Last Updated: January 1, 2020

  1. INTRODUCTION

    This Privacy Policy describes Ovation Vacations’ (www.ovationvacations.com) (“we,” “us,” or “our”) privacy practices and the rights and choices available to individuals with respect to their information.

  2. ABOUT OVATION VACATIONS

    Ovation Vacations is committed to providing exceptional service and unforgettable luxury leisure travel experiences for our clientele. As trusted advisors, we act as a one-stop source for the best value and candid, personalized advice. From traditional getaways to exotic adventures, Ovation Vacations connects you with travel consultants, who develop the right vacation experience for you year-round.

    Our websites and related services are designed for individual travelers who wish to connect with highly specialized third-party and/or in-house travel consultants, who develop the right vacation experience for our clientele year-round. When travelers share information with us in the context of our leisure travel services, it is with the understanding that we will share this information with our travel consultants, and with travel suppliers that our consultants use to book individual travel (e.g., airline carriers, hotels, and car rental agencies). This is because connecting travelers to such consultants and booking individual leisure travel is a core part of our business.

  3. INFORMATION WE COLLECT

    We may collect information about you from you directly, and we may receive information from companies or individuals who refer you to us, or other third parties when you use our website, our travel booking services, or otherwise interact with us, our service providers, or our advertising partners. The information we collect or otherwise receive may include:

    • Contact information, such as your first and last name, email and mailing addresses, phone number and professional title.
    • Login data, such as your agent or admin login ID and password.
    • Travel data, such as information about your travel itinerary and other information required to book your vacation, including date of birth, gender, passport or other government-issued identification number, TSA known redress number, airline frequent flyer or other rewards numbers, credit card information, preferences (e.g., meal choices and allergy restrictions).
    • Correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online, as well as when you complete our surveys.
    • Social media data, such as information that you publish on Ovation Vacation’s social media pages such as tweets, comments, news articles, video or audio content and your social media handle. When you visit or interact with our pages on social media platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information.
    • Automatically collected data. We, our service providers and third party partners may automatically log information about you, your computer or mobile device, and your activity over time on our website and other online services, such as:
      • Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing our website, and general location information such as city, state or geographic area.
      • Online activity data, including information about your use of and actions on our website, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
  4. COOKIES AND OTHER TECHNOLOGIES

    Some of our automatic data collection is facilitated by cookies and similar technologies. Cookies are small data files placed on your computer when you visit a site. We may set cookies when you use our website to understand how you are using our website, help you navigate between pages efficiently, remember your preferences and generally improve your browsing experience. Analytics service providers and advertising partners may also use cookies on our website. For example, we use Google Analytics for analytics and advertising purposes. For more information about Google Analytics’ privacy practices, click here. You can opt out of Google Analytics by downloading and installing the browser plug-in, available here. In addition to cookies, our website and our emails may use pixel tags (also known as web beacons and clear GIFs) to compile statistics about use of our website and related services, measure the success of our marketing campaigns, and indicate whether recipients of our emails open or click links within them.

  5. THE PURPOSES FOR WHICH WE USE PERSONAL INFORMATION

    We use personal information for the following purposes:

    • Operations, including to provide, develop, and improve our services, communicate with you about our services (including by sending you announcements, updates, security alerts, and support and administrative messages), understand your needs and interests, and personalize your experience with our services and our communications, provide support and maintenance for our services, and respond to your requests, questions and feedback. Our operations also include booking your travel or otherwise completing a reservation with an airline carrier, hotel, car rental agency, or other supplier named on your travel itinerary.
    • Research and development, including to develop new products and services, including by studying user demographics and use of our website and services (such as through market research).
    • Marketing, including to send you Ovation-related marketing and promotional communications as permitted by law. You will have the ability to opt‐out of our marketing and promotional communications as described in the Opt out of marketing section below.
    • Advertising. We work with advertising partners to display advertisements on our website or elsewhere online. These advertisements are delivered by our advertising partners and may be targeted based on your use of our website, services, or your activity elsewhere online. Please see the Targeted online advertising section below to learn more about your choices in connection with advertisements.
    • Compliance with law. As we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
    • Compliance, fraud prevention and safety. As we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern our services; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
    • Creating anonymous, aggregated or de‐identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de‐identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de‐identified data and share it with third parties for our lawful business purposes, including to analyze and improve our services and promote our business.
  6. HOW WE DISCLOSE PERSONAL INFORMATION

    We may disclose the personal information we collect to the following categories of recipients:

    • Travel consultants. Our business is to connect you with the right third-party and/or in-house travel consultant to provide you an unforgettable luxury leisure travel experience. We share the information that you provide to us in the context of our leisure travel services with such travel consultants, to provide you with the services that you request.
    • Travel suppliers. We share information with third-party travel suppliers to book the leisure travel services that you request, such as airline carriers, hotels, car rental agencies, or other suppliers named on your travel itinerary.
    • Corporate Affiliates. We may share information with our parent company, subsidiaries, or other affiliates for purposes consistent with this Privacy Policy.
    • Service providers. We may share information with service providers, including third party companies and individuals that provide services on our behalf or help us operate our services (such as customer support, hosting, analytics, email delivery, marketing, and database management services). These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.
    • Professional advisors. We may disclose information to our professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
    • Advertising partners. Third party advertising companies that collect information about your activity on our website and other online services to help us advertise our services.
    • To comply with law. As we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
    • For compliance, fraud prevention and safety. As we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern our services; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
    • Business transfers. We may share information in connection with a business transfer in which we may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
  7. YOUR RIGHTS AND CHOICES

    Users may have the following rights and choices available to them with respect to the personal information we hold about them.

    • Update your information. If your information changes during the course of our relationship with you, and you would like to update or correct the personal information we hold about you, please submit a request to privacy@ovationtravel.com.
    • Opt out of receiving electronic direct marketing communications from us. You may opt out of marketing‐related emails by following the opt‐out or unsubscribe instructions at the bottom of the respective email. You may continue to receive service‐related and other non‐marketing emails.
    • Cookies and browser web storage. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, our website may not work properly. Similarly, your browser settings may allow you to clear your browser web storage. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.
    • Targeted online advertising. Some of the business partners that collect information about users’ activities on or through our website may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior for purposes of targeted advertising. Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above. If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.
    • Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
  8. SECURITY

    We maintain commercially reasonable administrative, technical and physical safeguards designed to (i) protect the security and confidentiality of personal information; (ii) identify, assess and protect against any reasonably foreseeable internal and external threats, risks or hazards to the security or integrity of personal information; and (iii) protect against unauthorized access to or use of personal information. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

  9. INTERNATIONAL DATA TRANSFERS

    We are headquartered in the United States and have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.

  10. CHILDREN

    Our website is not directed to children under the age of 13, and we do not knowingly collect information from children under the age of 13 on our website. If a parent or guardian becomes aware that his or her child has provided us with personal information through our website, please contact us. We will delete such information from our files as soon as reasonably practicable.

  11. CHANGES TO THE PRIVACY POLICY

    We reserve the right to revise, amend, or modify this Privacy Policy at any time and in any manner. You can tell when changes have been made to the Privacy Policy by referring to the “Last Updated” legend on top of this page.

  12. CONTACT US

    Should you have any questions or concerns regarding this Privacy Policy, please contact us by email at: privacy@ovationtravel.com, or write to us at:

    Ovation Travel Group
    Attn: Privacy – Ovation Vacations
    71 Fifth Avenue
    New York, NY 10003

  13. NOTICE TO CALIFORNA RESIDENTS

    We are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide to California residents an explanation of how we collect, use and share their personal Information, and of the rights and choices we offer California residents regarding our handling of the personal information. This notice does not apply to information related to our business contacts, including travel consultants.

    Personal information we collect, use and share.

    We do not sell personal information. As we explain in this Privacy Policy, we use cookies and other tracking technologies to analyze website traffic and facilitate advertising. If you would like to opt out of our (and our third party advertising partners’) use of cookies and other tracking technologies, please review the instructions provided in the Online Tracking Opt-out Guide.

    In addition to the information in our Privacy Policy, the following chart further describes our privacy practices with respect individuals whose information is governed by the CCPA.

    Personal information we collect CCPA-defined categories Sources from which we may collect the personal information Purposes for which we may collect and use the personal information Categories of third parties to which we disclose the personal information
    Contact information Identifiers You

    Referrals

    Other travellers on your itinerary
    Operations

    Research and development

    Marketing
    Advertising partners

    Travel consultants

    Travel suppliers
    Correspondence Identifiers You Operations

    Research and development

    Marketing
    Travel consultants

    Travel data Identifiers

    Commercial Information

    Characteristics of protected classifications

    Customer records
    You

    Other travellers on your itinerary
    Operations

    Research and development

    Marketing
    Travel consultants

    Travel suppliers
    Social media data Identifiers You

    Social media platforms
    Operations

    Research and development

    Marketing
    Advertising partners
    Device data

    Online activity data
    Internet or other electronic network activity information Inferences You

    Automatic collection
    Operations

    Research and development

    Marketing
    Advertising partners

    Please note that we may also disclose all personal information as otherwise described in the "How We Disclose Personal Information" section of our Privacy Policy.

    California residents' privacy rights. Except as excluded from the scope of this notice above, the CCPA grants California residents the following rights.

    • Information. You can request information about how we have collected, used and shared and used your personal information during the past 12 months. We have made this information available to California residents without having to request it by including it in this notice, in the above chart.

    • Access. You can request a copy of the personal information that we maintain about you.

    • Deletion. You can ask us to delete the personal information that we collected or maintain about you.

    Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.

    You are entitled to exercise the rights described above free from discrimination.

    How to submit a request

    To request access to or deletion of personal information:

    Identity verification. The CCPA requires us to verify the identity of the individual submitting a request to access or delete personal information before providing a substantive response to the request. We may attempt to verify your identify by asking you to confirm information that we have on file about your or your interactions with us. Where we must ask for additional personal information to verify your identity, we will only use it to verify your identity or your authority to make the request on behalf of another consumer.

    Authorized agents. California residents can empower an "authorized agent" to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.