Advertising Choices
Travel5,
builder and operator of the Travel5 platform, is a member of several industry
groups that focus on effective communication, best practices, and policy review
in the field of Online Behavioral Advertising (OBA). These organizations
include the Network
Advertising Initiative (NAI), the Digital Advertising Alliance
(DAA), and the Interactive
Advertising Bureau (IAB). We are compliant with both the NAI
and DAA self-regulatory codes.
We believe that delivering targeted
and relevant advertising enhances your internet experience. We collect
non-personally identifiable information from many of the websites in which an Travel5
button is enabled, and use that information to deliver targeted advertising on
those websites as well as other websites you may visit. If you prefer that we
do not collect Non-Personally Identifiable Information about your website
visits for the purpose of delivering targeted advertising, you may opt out.
When you opt out, we will place an
opt-out cookie on your computer. The opt-out cookie tells us not to use your
information for delivering relevant online advertisements. Please note that if
you block cookies, our opt-out process may not function properly. Please also
note that if you delete, block, or otherwise restrict cookies, or if you use a
different computer or Internet browser, you will need to renew your opt-out
choice.
Privacy Practices by User Category:
(a) The Information We Gather and
How We Use it: The Site
is primarily directed to Publishers, although we welcome End Users who want to
know more about our Services. When you access the Site or Services, we may
collect the following information:
·
Personal Information — We collect Personal
Information when you knowingly provide it, including when you register for the
Site, provide feedback, or request information. Personal Information is information
that may be used to identify or locate an individual, like a person's full
name, postal address, e-mail address, or phone number, as well as other
non-public information that is associated with this Personal Information. We
use your Personal Information to administer your account and provide you
services, to send communications and administrative emails, to respond to your
inquiries, and to send marketing and product update messages to those who ask
for such messages. Typically, Publishers, rather than End Users visit the Site
in order to access and register for the Services.
·
Non-Personally Identifiable Information — We collect Non-Personally
Identifiable Information automatically when you visit our Site. Non-Personally
Identifiable Information is information that is not used nor intended to be
used to personally identify an individual and is not associated with nor linked
to Personal Information. This Non-Personally Identifiable Information we
collect via the Site includes your Internet Protocol address, browser type,
browser language, the date and time of your request, and the web page you have
visited immediately prior to visiting the Site.
·
Cookies — We use Cookies on this Site.
"Cookies" are small pieces of information that a website sends to
your computer's web browser while you are viewing a website. We may use both
session Cookies (which expire once you close your web browser) and persistent
Cookies (which stay on your computer until you delete them) to provide you with
a more personal and interactive experience. Persistent Cookies can be removed
or blocked by following the help file directions in your Internet browser. If
you elect to block Cookies, you may not be able to access certain personalized
sections of our Services such as Publisher reports. We also use log files and
Cookies to improve the quality of our Site; to keep track of your login name,
passwords, and pages you have visited on the Site; and to tailor content to
your interests and to personalize the Site on your behalf.
(b) Information Sharing: We share Personal Information and
Non-Personally Identifiable Information collected via the Site with other
companies or individuals as follows:
·
When they help us operate our business, such as with
vendors that assist us in sending email, marketing and customer service.
·
With third parties if we have a good faith belief that
access, use, or disclosure of such information is reasonably necessary to (a)
satisfy applicable law, regulation, legal process or an enforceable
governmental request, (b) enforce the applicable Terms of Service, including
investigation of potential violations thereof, (c) detect, prevent, or
otherwise address fraud, security or technical issues, or (d) protect against
harm to the rights, property or safety of Travel5, its users or the public as
required or permitted by law.
·
With any of our subsidiaries, joint ventures, or other
companies under common control with us, in which case we will require them to
honor this policy. Additionally, in the event we go through a business transition
such as a merger, acquisition by another company, or sale of all or a portion
of our assets, your Personal Information may be among the assets transferred.
·
With third parties to whom you ask us to send Personal
Information;
·
In addition, we may aggregate your Non-Personally
Identifiable Information with the Non-Personally-Identifiable Information of
others and share that aggregated information with third parties without
restriction.
(c) Forums: We make interactive forums
available on the Site. Any information that you post to these interactive
forums or otherwise choose to make publicly available, including your Personal
Information, may be disclosed and available to all users who have access to any
interactive forum and is no longer private. Please be thoughtful about what you
post and make publicly available through our interactive forums.
(d) Accessing and Controlling our
use of your Personal Information: If you have provided Personal Information when
registering for our Site, you may access and modify that information at any
time by visiting your account settings (http://travel5.com/settings). While we
would be sorry to see you go, you can delete your account at any time. Keep in
mind, however, that even if you delete your account, we may retain your
Personal Information in conformance with our data retention policy, under which
we may retain such information to comply with laws, prevent fraud, resolve
disputes, troubleshoot problems, assist with any investigations, enforce our
Terms of Use, and take other actions otherwise permitted by law. There may be
residual Personal Information that remains within our databases, access logs,
and other records. In addition, we are not responsible for updating or removing
your Personal Information already disclosed to third parties who have been
provided information as permitted by this Policy. You can opt out of receiving
certain email communications from the Site by clicking the
"Unsubscribe" link at the bottom of each email. Please note that even
if you unsubscribe or opt-out, we may still send you Site and Service related
communications.
As part of the Service, we operate
the Travel5 sharing platform, which makes sharing content on the web easy. If
you are reading this policy, you are probably familiar with our buttons and
menus that Publishers enable on their websites to allow you to share their
content through email, social networking websites, blogs and more. When you, an
End User use one of our buttons, menus and/or toolboxes that is enabled on one
of our Publisher websites (an "Travel5 Button"), we collect certain
non-personally identifiable information automatically for use on our platform
(the "Travel5 Platform"). We enable our Publishers to use this
information via the Platform for analytics purposes, and we also use some of
this information for online ad targeting as described below.
(a) The Information We Gather and
How We Use It:
·
Personal Information — We only collect Personal
Information via an Travel5 Button when an End User provides it to us, and never
use that information on the Travel5 Platform for delivering targeted
advertising. When you, an End User, send an email using an Travel5 Button we
use your email address, the email address of the person (or people) to whom you
are sending the content and allow you the opportunity to write an accompanying
message. We use this Personal Information only to send the email on your behalf
and for no other purpose, and it is not merged or otherwise combined with any
of the Non-Personally Identifiable Information that we collect. This Personal
Information will be available to the people to whom you send or share content
via the Travel5 Button, so please be careful.
·
Non-Personally Identifiable Information — We collect Non-Personally
Identifiable Information via the Travel5 Button for use on the Travel5
Platform. For example, when you visit a web page that contains one of our Travel5
Buttons, our server logs collect your Internet Protocol address, browser type,
browser language, the date and time you visited that web page, and (if you came
to a web page where an Travel5 Button is enabled via a search engine such as
Google), the web search that landed you on that web page. We also collect
information regarding how often you share content with others using the Travel5
platform. We use this information to help us build commercially viable data
segments (e.g., travel enthusiast, sports fan) for online ad targeting in order
to help make the ads you see on many of the websites you visit more relevant to
your interests, and for ad delivery and reporting purposes. For information
regarding how we use this information to help deliver more relevant advertising
please see the section below entitled "Targeted Advertising and
Choices." We also set Cookies and web beacons on web pages where our Travel5
Buttons are enabled, and allow our partners to set Cookies and web beacons that
are subject to those partners' privacy statements. We also use this information
to customize the Travel5 Button to your usage patterns. For example, if you
share to Facebook, we make sure that Facebook icon is at the top of your Travel5
Button menu.
(b) Information Sharing.
We generally don't share Personal
Information collected via the Travel5 Button except as specifically directed by
the End User in order to share a piece of content via email or via social
networking platform. We share information collected via the Travel5 Button with
other companies or individuals as follows:
·
We share Non-Personally Identifiable Information with
partners and the website Publishers who have the Travel5 Button enabled on
their websites for analytics and other business purposes. For example, we
provide our publishers with statistics on sharing trends, and the top content
segments shared (e.g., A blog post analyzing a speech given by the President),
so that Publishers can understand how End Users are sharing their content, as
well as how much web traffic such sharing brings back to the Publisher's site.
Publishers may use this information to tailor content and advertising on
individual publisher sites. Publishers can use filters to refine the data by
domain, time period, geography, and other options.
·
We share any information with third parties if we have
a good faith belief that disclosure of such information is reasonably necessary
to (a) satisfy applicable law, regulation, legal process or an enforceable
governmental request, (b) enforce the applicable Terms of Service, including
investigation of potential violations thereof, (c) detect, prevent, or
otherwise address fraud, security or technical issues, or (d) protect against
harm to the rights, property or safety of Travel5, its End Users or the public
as required or permitted by law.
·
We share information with our subsidiaries, joint
ventures, or other companies under common control with us, in which case we
will require them to honor this policy. Additionally, in the event we go
through a business transition such as a merger, acquisition by another company,
or sale of all or a portion of our assets, we expect that any and all
information that we have will be among the assets transferred.
·
In addition, we may aggregate your Non-Personally
Identifiable Information with the Non-Personally Identifiable Information of
others and share that aggregated information with third parties without
restriction.
(c) Targeted Advertising and Choices
We don't use Personal Information to
serve targeted advertising via the Platform. Most of our Services are available
to End Users and Publishers at no cost. To support our Services, we license or
otherwise provide the Non-Personally Identifiable Information we collect via
many of the Travel5 Buttons enabled on Publisher websites and use that
information via the Platform to deliver or enable the delivery of advertising
that is customized to End User interests. We also set Cookies and web beacons
on web pages where our Travel5 Buttons are enabled to help us with online ad
targeting and to provide analytics to our website Publishers.
If you prefer that we do not collect
Non-Personally Identifiable Information about your website visits for the
purpose of delivering targeted advertising, you may opt out.
When you opt out, we will place an
opt-out cookie on your computer. The opt-out cookie tells us not to use your
information for delivering relevant online advertisements. Please note that if
you block cookies, our opt-out process may not function properly. Please also
note that if you delete, block, or otherwise restrict cookies, or if you use a
different computer or Internet browser, you will need to renew your opt-out
choice.
We also allow our partners to set
cookies and web beacons via certain Travel5 Buttons. Some of them are also
members of the Network Advertising Initiative (NAI). For more information,
please visit the NAI website at Network
Advertising Initiative.
(d) Health and Finance Data
We abide by the NAI and DAA Codes in
the US, EU and Canada, which restrict the collection and use of health and
finance data for online advertising. We do not use or share with third parties
any health-related or finance-related data that we consider sensitive. We
recognize that others may have differing views regarding which categories of
health and finance data are sensitive.
The types of health information we
utilize may be found by clicking here.
The types of finance information we utilize may be found by clicking here.
While we do not consider any of these data categories to be sensitive, it is
important to provide this transparency to help you have a better idea of what
data might be collected by us, so that you can make informed decisions.
In addition to the Travel5 Buttons
that appear on Publisher websites, we offer toolbars (our "Toolbar")
that can be downloaded by End Users, installed as a plug-in on the End User's
browser and used to share content from virtually any website. We do not target
advertising based upon information collected through any Toolbar. When an End
User uses the Toolbar, we collect Non-Personally Identifiable Information about
the End User's usage of the Toolbar, including whether the End User downloads
and installs the Toolbar, how and when the End User utilizes the Toolbar and
when the End User uninstalls the Toolbar. We use this information to understand
how the Toolbar is being used, and to help us ensure that our Toolbars are
functioning properly. We also collect but do not store the keyword searches
that each End User executes via the Toolbar. We collect the keyword searches in
order to provide them to the search engine indicated in the Toolbar (e.g.,
Yahoo!), and such search engine's use of the keywords is governed by its own
privacy policy.
Information Security, Retention, and Data Integrity
We take reasonable security measures
to protect against unauthorized access to or unauthorized alteration,
disclosure or destruction of data. These include firewalls and encryption,
internal reviews of our data collection, storage and processing practices and
security measures, as well as physical security measures to guard against
unauthorized access to systems.
We restrict access to Personal
Information to Travel5 employees, contractors and agents who need to know that
information in order to operate, develop or improve our Services. These
individuals are bound by confidentiality obligations and may be subject to
discipline, including termination, if they fail to meet these obligations.
However, we are unable to guarantee that the security measures we take will not
be penetrated or compromised or that your information will remain secure under
all circumstances.
We retain Non-Personally
Identifiable Information on the Platform for up to five years. Any search
strings we collect via the Travel5 Button are converted into Non-Personally
Identifiable Information, and the raw search data is stored on our server logs
for up to 90 days. Aggregate reports generated from such information may be
kept longer.
Travel5 processes information in a
way that is compatible with and relevant for the purpose for which it was
collected.
Access
Travel5 will allow an individual
access to their Personal Information to the extent it is available and allow
the individual to correct, amend or delete inaccurate information, except where
the burden or expense of providing access would be disproportionate to the
risks to the privacy of the individual in the case in question or where the
rights of persons other than the individual would be violated. If you have
provided Personal Information when registering for our Site, you may access and
modify that information at any time by visiting your account settings (http://travel5.com/settings).
If you'd like us to update, correct, delete, or deactivate any other Personal
Information that you have provided to us, please send your request to us at travel5-info@Travel5.com
and we will process your request within a reasonable period of time after
receipt.
Children
We do not knowingly collect or
maintain Personal Information from individuals who are under 13 years of age,
and no part of our Site or Services are designed to attract people under the
age of 13. Protecting the privacy of children is very important to us. If we
obtain knowledge that a user is under the age of 13, we will take steps to
remove that user's Personal Information from our databases.
Links to Other Sites
Our Site and Services contain links
to, and allow you to share content on, third party websites and services. The
fact that we link to a website or service or allow you to share content on them
is not an endorsement, authorization or representation that we are affiliated
with that third party, nor is it an endorsement of their privacy or information
security policies or practices. This privacy policy applies only as provided in
the scope section
above. Other websites and services follow different rules regarding the use or
disclosure of the personal information. We encourage you to read the privacy
policies or statements of the other websites you visit.
International Users
The Site and Services are hosted in
the United States. If you access the Site or Services from the European Union,
Asia, or any other region with laws or regulations governing personal data
collection, use, and disclosure that differ from United States laws, please be
advised that through your continued use of the Site or Services, you are
transferring your Personal Information to the United States and you consent to
that transfer. Additionally, you understand that your Personal Information may
be processed in countries (including the United States) where laws regarding
processing Personal Information may be less stringent than in your country.
Enforcement, Questions, and Complaints
Travel5 regularly reviews its
compliance with this Privacy Policy. In compliance with the U.S.-EU and
U.S-Swiss Safe Harbor Principles, Travel5 commits to resolve complaints about
your privacy and our collection or use of your Personal Information. European
Union and Swiss citizens and others with inquiries or complaints regarding this
privacy policy should first contact Travel5 by emailing us at travel5-info@Travel5.com
or writing to us at:
Privacy Office
c/o Travel5
1595 Spring Hill Road, Suite 300
Vienna, VA 22182
USA
c/o Travel5
1595 Spring Hill Road, Suite 300
Vienna, VA 22182
USA
Travel5 has further committed to
refer unresolved privacy complaints under the Safe Harbor Principles to an
independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by
the Council of Better Business Bureaus. If you do not receive timely
acknowledgment of your complaint, or if the Privacy Officer at Travel5 does not
satisfactorily address your complaint, please visit the BBB EU SAFE HARBOR web
site at www.bbb.org/us/safe-harbor-complaints for more information and to file
a complaint.
Changes to this Privacy Policy
Please note that this Privacy Policy
may change from time to time. If you have any additional questions or concerns
about this Privacy Policy, please feel free to contact us any time through this
Site or by writing to us at the address set forth above.
Last Updated: July 7, 2014
