Effective Date: Feb 11, 2022

This Privacy Policy describes how TERMINAL101 Software Corporation and its subsidiaries, or subsidiaries of our parent company Terminal101 Inc. that we manage “Terminal101”, “we”, “our” or “us”) collect, use, process and share personal information. This Policy applies to visitors and users (individually, “you” of Terminal101's websites (including but not limited to, Terminal101, Heroku, Mongodb), applications, social media accounts, and other services (collectively, our “Services”). You can identify the Terminal101 company that hosts a particular Service and is responsible for your information under this Policy here. Please note that your use of our Services is additionally subject to the TERMINAL101 Terms and Use.

As the world's leading travel search engine, TERMINAL101 connects travelers with travel services and products offered by third parties, such as flights, accommodations, packages, and travel insurance. This involves sharing personal information with third parties, including online travel agencies, hotels, airlines, and others (collectively, “Travel partners”).

Terminal101 is part of the ??? corporate group, which includes Amadeus.com. In some cases, we receive personal information from our group companies, and we share personal information with our group companies.

For more information about the information we share with third parties and the recipients of such information, please refer to the How We Share Your Information section of this Policy. Please note that this Policy does not otherwise cover the use of personal information by third parties or their services, and we do not take responsibility for their privacy practices.

You may have certain rights or choices that relate to your personal information, including choices about how we share your personal information with others. For more information, please refer to the Your Choices and Rights section of this Policy.

OVERVIEW

Information We Collect and Use	When you use or visit our Services, we collect information directly from you (e.g., when you make a booking or reservation). We may also generate information about you (e.g., information about your device while you use our mobile application). In some cases, we also obtain personal information from third parties (e.g., our group companies, business partners, third-party websites, applications, and services, and others). Learn more
How We Use Your Information	We use your information to provide our Services, tailor your experience, show you bookings and transactions made with our travel partners through TERMINAL101 and our group companies, send you marketing communications, provide you with more relevant advertising and offers that may be of interest to you, and for other purposes described below. Learn more
How We Share Your Information	We share your information with our travel partners; with our group companies; with other business partners (including advertisers); with social networking services; with third-party services or applications you use to log into your Terminal101 account; with service providers (including payment card processors); and others as described below. We share information to provide and improve our Services, for our own marketing purposes, to facilitate offers and advertising from others that may interest you, and for other purposes as described below. Learn more
How We Store and Protect Your Information	We maintain technical, administrative, and physical security measures designed to protect your information. We may retain your information for as long as your account is active and for a period of time thereafter to allow you to re-activate your account without loss of information, and as necessary for purposes described below. Learn more
Cookies	We use cookies and similar technologies to help provide our Services, offer you a more personalized user experience and market our and third parties' products and services to you. Learn more
Your Choices and Rights	You have choices about your personal information, and in some circumstances, you may be able to opt out of receiving marketing communications, change your communication preferences, access and update your information, update location sharing options, exercise choices regarding cookies, and/or opt out of certain sharing of information with third parties (including our group companies, travel partners, and other business partners). These choices and other rights you may have are described in more detail below. Learn more
International Transfers of Information	We operate internationally, and information about you may be transferred to, or accessed by, entities located in countries outside of your home country. To protect your information, any such international transfers will be made in accordance with applicable law. Learn more
Links to Other Websites	Our Services may contain links to other websites or services that are not owned or controlled by Terminal101, including links to websites of our travel partners, our group companies, and other business partners (including advertisers). Learn more
Children	Our Services are not directed at or intended for use by children, nor do we knowingly collect information from children under 16 years of age. Learn more
Changes to This Policy	We update this Policy from time to time, and changes will be effective when posted (as identified in the Policy). Learn more
How to Contact Us	If you have any questions about this Policy or the way your personal information has been used, please contact us using our feedback form or at the contact details set out below. Learn more

INFORMATION WE COLLECT AND USE

“Personal information” is data that identifies, relates to, describes, can be used to contact, or could reasonably be linked directly or indirectly to you. For purposes of this Policy, there is no meaningful distinction between the terms “Personal information” and “Personal data”.

Personal Information We Collect Directly From You. As you visit or use our Services, we collect the following categories of personal information directly from you:

Personal details (such as your name, age, birthday, gender)
Contact information (such as email address, address, phone number)
Booking information (such as, for each traveler, the traveler's name, frequent flyer details, passport number, redress control number, country of citizenship, booking reference number, and itinerary, which may include name of airline or carrier, hotel accommodation and/or vessel, port of destination, port of arrival, date and time of departure and/or check-in, date and time of arrival and/or check-out, meal preferences, luggage information, and layover information)
Account information (such as login credentials, including email address and password, and account settings)
Social media data (if you choose to link your Terminal101 account with a social media account, Terminal101 may collect personal information such as name, age, gender, photograph, and other personal information relating to your social media account)
Billing information (such as credit, debit, or other payment card information and billing address)
Your contacts (such as contact information of people you add to, or notify of, your reservations or itineraries through our Services)
Your preferences (such as your home airport, seating preferences, meal preferences, communication preferences, and other preference information you provide us)
Reviews you submit (including any screenname you publish under or any personal information you include about yourself or others in such review)
Content you publish (including your travel recommendations and any personal information you include about yourself or others, or in content you publish in your Guide or other mediums provided by us)
Photos of you (such as when you add a photo of yourself to your profile, upload photos to a review, or link your social media account to your Terminal101 account)
Communications you send us (such as questions, conversations, complaints, or other information that you may submit to our support team)
Promotion information (if you choose to participate in a contest, sweepstakes, or similar campaign, we will collect any information you provide in relation to such activity, such as photos, images, captions, or other content, in accordance with the terms provided at that time)
Other information you may provide (including other information you provide about yourself or others through our Services or to which you provide us with access via third-party platforms)

You may choose not to provide some of the personal information described above. Please note, however, that many of our Services require some personal information to operate, so if you choose not to provide the personal information necessary to operate and provide you with a particular Service or feature of that Service, you may not be able to use that Service or feature.

We do not proactively collect sensitive personal information, such as health-related information. However, our Services include text boxes that are designed for you to describe certain details about your travel preferences or special requests that you want us or our travel partners to know. Please be aware that information you freely submit in these boxes may reveal to us or to the travel partners or third parties with whom we share information (as detailed in the How We Share Your Information section below) certain information that may be considered sensitive personal information under applicable law (for example, information about dietary restrictions or disability accommodations). Sensitive personal information you voluntarily submit is processed on the basis of your consent, which you may revoke at any time by contacting us at the details set out in the How to Contact Us section below.

Personal Information Generated By Us. As you use our Services, we generate certain personal information about you, including through automatic data collection and by inferences based on the information we collect about you and your activity. We may automatically collect information about your interactions with the Services or communications you receive (such as email) using certain technologies, such as cookies, web beacons and other technologies (see our Cookies and Interest-Based Advertising Policy for more details). We generate the following categories of personal information about you:

Personal Information We Obtain from Third Parties. We may also receive certain categories of personal information from third parties, such as third-party websites, applications, social media networks, and services (each, a “third-party platform”), our group companies, travel partners, and other third parties, including individuals who have shared their travel itineraries with you through our Trips service. If you are an existing Terminal101 user, we will combine this information with information we collect through our Services and use and share it for the purposes described below. The categories of personal information we may obtain from third parties includes:

Your name
Email address or other contact information
Social media data, if you connect to our Services using a social media third-party platform or interact with Terminal101 by liking or commenting on our social media pages or content, we may receive information from that social media third-party platform about those interactions and from your social media profile (e.g., name, age, gender, photograph, and other personal information related to that account)
Browsing, purchase, usage and advertising details, including information about restaurant or travel accommodations and bookings you make through our group companies and travel partners (for example, if you book a flight through one of our group companies, we or our travel partners may receive the general location of your destination and use that information to provide recommendations for hotels or other accommodations or complementary services); how you use third-party websites, applications, and services; information relating to your interactions with our advertising and marketing materials; and demographic information about users of our Services.

HOW WE USE YOUR INFORMATION

We use your personal information for the following purposes (“Purposes”), to:

Provide the Services, which includes providing you with the services, products, and functionality offered through our Services and fulfilling your requests, including, but not limited to: facilitating and processing bookings with our travel partners, reviewing travel partners, paying for travel partners' products and services through our Services, and notifying people you add to, or otherwise request to notify of, your bookings through the Services
Providing Trips services, including automatically creating a “Trips” account for you if you make a booking using our Services. This account collects your travel information to create and maintain your travel itineraries, which you can then share with others. If you sign up for the synchronization of your emails to our Trips service, we access the emails in the email accounts you have connected to your Trips account, to regularly review these emails in order to identify those that are booking confirmations that we can import into our Trips service, to parse these emails and to add the information we have collected (including a copy of the email to your Trips account) (see below for more detail on Trips Services)
Authenticate your account credentials and identify you, as necessary to log you in to the Services and ensure the security of your account
Show your reservations and bookings made through the websites, applications, and services of our group companies, such as Amadeus.com or OpenTable, on your account page
Communicate with you about your account or use of our Services, products, and/or functionality (e.g., soliciting reviews and feedback, sending alerts and notifications you have subscribed to, providing updates regarding itineraries processed by our Trips service, sending you booking confirmations, sending you information servicing and administrative emails or other notices required by law); respond to, or follow up on, your comments and questions; and otherwise provide customer service (see below for more detail on Electronic Communications)
Send you marketing communications, including communicating with you about services or products offered by TERMINAL101, our group companies, or our business partners and other marketing communications that we believe you would be interested in, as permitted by law (see below for more detail on Electronic Communications and Your Choices and Rights)
Operate and improve our Services and develop new products and services, including using analytics to better understand how you use our Services for purposes of product, website, application and service development and to enhance the user experience
Process and deliver contest entries and rewards
Process your payment information
Provide services and information to travel partners, such as providing user feedback and usage details
Tailor your experience with our Services, such as by making inferences or combining different pieces of information we have collected about you to offer better search results or otherwise tailor our Services to you according to your preferences or restrictions. For example, if you frequently book rooms at four-star hotels and buy insurance services when you travel, we may prioritize four-star hotels in your search results or bring you a combined package offer for hotel and insurance services, or prioritize accommodations you have previously booked
Provide you more relevant advertising on and off our Services, including to show you personalized offers and advertising on and off our Services. For example, if you tend to book rooms at four-star hotels and often travel to Istanbul, we may display advertising for a four-star Istanbul hotel to you on our Services or work with our travel partners and advertising partners to display advertisements for four-star Istanbul hotels to you on other websites you visit.
Protect against, investigate, and deter fraudulent, unauthorized, or illegal activity
Comply with our policies, procedures and legal obligations, including complying with law enforcement or government authority requests, addressing litigation-related issues, and exercising rights or obligations conferred by law.
As otherwise consented to by you and as required or permitted by applicable law. If you give your consent to any further use of personal information, you can withdraw that consent at any time by contacting us using the details set out below.

You have choices about your personal information, and in some circumstances, you may have the right to opt out or object to our uses of your personal information for these Purposes. For more information, or to exercise these or other rights (where available), see the Your Choices and Rights section below.

Trip Services. If you register for an account, send a booking confirmation to our Trips service or make a booking through our Services, you will have access to our Trips service, where we will collect your travel information to create and maintain your travel itineraries. If you directly send us booking confirmation emails, you authorize us to parse these emails automatically or manually and to add the information you provide to your Trips account, along with other information that we have collected (including saving a copy of the original email to your Trips account). If you sign up for the synchronization of your emails to our Trips service, you authorize us to access the emails in the email accounts you have connected to Trips, to regularly review these emails in order to identify those that are booking confirmations that we can import into our Trips service, to parse these emails automatically or manually and to add the information we have collected to your Trips account (including saving a copy of the original email to your Trips account). To the extent permissible by our email synchronization partners, we use the information in your Trips account to show you more relevant search results (e.g., accommodations you previously booked) or to provide you statistics about your travels, and we may use such information for marketing communications as described above. If you use or have itineraries as part of our Trips Service, you can send or grant access to your itinerary to anyone you choose. Your itinerary may contain enough details (e.g., booking reference codes) to allow the recipient to cancel or modify your booking, perform a check-in, etc. You should only share your itinerary with people you trust. Please also refer to our Getting Started with Trips page and the detailed Trips FAQ for answers to frequently asked questions, and visit your Account page to update your account settings and preferences. If you choose to display your itinerary on publicly-viewable web pages (Facebook, for instance), that information may be collected and used by others.

Electronic Communications. Consistent with the above Purposes and as permitted by applicable law, we may communicate with you via electronic messages, including email, text message, or mobile push notification to:

Send you information relating to our products and Services. This may include booking confirmations and updates, receipts, technical notices, updates, security alerts, and support and administrative messages.
Send you marketing communications. In other situations, subject to the Your Choices and Rights section below and applicable law, we may communicate with you about contests, offers, promotions, rewards, upcoming events, and other news about products and Services offered by us, our group companies, our travel partners, and other business partners.

With your consent, where required, we may contact you at the mobile phone number that you provide to us by way of direct dial calls, autodialed and prerecorded message calls, and text messages in connection with the above Purposes.

Our Role as Data Controller. For purposes of European Union law and similar data protection regimes, we generally act as a data controller, meaning we determine the purposes and means of processing your personal information. Our travel partners to whom we may connect you to make reservations are also data controllers. To learn more about how a travel partner may use your personal information, you should review its privacy notice.

Processing Bases and Consequences. When we process your personal information, we rely on the following legal bases:

Performance of the contract we have with you (for example, if you use our Services to book a flight, we will process your information in order to allow the relevant airline partner to complete and administer that booking) .
Compliance with legal obligations to which we are subject (such as when we are obliged to comply with lawful requests from competent authorities such as law enforcement).
To serve our legitimate interests (such as tailoring your experience with our Services, carrying out online advertising, and for fraud detection), provided that such processing does not outweigh your rights and freedoms. The processing must also be pursuant to other applicable legal bases for data processing, especially provisions set out under local law.

When we use personal information to meet our legitimate interests, we take steps to ensure that your rights to your personal information are not infringed. You can contact us using the details set out in the How to Contact Us section below for more information about the steps we take to ensure these rights are not infringed. You also have the right to object to such processing as described in the Your Choices and Rights section below.

Consent. To the extent that a legal ground described above would not apply to processing of your personal information by us, we will seek your consent for such specific purpose in accordance with applicable law (such as sending direct marketing messages by electronic means, like email, without an exception from the requirement to obtain consent).

Aggregate Information. We aggregate personal information collected directly from you, information generated about you by us, and information obtained from third parties (with your consent, where required) with personal information collected about other users in order to produce general statistics that cannot be linked to you or any other specific user. Information that has been aggregated and de-identified is no longer considered “Personal information” and may be subsequently used for any purpose.

Anonymized Information. We may process information that cannot be linked to you or any other specific user using any means available to us, either because it was collected anonymously or has been subsequently anonymized. Information that is anonymous or has been anonymized is no longer considered “Personal information” and may be subsequently used for any purpose.

HOW WE SHARE YOUR INFORMATION

We disclose the personal information we collect (or otherwise generate or obtain) as follows:

With our travel partners. We share your information with our travel partners to provide the Services (such as connecting users with airlines or online travel agents to book a flight or other travel service, and sharing personal details, contact information, passport information, preferences, requests, accommodations, and other information with the airline or online travel agent) and for our travel partners' own purposes, which may include marketing or advertising purposes (see below for more detail on Sharing with Travel Partners).
With our group companies in our corporate family. We share your information with our group companies within our corporate family, including but not limited to for the Purposes described above, to provide you with integrated products and services, and for our and their marketing purposes (see below for more detail on Sharing with Our Group Companies).
With other business partners. We share information with other third-party business partners for their own marketing purposes, including sharing with online advertisers or advertising technology (“ad tech”) companies to provide you with targeted advertising and marketing communications, where permitted under law (see below for more detail on Sharing with Our Business Partners).
Trips shared by you. If you use or have itineraries as part of our Trips Service, you can send or grant access to your itinerary through our Services to anyone you choose. See the Trips services section above for more detail.
With social networking services. We share (or facilitate your sharing of) your information with social networking services when you use our Services to connect and share your information publicly or with friends or when you use our Services to connect with us on, share on, or use third-party social networking platforms and services (see below for more detail on Sharing with Social Networking Services).
Third-party services or applications you use to log into your account. If you use a third-party service or application (e.g., Facebook) to log into your Terminal101 account, we share certain personal information with that third party.
How We Store and Protect Your Information. If you provide us with a review of your trip, you authorize us to publish it on all our Services under the screenname you provided and to share it with travel partners. You also authorize us to aggregate your review with other reviews.
Content you publish. If you publish travel recommendations as part of Guides or other mediums provided by us, you authorize us to publish it on all our Services.
To process payments. Credit or debit card information is required to process certain transactions, including to make certain bookings and reservations or to purchase other products or services from travel partners or other third parties, in which case we share your payment information with travel partners, and other third-party service providers (such as fraud detection services) (see below for more detail and additional terms regarding Sharing to Process Payment Information).
With other service providers. We share information with third-party vendors, consultants, and other service providers who perform services or functions on our behalf (see below for more detail on Sharing with Other Service Providers).
In the event of a corporate transaction. We may disclose or transfer your information to a third party if we sell, transfer, divest, or disclose all or a portion of our business or assets to another company in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding.
To protect rights and property. We may disclose your information to third parties when we believe in good faith that disclosure is necessary to protect our rights, our property, the integrity of the Services, personal safety, or the interests of you or any other person, and to detect, prevent and/or otherwise address fraud, risk management, security or technical issues.
To comply with and as required by law. We may disclose your personal information to government authorities or other relevant third parties in order to comply with applicable legal requirements, judicial proceedings, court orders, legal process, or lawful requests from governmental authorities.
Aggregate Information. We share aggregate statistical data for the improvement of our Services. We may also share aggregate or de-identified information with third parties at our discretion.
At your request. We also share your information as directed or requested by you, or subject to your consent.

In some circumstances, you may have the right to opt out or object to our sharing of your information with certain third parties. For more information, or to exercise these or other rights, see the Your Choices and Rights section below.

Sharing with Travel Partners

Our travel partners include online travel agencies, hotels, airlines and travel insurance providers. When you make a request for a booking or reservation from one of our partners through our Services, we share your information with that travel partner to facilitate the booking or reservation and provide the services you requested. Depending on the request, this may include your name, contact information, passport information, frequent flyer details, itinerary details as described above, your preferences, any special requests or accommodations, information or comments that you choose to submit (if any), and other information as required by the particular travel partner. Your information is provided to the travel partner, just as it would be if you contacted the travel partner directly. If you provide a mobile phone number in connection with your request, travel partners may send you text messages regarding your request. Some travel partners also require you to provide credit or debit card account information to secure your reservation.

When you make a request, we also share with the travel partner additional information about you, such as information about your travel activity and history, and/or information that we collect from you and third parties. Travel partners use this information for their own purposes, which may include to improve their products or services and to provide you with targeted advertising and marketing communications, where permitted under law.

Sharing with Our Group Companies

We share your information with our affiliates and subsidiaries in the U.S. and worldwide, as well as with our parent corporation, Amadeus, and its other subsidiaries (collectively, as also defined earlier in this Privacy Policy, our “group companies”). We may share your information with our group companies for the following reasons:

Provide you with integrated services (including to administer and manage reservations, bookings, services, and payments across our affiliated platforms).
Provide personalised offers or send you marketing communications with your consent or as otherwise permitted by applicable law.
Enable “single sign-on”, i.e., allowing you to log into a shared account for multiple Booking Holdings Inc. brands using a single set of log-in credentials, which allows us to, for example, show your reservations and bookings made through the websites, applications, and services of our group companies on your account page, and allow our group companies to show information in your respective account(s) with them.
Provide customer support services.
Detect, prevent, and investigate fraud and misuse of our services, other illegal activities, and data breaches.
Analyse how users use our independent and affiliated platforms, including so that we may improve existing products and services and develop new features, products, and services that may be of interest to our users.
Ensure compliance with applicable law.

To learn more about your choices related to how we share your information with our group companies (including our subsidiaries, our parent company, and its other subsidiaries), please see the Your Choices and Rights section below.

Sharing with Our Business Partners. We share your information with other third-party business partners for their own marketing purposes. These third parties include online advertisers or ad tech companies, who may provide you with targeted advertising and marketing communications, where permitted under law. The information we share includes information collected through your use of our Services (e.g., information about your bookings and reservations for flights, hotels, or other travel accommodations) and information we collect about you through the use of cookies and similar technologies (e.g., information about the websites you visit; information about your searches, including the cities or destinations you search for, the types of accommodations you search for, your travel preferences, price range, intended travel dates, and the number of travelers in your party).

For example, if you frequently search for flights from Seattle to Paris around certain holidays, we may share that information with a particular airline partner so it can better understand which of our customers are interested in flights from Seattle to Paris on certain dates. The airline partner may then, for example, use this information to offer you a promotion.

To learn more about your choices related to how we share your information with our business partners, please see the Your Choices and Rights section below.

Sharing with Social Networking Services

Our Services allow you to connect and share your actions, comments, content, and information publicly or with friends. Our Services may also allow you to connect with us on, share on, and use third-party platforms, including those on which Terminal101 has a presence. Please be mindful of your personal privacy needs and the privacy needs of others as you choose whom to connect with and what to share and make public. We cannot control the privacy or security of information you choose to make public or share with others. Terminal101 also does not control the privacy practices of third-party platforms. Please contact those sites and services directly to learn about their privacy practices.

Sharing to Process Payment Information

To use certain Services (such as to book a flight) and to make payments to certain of our travel partners, we require payment information (e.g., credit or debit card account information, other online payment method information, etc.). When you submit your payment information through our Services, we will share that information with travel partners, third-party payment processors, and other third-party service providers (including, but not limited to, vendors who provide fraud detection services to us and other third parties), to the extent necessary to meet our contractual obligations to you (e.g., to secure your reservation or make a payment to a travel partner where required), to meet our legitimate interests in preventing fraud and other misuses of our platforms or Services, or with your consent where this is required by law. In particular:

When you use a credit or debit card to secure a booking or reservation through our Services, we provide your credit or debit card account information (including card number and expiration date, and if required by the travel partner, CVV number) to the applicable travel partner to process the transaction.
When you provide your credit or debit card account information through our Services, you will have the option to save your information to your account for future use. If you choose not to save your credit or debit card account information to your account, we will delete your credit or debit card account information after the transaction is complete.
For information about the security of your payment information, see the How We Store and Protect Your Information section below.

Sharing with Other Service Providers

We share information with third-party vendors, consultants, and other service providers who perform services or functions on our behalf (e.g., hosting or operating our Services, data collection, manually parsing booking confirmations, reporting, ad response measurement, site analytics, data analysis, delivering marketing messages and advertisements, processing credit card payments, and providing fraud detection services). We do not authorize these third parties to use or disclose your information for purposes other than those for which it has been provided. We require these third parties to maintain and implement security measures to protect your information from unauthorized access or processing.

HOW WE STORE AND PROTECT YOUR INFORMATION

Terminal101 maintains commercially-reasonable technical, administrative, and physical security measures designed to protect your information from loss, misuse, unauthorized access, disclosure, alteration, and destruction.

When your payment information is being transmitted to our Services or through our Services, it will be protected by cryptographic protocols. To be clear, Terminal101 only stores your payment information if you choose to save that information to your account. When you submit a booking or reservation, we transfer your payment information to the applicable travel partner to process the transaction. Our contracts with third parties that receive your payment information require them to keep it secure and confidential.

However, we cannot guarantee that transmissions of your payment information or your other information will always be secure or that unauthorized third parties will never be able to defeat the security measures taken by Terminal101 or our third-party service providers. Except to the extent that liability cannot be excluded or limited due to applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control. You play an important role in keeping your information secure. You should not share your user name, password, or other security information for your Terminal101 account with anyone. If we receive instructions using your user name and password, we will assume you have authorized the instructions. If you have reason to believe that your interaction with us is no longer secure (e.g., if you feel that the security of any account you might have with us has been compromised), please contact us immediately as detailed in the How to Contact Us section below.

Retention

We may retain your personal information for as long as your account is active and for a period of time thereafter to allow you to re-activate your account without loss of information. We may also retain your personal information as necessary to:

Maintain logs and business records for analysis, security, and/or audit purposes
Comply with record retention requirements under the law
Deal with any complaints regarding the Services; and
Comply with our legal obligations, protect or defend our rights, resolve disputes and enforce our contracts

COOKIES

When you use or visit the Services, we collect information about your usage and activity using cookies, web beacons, and other technologies. Third parties may also view, edit, or set their own cookies. We and our third-party service providers, affiliates, and other business partners may also place web beacons for these third parties. The use of these technologies by third parties is subject to their own privacy policies and is not covered by this Policy, except as required by law. See our Cookies Policy for more details.

YOUR CHOICES AND RIGHTS

Email. If you no longer want to receive marketing and promotional emails from Terminal101, you may click on the “unsubscribe” link in such emails to opt out of future marketing email communications. If you have a Terminal101 account, you may also opt out of marketing emails in your account settings. Please note that even if you opt out of receiving marketing communications from one or all of our Services, we will still send you service-related communications, such as confirmations of any future bookings you make.

Push Notifications (on Mobile Devices). You can use the settings on your mobile device to enable or turn off mobile push notifications from Terminal101.

Text Messages. If you no longer want to receive text messages from Terminal101, reply STOP (or as otherwise instructed) to the text message. If you have a Terminal101 account, you may also adjust your account settings to opt out of text messages.

Cookies and Interest-Based Advertising. To exercise choices regarding cookies set through our websites or Services, as well as other types of online tracking and online advertising, see our Cookies and Interest-Based Advertising for more details. We currently do not employ technology that recognizes “do-not-track” signals from your browser.

Application Location. As explained in more detail in the Information We Collect and Use section above, we collect information about your location if you enable location services through the settings in your mobile device, or with your consent, as may be required by law. You can change the privacy settings of your device at any time to turn off the sharing of this location information with our Services. If you choose to turn off location services, this could affect certain features of our Services. If you have specific questions about the privacy settings of your device, we suggest you contact the manufacturer of your device or your mobile service provider for help.

Sharing with third parties. As described above in the How We Share Your Information section, we share your information with third parties for their own purposes or work with those partners to support their own marketing purposes. You can opt out of sharing your information with:

Our group companies, for their own marketing purposes;
Travel partners, for their own marketing purposes (including sending marketing communications and providing targeted advertising, promotions, and other offers
Other business partners, who use information for their own marketing purposes

You can opt out of such sharing by changing your Terminal101 account preferences. You may also send such opt-out requests to us as described in the How to Contact Us section below.

Access and Correction of Your Information

If you have created an online account with us and would like to update the information you have provided to us, you can access your account to view and update your information. You may also contact us as described in the How to Contact Us section below.

Legal Rights

Where applicable under local law, you may have the following rights regarding your personal information: the right to access personal information we hold, and in some situations, the right to have that personal information corrected or updated, erased, restricted, or delivered to you or a third party in a usable electronic format (the right to data portability). Where applicable, you may also object to how we use your personal information if the legal basis for processing that information is our legitimate interest. Where we are using your personal information on the basis of your consent, and where applicable under local law, you have the right to withdraw that consent at any time. Where you have granted consent to receive direct marketing communications from us, and where applicable under local law, you may withdraw that consent at any time.

If you wish to exercise the legal rights you may have under applicable law, please submit your request by using our feedback form. So that we can better process your request, please provide the email you use to log into your Terminal101 account. If you do not have a Terminal101 account, please provide the email you used to make requests or to use our Services.

Where applicable, you may also have the right to register a complaint to your local data protection authority. For residents of the EU and UK, contact the EU data protection authorities. For residents of Australia, if you are not satisfied with the outcome of your complaint after first contacting us, you may wish to contact the Office of the Australian Information Commissioner.

INTERNATIONAL TRANSFERS OF INFORMATION

Information about you will be transferred to, or accessed by, entities located around the world as described in this Policy. Some of these entities may be located in countries that do not provide an equivalent level of protection for personal information as your home country.

We have put in place safeguards to provide adequate protection for transfers of certain information, in accordance with applicable legal requirements. For more information on the appropriate safeguards in place, or to request a copy of these safeguards, please contact us using the contact details listed in the How to Contact Us section below.

LINKS TO OTHER WEBSITES

Our Services contain links to other websites or services that are not owned or controlled by Terminal101, including links to websites of travel partners and our advertisers, our group companies, and other business partners. This Policy only applies to information collected by our Services. We have no control over these third party websites, and your use of third party websites and features are subject to privacy policies posted on those websites. We are not responsible or liable for the privacy or business practices of any third party websites linked to our Services, including those of our group companies. Your use of third parties' websites linked to our Services is at your own risk, so we encourage you to read the privacy policies of any linked third party websites when you leave one of our Services.

CHILDREN

Our Services are not directed at or intended for use by children. We do not knowingly collect information from children under 16 years of age. If you become aware that your child or any child under your care has provided us with information without your consent, please contact us using the contact details listed in the How to Contact Us section below.

CHANGES TO THIS POLICY

Except to the extent limited by applicable law, we will update this Privacy Policy from time to time to reflect changes in our privacy practices, legal requirements, and other factors by prominently posting notice of the update on our Services. Changes to our Privacy Policy will be effective when posted and the new effective date will be identified.

If we make any changes to the Privacy Policy that materially impact previously collected personal information about you, we will make reasonable efforts to provide notice and obtain consent to any such changes as may be required by law.

To request a copy of this Policy, or to request a copy of the Privacy Policy in place at the time you signed up for an account, please contact us at the details below.

How to Contact Us

If you have any questions about this Policy or the way in which your personal information has been used, please contact us using our feedback form or by postal mail at:

TERMINAL101 Attn: ???

Our representative in the United Kingdom is

Terminal101 ???

COOKIES AND INTEREST-BASED ADVERTISING POLICY

What are Cookies?

Cookies and similar tracking technologies, such as beacons, scripts, web beacons and tags (which together we refer to as “cookies”), are small bits of text, usually stored on a user's computer hard drive or within a browser. They enable a website to remember information about the user's visit to the website. On mobile websites and mobile applications, we use device IDs and / or Advertising IDs in a similar manner to which we use cookies.

We and certain third-party partners (as described below) use cookies on our websites, our mobile applications and within emails or other communications we send to you (we refer to these together as our “Sites”).

To the extent the cookies we use for these purposes lead to the processing of your personal information, details about how we use that personal information and your rights over that personal information are discussed in our Privacy Policy.

What types of Cookies are used on our Sites and what do we use them for?

We use “first-party cookies,” i.e., those that are used solely by us or by third parties who act only on our instructions or on our behalf. These types of cookies are used for our own analysis of our own Sites, or to provide functionality such as remembering your language preference.

Other cookies on our Sites are used both by us for the purposes described in this policy and by third parties for purposes where those third parties may wish to combine information from our Sites with information from other sites to improve their services. For example, these types of cookies may be used for interest-based advertising purposes.

The cookies used on our Sites, by either us or by third parties, can be “session” cookies, or “persistent” cookies. “Session” cookies are deleted automatically when you close your browser, and are used for things like ensuring you are kept logged in as you navigate around our Sites. “Persistent” cookies remain stored on your device or browser even after you close it. These cookies are used, for example, to recognize you when you come back to our Sites.

We divide the cookies we use into three categories:

Type of cookie	Description of how we use this type of cookie	What choices do you have?
Required	To provide a secure log-in to our Sites. To keep you logged in so that you do not have to log in repeatedly to access different pages of the Sites.	Required cookies are necessary for our Sites to operate. On some platforms, you can delete all cookies, but this may affect the basic functionality of the Sites.
Functional	To recognise you if you have visited previously, and remember your preferences from past visits, such as your language preference. To track when you make purchases or bookings on websites operated by our group companies (e.g., travel bookings on Amadeus.com), so that we can display your bookings with our group companies on your account page. To improve our Sites and our offerings by helping us to understand how users use the Sites and to analyse trends which appear in that data. For example, we make changes to the user interface if we can see that certain pages are difficult for a large number of users to navigate. We also collect broad information about how our users use the Sites, for example, to understand which aspects of our Sites and our services are particularly popular, so that we can make improvements going forward. To personalise your experience of our Sites, for example, by showing you offers on our homepage or in emails that are most relevant to you based on your previous visits to our Sites or those operated by our group companies or by ranking certain types of options (e.g., only non-stop flights) higher in your search results.	Where required by law, functional cookies will only be used on the Sites where you have given your consent to their use. You can opt out of our use of Google Analytics by downloading the browser add-on
Advertising (e.g., Google DoubleClick, Google Ads, Oath, Bing Ads)	To recognise you if you have used our services on another device. We combine information received from multiple devices to determine if you are using a new device, so that we can continue to provide you with a personalised experience on our Sites. To enable you to post to social media sites and other platforms, for example, to allow you to access a particular social media page to post a comment or a “like.” To collect information for use in advertising on our own Sites and on third party sites which you may visit. Such information is based on your preferences and your usage of our Sites. We have included more information about our use of advertising cookies below.	Where required by law, advertising cookies will be used only on the Sites where you have given your consent to their use. See the section entitled “Your Cookie Choices” below to learn more about how to withdraw your consent to advertising cookies. You can opt out of our use of Google Analytics by downloading the browser add-on

Our Advertising Cookies

We work with third parties that place cookies on our Sites to provide their services, including:

1.Ad Targeting.We work with third-party advertising companies to serve ads while you are visiting our Sites and to permit these companies to place and access their own cookies on your computer in the course of serving advertisements on our Sites.

These companies may use information obtained through their cookies (which does not include your name, address, e-mail address or telephone number) about your visits to our Sites and other websites, in combination with information about your purchases and interests from other online sites in order to provide advertisements about goods and services of interest to you.

We also allow certain third parties (as described in our Privacy Policy to collect web log data from you (which may include IP address, where permitted, and information about your browser or operating system), when you visit our Sites, or to place or recognize a unique cookie on your browser to enable you to receive customized ads or content. The cookies may reflect de-identified usage data or other data linked to data you voluntarily have submitted to us, for example, your email address, that we may share with third parties solely in hashed, non-human readable form.

2.Advertising Analytics/Measurement. We make use of analytics cookies as part of our online advertising campaigns to learn how users interact with our Sites after they have been shown an online advertisement, which may include advertisements on third-party websites. In particular, our Sites use Google Analytics 360 Suite, including Google Analytics Advertising, which are web analytics and analytics advertising services provided by Google, Inc., which use third party cookies. Where required, our Sites have activated the IP address anonymization functionality so that the IP address of the user is shortened by Google. Our Sites also use the following Google Analytics Advertising features: Google Remarketing, Google Segments, Google Ads Manager and Google Ads. These features use third party cookies to collect information about our website traffic by tracking users across websites and across time and generating reports for us to better understand our website users and to create audiences for our advertisements based on such understanding.

3.Remarketing Pixel Tags. In addition, we may share website usage information about visitors to our Sites with third-party advertising companies for the purpose of managing and targeting advertisements and for market research analysis on our Sites and other sites. For these purposes, we and our third-party advertising companies may place pixel tags (also called clear gifs) on some of the pages you visit on our Sites. We will then use the information that is collected using these pixel tags to serve you relevant advertisements when you are visiting other sites on the Internet. These advertisements may be based on your interests, for example, on the basis of specific searches you conducted on our Sites during earlier browsing sessions.

4.Other Cookies: Our partners, who provide certain features on our Sites or display advertising based on your browsing activity, also use Local Storage such as HTML5, to collect and store content information and preferences. Please note that different web browsers offer their own management tools for removing HTML5 local storage.

Mobile Devices, Anonymous Device Identifiers and Hashed IDs.

We and/or third parties that we have engaged may collect and store a unique identifier matched to your mobile device, in order to deliver customized ads or content while you use applications or surf the internet, or to identify you in a unique manner across other devices or browsers. In order to customize these ads or content, we or a third party may collect de-identified usage data or other data about you which you have either voluntarily submitted to us, for example, your email address, or has been passively collected from you, such as your device identifier or IP address, where permitted. However, if we share your email address, we share it solely in hashed, non-human-readable form.

Your Cookie Choices

We provide you with choices over the use of cookies as described in this policy.

When you first visit our Sites, where required by law, you will have the option to give your consent to the advertising and functional cookies we use, or to refuse your consent to our use of those cookies by clicking on the [X] within that disclosure.

Browsers. Most browsers accept cookies by default. You may be able to change the settings to have your browser refuse certain cookies or notify you before accepting cookies. To do so, please follow the instructions provided by your browser which are usually located within the "Help", "Tools" or "Edit" facility. Some third parties also provide the ability to refuse their cookies directly by clicking on an opt-out link, and we have tried to indicate where this is possible in the table above.

You can also find more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, at www.allaboutcookies.org and www.youronlinechoices.eu.

Mobile Devices. If you no longer wish to receive interest-based advertising on your mobile applications, please refer to your device's operating system settings and follow instructions below.

iOS users: To use the "Limit Ad-Tracking" option, follow the instructions provided by Apple here: Apple Support Center
Android Users: To use the "opt-out of interest-based advertising" option, follow the instructions provided by Google here: Google Play Help
You may also consider downloading the DAA AppChoices Mobile App to manage online behavioural advertising technology.

If you no longer wish to receive interest-based advertising on your mobile device browser, you can follow the steps in relation to Browsers outlined above.

Do-Not-Track Signals. We currently do not employ technology that recognizes "do-not-track" signals from your browser.

Please keep in mind that, without cookies, you may not have access to certain features on our Sites, including access to your profile/account and certain personalized content. Removing all cookies from your computer could also affect your subsequent visits to certain websites, including our Sites, by requiring that, for example, you enter your login name when you return to that website. Please note that even if you exercise any of the choices described above, you will still see ads, but they will not be based upon the information collected through these tracking technologies, and therefore not necessarily relevant to your interests.

Privacy Policy. Please review our privacy policy for additional details about how we collect, use, and disclose information in connection with our Sites, including personal information obtained from cookies.

Contact. If you have any questions about our use of cookies, please use our feedback form.

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