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PRIVACY POLICY

Revised: 8/23/2023

Introduction


Arrivia, Inc. its affiliates and subsidiaries ("Company," "We," “Us,” and “Our”) respects your privacy and are committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you or that you may provide when you visit the website (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy describes the processing of information provided or collected on our websites when you participate in any of our programs. Such information may be gathered in one of the following ways:

- On or through this Website.

- Over the phone, email, text, and other electronic messages between you and Us.

- Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.

- When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Website.


We follow this policy in accordance with the applicable law in the places Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is to not use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Information We Collect About You and How We Collect It


We collect several types of information (“Personal Information”) from and about users of our Website, including the following categories of information:

Purchasing Information. This is information that we may collect about your transactions in our stores, on our websites or via our mobile applications, including but not limited to what products you purchase, how frequently you purchase them, any rewards or promotions associated with a purchase.

We collect this information:

- Directly from you when you provide it to us.

- Some information such as your internet connection and equipment you use to access our Website and usage details is automatically collected as you navigate through the Website. Information collected automatically may include usage details, IP addresses, location and information collected through cookies and other tracking technologies.

- We collect some information through automatic data collection technologies, which are discussed in more detail below.

- We use third party analytics providers and products, such as Google Analytics, to obtain, compile and analyze information about how users are using and interacting with the Website. In order to collect this information, such providers may set cookies on your browser or mobile device or read cookies that are already there. Google Analytics may also receive information about you from apps you have downloaded, that partner with Google. We do not combine the information collected through the use of Google Analytics with personally identifiable information. You can control the information provided to Google and opt out of certain ads provided by Google by using one of the methods set forth in https://www.google.com/policies/privacy/partners/

- From third parties, for example, our business partners, affiliates and agents.

Information You Provide to Us. The information we collect on or through our Website may include:

You also may provide information, or comments, or photographs to be published or displayed (hereinafter, "posted") on public areas of the Website or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages/you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies: As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

- Details of your visits to our Website, including traffic data, logs, and other communication data and the resources that you access and use on the Website.

The information we collect automatically is statistical data and does not include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

- Estimate our audience size and usage patterns.

The technologies we use for this automatic data collection may include:

We may tie information gathered above to Personal Information you provide to us.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use Your Information and Legal Bases for Processing


We only process your information where it is necessary in order to support:

There may be occasions where we request your consent to process your Personal Information. Where applicable, you may withdraw consent subsequently at any time by contacting us as detailed under Contact Information, below, without affecting the lawfulness of processing based on consent before its withdrawal. For example, we may use your information to contact you about our own and third-parties' goods and services that may be of interest to you. We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria. Information on how to opt-out of interest-based advertising can be found under the section titled Choices on How We Use and Disclose Your Information or by contacting us as detailed under Contact Information.

Disclosure of Your Information


Arrivia, Inc. is the data controller for your information and is responsible for and may use your information for the purposes designated in this policy. We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose and share Personal Information that we collect or you provide as described above (How We Use Your Information and Legal bases for Processing) to the following:

Choices About How We Use and Disclose Your Information


We strive to provide you with choices regarding the Personal Information you provide to us. Below are some of the mechanisms available to change control over your information automatically provided when visiting the Website:

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Digital Advertising Alliance or the Network Advertising Initiative ("NAI") on the NAI's website or by visiting www.AboutAds.info.

Information Sent Abroad


We are global organization and may rely on our international subsidiaries, affiliates and partners in order to provide global services. In certain circumstances, sharing data cross-border is essential to the services you receive from Us.

  1. Special Requirements under UK and EU Data Protection Laws:

    In order to complete your booking, complete analysis, or for other legitimate purposes we transfer, process and store information about you outside of either the United Kingdom ("UK”) or the European Economic Area ("EEA”), as applicable, on servers located in the United States by Arrivia, Inc. and its affiliates located at 15147 N. Scottsdale Rd, Ste. 210 Scottsdale, AZ 85254. Therefore, your information may be transferred to, stored, or processed in the United States. We will ensure that in terms of Data Security Standards, our systems in the US will have the same level of data protection that is required of our EU affiliate. If we transfer your Personal Information to agencies or third parties outside the EEA, we require similar, binding EU Standard Contractual Clauses, and we monitor compliance with such. Our affiliated or related entities, associates and partners have also agreed to adopt equivalent measures. Copies of these measures can be obtained by contacting Us as detailed under Contact Information below. You may lodge a complaint with the UK Information Commissioner’s Office or the relevant EEA data protection authorities if you consider that our processing of your Personal Information infringes applicable law

  2. Special Requirements under Mexican Data Protection Laws:

    In accordance with the requirements of the Mexican Federal Law on the Protection of Personal Information Held by Private Parties (Ley Federal de Protección de Datos Personales en Posesión de los Particulares) (the “Mexican DP Law”), We inform our users and subscribers located in Mexico of Our compliance with the Mexican DP Law. Under Mexican DP Law, We do not need to obtain your consent for the processing of your Personal Information for the purposes that give rise and are necessary for the fulfillment of our relationship (e.g. personal information required in order for you to subscribe to our vacation programs). In case you do not agree with the processing of your Personal Information for such purposes and as described in this policy, please abstain from acquiring or using our services.

Our Website users and subscribers located in Mexico should note that:

See the section Disclosure of Your Information for information regarding the manner in which we share your Personal Information with third parties and data-processors. Please note that we require your consent to transfer your Personal Information to third parties to market their own products or services to you.

Should you not wish that your Personal Information be transferred to third parties for their own marketing purposes please send an email to legalaffairsrequest@arrivia.com with subject line “Request for Restriction on the Transfer of Personal Information to Third Parties for their Own Marketing Purposes / Mexico”.

Your Rights to Accessing and Correcting Your Information


You can review and change your Personal Information by logging into the Website and visiting your account profile page. You have the right to ask us not to process your Personal Information for marketing purposes. You also have the right to access Personal Information about you by us and to correct inaccurate Personal Information. Please ensure that we have an up-to-date active and deliverable email address for you. In accordance with applicable law, you may also have the right to object to or request restriction of the processing of your Personal Information and to request erasure and to port Personal Information about you.

Should you wish to exercise your rights, or to unsubscribe please contact legalaffairsrequest@arrivia.com or Attn: Privacy Policy Manager, Arrivia, Inc., 15147 N. Scottsdale Rd, Ste. 210, Scottsdale, AZ 85254 or via our toll-free number: 888-320-4234.

Access to your Personal Information will be granted in accordance with the requirements of applicable national legislation. The information will be forwarded to you within an to validate and, where appropriate, correct our records.

Retention of Data


We will retain your Personal Information during the term of the provision of the services availed by You only for so long as reasonably necessary for the purposes set out herein, in accordance with applicable laws.

Children Under the Age of 18


Our Website is not intended for children under 18 years of age. No one under age 18 may provide any Personal Information to Company or on the Website. We do not knowingly collect Personal Information from children under 18. If you are under 18, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us as detailed under Contact Information, below.

Data Security and Retention


We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions provided therewith will be encrypted.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Your Personal Information will be retained only for so long as reasonably necessary for the purposes set out above, in accordance with applicable laws.

CALIFORNIA RESIDENTS- Your Privacy Rights


Under the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights, California residents have the right to opt-out of the selling or sharing of your personal data, including Personal Information. We do not sell your Personal Information for monetary or other valuable consideration or otherwise share your information with third parties. However, based on the CPRA’s broad definition of the term “share”, certain data collection on our sites and applications may be considered sharing under the CPRA. As such, you may have the right under applicable law to opt-out or object to such sharing. We do not sell your Personal Information for monetary or other valuable consideration or otherwise share your information with third parties. However, based on the CPRA’s broad definition of the term “share”, certain data collection on our sites and applications may be considered sharing under the CPRA. As such, you may have the right under applicable law to opt-out or object to such sharing.

In addition, if you are a California resident, you may request a copy of your Personal Information; request disclosure of Personal Information sold or disclosed for a business purpose; and request the deletion of your Personal Information. Please be advised that we may keep certain information, including but not limited to your transaction history and complaints you have filed, for an extended period of time and as may be required to fulfill our legal obligations.

You may exercise these rights by clicking the “Your California Privacy Rights” link present on our websites and applications. The link will provide you with a form to complete to request to opt out. To opt out, please follow the instructions provided when you click on the “Your California Privacy Rights” link. You may also choose to email us at legalaffairsrequest@arrivia.com. Please note "CA Opt-out Request" in the subject line of your email. To protect your privacy and security, we will need to ask for information to verify your identity before acting on a request. This information may include, but is not limited to, your name, contact information, and information related to your or relationship with us, but the information requested may vary depending on the nature and circumstances of your request.

If you request information, we will provide digital copies of any Personal Information you request free of charge, unless the information is not subject to the CCPA. If you request that we delete your personal information, we will both render certain Personal Information about you permanently unrecoverable and also deidentify certain personal information.

Please be advised that we do not discriminate against anyone for asserting or exercising their rights under the CCPA

Nevada Residents


Although we do not exchange Nevada residents’ Personal Information for money with anyone, Nevada residents have the right to opt-out of the future sale of their information to a third-party so that they may license or sell information by contacting us at legalaffairsrequest@arrivia.com.

Changes to Our Privacy Policy


It is our policy to post any changes we make to our privacy policy on this page with a pop-up notice that indicates the privacy policy has been updated on the Website home page. The date the privacy policy was last revised is identified at the top of the page. Please visit our Website and this privacy policy periodically to check for any changes.

Contact Information


To ask questions or comment about this privacy policy and our privacy practices, or request that we remove or opt-out any information gathered about you, that we actually control, please email or write to us at: legalaffairsrequest@arrivia.com or Attn: Privacy Policy Manager, Arrivia, Inc., 15147 N. Scottsdale Rd, Ste. 210 Scottsdale, AZ 85254 or via our toll-free number: 888-320-4234. The Privacy Policy Manager would also act as a designated grievance officer and shall address any discrepancies and grievances that you may have with respect to this Privacy Policy.