Your use of this Web site or our mobile application constitutes your agreement to the terms of this Privacy Policy as detailed below.

At Travel Edge (USA) Inc. and Travel Edge (Canada) Inc. (collectively, "Travel Edge", “we” or “us”), we endeavour to protect the privacy of personal information in our custody or control. This Privacy Policy explains how Travel Edge collects, uses and discloses personal information and the measures we have implemented to protect the personal information provided to us. This Privacy Policy applies to the personal information collected, used, disclosed or processed by Travel Edge in the course of its business. Travel Edge and its affiliated companies, including, without limitation, Travel Edge Holdings (USA) Inc., Travel Edge Holdings (Canada) Inc., TripArc Inc., Travel Edge (Bermuda) Ltd. Travel Edge Group (Canada) Inc., Kensington Tours Ltd., Kensington Yacht Inc., and Travel Edge Group ULC (collectively, the “Affiliates”, and together with Travel Edge, the “TE Group”) operate in Canada, the United States and Bermuda.

As a provider of travel services to our clients, Travel Edge collects, uses and discloses personal information of individuals authorized to travel (a “Traveller”) and individuals who provide travel services (an “Agent”) (Travellers and Agents, collectively and individually, “you”). Anyone who submits personal information to us, including our service providers’ employees and other personnel, should understand the nature of our business and how their personal information is collected, used, disclosed or processed by Travel Edge.

Travel Edge adopts the ten principles for the protection of personal information as set out below. (“Privacy Principles”) The Privacy Principles for the collection, use and disclosure of personal information are:

1. Accountability
2. Identifying Purposes
3. Consent
4. Limiting Collection
5. Limiting Use, Disclosure and Retention
6. Accuracy
7. Safeguards
8. Cookies and Data Collection; Advertising
9. Openness
10. Choices and Access
11. Challenging Compliance
12. Updating this Privacy Policy
13. For Nevada Residents
14. For California Residents

1. ACCOUNTABILITY

Travel Edge is responsible for personal information in its custody or under its control. Travel Edge requires a comparable level of protection for personal information handled by its third-party contractors and service providers.

Each TE Group office is responsible for maintaining and protecting the personal information of Travellers and applicable Agents under its control. In fulfilling this mandate, each TE Group office has designated an individual or individuals who are accountable for compliance with this Privacy Policy.

In addition, Travel Edge has designated a corporate Privacy Manager to facilitate Travel Edge’ privacy compliance, in conjunction with senior leadership - who has overall responsibility for Travel Edge’ privacy compliance.

2. IDENTIFYING PURPOSES

The primary purposes for which Travel Edge collects personal information include:

• to establish and maintain responsive relationships with Travellers and Agents and to respond to your inquiries and fulfil your requests, when you contact us via one of our online contact forms or otherwise;

• to send administrative information to you, such as changes to our terms, conditions, and policies;

• to personalize and provide travel services to Travellers and Agents including, without limitation, making travel arrangements on behalf of Travellers, providing travel policy compliance services, and collecting, analysing and reporting on Traveller travel data;

• to enable alternative travel service providers to provide travel-related services to you, in the event that we are not able to provide you with a suitable product or service;

• to understand Traveller and Agent needs and preferences, including special requirements;

• to remember information so that you will not have to re-enter or look for it the next time you visit our website;

• to obtain payment for services;

• to send you our newsletter when you have signed up for it and to develop, enhance, market or provide products and services which we think may be of interest to you, including, without limitation, to market or provide products and services through the TE Group, Affiliates of the TE Group or third-party travel providers;

• to accomplish our business purposes, including, without limitation, for managing and developing Travel Edge’ business and operations for data analysis to improve our services, for audits, for fraud and security monitoring, for identifying usage trends, and for determining the effectiveness of our promotional campaigns;

• to conduct surveys and promotions;

• to aggregate and/or anonymize personal information so it no longer identifies you or any other individual, in order to generate data for our statistical and analytical use; and

• to meet applicable legal and regulatory requirements and to cooperate with law enforcement and government authorities.

3. CONSENT

Travel Edge provides travel services to Travellers and Agents. In order to complete these services, Travel Edge requires personal information for authorized Travellers. The personal information collected by Travel Edge may include, but is not limited to, name, address, age, marital status, passport and visa information, emergency contact, email, phone number, financial information and employment information.

Travel Edge may also collect sensitive personal information related to a Traveller’s travel arrangements (such as the Traveller’s disabilities, allergies and other medical information and special needs) (“Sensitive Personal Information”) to help the Traveller obtain special accommodations for travel arranged by or through Travel Edge, but only if the Traveller submits such Sensitive Personal Information to us. If a Traveller does not want us to collect and use such Sensitive Personal Information, then the Traveller and/or Agent should not submit this information to us. Travel Edge will not share a Traveller’s Sensitive Personal Information with a third party unless authorized to do so by the Traveller. If you disclose any personal information relating to other people to us or to our service providers in connection with our services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy

In order to complete the travel arrangements requested by the Traveller, Travel Edge may input the Traveller’s personal information into a proprietary booking/operating system or provide the Traveller’s personal information to travel suppliers, such as airlines, hotels and rental car agencies, internet booking engines or global distribution systems (individually and collectively, “Travel Supplier”). The Travel Supplier uses such personal information to aid in fulfilling the travel arrangements requested by a Traveller, such as for flights, lodging and rental car services. Travel Edge receives confirmation of the travel arrangements requested by a Traveller or Agent.

Upon completion, Travel Edge provides information to the Traveller and/or Agent, as applicable, on travel arrangements made for a Traveller. This information may include, but is not limited to, information regarding the dates and times of travel, locations travelled to and from, classes of service provided, the names and locations of any hotels or other lodging arranged for the Traveller by Travel Edge, the names of other Travel Suppliers providing services to the Traveller, and the costs incurred for all travel services selected by the Traveller. A Traveller’s personal information may also be shared with the Agent through which a Traveller is making travel arrangements.

In the event that Travel Edge is not able to provide a suitable travel experience for Traveller, Travel Edge may sell your personal information with other providers of travel services (“Travel-Related Service Partner”), in order to facilitate your opportunity to purchase travel-related services suitable to your needs.

Travel Edge does not exercise any control over personal information that has been transmitted to Travel Suppliers or Travel-Related Service Partners. By submitting personal information to Travel Edge, the Traveller authorizes the use and disclosure of such personal information to complete the travel arrangements requested by the Traveller. Personal information transferred to a Travel Supplier or Travel-Related Service Partner will be used by such Travel Supplier or Travel-Related Service Partner in accordance with their applicable privacy policies. Personal information transferred to a Travel Supplier or Travel-Related Service Partner may be subject to the privacy laws of a foreign jurisdiction. In addition, United States or other government and law enforcement authorities may have access to a Traveller’s personal information under certain security screening protocols.

A Traveller may choose not to have any of his or her personal information disclosed or transferred to third parties in accordance with the terms of this Privacy Policy. However, if a Traveller chooses not to submit his or her personal information to Travel Edge or allow Travel Edge to provide such personal information to a Travel Supplier, then Travel Edge may not be able to provide the travel services requested.

By contacting Travel Edge and requesting travel services information, Traveller consents to, and Agent represents that it has obtained Traveller’s consent to, the collection, use or disclosure of Traveller personal information in accordance with the purposes identified in Section 2 of this Privacy Policy. Travel Edge may seek additional consent to use and disclose personal information after it has been collected, but before it is used or disclosed for a new purpose.

In addition to collecting, using and disclosing personal information in connection with the provision of services, Travel Edge may collect personal information from its employees and service provider representatives, and this personal information may be transferred among Travel Edge and its Affiliates, and may be subject to the privacy laws of a foreign jurisdiction. Travel Edge handles all such personal information in accordance with applicable privacy law.

4. LIMITING COLLECTION

Travel Edge limits the collection of personal information to that which is necessary for the purposes identified by Travel Edge in this Privacy Policy.

Children Under 18: Travel Edge does not knowingly collect personal information online from individuals under the age of 18 without parental consent. Should Travel Edge inadvertently acquire personal information from individuals under the age of 18, a parent or guardian of such child may contact us and upon notification, we will delete from our records any information collected as required by law.

5. LIMITING USE, DISCLOSURE AND RETENTION

Travel Edge only uses or discloses personal information for the purposes outlined in this Privacy Policy, or when it is required or permitted by law.

Travel Edge may disclose your personal information as described in this Privacy Policy, including to or for:

• Affiliates: We may disclose some or all of your personal information to Affiliates for the purposes described in this Privacy Policy. Affiliates are required to comply with this Privacy Policy.

• Service Providers and Vendors: As described in this Privacy Policy, we may disclose your personal information to travel suppliers, distributors, service providers, payment processors and other vendors in order to fulfil requests for the Travellers, to process payments and to administer our travel arrangements and tours. We may also disclose personal information to technical service providers, in order to maintain our website and systems and to provide better and more personalized products and services to the Traveller, and professional service providers, such as auditors and lawyers.

• Travel Agents: Travel Edge often works with Agents to provide services to the Traveller, including facilitating and completing travel reservations, organizing the Traveller’s tour or travel arrangements, and sharing information relating to the Traveller’s tour or travel arrangements.

• Business Partners: Travel Edge may share your personal information to businesses that have partnered with us, including credit card issuers.

• Travel-Related Service Partners: Travel Edge may share your personal information with select third parties for marketing purposes. For example, we may work with other travel/tour companies to provide you with the opportunity to purchase travel-related services suitable to your needs. If you are a resident of California or Nevada, please see the “For California Residents” and “For Nevada Residents” sections below for more information about your rights with respect to Travel-Related Service Partners.

• Legal Obligations: Travel Edge may disclose personal information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or otherwise pursuant to a legal process.

• Protection of Rights: Travel Edge may use and disclose personal information to establish or exercise our legal rights, to enforce our Terms and Conditions or this Privacy Policy, to assert or defend against legal claims or to take action against illegal or fraudulent activities or potential threats to the physical safety or well-being of any person.

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of the above third parties, including any third party operating any website or service to which our website links. The inclusion of a link on our website does not imply endorsement of the linked site or service by us or by our Affiliates.

6. ACCURACY

Travel Edge uses commercially reasonable efforts to ensure that personal information maintained by Travel Edge is accurate, complete and up-to-date as is necessary to fulfil the purposes for which it is to be used. Travel Edge relies upon the accuracy of the personal information submitted by the Traveller or Agent, if applicable, in order to provide the specific travel services and does not routinely update that information.

7. SAFEGUARDS

Keeping a Traveller’s personal information confidential is important to us, and Travel Edge takes commercially reasonable steps to protect that information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction. Travel Edge employs reasonable physical, administrative and technological safeguards to protect the security of personal information. 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 immediately notify us in accordance with the “Handling Complaints and Suggestions” section below.

8. COOKIES AND DATA COLLECTION; ADVERTISING

Our website may utilize cookies. Cookies enable us to monitor website traffic patterns and serve you more effectively. When you visit our website, our servers may automatically recognize certain information about you. A cookie does not identify you personally, but it does identify your computer or web browser. Cookies may tell us things like whether you have visited our website before and which of our website’s features you used. The information collected from cookies allows us to provide better customer service to you and helps us improve the features of our website. We do not currently respond to browser do-not-track signals.

We may also use web beacons or “pixels” that collect IP address, screen resolution and browser software and operating system types, clickstream patterns, dates and times that our site is accessed, and other categories of data.

You may opt out or disable cookies. Most computer systems and web browsers offer privacy settings and options that allow users to disable cookies. Certain features, services, products, content, or benefits of our website require that you provide us with certain information, including some types of personal information or information obtained from cookies, web beacons, and similar tracking technologies. If you do not wish to provide us with certain information or disable cookies, you may be unable to obtain certain features, services, products, content, or benefits of our website.

If you use our mobile application or access the website from a mobile device, we may collect additional information, such as device information (such as your mobile device ID, model and manufacturer), operating system, version information, IP address, carrier-related information, including the name of your wireless carrier, and IDs related to the cell phone hardware in your phone, as well as the network to which the device is connected, mobile phone number, application-specific and instance-specific identifiers, and location information, as further described in this Privacy Policy.

Analytics: We may use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Advertising: We may partner with third-party advertising companies that serve advertisements regarding goods and services that may be of interest to you when you access and use other websites or online services. You may receive advertisements based on information relating to your access to and use of our services and other websites or online services on any of your devices, as well as on information received from third parties. These companies 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 it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/

9. OPENNESS

Travel Edge makes information available to individuals concerning the policies and practices that apply to the management of their personal information, including as set out in this Privacy Policy.

Individuals may contact us at privacy@traveledge.com if they have any questions about our privacy practices.

10. CHOICES AND ACCESS

We give you choices regarding our use and disclosure of your personal information for marketing purposes. You may opt out from:

• Receiving marketing-related emails from us. If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt out by clicking “Unsubscribe” at the bottom of any email received from us or by emailing privacy@traveledge.com.

• Our sharing of your personal information with Affiliates for their direct marketing purposes. If you would prefer that we discontinue sharing your personal information on a going-forward basis with our Affiliates for their direct marketing purposes, you may opt out of this sharing by emailing privacy@traveledge.com.

• Our sharing of your personal information with unaffiliated third parties for their direct marketing purposes. If you would prefer that we discontinue sharing your personal information on a going-forward basis with unaffiliated third parties for their direct marketing purposes, you may opt out of this sharing by emailing privacy@traveledge.com.

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.

If you have made a request to delete your personal information under applicable law, please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion)

Nevada Privacy Rights: If you are a Nevada resident, please refer to the “For Nevada Residents” section at the end of this Privacy Policy for more information about your rights under Nevada law.

California Privacy Rights: If you are a California resident, please refer to the “For California Residents” section at the end of this Privacy Policy for information about the information requests you may make under the California Consumer Privacy Act (CCPA).

11. HANDLING COMPLAINTS AND SUGGESTIONS

Individuals may direct any questions or enquiries with respect to this Privacy Policy or about our practices by writing to privacy@traveledge.com, or by contacting the designated person accountable for privacy in each TE Group office.

A Traveller who thinks that his or her personal information has been misused should direct any questions or complaints to Travel Edge at privacy@traveledge.com providing a written description of the complaint. After receiving a written description of the complaint, a representative of Travel Edge will contact the Traveller in order to discuss his or her concerns. Travel Edge is interested in addressing all legitimate complaints about its adherence to applicable privacy paws and will make a good faith effort to resolve any complaint brought to its attention as required under applicable law.

12. UPDATING THIS PRIVACY POLICY

We might update our Privacy Policy from time to time, and any changes become effective when we post the revised Privacy Policy on the website. For material changes that apply to personal information that you provided already, we may notify you and we may ask for your consent to the change. This Privacy Policy was last updated on April15, 2021. We encourage you to check this page periodically for any changes. Your continued use of our website after we have updated or changed our Privacy Policy will be considered your consent to those updates or changes.

13. FOR NEVADA RESIDENTS

If you would like to request that Travel Edge Ltd., refrain from selling your Covered Information, as defined under Nevada law, please contact privacy@traveledge.com.

14. FOR CALIFORNIA RESIDENTS

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following additional details regarding the categories of Personal Information about California residents that we have collected or disclosed within the preceding 12 months:

(1) We collected the following categories of Personal Information:

Identifiers, such as name, contact information, online identifiers, passport and Social Security numbers and other government ID numbers;

A. Personal information, as defined in the California customer records law, such as name, contact information, signature, payment card number, government-issued ID numbers, medical, health insurance, insurance information, and education and employment information;

B. Characteristics of protected classifications under California or federal law, such as sex and marital status;

C. Commercial information, such as transaction information and transaction history;

D. Internet or network activity information, such as browsing history and interactions with our website;

E. Geolocation data, such as device location and IP location;

F. Audio, electronic, visual, and similar information, such as call and video recordings;

G. Professional or employment-related information, such as work history and prior employer; and

H. Inferences drawn from any of the Personal Information listed above to create a profile/summary about, for example, an individual’s preferences and characteristics.

We collect this Personal Information from the Traveller and/or Agent and from other categories of sources: joint marketing partners, when they share the information with us.

As described above, we may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, for our employment and vendor management purposes, and to accomplish our business purposes and objectives, including, for example, using Personal Information to: develop, improve, repair, and maintain our products and services; personalize, advertise, and market our products and services; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.

(2) We disclosed the following Personal Information to third parties for our operational business purposes:

A. Identifiers, such as name, contact information, online identifiers, passport and Social Security numbers and other government ID numbers;

B. Personal information, as defined in the California customer records law, such as name, contact information, signature, payment card number, government-issued ID numbers, medical, health insurance, insurance information, and education and employment information;

C. Characteristics of protected classifications under California or federal law, such as sex and marital status;

D. Commercial information, such as transaction information and transaction history;

E. Internet or network activity information, such as browsing history and interactions with our website;

F. Geolocation data, such as device location and IP location; and

G. Inferences drawn from any of the Personal Information listed above to create a profile/summary about, for example, an individual’s preferences and characteristics.

We share Personal Information with our service providers, third-party sponsors of sweepstakes, contests and similar promotions, and our business partners.

(3) We have “sold” the following categories of Personal Information:

A. Identifiers, such as name, contact information, online identifiers, passport and Social Security numbers and other government ID numbers;

B. Personal information, as defined in the California customer records law, such as name, contact information, signature, payment card number, government-issued ID numbers, medical, health insurance, insurance information, and education and employment information;

C. Characteristics of protected classifications under California or federal law, such as sex and marital status;

D. Commercial information, such as transaction information and transaction history;

E. Internet or network activity information, such as browsing history and interactions with our website;

F. Geolocation data, such as device location and IP location; and

G. Inferences drawn from any of the Personal Information listed above to create a profile/summary about, for example, an individual’s preferences and characteristics.

For purposes of this Privacy Policy, “sold” or “sale” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.

If you are a California resident, applicable law may give you the right to request that we:

(1) Disclose to you the following information covering the 12 months preceding your request:

• The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
• The specific pieces of Personal Information we collected about you;
• The business or commercial purpose for collecting or selling (if applicable) Personal Information about you;
• The categories of Personal Information about you that we sold and the categories of third parties to whom we sold such Personal Information (if applicable); and
• The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).

(2) Delete Personal Information we collected from you.

To make a request for the disclosures or deletion described above, please contact us in accordance with the “Contacting Us” section above. We will respond to your request consistent with the CCPA. In some instances, we may decline to honor your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another California resident.

(3) Opt you out of any future “sale” of Personal Information about you by clicking here: https://traveledge.com/privacy-policy-form.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

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September 20, 2021