I. DEFINITIONS

“Disclose†means to release, transfer, disseminate, or otherwise communicate all or any part of any record orally, in writing, or by electronic or any other means to any person or entity.

“Member†means an individual who has registered with the website.

“Minor†means any individual under 18 years of age, or as defined under the laws of their jurisdiction or residence.

“Personal Information†means any recorded information that can be used to identify an individual or any information linked to a particular individual. This information includes, for example, name, email and mailing address, phone number, account and billing information, IP address, and other identifying information provided by a visitor to our website or otherwise incidental to providing or advertising products and services to you.

“Website†means www.AvoyaTravel.com, as well as its related sites and web pages, and any domestic or international-owned or managed website of Avoya Travel that may be accessed through it.

II. GENERAL

By submitting Personal Information to us or our website, and / or by visiting www.AvoyaTravel.com, you agree that we may collect, use and Disclose such Personal Information in accordance with this Privacy Policy and as permitted or required by law.

If you do not agree with these terms, do not provide any Personal Information to Avoya Travel.

Avoya Travel is not intended for Minors, and does not sell or market products to Minors. Minors are not eligible to register with, use or purchase services via www.AvoyaTravel.com. We do not knowingly collect Personal Information from any Minor, and will not deliberately use such information. If you are under 18, you may use www.AvoyaTravel.com only with the involvement of a parent or guardian.

If you provide Personal Information regarding any third party, including parties traveling or vacationing with you, you must obtain consent prior to your disclosure of this information. By providing Personal Information of any third party, you represent that you have all necessary authority and / or have obtained all necessary consents from such person to allow our collection of Personal Information as set forth in this Privacy Policy.

III. PERSONAL INFORMATION COLLECTED

Avoya Travel only collects Personal Information that you voluntarily provide to us, or that is incidental to your use of our services. The information we collect helps us personalize and continually improve your experience with Avoya Travel, and assists us in providing for your vacation needs. Here are the types of information we gather:

• Information You Give Us: We receive and store any information you enter on our website or give us in any other way. You can choose not to provide certain information, but then you might not be able to take advantage of many of our features. We use the information that you provide for such purposes as responding to your requests, customizing future vacations for you, improving our website and communicating with you. Such information may include service and purchase information, Membership and billing information, when you call or write to our Customer Service and other volunteered information.
• Web Behavior Information: We receive and store certain types of information whenever you interact with us. For example, like many websites, we use “cookies,” and we obtain certain types of information when your Web browser accesses the website. Such information may include login information, browsing history, preferences and other personalization information. Please see “Cookies and Other Tracking Mechanisms” below for additional information.
• E-mail Communications: Avoya Travel may retain copies of our email correspondence, or if you have received and opened correspondence. We also compare our customer lists in an effort to avoid duplicative marketing.
• Information from Other Sources: We might receive information about you from other sources and add it to our account information. Such information may include when you visit sites on which we advertise, information collected on sites that we host for third parties and other content served by or on behalf of Avoya Travel on other websites.
• Incidental Information: Avoya Travel may collect information incidental to your visit of the website or purchase of products or services. Such information may include when you have visited the website or when you registered as a Member.

IV. USE OF PERSONAL INFORMATION

Avoya Travel uses your Personal Information for the purposes of responding to and processing your requests for Avoya Travel products and services:

• To record your travel preferences, to provide travel quotes, or make travel reservations on your behalf, to communicate with you or your travel provider about your travel plans;
• To process and track your transactions and to send information to Independent Agencies in the Avoya Travel Network and other agencies via our systems and software regarding our and our business partners’ products and services and other information and materials that may be of interest to you;
• To issue invoices, administer accounts, and collect and process product and services payments;
• To provide tips or guidance on how to use our website, inform you of new features on our site or provide other information that may be of interest to users;
• To personalize the service we provide to you, tailor your experience at our website to your interests and make more appropriate travel recommendations;
• To send you e-mails, e-newsletters, personalized offers via direct messaging or other communications about our services, if you have subscribed to receive this information or you have not advised us that you do not wish to receive such communications;
• To manage our website, diagnose technical problems, improve content and allocate the resources of our systems so that your experience with our website is as efficient as possible;
• To process and track your transactions and to send you information about our products and services and those of business partners’ and Independent Agencies in the Avoya Travel Network and other information and materials that may be of interest to you;
• To develop, enhance, market, sell or provide Avoya Travel products or services, or those of companies with which we have a commercial relationship, but only if you have granted us permission to do so or we are otherwise able to do so under applicable law;
• To effect a corporate transaction in connection with the sale, merger, spin-off or other corporate reorganization of our corporation, where the information is provided to the new controlling entity in regular course of business;
• To audit compliance with our policies and contractual obligations;
• As permitted by, and to comply with, any legal or regulatory requirements or provisions; or for any other purpose to which you consent.
• Avoya Travel does, at times, request credit card information, Membership ID, or national identification numbers to help plan and book vacations. Any such information is kept and maintained in accordance with Section VI below.
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V. DISCLOSURE OF PERSONAL INFORMATION

Avoya Travel will only share your Personal Information with our authorized service providers that perform services or functions on our behalf, as required by law, or as described below.

We may Disclose Personal Information as follows:

• To those travel service providers with which you have or may make arrangements through via our website. For example, associated cruise lines, tour operators, vacation packages, wholesalers, Independent Agencies in the Avoya Travel Network, travel agents and agencies, hotel or ground transport, attraction and travel insurance companies. We provide them only with the Personal Information needed to assist you in choosing and completing your purchases, as well as the booking and reservation of travel related products and services.
• To organizations that provide services for or on behalf of Avoya Travel. Examples include fulfilling orders, delivering packages and brochures, sending postal mail and e-mail, removing repetitive information from customer lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit card payments, and providing customer service. These parties have access to the Personal Information needed to perform their functions.
• Avoya Travel may collaborate with other companies via software and systems to offer additional products and services, and may share Personal Information to marketers of products and services which you have authorized. This Policy does not cover the use of your Personal Information by these other companies. We encourage you to read a company’s privacy policy before requesting any of its products or services.
• To protect our website and our rights under our Terms and Conditions of Use; to protect ourselves against liability or prevent fraudulent activity; or where it is necessary to permit us to pursue available remedies or limit any damages that we may sustain.
• To effect a corporate transaction, in connection with the sale, merger, spin-off or other corporate reorganization of our corporation, where the information is provided to the new controlling entity in regular course of business.
• To our insurers and to regulatory agencies.

VI. PERSONAL INFORMATION RETENTION

We will retain your Personal Information in our databases in accordance with our records management policy and applicable laws. While this information may be periodically purged, the retention period may extend beyond the end of your relationship with us. We may also need to retain certain information to prevent fraudulent activity; to protect ourselves against liability, permit us to pursue available remedies or limit any damages that we may sustain; or if we believe in good faith that a law, regulation, rule or guideline requires it.

Your Personal Information will be stored in secured locations and on servers controlled by Avoya Travel, located either at our offices, in a cloud instance, or at the offices of service providers. However, no system is perfect or can guarantee that unauthorized access or theft might not occur.

VII. HOW YOU CAN CONTROL THE USE OF YOUR INFORMATION

You can always choose not to provide Personal Information. Guest browsing is available on the www.AvoyaTravel.com website, even though Personal Information might be needed to make a purchase or to take advantage of certain Avoya Travel services. You can also disable or delete certain cookies or tracking technologies as indicated in Section VIII “Cookies and Other Tracking Mechanisms”, below.

Avoya Travel provides you with the opportunity to specifically choose the promotional marketing communications you wish to receive from Avoya Travel. Members can opt out of e-newsletters and other communications we offer by emailing CustomerCare@AvoyaTravel.com and putting “Unsubscribe” in the Subject line. You may further adjust your marketing preferences by providing your full name, street address and e-mail address, and specify that you don’t want to continue receiving postal mail, email, or both. If you choose not to receive any of the promotional marketing services that Avoya Travel provides, then Avoya Travel will not send them to you.

VIII. COOKIES AND OTHER TRACKING MECHANISMS

We use cookies and other tracking mechanisms to track information about your use of our website and our services on our website. We may combine this information with other personal information we collect from you.

Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our website, while others are used to enable a faster log-in process or to allow us to track your activities at our website. There are two types of cookies: session and persistent cookies.

• Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the website. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.
• Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity.

Each cookie serves one of four different purposes:

• A. Essential Cookies: These first party cookies allow users to use a feature of the Site such as: (i) staying logged in, or (ii) making purchases.
• B. Analytics Cookies: These cookies track information about how the Site is used so that we can make improvements and report on our performance. We may also use analytics cookies to test new ads, pages or features to see how users react to them. Analytics cookies may either be first party or third party cookies.
• C. Preference Cookies: These first party cookies store your Site preferences.
• D. Ad Targeting Cookies: These third party cookies (also known as “behavioral” or “targeted” advertising) are placed by advertising platforms or networks in order to: (i) deliver ads and tracks ad performance, and (ii) enable advertising networks to deliver ads that may be relevant based upon your activities. See additional information in “Online Advertising and Behavioral Tracking” below.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our website who disable cookies will be able to browse certain areas of the website, but some features may not function.

Local Storage Objects. We may use Flash Local Storage Objects (“Flash LSOs”) to store your website preferences and to personalize your visit. Flash LSOs are different from browser cookies because of the amount and type of data stored. Typically, you cannot control, delete, or disable the acceptance of Flash LSOs through your web browser. For more information on Flash LSOs, or to learn how to manage your settings for Flash LSOs, go to the Adobe Flash Player Help Page, choose “Global Storage Settings Panel” and follow the instructions. To see the Flash LSOs currently on your computer, choose “Website Storage Settings Panel” and follow the instructions to review and, if you choose, to delete any specific Flash LSO.

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our website to, among other things, track the activities of website visitors, help us manage content, and compile statistics about website usage. We and our third party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

IX. ONLINE TRACKING AND BEHAVIORAL ADVERTISING

We may use third parties such as network advertisers to display advertisements on our websites and to assist us in determining relevant advertising and placement on third party websites. Network advertisers are third parties that display advertisements based on your visits to our website as well as other websites. This enables us and these third parties to target advertisements by displaying ads for products and services in which you might be interested. Third party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. We may provide these third-party advertisers with information about your usage of our website and our services, as well as aggregate or non-personally identifiable information about visitors to our website and users of our services.

We also use services like Google Analytics and Google Customer Match to allow us to use information collected from your use of our site and other websites to customize the pages and advertisements that we present to you. The use of these services could also be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. These services collect data about your use of our site and other websites through Google advertising cookies. In connection with our use of the Google Customer Match service, we may share your email with the Google Customer Match service. Any data collected or shared through the use of this service will be used in accordance with our own privacy policy and Google’s privacy policy. You can set preferences for how Google advertises to you using the Google Ad Preferences page. Google Ad Preferences page. Alternatively, you can opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page.

If you wish to prevent your data from being used by Google Analytics, you may use the opt-out browser add available here.

We do not honor browser requests not to be tracked.

You may, however, opt-out of the collection of web viewing data over time and across unaffiliated website by Google and many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information regarding this practice by NAI members and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: www.networkadvertising.org/optout_nonpPersonal Information.asp (NAI) and www.aboutads.info/choices (DAA).

Opting out of one or more NAI member or DAA member networks (many of which will be the same) only means that those members no longer will deliver targeted content or ads to you. It does not mean you will no longer receive any targeted content or ads on our website or other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your NAI or DAA opt-out may no longer be effective. Additional information is available on NAI’s and DAA’s websites accessible by the above links.

X. THIRD PARTY ANALYTICS

We use automated devices and applications, such as Google Analytics, to evaluate use of our website. We use these tools to help us improve our website, services, performances, and user experiences. These third party services may use cookies and other tracking technologies to perform their services.

XI. HOW WE PROTECT YOUR INFORMATION

To protect the confidentiality of your Personal Information, Avoya Travel employs physical, administrative, and technical safeguards to help protect the confidentiality and integrity of the information and to reduce the risk of loss, misuse, unauthorized access disclosure or modification of Personal Information. However, no system is perfect or can guarantee that unauthorized access or theft might not occur.

XII. CHANGES TO THE PRIVACY POLICY

By providing you with this Privacy Statement, Avoya Travel is pledging our continued commitment to protecting the information you provide us. Avoya Travel regularly examines our information privacy practices to determine whether we are adhering to the disclosures about the collection, use, sharing, and protection of your Personal Information made in this privacy statement.

We may change or supplement this Privacy Policy from time to time. We may also undergo a change of ownership. Privacy Policy changes will apply to the information collected from the date we post the revised Privacy Policy to the website, as well as to existing information held by us.

If we decide to change this policy in a material way, we will obtain the necessary consents required under applicable privacy laws if we seek to collect, use or disclose Personal Information for purposes materially different than those to which consent has been obtained, unless otherwise required or permitted by law. If any proposed change is unacceptable to you, you may request that we remove your Personal Information from our records, as described above.

XIII. DISPUTES

Avoya Travel shares your concerns over privacy disputes. Your visit and any dispute over privacy is subject to this Privacy Policy and our Terms of Use, including any limitations on damages, resolution of disputes via Arbitration, and application of the law of the state of Florida. If you have questions or concerns regarding Avoya Travel privacy practices, you should first contact the Chief Privacy Officer (see contact information in next section). Avoya Travel will investigate and attempt to resolve complaints regarding violations of its published Privacy Policy directly with the complainant. In the event that the complaint cannot be resolved internally, the “Legal Disputes and Arbitration Agreement” provisions of the Terms of Uses will govern.

XIV. CONTACT INFORMATION

If you have any questions or concerns about (a) access to Personal Information, (b) the collection, use, management or disclosure of Personal Information, (c) this policy or our information handling practices, (d) with whom your Personal Information is shared, or if you need further assistance with respect to our Privacy Policy, you may contact our Chief Privacy Officer via our Customer Care department as indicated below. We will attempt to respond to your questions or concerns promptly after we receive them. e-mail: Privacy@AvoyaTravel.com.

XV. CALIFORNIA PRIVACY RIGHTS

Under California Law, California residents have a number of rights.

• Disclosure Rights: California consumers have the right to request in writing from a business, (a) a list of the categories of personal information, such as name, address, e-mail address, and the type of services provided to the customer, that a business has disclosed to third parties (including Independent Affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (b) the names and addresses of all such third parties.
• Deletion Rights: Californian consumers have the right to have their personal information deleted, unless the personal information is necessary for the business or service provider to:
• complete a transaction for which the personal information was collected, provide a good or service requested by the consumer or otherwise perform a contract between the business and the consumer;
• detect security incidents;
• protect against malicious, deceptive, fraudulent or illegal activity (or prosecute those responsible);
• debug to identify and repair functionality errors;
• exercise or ensure the right of another to exercise free speech or another legal right;
• comply with the California Electronic Communications Privacy Act, which compels the production of or access to electronic communication information or electronic device information with a search warrant;
• engage in research in the public interest (if the consumer has provided informed consent);
• to enable solely internal uses aligned with the consumer’s expectations given their relationship with the business;
• comply with a legal obligation;
• otherwise use the information internally in a lawful manner compatible with the context in which the consumer provided it.

Do Not Sell: Californian consumers have the right to opt-out of having their personal information sold. Avoya Travel does not sell personal information. However, when you inquire about a vacation through Avoya Travel, we provide your contact information to one of our independent travel agency partners to help you arrange your trip. If you don’t want the independent travel agencies in the Avoya Travel Network to assist in planning and booking your vacations and cruises, you should not use our site or services. Californians can exercise their privacy rights by contacting our Chief Privacy Officer via our Customer Care department via e-mail: Privacy@AvoyaTravel.com.

We will handle the request under applicable law. When a request is made, we may verify your identity to protect your privacy and security. We will respond to written rights requests within 30 days following receipt at the e-mail or mailing address stated above. If we receive your request at a different e-mail or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received. Please note that we are only required to respond to each customer once per calendar year.

XVI. NEVADA RESIDENTS

Nevada law entitles you to request that we refrain from sale of your personal information. We do not sell your personal information. However, when you inquire about a vacation through Avoya Travel, we provide your contact information to one of our independent travel agency partners to help you arrange your trip. If you don’t want our independent travel agency partners to assist in planning your vacation, you should not use our Website or services.

XVII. CHILDREN

The website is not intended for children under the age of 13. We will not knowingly collect any personally identifiable information from children under the age of thirteen (13). If we learn that we have obtained any personally identifiable information from a child under age 13, we will delete that information.

XVIII. U.S. WEBSITE

Our business is located in the United States. Our online privacy practices are governed by the laws of the United States and the State of Florida. By using the website, you understand and agree that any information you submit or is gathered about you will be transmitted to and stored in the United States. You further consent to the use and disclosure of that information accordance with applicable U.S. Federal and State laws and with this Privacy Policy.