"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.
"Personally Identifiable Information" or "PII" means any recorded information about specific individual whose identity may be inferred from the information. This information includes, for example, name, email and mailing address, phone number, account and billing information, and other information provided by a visitor to our website or incidental to providing products and services to you.
"Website" means www.JoinAvoya.com, as well as its child sites and web pages, and any domestic or international–owned or managed website of Avoya Travel that may be accessed through it.
If you do not agree with these terms, do not provide any PII to Avoya Travel. If you choose to refuse or withdraw your consent, we may not be able to provide you with services normally offered by Avoya Travel.
Avoya Travel does not sell or market products to Minors. Minors are not eligible to register with, use or purchase services via www.JoinAvoya.com. We do not knowingly collect PII from any Minor, and will not deliberately use such information. If you are under 18, you may use www.JoinAvoya.com only with the involvement of a parent or guardian.
III. WHAT PERSONALLY IDENTIFIABLE INFORMATION WE COLLECT
Avoya Travel only collects PII that you voluntarily provide to us, or that is incidental to your use of our services. The information we learn 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.
- Automatic 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. HOW WE USE PERSONALLY IDENTIFIABLE INFORMATION
Avoya Travel uses your PII for the purposes of responding to and processing your requests for Avoya Travel products and services:
- To collect, record and verify the information, questions and answers, documentation and setup needed for your independent travel business to qualify as an Independent Agency in the Avoya Travel Network and to use our resources and technology and to communicate with you about this.
- 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 recommendations or other best practices;
- 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 requests 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. Any such information is kept and maintained in accordance with Section VI below.
V. TO WHOM WE DISCLOSE PERSONALLY IDENTIFIABLE INFORMATION
Information about our customers is an important part of our business, and we are not in the business of selling it to others. Avoya Travel will only share your PII with our authorized service providers that perform services or functions on our behalf, as required by law, or as described below.
From time to time, we may Disclose PII as follows:
- To those travel service providers or others with which you have or may make arrangements through via our website(s) and other technology or for products and services which you have authorized. For example, associated cruise lines, tour operators, vacation packages, wholesalers, Independent Agencies in the Avoya Travel Network, travel agents and agencies, technology companies, hotel or ground transport, attraction and travel insurance companies.
- 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 PII needed to perform their functions.
- 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 affect 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.
- Where the information is public.
- To our insurers and to regulatory agencies.
VI. HOW WE RETAIN PERSONALLY IDENTIFIABLE INFORMATION
We will retain your PII 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 PII will be stored in secured locations and on servers controlled by Avoya Travel, located either at our offices or at the offices of service providers.
VII. HOW YOU CAN CONTROL THE USE OF YOUR INFORMATION
You can always choose not to provide PII. Guest browsing is available on the www.JoinAvoya.com website, even though PII might be needed to make a purchase or to take advantage of certain Avoya Travel services.
Avoya Travel provides you with choice and control over the collection and use of your PII. 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 [email protected] 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
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.
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
If you wish to prevent your data from being used by Google Analytics, you may use the opt–out browser add on 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_nonppii.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
XI. HOW WE PROTECT YOUR INFORMATION
To protect the confidentiality of your PII, 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 PII.
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 PII made in this privacy statement.
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 PII 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 PII from our records, as described above.
XIV. CONTACT INFORMATION
XV. YOUR CALIFORNIA PRIVACY RIGHTS
Under California Law, California residents 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. To request the above information, please contact us by contacting our Chief Privacy Officer via our Customer Care department via e–mail: [email protected]
We will respond to such written 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.