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Submitted URL:
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Submission: On September 27 via api (September 27th 2022, 8:02:25 pm UTC) from IE — Scanned from DE

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Text Content

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TRIPACTIONS PRIVACY POLICY

Last Updated February 7, 2022

TripActions, Inc. and its affiliates (collectively, “TripActions,” “we,” “us,”
and "our") respect your privacy. We are a travel management platform that helps
companies manage all of their corporate travel and expense management in one
place as described in our Terms of Service. “You” may be a visitor to one of our
Websites, a corporate customer of one or more of our Services (“Corporate
Customer”), or an employee, traveler, or guest of a Corporate Customer
(“Users”).

This Privacy Policy describes the types of Personal Information we collect
through our main website at tripactions.com (“Website”) and through our travel
products and services that we provide to Corporate Customers and Users
(“Services”). This Privacy Policy also describes how we use Personal
Information, with whom we share it, your rights and choices, and how you can
contact us about our privacy practices.

* Overview
* Personal Information
* How We Collect Personal Information
* How We Use Personal Information
* How We Disclose Personal Information
* Your Rights and Choices
* Security and Retention
* Links to Other Websites
* Use of Services by Minors
* Jurisdiction and Cross-Border Transfer
* Sensitive Information
* International Privacy Practices
* Updates to This Privacy Policy
* Contact Us

Overview

TripActions obtains Personal Information about you from various sources to
manage our Website and provide our Services. There are two primary ways you may
interact with TripActions online.

Website Visitors

Our Website at tripactions.com is publicly available and allows visitors to
learn more about TripActions, request a demo, submit questions, join a
discussion thread on our community pages, and contact us. Personal Information
may be collected through webforms where you type in your information, comments
you choose to post on our community discussion boards, or automatically using
tracking technologies, like cookies.

TripActions Services

Our Services include our web application at app.tripactions.com and TripActions
mobile applications made available by us. The web application and our mobile
applications (collectively, our “Apps”) provide the ability to search for and
book travel, access traveler support, trip consolidation, as well as corporate
administrative functionality including real-time reporting, traveler tracking,
spend reconciliation, travel continuity, and traveler customer support.
TripActions Liquid, a payments and expense application, provides the ability to
make travel payments, track and submit business expenses, reconcile expense
reports, link to personal accounts for expense submittals and reimbursements,
import transactions, manage business expenses, and access customer support.
These Services are offered through a corporate subscription.

When you use our Services because one of our Corporate Customers (e.g., your
employer) has purchased the Services, and you use our Services to book business
travel or manage expenses, we collect, use, and disclose Personal Information
about Corporate Users acting in our capacity as a “processor” or “service
provider” to our Corporate Customers. TripActions’ Corporate Customers are the
controllers of this Personal Information and responsible for making sure that
the Traveler’s privacy rights are respected, including ensuring appropriate
disclosures about third-party data collection and use are made. When we act as a
“processor” or “service provider” to our Corporate Customers, we process
Personal Information in accordance with our Corporate Customer’s lawful
instructions, the terms of the agreement we have with the TripActions Corporate
Customer, and consistent with this Privacy Policy.

By contrast, when you use our Services to book personal travel (as opposed to
business travel) or when you respond to one of our surveys, we collect, use, and
disclose Personal Information about Users acting in our capacity as a
“controller” or “data owner.” Our Corporate Customers do not have access to the
Personal Information you provide when you book personal travel, unless you
choose to share that information with your employer. When we act as a
“controller,” we process Personal Information consistent with this Privacy
Policy.

As a travel management platform, our Services may share your booking information
with other parties to fulfill your travel reservations, including third-party
websites, services or applications. This Privacy Policy does not apply to
third-party websites, services, or applications, even if they are accessible
through our Services, and you should consider the privacy practices of those
third parties carefully.

Personal Information

“Personal Information” is information that identifies you as an individual or
relates to an identifiable individual. The types of Personal Information we
collect vary according to your interactions with us, for example, depending on
whether you are a visitor to our website, a Corporate Customer of TripActions,
or an employee of Customer using our Services. The Personal Information we
collect from our Corporate Customers or Users booking business travel or using
our payment services is “Corporate Customer Data,” and the Personal Information
we collect from our Website visitors, Users booking personal travel, or
otherwise apart from providing Services is “Other Information.”

How We Collect Personal Information

Information You Provide to Us

Website Visitors. If you visit or use our Website, you can fill out web forms to
ask for a demo, sign-up for a newsletter, register for a TripActions event or
account, or take a survey. The specific Personal Information you provide on
these forms, as well as any Personal Information you choose to provide on our
community discussion boards, will be treated as Other Information. For example,
when you respond to TripActions emails or surveys, or create a user account to
participate in our community discussion boards, we collect your name, contact
details, profile photo, and any other information you choose to include in your
email, survey response, or account profile.

TripActions Services. When you use our Services, the Personal Information that
you provide directly to us through our Services will be apparent from the
context in which you provide the data. You may provide Personal Information to
us when you book travel or use our expense management services. Personal
Information may be provided to us directly by you or others, such as our
Corporate Customer (e.g., your employer), a designated travel admin, or a
traveling companion, on your behalf.

When you use TripActions to register an account (“Account”) on our Services, we
collect Personal Information, such as name, email, postal address, telephone
number, financial data (payment card information and billing address), date of
birth, gender, and emergency contact information (optional). When you use our
Services for personal travel, we collect Personal Information such as your
personal payment card information, billing address, and your personal email
address. You may customize your travel profile by providing additional Personal
Information, such as passport data, marital status, travel preferences, Known
Traveler Number, TSA-Pre number, special meal preference, travel loyalty
programs, and COVID-19-related health data.

When you contact us for travel support through our chat feature on our Apps or
by telephone, we collect Personal Information to verify your identification and
help with your travel issue. In addition, we may record telephone calls between
you and our representatives for training and quality assurance purposes. To the
extent you may choose to provide us with feedback, suggestions, or
recommendations about your experience, we collect that information and treat it
as Other Information.

Other Methods. You may also choose to submit Other Information to us via other
methods, including in response to marketing or a survey, through social media or
online forums, through participation in an offer or promotion, or by giving us
your business card or contact details at trade shows or other events.

Information Automatically Collected

In addition to the information you provide when you visit our Website and use
our Services, we automatically collect Other Information about how you access
and interact with our Website and Services. This information is a key part of
how we improve your experience on TripActions and provide you with personalized
insights, recommendations, and travel notices. These may include things like
cookies, browser web storage, web beacons, and similar technologies. These
technologies record information about your use of our Website and Services.

* Browser and Device Information. Certain information is collected by most
browsers or automatically through your device, such as your Media Access
Control (MAC) address, IP address for purposes of connecting, computer type
(Windows or Mac), screen resolution, operating system name and version,
device manufacturer and model, language, Internet browser type, add-ons, and
version and the name of the website or app you are using. We use this
information to ensure that our Website and Services function properly.

* Log Information. When you use our Website, certain information is
automatically collected in system logs about how you interact with our
Website, such as your online activity, search terms, pages you visit, date
and time of access, and cookie information, such as mouse clicks and
keystrokes. This information is used to improve your experience on our
Website and keep the Website free of bugs or errors. When you use our
Services, we also may collect information about your online activity, such as
trips viewed, travel reservations made, and other actions within our App.
When you download and use one of our Apps, we and our service providers may
track and collect App usage data, such as the date and time the App on your
device accesses our servers and what information and files have been
downloaded to the App based on your mobile device's identifier.

* Cookies. TripActions uses a variety of cookies and similar technologies in
our Websites and Services to help us collect Other Information. For more
details about how we use these technologies, and your opt-out opportunities
and other options, please see our Cookies Policy.

* Geolocation. When you use certain features of the Services, we may collect
certain information like IP address, device information, or log information
to estimate your location (e.g., city or state) and to offer you an improved
user experience and provide you with personalized location-based services,
such as identifying nearby hotels, airports, or merchants. For Liquid, you
have the option to share location information when uploading receipts. Most
mobile devices allow you to control or disable the use of location services
for applications in device settings menu.

Information From Third Parties

We may obtain and rely on Personal Information about you from third parties and
other sources, such as our business partners, Corporate Customers, and other
Users of our Services. For example, TripActions Corporate Customers may provide
Personal Information about Users when they create new Accounts for their
employees or guests. Organizers of meetings and events may share Personal
Information when they are organizing business travel for attendees. Users may
provide Personal Information about their travel companions when booking personal
travel. We may also work with different third-party partners to supplement
information we collect directly from you.

As a travel management platform, when we conduct fraud monitoring, prevention,
and detection activities, we may also receive Other Information about you from
our business partners, financial service providers, identity verification
services, and publicly available sources as necessary to confirm your identity
and prevent fraud.

If you disclose any Personal Information relating to other people to us or to
our service providers in connection with our Services, you represent and warrant
that you have the authority to do so and to permit us to use the information in
accordance with this Privacy Policy and/or any other agreements we may have with
you.

How We Use Personal Information

We use the information we collect from you and third parties to operate our
Website and Services, communicate with you, conduct research and development to
improve our Website and Services, and promote our Services.

TripActions Services for Corporate Customers. TripActions uses Corporate
Customer Data for the purpose of providing our Services to Corporate Customers
to enable their employees to book business travel and manage expenses. Corporate
Customer Data will be used by TripActions in accordance with Corporate
Customer’s instructions, including any applicable terms in our agreements with
our Corporate Customers, and as required by law. TripActions is a processor of
Personal Information and Corporate Customer is the controller. Some examples of
how we use Corporate Customer Data:

* Account Information. To create, maintain, and secure accounts, including
customizing your travel profile.

* Reservations. To complete travel bookings, process your payments, provide
travel confirmations, provide notifications and updates, and verify your
information.
* Services Communications. To communicate with you regarding travel
interruptions, flight changes, delays, travel alerts and restrictions, and
cancellations; respond to inquiries and questions; and notify you of updates
to our Services, product updates, and service announcements. Communications
may be sent via email, push notifications, browser notifications, SMS, and
postal mail.
* Payments and Expenses. To track and submit travel or other business expenses,
reconcile expense reports, link to personal accounts for expense submittal
and reimbursement, and manage expenses.
* Corporate Customer Support. To provide customer support when you contact us
via chat, telephone, or email. We use this Corporate Customer Data to verify
your identity and retrieve travel records related to your inquiries.
* Providing Personalized Services. To personalize your experience on our
Services, such as to curate booking recommendations, identify nearby hotels
and airports, record travel meal and seating preferences, and optimize search
results. We provide these personalized services in accordance with the terms
of our agreement with our Corporate Customer.
* TripActions Digital Health Passport. To enable access to health documents
required to meet airline and state/country requirements for travel.

TripActions Services for Travelers Booking Personal Travel. TripActions uses
Other Information for the purpose of providing our Services to Users booking
personal travel. TripActions is the controller of Other Information and uses it,
for example, as follows:

* Account Information. To create, maintain, and secure accounts, in order to
manage our contractual relationship with you and/or to comply with a legal
obligation.
* Reservations. To complete travel bookings, process your payments, provide
travel confirmations, provide notifications and updates, and verify your
information, in order to manage our contractual relationship with you or to
comply with a legal obligation.
* Services Communications. To communicate with you regarding travel
interruptions, flight changes, delays, travel alerts and restrictions, and
cancellations; respond to inquiries and questions; and notify you of updates
to our Services, product updates, and service announcements. Communications
may be sent via email, push notifications, browser notifications, SMS, and
postal mail. We engage in these communications to manage our contractual
relationship with you, where we have a legitimate interest, or to comply with
a legal obligation.
* Payments and Expenses. To track and submit travel or other business expenses,
reconcile expense reports, link to personal accounts for expense submittal
and reimbursement, and manage expenses, in order to manage our contractual
relationship with you, where we have a legitimate interest, or to comply with
a legal obligation.
* Traveler Support. To provide traveler support when you contact us via chat,
telephone, or email. We use Other Information to verify your identity and
retrieve travel records related to your inquiries. We engage in travel
support in order to manage our contractual relationship with you or where we
have a legitimate interest.
* Providing Personalized Services. To personalize your experience on our
Services, such as to curate booking recommendations, identify nearby hotels
and airports, record travel meal and seating preferences, customize your
travel profile, and optimize search results. We provide these personalized
services based on our legitimate interests, and with your consent to the
extent required by applicable law.
* TripActions Digital Health Passport. To enable access to health documents
required to meet airline and state/country requirements for travel, in order
to manage our contractual relationship with you or to comply with a legal
obligation.

Accomplishing Our Business Purposes. TripActions uses Other Information in
furtherance of our legitimate interest in operating our Services, Websites, and
business, as well as to comply with our legal obligations. Our business purposes
include:

* Data analysis to improve our Services, develop new products and services,
enhance, modify, and maintain our current products and Services, as well as
undertaking quality and safety assurance measures;
* Security of our Website and Services. To protect the safety, integrity of our
Corporate Customers and Users, including monitoring, detecting, and
preventing fraud, cyberattacks, attempts to commit identity theft, and
unauthorized or illegal use of our Website or Services;
* Identification of usage trends. To better understanding which parts of our
Services are of most interest to users and focus our energies on meeting our
users’ interests;
* Determine the effectiveness of our promotional campaigns, so that we can
adapt our campaigns to the needs and interests of our users;
* Audits. To verify that our internal processes function as intended and to
address legal, regulatory, or contractual requirements;
* Aggregated reports. To analyze and/or predict preferences in order to prepare
aggregated trend reports on how our Website and Services are used, so we can
improve our Website and Services.

Legal compliance. We use Other Information to verify the identity of our Users
and Corporate Customers in order to comply with fraud monitoring, prevention and
detection obligations, laws associated with the identification and reporting of
illegal and illicit activity, such as AML (Anti-Money Laundering) and KYC
(Know-Your-Customer) obligations, and financial reporting obligations. For
example, we may be required to record and verify a User’s identity for the
purpose of compliance with legislation intended to prevent money laundering and
financial crimes. These obligations are imposed on us by the operation of law,
industry standards, and by our financial partners, and may require us to report
our compliance to third parties, and to submit to third party verification
audits.

Marketing and Events-Related Communications. When you use our Website or
Services, we may use Other Information to send you marketing communications
about our Services, products and features, and other news about TripActions.
Marketing communications may invite you to participate in our events, product
demos, beta program, or surveys. We will engage in marketing activities with
your consent or where we have a legitimate interest.

TripActions Events. When you participate in trade shows or other events, we may
collect Other Information, such as your business contact details, to follow-up
with you regarding an event, offer a demo of our Services, send you information
that you requested, and, with your permission, include you on our marketing
campaigns.

Consent. We may use Personal Information for other purposes that are clearly
disclosed to you at the time you provide Personal Information or with your
consent.

Aggregated and De-Identified Personal Information. We may aggregate and/or
de-identify Personal Information such that it is no longer considered Personal
Information. We do so to generate other data for our use, which we may use and
disclose for any purpose, as it no longer identifies you or any other
individual. We engage in these activities based on our legitimate interest.

How We Disclose Personal Information

We disclose your Personal Information in connection with providing our Services
and the operation of our business.

TripActions. We share Personal Information with other TripActions entities in
order to provide our Services and for internal administration purposes. These
entities are TripActions Labs BV (Netherlands), TripActions BV (Netherlands),
TripActions Limited (UK), and TripActions Pty Limited (Australia).

TripActions Corporate Customers. As a corporate travel management platform, we
share Corporate Customer Data, such as Traveler Personal Information related to
business travel, with the Corporate Customer who has made our Services available
to the user. Information may include business travel bookings and details,
business travel status, business expenses, profiles, current locations (based on
business travel itinerary), travel preferences, business payments and
transactions history. Only travel bookings designated as business are accessible
by the Traveler’s employer. If your employer has elected to establish a
TripActions Rewards Program, information related to your business travel will be
shared with your employer, such as traveler, booking, destination, travel dates,
and pricing information. Please note that the information we provide will be
subject to the receiving Corporate Customer’s privacy policy. We are not
responsible for the privacy and security practices of our Corporate Customers.

Service Providers. We share Corporate Customer Data and Other Information with a
limited number of our service providers. We have service providers that provide
services on our behalf, such as website hosting, data analysis, credit card
payment processors, billing services, business analytics, distribution of
surveys or sweepstakes programs, information technology and related
infrastructure, customer service, email delivery, identity verification,
auditing, and fraud protection.

Business Partners and Providers of Travel Services. We may share Corporate
Customer Data and Other Information with third-party business partners when this
is necessary to provide our Services. Third parties to whom we may disclose
Personal Information include airlines, hotels, rail, rental car companies,
travel networks and agencies in order to make the travel bookings you requested.
Please note that the business partners are third-party controllers and that
information we provide may be subject to and processed according to the
receiving third party’s privacy policy. If your booking is made via a
reservation system provider ("GDS"), it will be processed according to its
privacy policy available at http://www.iatatravelcenter.com/privacy. You should
read this documentation, which applies to your booking and specifies, for
example, how your personal data is collected, stored, used, disclosed and
transferred. We are not responsible for the privacy and security practices of
these third parties.

Your Choice to Disclose Personal Information. By participating in any community
discussion boards, blogs, or other services to which you are able to post
information and content, you may choose to disclose Personal Information. Please
note that any information you post or disclose through these services will
become public and may be available to other users and the general public.

Legal Compliance and Obligations. We share Personal Information as necessary or
appropriate (i) to comply with applicable laws and regulation which may include
laws outside your country of residence; (ii) to protect the rights, privacy,
safety, and property of our Corporate Customers, you, others, or TripActions and
to enforce our Terms of Service; (iii) to collect amounts owed to us, and (iv)
to respond to requests from courts, law enforcement agencies, regulatory
agencies, and other public and government authorities (including national
security requests) which may include authorities outside your country of
residence.

Corporate Transactions. We may disclose or transfer Personal Information to a
third party in the event we enter into, or intend to enter into, a transaction
that alters the structure of our business, such as a reorganization, merger,
sale, joint venture, assignment, transfer, or disposition of all or any portion
of our business, assets, or stock (including in connection with any bankruptcy
or similar proceedings).

Your Rights and Choices

You have choices regarding our use and disclosure of your Personal Information.
You may opt out from:

* Receiving marketing-related emails from us. If you no longer want to receive
marketing-related emails from us, you may opt-out via the “unsubscribe” link
included in such emails. Please note that if you opt-out of receiving
marketing-related emails from us, we may still send you important
administrative messages that are required to provide you with our Services,
from which you cannot opt-out. We will try to comply with your request(s) as
soon as reasonably practicable.

* Receiving Travel Alerts from Us. You can manage your communication
preferences by visiting your Account Profile and then Settings. You can
choose which types of travel alerts to receive and the method for receiving
the alerts. You may also opt-out of SMS alerts in your Account Settings.

* Our Use of Certain Cookies. You can manage some of the cookies we use on our
Website and Services by visiting our Cookie Policy.

Accessing and Changing Your Personal Information. You may access, update,
correct, or delete your profile information and preferences at any time by
logging in to your Account through our Apps.

Your Data Protection Rights. In accordance with applicable law and depending on
where you reside, you may have the right to: (i) request confirmation of whether
we are processing your Personal Information; (ii) obtain access to or a copy of
your Personal Information; (iii) receive an electronic copy of Personal
Information that you have provided to us, or ask us to send that information to
another company (the “right of data portability”); (iv) object to or restrict
our uses of your Personal Information; (v) seek correction or amendment of
inaccurate, untrue, incomplete, or improperly processed Personal Information;
(vi) withdraw your consent at any time, without affecting the lawfulness of
processing based on consent before its withdrawal; and (vii) request erasure of
Personal Information held about you by us, subject to certain exceptions
prescribed by law.

If you would like to exercise any of these rights, please email us at
privacy@tripactions.com or contact us as specified in the Contact Us section
below. We will respond to your request consistent with applicable law and as
soon as reasonably practicable. To protect your privacy, we will verify your
request using the information associated with your account, including email
address.

Please note that if you use our Services on behalf of an organization that is
our Customer (e.g., your employer), that Customer may be responsible for
fulfilling the rights listed above.

California Privacy Rights. This section only applies to our processing of
Personal Information that is subject to the California Consumer Privacy Act
(CCPA). The CCPA affords California residents certain rights regarding
categories of personal information that we collect, use, and disclose acting in
our capacity as a “business.”

Subject to certain limitations, CCPA provides California residents the right (i)
to request to know more details about the categories or specific pieces of
personal information we collected, including how we use the information and the
categories of third parties to whom we disclose this information; (ii) to
request the categories of sources from which we collect personal information;
(iii) to access or delete their personal information; (iv) to opt out of any
“sales” of personal information that may be occurring; and (v) to not be
discriminated against for exercising these rights.

In the preceding 12 months, we may have collected and disclosed the following
categories of personal information for one or more business purposes:
identifiers, personal information (as defined in the California customer records
law), characteristics of classifications protected by California or federal law,
commercial information, internet or electronic network activity information,
geolocation data, audio, electronic, or similar information, such as call
recording, professional or employment information, and inferences drawn from
other personal information to create a profile.

For a more detailed explanation of the Personal Information we have collected
about you, please refer to “Information You Provide to Us,” “Information
Automatically Collected,” and “Information From Third Parties” sections of this
Privacy Policy. For an overview of how we use and disclose the information we
collect for the business purposes described in this policy, please refer to “How
We Use Personal Information” and the “How We Disclose Personal Information”
section(s) above.

For purposes of the California Consumer Privacy Act, we do not “sell” (as such
term is defined in the CCPA) the personal information we collect, nor do we have
actual knowledge of any “sale” of Personal Information of minors under 16 years
of age.

Only you, or someone legally authorized to act on your behalf, may make a
verifiable consumer request related to your Personal Information under the CCPA.
To designate an authorized agent, please contact us as set forth below.

California residents or their authorized agents may make a request pursuant to
their rights under the CCPA by contacting us as set forth below. We will verify
your request using the information associated with your account, including email
address. Government identification may be required.

If you are a resident of California, under 18, and have an Account on our
Services, you may ask us to remove content or information that you have posted
to our Services by writing to privacy@tripactions.com. Please note that your
request does not ensure complete or comprehensive removal of the content or
information, as, for example, some of your content may have been reposted by
another user.

Security and Retention

We maintain commercially reasonable technical and organizational measures
designed to protect Personal Information within our organization. Unfortunately,
no data transmission or storage system can be guaranteed to be 100% secure. If
you have reason to believe that your interaction with us is no longer secure,
please Contact Us immediately.

We retain Personal Information for as long as needed or permitted in light of
the purpose(s) for which it was obtained and consistent with applicable law. If
you are a Corporate Customer or Traveler, we retain your Personal Information as
long as we are providing Services to you. We may retain Personal Information and
certain records of your transactions to the extent necessary to comply with our
legal and regulatory obligations. We may also retain Personal Information in
light of our legal position such as in regard to applicable statute of
limitations, litigation, or regulatory investigations.

Links to Other Websites

The Website and Services may provide the ability to connect to third-party
websites or other online services. These third-party websites and services
operate independently from us. This Privacy Policy does not address, and we are
not responsible for, the privacy, information, or other practices of any third
parties, including any third party operating any website or service to which the
Website and Services link. The inclusion of a link does not imply endorsement of
the linked site or service by us or by our affiliates.

Our Apps use Google Maps/Earth services, including the Google Maps API(s). Use
of Google Maps/Earth is subject to Google Maps/Earth Additional Terms of Use and
the Google Privacy Policy.

In addition, we are not responsible for the information collection, use,
disclosure, or security policies or practices of other organizations, such as
Facebook, Apple, Google, Microsoft, or any other app developer, app provider,
social media platform provider, operating system provider, wireless service
provider, or device manufacturer, including with respect to any Personal
Information you disclose to other organizations through or in connection with
our Apps or social media pages.

Interest-Based Advertisement Practices

When you visit our Website, we and certain third-party advertising companies
engaged by us, collect information about your online activities over time to
provide you with advertising about products and services tailored to your
individual interests. You may see TripActions ads or promotions on other
websites or mobile apps based on information related to your visit to our
Website, as well as information received from third parties, because we
participate in advertising networks. These advertising networks may place or
recognize a unique cookie on your browser (including through the use of pixel
tags). They also use these technologies, along with information they collect
about your online use, to recognize you across the devices you use, such as a
mobile phone and a laptop. If you would like more information about this
practice, and to learn how to opt out of some personalized advertising in
desktop and mobile browsers on the particular device on which you are accessing
this Privacy Policy, please visit http://optout.aboutads.info/#,
http://optout.networkadvertising.org/#, and http://www.youronlinechoices.eu.

Use of Services and Website by Minors

Our Website and Services are not directed to individuals under the age of
sixteen (16), and we do not knowingly collect Personal Information from
individuals under 16.

Sensitive Information

Unless we request it, we ask that you not send us, and you not disclose, any
sensitive Personal Information (e.g., social security numbers, information
related to racial or ethnic origin, political opinions, religion or other
beliefs, health, biometrics or genetic characteristics, criminal background, or
trade union membership) on or through the Services or Website, or otherwise to
us.

Jurisdiction and Cross-Border Transfer

Your Personal Information may be stored and processed in any country where we
have facilities or in which we engage service providers, and by using our
Website or Services you understand that your information may be transferred to
countries outside of your country of residence, including the United States,
which may have data protection laws that are different from those of your
country. In certain circumstances, courts, law enforcement agencies, regulatory
agencies or security authorities in those other countries may be entitled to
access your Personal Information.

International Privacy Practices

European Economic Area. Some non-EEA countries are recognized by the European
Commission as providing adequate level of data protection according to EEA
standards (the full list of these countries is available here). For transfers
from the EEA to countries not considered adequate by the European Commission, we
endeavor to put in place adequate measures to ensure your Personal Information
is safeguarded consistent with the requirements of applicable laws. You may
obtain more information by contacting us in accordance with the “Contact Us”
section below.

You may contact our Data Protection Officer at dpo@tripactions.com. You may also
lodge a complaint with the EU/EEA data protection authority for your country or
region where you have your residence, place of work, or where an alleged
infringement of applicable data protection law occurs.

EU-U.S. Privacy Shield Statement. TripActions, Inc. complies with the EU-U.S.
Privacy Shield Framework as set forth by the U.S. Department of Commerce
regarding the collection, use, and retention of personal information from
European Union to the United States. TripActions, Inc. has certified to the U.S.
Department of Commerce that it adheres to the Privacy Shield Principles. If
there is any conflict between the terms in this privacy policy and the Privacy
Shield Principles, the Privacy Shield Principles shall govern. To learn more
about the Privacy Shield program, and to view our certification, please visit
https://www.privacyshield.gov/.

In compliance with the Privacy Shield Principles, TripActions commits to resolve
complaints about our collection or use of your personal information. EU
individuals with inquiries or complaints regarding our Privacy Shield practices
should first contact privacy@tripactions.com.

TripActions has further committed to refer unresolved privacy complaints under
the Privacy Shield Principles to an independent dispute resolution mechanism,
the BBB EU PRIVACY SHIELD, operated by BBB National Programs. If you do not
receive timely acknowledgment of your complaint, or if your complaint is not
satisfactorily addressed, please visit
https://bbbprograms.org/privacy-shield-complaints for more information and to
file a complaint. This service is provided free of charge to you.

As part of our participation in Privacy Shield, we are subject to the
investigatory and enforcement powers of U.S. The Federal Trade Commission and
other authorized statutory bodies. Under certain conditions, more fully
described on the Privacy Shield website, you may be entitled to invoke binding
arbitration when other dispute resolution options do not satisfactorily resolve
your concerns.

Russian Federation. The services hereunder are not intended for use by Russian
citizens who are resident in Russia. If you are a Russian citizen residing in
Russia, any Personal Information that you provide to us through our Website or
Services will be solely at your own risk and responsibility. You expressly agree
that we may gather your Personal Information and will process this data in the
United States and in other countries, and that you will not hold us accountable
for any potential non-observance of Russian law.

Updates to This Privacy Policy

We reserve the right to change this Privacy Policy at any time to reflect new
services, changes in our Personal Information practices or relevant laws. If we
make material changes, we will notify you as required by applicable law. The
“Last Updated” legend at the top of this Privacy Policy indicates when this
Privacy Policy was last revised. Any changes will become effective when we post
the revised Privacy Policy.

TripActions, Inc., located at 1501 Page Mill Road, Building 1, Palo Alto, CA
94304, USA, is the company responsible for collection, use, and disclosure of
your Personal Information under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us at
privacy@tripactions.com, or write to us at TripActions, Inc., 1501 Page Mill
Road, Building 1, Palo Alto, CA 94304 USA.

Because email communications are not always secure, please do not include credit
card or other sensitive information in your emails to us.

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