Wanderu Privacy Policy

Personal data you provide us:

Wanderu collects and uses information that you provide us. If you make a reservation through one or more of the Wanderu Channels personal data may be needed to facilitate the reservation. Personal data that may be collected related to a reservation may include your name, the names of one or more people that will be using the travel services reserved and/or the name associated with the billing information used for the reservation, passport or other government identification number, age, birth date, email address, telephone number, carrier reward or account information, credit card information, billing address and travel information. When providing information you ensure that the information you are providing is valid, true, and up to date and complete and that you are authorized to provide such information to Wanderu. If you make a reservation on a Wanderu Channel we may automatically create a Wanderu Account for your use though which you can access My Trips features where we may collect your travel information to maintain your travel reservations.

If you contact our customer support through email, our support platform or social media we will collect information including your contact information, inquiry, feedback or user review.

If you register for an account we will collect your email address, password and your passenger travel information and/or preferences that you provide us. If you select to register or login through a third-party service like Facebook or Google you are permitting us to use and store information related to the account used.

You may provide us with personal information when you perform a reservation, sign up for email notifications or the like. We may also collect device information and settings that may allow us to establish your physical location including location information associated with your IP address, WiFi information, GPS location information and other technologies that allow you search using your location or receive content relevant to your location. Wanderu uses this information to personalize your interaction and content served by Wanderu to offer you an experience and products that are more interesting to you. Wanderu only has access to information that you enable your device to provide to us.

Personal data you provide us about others:

As part of making a reservation you may provide us with the personal data of another person who is either a passenger on reservation you are making or a person on whose behalf you are performing a reservation on Wanderu. It is your responsibility to ensure that the persons whose information you provide to us is aware that you provided us such information and that they have accepted how Wanderu uses their data per this Privacy Policy.

Personal data we automatically collect about you:

When you visit the Wanderu Channels, Wanderu may collect information about your visit including personal information. This may include IP address, screen size, browser and operating system info and settings, and referral information of your visit. We also collect information about your interaction with the Wanderu Channels such as what pages you visit. If your interaction is on a mobile device we may collect mobile device identifying information as well as device location and settings.

Personal data we receive from other sources:

Besides the information that you provide us we may also receive information about you from other sources including business partners and other third parties. This information may be combined with the information that you provide us. For example to complete a reservation you may provide information to a payment processor or travel provider and these third parties may share that information with us to facilitate the completion of a reservation.

In addition we might also receive information about you to deliver more relevant content or marketing information. If you link your Wanderu account with a social media provider some of your personal data may be shared with Wanderu by the social media provider, but only if you have granted the social media provider such permission.

Anonymous Information:

Wanderu Channels may also gather anonymous information, which may be used by Wanderu or shared with third parties. This is information which does not personally identify you, but which may be helpful for marketing purposes or for improving the services we offer, such as Google Analytics. Generally this information is collected through “traffic data” and may entail the use of “cookies,” “IP addresses,” or other numeric codes used to identify a computer.

Wanderu Channels employs cookies to recognize you and your access privileges on the Web site, as well as to track site usage. Subscribers who do not accept cookies from the domain (e.g. “Wanderu.com”) might not be able to access areas of Wanderu Channels. We may use an advertising server developed by a third party, to display ads on our site or ad links to third party websites. Some of these ads may contain cookies that are set by third parties (i.e., advertising agencies or advertising clients). We do not have access to these cookies or any information that they may contain. Acceptance of cookies from domains other than Wanderu.com is optional.

Wanderu uses the personal information to provide and improve the offerings and services of the Wanderu Channels, as well as to facilitate your reservation of products on Wanderu, store your travel information for your convenience and display relevant and useful advertising and offerings. More specifically your personal data may be used in one or more of the following ways:

1. Travel Reservations: We use your personal data to complete and service your online travel reservations.
2. Customer Service: We work hard to ensure we can answer all of your question and concern. To help with your question we need to be able to provide our customer support your information.
3. Wanderu Account: On the Wanderu Channels you can create a user account. With the information you provide us we are able to offer the account features. You can set your reservation information to use for future reservations, retrieve your completed reservations, and if the travel provider allows you can retrieve your tickets or cancel your reservation.
4. Marketing: We use the information you provide for marketing activities including:
   
   • Sending news of travel offerings and company updates when you make a reservation with us or if you set up an account. If you would like to unsubscribe from these marketing emails you can just click “Unsubscribe” at the bottom of such emails.
     *We may use your information to provide personalized content offerings on the website to better offer you more relevant content.
     *If you participate in promotion activities with Wanderu like giveaway, sweepstakes and the like we may use your information to administer such activities.
5. Market and User Research: We may ask some users to participate in surveys or user testing. As part of such activities personal information you provide us for these activities will be used only with your consent.
6. Fraud Prevention: To make sure only valid transactions occur on the Wanderu Channels we and our travel providers may use your personal data to detect and prevent fraud and other activities that are illegal or in breach of our terms. Personal data may be used for threat assessment and validation of transactions and reservations including the blocking of certain transactions or reservations.
7. Statistical Analysis for Product Improvement: Wanderu may perform statistical analyses of user behavior in order to measure interest in the various areas of our site (for product development purposes). We make the outmost effort to use anonymized information when performing such analysis. Such analysis is used to improve the Wanderu Channels and serve more relevant content for our users.
8. User reviews: We may ask you to provide a review of your experience with the Wanderu Channels or your travel experience.
9. Communication with you: We may from time to time get in touch with you by email, mail or phone based on the contact information you provided us and reasons for the communication. Such reasons for communicating with you include:
   
   • In furtherance of assisting you with a transaction or reservation you made or are trying to make.
   • If you have not finished a reservation we may contact you to remind you and offer help completing the reservation to ensure that you are successful in fulfilling your travel needs.
   • We may send information that we believe would help you with your reservation like a reminder of your upcoming travel details.
   • Administrative and other messages that we believe are necessary for your use of the Wanderu Channels.
10. Legal purposes: In certain case we might need to use the information that you provide us in furtherance of resolving legal disputes, for regulatory investigation and/or compliance, to enforce the Wanderu reservation terms or to comply with lawful requests from law enforcement.

Performing a contract: Using the information you provide us may be needed to perform the contract that you have with Wanderu. For example, if you use Wanderu to make a reservation we use the data to process, complete and carry out the reservation obligations under the contract we have with you. For travel reservations and customer support Wanderu relies on performance of a contract to process your information as we would not be able to carry out our contractual obligations without this information.

Legal interests: Using your information may be required for our legitimate interests such as delivering an experience on the Wanderu Channels that is most relevant and useful for you, as well as deliver the appropriate emails and newsletters, as well for user support, fraud protection, legal purposes and to improve and promote Wanderu services. For reasons 3-9 listed above Wanderu relies on legitimate interest to process your data and we always balance your users’ right and interests in protecting your personal data with Wanderu’s rights and interests. For purpose 10 when applicable Wanderu also relies on legal obligation to process your data in case such as lawful law enforcement requests.

For the use of your data for direct marketing we will obtain your consent, if required by applicable law, as a prerequisite to processing your data for such purpose.

To prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of information, we have put in place appropriate physical, electronic, and managerial procedures to protect the information we collect online.

Wanderu’s servers and data centers are in the United States and the Republic of Ireland. Wanderu’s service providers may be located in these countries or in other countries. By providing Wanderu your personal information you agree that your personal information may be transferred and stored in such countries which may have different or more lax privacy protection, data protection or data security laws. By providing your information to Wanderu your personal information may be subject to data requests from law enforcement, courts or government agencies in such countries according to their applicable laws and regulations. Wanderu will make provisions for proper protection of your personal information. Wanderu implements security measures to protect the transmission and storage of personal information to protect from unauthorized access or use. Wanderu implements Secure Socket Layer (SSL) to protect data in transmission over the internet and stored personal information is protected by security technologies including firewalls, possible encryption and other security measures in line with industry standards. In addition, personal information is restricted to only access and use by Wanderu team members when necessary for them to perform their duties and our authorized third party service providers for the purposes outlined in this Privacy Policy.

Wanderu uses a variety of third party service providers as part of providing the Wanderu Channels. These service providers may be located outside or inside the European Economic Area. The service providers may assist Wanderu with fraud prevention, customer service, advertising or payment processing. The providers have access to the information limited to what they require to perform the tasks for us and are contractually required to use the information consistent with our Privacy Policy.

Some Wanderu products incorporate Google Maps API(s) which are covered by Google Privacy Policy which you agree to by using Wanderu services. https://www.google.com/policies/privacy

If you navigate to third party websites or platforms, Wanderu’s Privacy Policy no longer applies.

You have the ability to request with proof of identification and receive a report of all of your personal information that we store in accordance to applicable law without charge unless in rare cases where a charge maybe necessary if the law permits. In some case we may not be able to provide you access to your stored personal data if it contains other sensitive information or if restricted by law, but we will provide you an explanation of the situation.

Upon request, Wanderu will: (a) remove you and your personal information from our database not associated with a reservation; (b) correct personal information that you state is erroneous; or (c) permit you to “opt out” of further email contact (except administrative and transactional emails) while still allowing access to the site. Wanderu will make a best effort to carry out your requests, but legal or other obligations such as mandatory data retention may prevent us from deleting, modifying or anonymizing some information.

To request a correction or cancellation, or any other question regarding this Privacy Policy please contact us at [email protected] or Privacy Officer – Wanderu Inc., 6 Liberty Square #2410, Boston MA 02109

Wanderu complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. Wanderu has certified to the 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 visit the Privacy Shield website as well as Wanderu’s Privacy Shield certification. https://www.privacyshield.gov/

Under the Privacy Shield Framework, Wanderu is subject to the authority of the Federal Trade Commission. For any questions or concerns relating to our Privacy Shield certification, contact Wanderu at Wanderu, Inc., Legal Department, 6 Liberty Square #2410, Boston MA 02109 or by email at [email protected]. If we are not able to resolve your concern, you may also contact your European Data Protection Authority or Commissioner or contact our designated Privacy Shield independent recourse mechanism, JAMS. https://www.jamsadr.com/ In certain circumstances, you may also have the right to pursue binding arbitration through the Privacy Shield Framework, as described in Annex I to the Privacy Shield Principles. https://www.privacyshield.gov/article?id=ANNEX-I-introduction

In accordance to our Privacy Policy, Wanderu sometimes shares information with third parties to perform services on our behalf. Wanderu continues to be responsible for the information shared under the Privacy Shield with such third parties except where we can establish that Wanderu is not responsible for the violation.

The California Consumer Privacy Act provides some California residents with the additional rights in this section.

Right to Know. You have the right to know and get access to what data we have collected about you over the past 12 months, including:

1. The categories of personal information we have collected about you
   
   • The types of sources from which the personal information is collected
   • The business or commercial purpose for collecting your personal information
   • The categories of third parties to whom we have shared your personal information; and
   • The specific personal information we have collected about you.

Right to Delete. You have the right to request that we delete the personal information we have collected from you (and direct our service providers to do the same). Certain exemptions apply that include, but are not limited to, when the personal information collected is necessary for us or a third party to do any of the following:

1. Complete your transaction
   
   • Provide you a good or service
   • Perform a contract between us and you
   • Protect your security and prosecute those responsible for breaching it
   • Fix our system in the case of technical issues
   • Protect the free speech rights of you or other users
   • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.)
   • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws
   • Comply with a legal obligation; or
   • Make other internal and lawful uses of the information that are in line with the context in which you provided it.

Other Rights. You can request certain types of information about our disclosure of personal information to third parties for their own direct marketing purposes during the previous calendar year. You may such request once per year and there is no associated fee. You also have the right not to be discriminated against for exercising any of the rights listed above.

How to Exercise Your California Privacy Rights. To request access to your personal information or deletion thereof, or to exercise any other data rights under California law, please contact us using one of the following methods:

Email: Please email us to exercise rights under these laws at [email protected]. Please include your full name and email address associated with your use of the Wanderu platform and your specific request.

Expected Time to Respond. Our goal is to respond to you with 45 days of receiving your request. If more time is required, we will inform you in writing of the reason that more time is required and the time frame you should expect.