Privacy Policy

The Triparound Inc. (“Triparound” or “we” or “us”) Team values your trust and makes it a high priority to ensure the security and confidentiality of the personal information you provide to us. Below you will find our Privacy Policy, which describes the types of information we may collect from you or that you may provide to us when you book travel services using our platform, such as spa treatments, tours, sporting activities, restaurant reservations, transfers, rentals and other similar tourism/travel activities (each, an “Experience”), either directly through www.triparound.com, or through your hotel, travel agent, activity provider or other types of travel professionals (collectively, the “Services”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. Note that in some cases this Privacy Policy may be supplemented or replaced by the privacy policy of your hotel operator or travel professional who provides you access to the Services or who accesses the Services on your behalf. Please contact your hotel operator or travel professional for more information or you may contact us through the Contact Information below to determine if this Privacy Policy has been supplemented or replaced.

This policy applies to information we collect on our Services, whether entered directly by you or by a concierge or other hotel operator or travel professional.

We encourage you to read the policy to learn about our privacy practices so you can better understand what we collect from you, why we collect it and your rights. Remember, by visiting our website or using our Services, you are accepting our practices. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

Triparound always complies with the applicable privacy and data protection laws and with the provisions of General Regulation on Data Protection of the EU 2016/679 as amended.

Data Controller, Data Protection Officer, and Representative

Unless otherwise agreed upon with your hotel operator or other travel professional, Triparound is the data controller of your Personal Data. Please contact your hotel operator or other travel professional, or contact us through the “Contact Information” below if you have any questions regarding if Triparound is the data controller of your Personal Data or if your hotel operator or travel professional may be the controller.

What information do we collect? How do we collect this information?

We collect several types of information from and about the users of our Services (“Personal Data”):

– by which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline;

– such as health conditions, level of expertise relating to an Experience, and dietary restrictions, as required by Triparound and our partners in order to provide the best possible quality of service;

– that is about you but individually does not identify you, such as traffic data, location data, logs, referring/exit pages, date and time of your visit to our Services, error information, clickstream data, and other communication data and the resources that you access and use on the Services, and travel interests; and/or

– about your internet connection, the equipment you use to access our Services and usage details.

We collect this information directly from you when provided to us; automatically as you navigate through the Services; and from third parties, for example our business partners, including hotel operators, travel professionals, and Experience operators/providers.

Please note that our collection and use of information may be limited by our agreement with hotel operators, travel professionals, and Experience operators/providers and in some cases, we may not be able to provide you with full use of the Services.

How do we use your information?

We use information that we collect about you or that you provide to us, including any Personal Data:

– to present our Services and its contents to you;

– to provide you with information that you request from us;

– to book an Experience with an Experience provider;

– to provide information about your interests to hotel operators and travel professionals so they may offer you new Experiences while using their services;

– to fulfill any other purpose for which you provide them;

– to carry out our obligations and enforce our rights arising from any contracts entered into between you, travel professionals and us;

– to notify you about changes to our Services or any Experiences offered through them;

– in any other way we may describe when you provide the information; and

– for any other purpose, with your consent.

We may also collect and store information about you that we receive from other sources to, among other things, enable us to verify, update and correct the information contained in our databases, prevent fraud, provide services to our other clients, and to better customize your experience on our site.

We regularly review our information and erase or anonymize personal data when we no longer need them. We clearly identify any personal data that we need to keep for statistical purposes.

Note: If at any time you would like to unsubscribe from receiving marketing emails, you can contact us at legal@triparound.com.

Lawful basis for processing your personal data

If you are in the European Union, the processing of your Personal Data is lawful only if it is permitted under the applicable data protection laws. We have a lawful basis for each of your processing activities (except when an exception applies as described below):

– Consent. By using our Services, you consent to our collection, use and sharing of your Personal Data as described in this Privacy Policy.

– Legitimate interest. We will process your Personal Data as necessary for our legitimate interests. Our legitimate interests are balanced against your rights and freedoms and we do not process your Personal Data if your rights and freedoms outweigh our legitimate interests. Our legitimate interests are to: facilitate communication between Triparound and you; detect and correct bugs and to improve our Services; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other crime; promote and market our business; check your credit and perform risk assessments; facilitate the personalization of your stay with a hotel operator or other travel plans; provide you with information about Experiences that you may be interested in.

– As required by law. We may also process your Personal Data when we are required or permitted to by law.

Special Categories of Information

Triparound may collect and process special categories of personal data, specifically personal data concerning health, such as health conditions and dietary restrictions, only if the data

subject has given explicit consent to the processing of those personal data for one or more specified purposes, as set forth in this Privacy Policy.

Automated Decision Making

Triparound may in some cases use automated decision-making that enhances the quality of service we and our partners offer to you, including profiling, in compliance with what is legally required.

Triparound shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on Triparound’s part, to express his or her view and to contest the decision.

Disclosure of your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Data that we collect, or you provide to us, as described in this Privacy Policy:

– to our subsidiaries and affiliates;

– to providers or operators of Experiences;

– to our business partners, including hotel operators and travel professionals;

– to contractors, service providers, and other third parties we use to support our business. These entities provide IT and infrastructure support services, and payment processing services;

– to a potential or actual buyer or other successor in the event of a planned or actual merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Triparound, Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Triparound, Inc. about our Service’s users is among the assets transferred;

– to market our products and services and other Experiences to you if you have consented to/not opted out of these disclosures. For more information, see Choices About How We Use and Disclose Your Information;

– to fulfill the purpose for which you provide them. For example, if you give us your contact information or special requests when you book an Experience, we will transmit that information to the provider(s) of the Experience you are booking;

– for any other purpose disclosed by us when you provide the information; and

– with your consent.

We may also disclose your Personal Data:

– to comply with any court order, law, or legal process, including to respond to any government or regulatory request; and

– if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Triparound, Inc., our customers, an Experience operator, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Do we disclose any information to outside parties? Choices About How We Use and Disclose your Information

We do not control the collection and use of your information collected by third parties as described above in Disclosure of Your Information.

In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We provide you control over your Personal Data on:

– Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not functioning properly.

How do we use cookies?

Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow) that enables the sites or service providers’ systems to recognize your browser and capture and remember certain information.

We use cookies to help us remember and process your bookings, understand and save your preferences for future visits, keep track of advertisements, market our services, and compile data about site traffic and site interaction so that we can offer better site experience and tools in the future. We may contract with third-party service providers to assist us in better understanding our site visitors. These service providers are not permitted to use any personally identifiable information collected on our behalf except to help us conduct, improve or market our business.

Exercising Access, Data Portability, Deletion, and Opt-out Rights

Applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Data.

– Access and Update. When we act as the controller for your Personal Data, you can notify us through the Contact Information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

– Restrictions. You have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing but we have retained it as permitted by law.

– Portability. To the extent the Personal Data you provide Triparound is processed based on your consent and that we process it through automated means, you have the right to request that we provide you with a copy of, or access to, all or part of such Personal Data in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Data to another controller, when technically feasible.

– Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time by reaching us through the Contact Information below. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data.

– Right to be Forgotten. You have the right to request that we delete all of your Personal Data. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies.

– Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.

– How You May Exercise Your Rights. When we are the controller of your Personal Data, you may exercise any of the above rights by contacting us through any of the methods listed under Contact Information below. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Data, you may be charged a fee subject to a maximum set by applicable law.

– You must contact your hotel operator or travel professional when one of them is the controller of your Personal Data. In these cases, we are not permitted to permit you to exercise any of the above rights without approval from the controller of your Personal Data. If you contact us to exercise any of the above rights and we are not the controller of your Personal Data, we will provide you with the identity of the controller.

Data Security

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to our Services confidential.

Consent to Processing of Personal Data in Countries Outside the European Economic Area

We may process your Personal Data outside of your home country, including to the United States. We only do this when we are legally permitted to do so and when we have appropriate safeguards in place to protect your Personal Data. By using our Services, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data that you provide directly to us on our Services.

To ensure your Personal Data are treated in accordance with this Privacy Policy, when we transfer your information outside of the EEA, Triparound uses Data Protection Agreements between Triparound and all other recipients of your data that include, where applicable, the Standard Contractual Clauses adopted by the European Commission (the “Standard Contractual Clauses”). The European Commission has determined that the transfer of Personal Data pursuant to the Standard Contractual Clauses provides for an adequate level of protection of your Personal Data. Under these Standard Contractual Clauses, you have the same rights as if your data were not transferred to such third party. You may request a copy of the Data Protection Agreement by contacting us through the Contact Information below.

Data Retention Periods

We regularly review our information and erase or anonymize personal data when we no longer need them. We clearly identify any personal data that we need to keep for statistical purposes.

Non-Discrimination

We will not discriminate against you for exercising any of your GDPR rights. Unless permitted by the GDPR, we will not:

– Deny you goods or services.

– Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

– Provide you a different level or quality of goods or services.

– Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to our Privacy Policy

We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on our website or services home page. You are responsible for periodically visiting our Services and this Privacy Policy to check for any changes.

This policy was last modified on March 24, 2022.

Contact Information

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you may contact us at the contact information below or through the “Contact” page on our services.

To Contact Triparound in the United States

Triparound, Inc.

555 Bryant St #558

Palo Alto, CA 94301, USA

(+1) 650 30 40 501

legal@triparound.com

To Contact Triparound in the European Union

Triparound IKE

Agiou Konstantinou, 59-61

Maroussi, 151 24, Greece

(+30) 210 700 6315

legal@triparound.com