Terms of Use, Privacy Policy, & Other Policies

Terms of Use

Last Updated: January 1, 2020

Acceptance of Terms

Please read these Terms of Use (the "Terms of Use") before accessing or using this website (the "Site"). This Site is maintained, operated and offered by Travefy, Inc., and its affiliates and subsidiaries (collectively, "Travefy"), and is intended to allow you, the User (or "you,", to assist in the planning and execution of travel. You understand that a significant portion of Travefy's business is facilitating transactions with third parties, and your rights and obligations with respect to such third party transactions, along with Travefy's role therein, are addressed below in these Terms of Use. By clicking the "I ACCEPT" button or accessing or using the Site or any services offered or materials available thereon, you, the user, are agreeing to be bound by the terms and conditions set forth herein, as well as any changes made thereto that Travefy may publish from time to time. If you do not agree to all of the terms and conditions contained in the Terms of Use, do not access or use this Site. Travefy may change the Terms of Use and other guidelines and rules posted on the Site from time to time at its sole discretion. Travefy will use reasonable efforts to notify you of any material changes to any of these Terms of Use, but your continued access or use of the Site constitutes your acceptance of the changes. Your access and use of the Site will be subject to the most current version of the Terms of Use, rules and guidelines posted on the Site at the time of such use. Please regularly check the "Terms of Use" to view the then-current terms. If you breach any of the Terms of Use, your authorization to access or use this Site automatically terminates. Should you at any time object to any provision of the Terms of Use, or become dissatisfied with our Site in any way, your only recourse is to immediately terminate use of the Site, Materials, and Services.

The Site

Travefy makes the Site and the Services available for your use solely in connection with your activities on the Site and further subject to these Terms of Use. Your rights in the Site and Services are limited solely to those rights expressly granted to you herein. "Services" means all services and resources offered, made available or enabled via the Site by Travefy, or third party service providers featured on the Site, including any software and software-as-a-service made available on the Site. We do not provide, own or control any of the travel services and products that you can access through our Site, such as flights, accommodations, rental cars, packages, or travel insurance (the "Travel Products"). The Travel Products are owned, controlled or made available by third parties (the "Travel Providers"). The Travel Providers are responsible for the Travel Products. The Travel Provider's terms and privacy policies apply to your booking so you must agree to and understand those terms. Furthermore, the terms of the actual travel provider (airline, hotel, tour operator, etc.) apply to your travel, so you must also agree to and understand those terms. Your interaction with any Travel Provider found or accessed through our Site is at your own risk; Travefy does not bear any responsibility should anything go wrong with booking or otherwise using the Travel Products.

Quality, Accuracy and Completeness

The Site may occasionally contain information found to be inaccurate, incomplete or out of date. Travefy makes no representations as to the completeness or accuracy of the Site or Services and other information, advice or recommendations made available on this Site, nor does it make any representations or warranties as to the quality or safety of any Services, Travel Products, or other third party products or services offered or made available via the Site. All features, content, specifications and prices of Travel Products and Services described or depicted on this Site are subject to change without notice. The inclusion of any Travel Product or Service on this Site at a particular time does not imply or warrant that such Travel Product or Service will be available at any time.

Intellectual Property

Travefy, the Travel Providers, and all other third party licensors own all of the text, images, software, trademarks, service marks and other material contained on the Site ("Material") except User Content. You will not copy or transmit any of the Material except as permitted by these Terms of Use. All copyright, trademark and other proprietary rights notices presented on the Site must appear on all copies you print or otherwise reduce to physical or digital form. Other third party product, service, or company designations ("Third Party IP") belong to those respective third parties and may be used for identification purposes only and not to imply or otherwise suggest an endorsement of your commercial or personal services by the owners of the Third Party IP. You should contact the appropriate third party for more complete information regarding such designations and their registration status. Your use of and access to the Site and Services does not grant you any license or legal right to use any of the marks included on the Site.

The trademarks, service marks, logos and URLs (collectively, the "Marks") displayed on this Site are the property of Travefy, its licensors or other third parties. You are not permitted to use the Marks without the prior written consent of Travefy, its licensors or such third party that may own the Marks.

Prohibited Use

By continuing to use the Site and Services, you agree not to engage in any of the following prohibited uses ("Prohibited Use(s)"). You acknowledge and agree that if it is determined, in Travefy's sole discretion, that you have engaged in any Prohibited Use, we may immediately terminate your access to the Site and Services, with no possibility of appeal. Travefy Professional will be billed on a per-seat basis, and you acknowledge and agree that a seat is individually-named or identified user.

You agree that you will not:

Registration on the Site

You may be required to register for an account ("Account") in order to access the Site and the Services. All required registration information that you provide must be current, complete and accurate and kept up to date on a prompt, timely basis. It is your sole responsibility to keep your user name, password and other sensitive information confidential. If you become aware of any unauthorized use of your account or any other breach of security, you shall notify Travefy immediately. In order to be eligible to register, you must meet the following requirements:

Failure to comply with the above requirements will result in the immediate termination of your Account, and your access to the Site and/or Services.

User Content

Portions or features of the Services or Site may allow you to contribute or otherwise provide content or other information to the Site. For such information, data, commentary, communications, downloads, files, text, images, graphics, videos, links, publications, content, tools, resources, programs and products that you post or submit to, or otherwise make available on, the Site ("User Content"), you grant Travefy and the users of the Site an unrestricted, irrevocable, non-exclusive, worldwide, royalty-free and fully paid up license under all Intellectual Property Rights to use, reproduce, publicly display, publicly perform, copy, edit, modify, translate, reformat, transmit and distribute such User Content, with or without having your name attached thereto, in any manner or form and for any lawful purpose, with full rights to sublicense such rights through multiple tiers of distribution. You will remain the owner of any User Content. You acknowledge and agree that Travefy shall not be liable for any damages arising out of or related to your User Content. You represent and warrant that you own all right, title and interest in and to your User Content that you post, or that you own or control, or have received the necessary licenses or other rights to, contribute such User Content to the Site. You agree not to disclose any Personal Information (as defined in Travefy's Privacy Policy) as part of a contribution of User Content. In particular, you represent and warrant that you are the copyright owner of any photographs you make available via the Site, or that you have all appropriate authority and permissions from the copyright holder of such photographs to permit their dissemination on the Site and to otherwise grant the rights addressed herein.

In certain instances, your User Content may include trip itinerary information, and Travefy may seek to use such information and provide access to such information to third parties. Before providing such information to any third party, Travefy will seek your permission.

You are solely and entirely responsible for all of your User Content. You assume all risks associated with any reliance on the accuracy, completeness or usefulness of your User Content from or by others. Travefy does not guarantee the accuracy, integrity or quality of the material you contribute or the material anyone else contributes as part of a User Content. You acknowledge and agree that by accessing or using the Site, you may be exposed to material from others that you find objectionable. You acknowledge and agree that Travefy shall not be liable for any actions or inactions resulting from or related to any User Submission made on the Site.

Copyright Infringement Complaints

We respect the intellectual property rights of others and we prohibit users from posting on the Site any content that violates another party's intellectual property rights. The Digital Millennium Copyright Act of 1998 (the "DMCA") provides a complaint procedure for copyright owners who believe that website material infringes their rights under U.S. copyright law. If you believe that your work has been improperly copied and posted on the website, please provide us with the following information: (1) name, address, telephone number, email address and an electronic or physical signature of the copyright owner or of the person authorized to act on his/ her behalf; (2) a description of the copyrighted work that you claim has been infringed; (3) a description of where on the Site the material that you claim is infringing is located; (4) a written statement that you have a good faith belief that the disputed use is not authorized by the copyright owner, its agent, or the law; and (5) a statement by you, made under penalty of perjury, that the above information in your notice is accurate and that you are the copyright owner or authorized to act on the copyright owner's behalf. These requirements must be followed to give Travefy legally sufficient notice of infringement. Send copyright infringement complaints to:

Travefy Incorporated

Attn: David Chait, CEO

Email: copyright@travefy.com

We suggest that you consult your legal advisor before filing a DMCA notice with Travefy's copyright agent. There can be penalties for false claims under the DMCA.

Links to Third Party Sites

The Site, Services or Materials may include links that will take you to other sites outside of the Site ("Linked Sites"). The inclusion of the Linked Sites does not imply any endorsement by Travefy of any Linked Site. Travefy has no control of the Linked Sites and you therefore acknowledge and agree that Travefy is not responsible for the contents of any Linked Site, any link contained in a Linked Site or any changes or updates to a Linked Site, or any transactions that may occur on such Linked Sites or that you may enter into with respect to the owners of such Linked Sites. You further acknowledge and agree that Travefy is not responsible for any form of transmission (e.g. webcasting) received from any Linked Site.

Processing Funds

Payment processing services for Travefy Expense on Travefy are provided by Stripe and are subject to the Stripe Connected Account Agreement, which includes the Stripe Terms of Service (collectively, the "Stripe Services Agreement"). By agreeing to these terms or Travefy Expense on Travefy, you agree to be bound by the Stripe Services Agreement, as the same may be modified by Stripe from time to time. As a condition of Travefy enabling payment processing services through Stripe, you agree to provide Travefy accurate and complete information about you and your business, and you authorize Travefy to share it and transaction information related to your use of the payment processing services provided by Stripe.

Warranties and Disclaimers

THE SITE, PRODUCTS, SERVICES AND MATERIALS ARE PROVIDED BY TRAVEFY "AS IS" WITHOUT WARRANTY OF ANY KIND, EITHER EXPRESS OR IMPLIED, WHETHER BY STATUTE, COMMON LAW, CUSTOM, USAGE OR OTHERWISE, INCLUDING, BUT NOT LIMITED TO, PERFORMANCE, SECURITY, INTEGRATION, QUIET ENJOYMENT, SATISFACTORY QUALITY, AND THE IMPLIED WARRANTIES OF TITLE, NON-INFRINGEMENT, MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE. WITHOUT LIMITING THE FOREGOING, TRAVEFY MAKES NO WARRANTY THAT (i) THE SITE, PRODUCTS, SERVICES OR MATERIALS WILL MEET YOUR REQUIREMENTS; (ii) THE SITE, PRODUCTS, SERVICES OR MATERIALS WILL BE ACCURATE, UNINTERRUPTED, TIMELY, SECURE, OR ERROR-FREE; (iii) THE RESULTS THAT MAY BE OBTAINED FROM THE USE OF THE SITE, PRODUCTS, SERVICES OR MATERIALS WILL BE EFFECTIVE, ACCURATE, OR RELIABLE; (iv) THE QUALITY OF THE SITE, OR ANY PRODUCTS, MATERIALS OR SERVICES PURCHASED OR ACCESSIBLE BY YOU WILL MEET YOUR EXPECTATIONS; AND (v) ANY ERRORS OR DEFECTS IN THE SITE, PRODUCTS, SERVICES OR MATERIALS WILL BE CORRECTED.
THIS SITE, PRODUCTS, MATERIALS AND SERVICES MAY INCLUDE TECHNICAL OR OTHER MISTAKES, INACCURACIES, OR TYPOGRAPHICAL ERRORS. TRAVEFY MAY MAKE CHANGES TO THE SITE, PRODUCTS, MATERIALS AND SERVICES, AT ANY TIME IN ITS SOLE DISCRETION AND WITHOUT NOTICE. THE SITE, PRODUCTS, MATERIALS AND SERVICES MAY BE OUT OF DATE, AND TRAVEFY MAKES NO COMMITMENT TO UPDATE THE SITE, MATERIALS, PRODUCTS AND SERVICES.
YOU ACKNOWLEDGE AND AGREE THAT: (i) TRAVEFY DOES NOT CONTROL, ENDORSE, OR ACCEPT RESPONSIBILITY FOR ANY PRODUCTS, MATERIALS OR SERVICES OFFERED BY THIRD PARTIES; (ii) TRAVEFY MAKES NO REPRESENTATIONS OR WARRANTIES ABOUT ANY SUCH THIRD PARTIES, THEIR PRODUCTS, MATERIALS OR SERVICES; (iii) ANY DEALINGS YOU MAY HAVE WITH SUCH THIRD PARTIES ARE AT YOUR OWN RISK; AND (iv) TRAVEFY SHALL NOT BE LIABLE OR RESPONSIBLE FOR ANY PRODUCT, MATERIALS OR SERVICES OFFERED BY THIRD PARTIES. TRAVEFY DISCLAIMS ANY AND ALL LIABILITY WITH RESPECT TO ANY DAMAGES, PERSONAL INJURY OR OTHER HARM THAT MAY BE CAUSED BY YOUR RELIANCE ON ANY ADVICE, SUGGESTIONS, RECOMMENDATIONS OR OTHER INFORMATION PROVIDED ON THE SITE.
SOME STATES OR JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF IMPLIED WARRANTIES OR LIMITATIONS ON HOW LONG AN IMPLIED WARRANTY MAY LAST, SO THE ABOVE LIMITATIONS MAY NOT APPLY TO YOU. TO THE EXTENT PERMISSIBLE, ANY IMPLIED WARRANTIES ARE LIMITED TO NINETY (90) DAYS.

Limitation of Liability

IN NO EVENT SHALL TRAVEFY, ITS DIVISIONS, SUBSIDIARIES AND AFFILIATES OR THEIR RESPECTIVE OFFICERS, DIRECTORS, PARTNERS, EMPLOYEES, SHAREHOLDERS, MEMBERS, MANAGERS, OWNERS AND AGENTS BE LIABLE TO YOU OR ANY THIRD PARTY FOR ANY SPECIAL, PUNITIVE, INCIDENTAL, INDIRECT OR CONSEQUENTIAL DAMAGES OR LOSSES OF ANY KIND, OR ANY DAMAGES OR LOSSES WHATSOEVER, WHETHER OR NOT FORESEEABLE OR IF TRAVEFY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES OR LOSSES, AND ON ANY THEORY OF LIABILITY, INCLUDING BREACH OF CONTRACT OR WARRANTY, NEGLIGENCE OR OTHER TORTIOUS ACTION, OR ANY OTHER CLAIM ARISING OUT OF OR IN CONNECTION WITH: (i) THE ACCESS, CONSUMPTION OR USE OF OR THE INABILITY TO ACCESS OR USE ANY PART OF THE SITE, PRODUCTS, SERVICES, OR MATERIALS; (ii) ANY DEALINGS WITH VENDORS OR OTHER THIRD PARTIES; (iii) ANY INFORMATION THAT IS SENT OR RECEIVED OR NOT SENT OR RECEIVED; (iv) ANY PRODUCTS OR SERVICES AVAILABLE THAT ARE DELAYED OR INTERRUPTED; (v) ANY WEBSITE REFERENCED OR LINKED TO FROM THIS SITE; (vi) YOUR ACCESS TO OR USE OF OR INABILITY TO ACCESS OR USE ANY LINKED SITE; OR (vii) YOUR RELIANCE UPON ANY MATERIAL, PRODUCT, SERVICE OR ANY CONTENT OR OTHER INFORMATION AVAILABLE ON THE SITE.

Indemnity and Liability

You agree to indemnify and hold Travefy, its divisions and affiliates, and their respective officers, directors, partners, employees, shareholders, members, managers, owners and agents harmless from any claim or demand, including reasonable attorneys' fees, made by any third party due to or arising out of: (i) your access to, reliance on, use, purchase or, as applicable, consumption of the Site, Services or Materials (including any use by your employees, contractors, customers, clients or agents and all uses of your account numbers, user names and passwords, whether or not actually or expressly authorized by you, in connection with the Site or any Services or Materials); (ii) your connection to the Site, Travel Products, Services or Materials; (iii) your violation of the Terms of Use or your breach of any representation or warranty made herein; (iv) your infringement of any third party's Intellectual Property Rights when using the Site, Products, Services or in any Materials; (v) your violation of any rights of any third party; (vi) your access to or use of Linked Sites and your connections thereto; (vii) any dealings between you and any third parties advertising or promoting via the Site, Products, Services or Materials; or (viii) Travefy's use of your User Submissions.

Governing Law and Jurisdiction

This Site (excluding Linked Sites) is controlled by Travefy from its offices within the State of Nebraska, United States of America. By accessing this Site, you agree that all matters relating to your access to, or use of, this Site shall be governed by the statutes and laws of the State of Nebraska without regard to the conflicts of laws principles thereof. You also agree and hereby submit to the exclusive personal jurisdiction and venue of an appropriate state or federal court in Lancaster County, Nebraska, with respect to such matters.

General

The Terms of Use and other rules, guidelines and disclaimers posted via the Site, or in connection with the Materials and Services, constitute the entire agreement between Travefy and you with respect to your access to or use of the Site, Materials and Services, superseding any prior agreements between you and Travefy on such subject matter (including any prior versions of the Terms of Use). You may also be subject to additional terms and conditions that may apply when you use other Travefy products, services, third party content or third party software. You may not assign or otherwise transfer the Terms of Use nor any right granted hereunder without Travefy's prior written consent. If for any reason a court of competent jurisdiction finds any provision of the Terms of Use, or portion thereof, to be unenforceable, that provision shall be enforced to the maximum extent permissible so as to effect the intent of the parties as reflected by that provision, and the remainder of the Terms of Use shall continue in full force and effect. Any failure by Travefy to enforce or exercise any provision of the Terms of Use or related right shall not constitute a waiver of that right or provision. The section titles used in the Terms of Use are purely for convenience and carry with them no legal or contractual effect.


Privacy Policy

Last Updated: January 1, 2020

Introduction

Welcome to Travefy's privacy policy.

Travefy respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website and tell you about your privacy rights and how the law protects you. Please refer to the Glossary for more information about capitalized but undefined terms used in this Privacy Policy.

Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Travefy collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our service or purchase a product.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

Controller

Travefy, Inc. is the controller responsible for your personal data (collectively referred to as "Travefy", "we", "us" or "us" in this privacy policy). Travefy is made up of different legal entities. This privacy policy is issued on behalf of the Travefy Group so when we mention "Travefy", "we", "us" or "us" in this privacy policy, we are referring to the relevant company in the Travefy Group responsible for processing your data. Travefy, Inc. is the controller responsible for this website.

We have appointed a data protection manager ("DPM") who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPM using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Travefy, Inc.
Name or title of DPM: Chris Davis, Chief Technology Officer
Email address: chris@travefy.com
Postal address: Travefy, Inc., 151 N. 8th St, BSMT, Lincoln, NE 68508

If you are a citizen of the EU, you have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

This version was last updated on January 1, 2020 and historic versions can be obtained by contacting us. We may change this privacy policy in our sole discretion, and your continued use of the Site or Services indicates acceptance of the new policies.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

User Content (as defined in the Travefy Terms of Use) is, to the extent that it doesn't include any personal information as detailed in this Policy, shall not be subject to the terms of the deletion policies of Travefy as it does not include any personal information.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you are including through:

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

See the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data. Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you for feedback

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Travefy group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transaction.

Cookies

In order to improve our services and provide more convenient, relevant experiences to our customers, we and our agents may use "cookies," "web beacons," and similar devices to track your activities. A cookie is a small amount of data that is transferred to your browser by a web server and can only be read by the server that gave it to you. It functions as your identification card and enables us to record your passwords and preferences. It cannot be executed as code or deliver viruses. A web beacon is a small transparent .gif image that is embedded in an HTML page or email used to track when the page or email has been viewed. Most browsers are initially set to accept cookies, and most services that include similar devices are typically initially activated to collect data. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Travefy Account holders may likely share Client Data with entities around the world (for example, when making a hotel booking on a client's behalf). Clients should refer to the privacy policy of the relevant Travefy Account holder to understand the way in which their personal data will be processed by third parties in relation to specific bookings.

For EU Citizens

We share your personal data within the Travefy Group. This will involve transferring your data in and out of the United States and the European Economic Area. We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called "binding corporate rules".

Many of our external third parties are based outside the European Economic Area so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see Request erasure below for further in some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. See the Glossary for more about these specific rights.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the Travefy Group acting as joint controllers or processors and who provide IT and system administration services and undertake leadership reporting.

External Third Parties

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.


Copyright Take-Down Notice

We respect the intellectual property rights of others and we prohibit users from posting on the Site any content that violates another party's intellectual property rights. If your copyright-protected work was posted on Travefy's Site or Services without authorization, you may submit a copyright infringement notification. Be sure to consider whether fair use, fair dealing, or a similar exception to copyright applies before you submit. These requests should be sent by the copyright owner or an agent authorized to act on the owner's behalf.

Be advised that the name you enter as copyright owner will be published on the Travefy Site in place of the turned off content. If you can give us a valid legal alternative, such as a company name or the name of an authorized representative, we'll review and apply it if appropriate. The name will become part of the public record of your request, along with your description of the work(s) allegedly infringed. All other information, including your full legal name and email, are part of the full takedown notice, which may be given to the uploader.

If you choose to submit a copyright takedown request, remember that you're starting a legal process. The below steps set out the process by which you can submit a takedown request. The Digital Millennium Copyright Act of 1998 (the "DMCA") provides a complaint procedure for copyright owners who believe that website material infringes their rights under U.S. copyright law. If you believe that your work has been improperly copied and posted on the website, please provide us with the following information:

(1) A physical or electronic signature of a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.

(2) Identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted works at a single online site are covered by a single notification, a representative list of such works at that site.

(3) Identification of the material that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit the service provider to locate the material.

(4) Information reasonably sufficient to permit the service provider to contact the complaining party, such as an address, telephone number, and, if available, an electronic mail address at which the complaining party may be contacted.

(5) A statement that the complaining party has a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law.

(6) A statement that the information in the notification is accurate, and under penalty of perjury, that the complaining party is authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.

These requirements must be followed to give Travefy legally sufficient notice of infringement. Send copyright infringement complaints to:

Travefy Incorporated
Attn: David Chait, CEO
Email: copyright@travefy.com

We suggest that you consult your legal advisor before filing a DMCA notice with Travefy's copyright agent. There can be penalties for false claims under the DMCA.