you choose to unsubscribe from or opt out of marketing emails, we may still send you important transactional and account-related messages from which you will not be able to unsubscribe.
  • For our mobile apps, you can view and manage notifications and preferences in the settings menus of the app and of your operating system.
  • If we are processing your personal information on the basis of consent, you may withdraw that consent at any time by contacting us. Withdrawing your consent will not affect the lawfulness of any processing that occurred before you withdrew consent, and it will not affect our processing of your personal information that is conducted in reliance on a legal basis other than consent.

How is your personal data secured?

We want you to feel confident about using our platform and all associated tools and services, and we are committed to taking appropriate steps to protect the information we collect. While no company can guarantee absolute security, we do take reasonable steps to implement appropriate physical, technical, and organizational measures to protect the personal information that we collect and process.

The personal information we process may be transmitted or transferred to countries other than the country in which you reside. Those countries may have data protection laws that
are different from the laws of your country.

The servers for our platform are located in the United States, and third-party service providers operate in many countries around the world. When we collect your personal information, we may process it in any of those countries.

We have taken appropriate steps and put safeguards in place to help ensure that your personal information remains protected in accordance with this Privacy Statement. For example, any data transfers between our group companies are governed by our intragroup agreements which incorporate strict data transfer terms (including the European Commission’s Standard Contractual Clauses, for transfers from the EEA) and require all group companies to protect the personal information they process in accordance with applicable data protection law.

We also require that third-party service providers to whom a data transfer is made have appropriate safeguards in place to protect your personal information, in compliance with applicable data protection law. The particular measures used will depend on the service provider, and our agreements with them may include European Commission approved Standard Contractual Clauses, the service provider’s certification under the EU-U.S. and/or Swiss-U.S. Privacy Shield certification, or reliance on the service provider’s Binding Corporate Rules, as defined by the European Commission. However, Guest Max LLC assumes no responsibility or liability for the actual measures implemented by the third-party service providers, or the results of said measures.

Who is responsible for the processing and securing your data?

Guest Max LLC is responsible for processing and securing your data as pertains to the specific requirements set for in our Terms and Conditions and Privacy Policy, for use of the Guest Max LLC Web Application, and any purchases or reservations made therein.

Your credit card details are processed and secured exclusively by the Payment Processor selected by Guest Max LLC, and at no time does Guest Max LLC have any visibility into this sensitive information.

Additionally, the Travel Providers servicing you (ie. Your hotel, excursion or activity provider, or any vendor from which you make purchases through the Guest Max Web Application) are responsible for processing and securing your data for the purposes of providing you with the selected products or activities.

How can you Contact Us?

You can reach us for any questions or concerns at [email protected].