The Website is designed as an invitation-only website providing members with essential news and information on the latest opening and launches, travel recommendations and details of exclusive privileges and events. Some content and facilities of the Website are made available to users who register with us for, and to whom we grant, access via an account (“Members”).
1. What information do we collect from you?
2. For what purposes do we collect information from you?
3. Who is collecting your information and with whom do we share it?
4. Where is your information stored?
5. How can you update or rquest to see your personal information?
6. What are your choices regarding collection, use, and distribution of your information?
7. What security precautions are in place to protect against loss, misuse, or alteration of your information?
9. You should carefully review privacy policies of any third-party sites accessible from the Website
10. Contacting us about about privacy questions or concerns
1. What information do we collect from you and why?
We may collect and keep the following types of information:
We also monitor usage of the Website by users (including Members) and collect and process statistical information on a non-personally identifiable basis about users, their profile, preferences and use of the Website. This includes the information which is otherwise Personal Information except that it is processed on an anonymous basis and cannot be linked to specific individuals or entities.
On an aggregated basis, we also collect anonymous data related to the pages, downloads and other content that is sampled, clicked on, streamed, searched for, transferred from and downloaded (“Profile Data”).
Our main purposes in collecting and holding Personal Information are:
(i) to verify that each Member is a suitable user for the Website and/or Member and to ensure that only users to whom the Website is aimed are using the Website;
(ii) to monitor and maintain the security of the Website and to protect the Website and other users or Members against abuses;
(iii) to meet our legal and regulatory obligations, to prevent the Website from being used for fraud and other unlawful activities;
(iv) to enable us to communicate with you; and
(v) to enable us to build up a picture of your preferences, the types of products, services, news, services and facilities which may be of interest to you and create a more personalised online experience for you, to enhance your experience and to tailor the Website to your preferences and usage.
We may also share your Personal Information with third parties who provide services to us. Those third parties include authorised contractors, temporary employees and consultants and other companies working with us (collectively, “agents”). We will require our agents not to disclose or use your Personal Information for purposes other than to provide services to you or to HappyHolidayTime and to process your Personal Information only in accordance with our instructions.
We may also share your Personal Information with third party suppliers of goods and services with whom you communicate through the Website (“Product Providers”) in order to allow these Product Providers to keep the records they are required to keep in order to comply with their legal and regulatory duties. Please refer to the section “Who is collecting your information and with whom do we share your information” in relation to other third parties who may collect information from you or with whom we may share your Personal Information.
We reserve the right to use and share Profile Data at our discretion.
We may use Profile Data for any purpose but we intend to use it primarily to build a picture of the aggregate preferences, types of products, services, news and information which may be of interest to uers, to process and make such information available on the Website, to advertisers or to any other person whether publicly or in confidence; to help formulate our marketing and business strategy, to help to improve the Website, for analysing and researching our business, customers and products; and to gather information about users’ usage of the Website and in order to enhance users’ experience by tailoring the Website to meet users’ needs.
Online Surveys and Polling
In order to improve our services, we may from time to time ask you to voluntarily complete surveys, which may be collected by an independent third party. Individual survey answers are confidential, although Profile Data is collected and disclosed to third parties. If you do not wish to participate in a survey, simply decline to participate when asked.
Newsletters, Promotional E-mails and Personalised Online Advertisements
We may wish to contact you by e-mail and/or through the messaging system(s) on the Website to offer information, promote products and services, offer newsletters and other promotional communications.
We may ask you to indicate your consent to receiving unsolicited promotional communications from us and you may at any time advise us that you do not wish to receive such promotional communications.
Contact Information and Third Party Data
If you contact an HappyHolidayTime representative by telephone, e-mail or letter, we may keep a record of your correspondence or comments.
If you report a problem with the Website, we may collect such information in a file specific to you. If you contact us through our feedback area or by calling one of our customer service representatives, we may ask for your name, e-mail address and/or other contact information in order to send you a reply.
If other users or third parties send us correspondence about your activities or purchases on the Website, we may keep the information in a file specific to you.
We may display advertisements on the Website.
By knowing a little about you, HappyHolidayTime will be able to deliver more relevant advertisements and content to you in the form of targeted banners and promotions. For example, advertisers give us an advertisement and tell us the type of audience they want to reach. We may take the advertisement and include it in a promotional e-mail to Members. We may also have third-party advertising servers display advertisements linked to certain search terms that you have entered, or to certain pages that you are viewing. In this process, advertisers never have access to your Personal Information.
HappyHolidayTime will give you the opportunity to stop such forms of personalised advertising.
We also track Members’ traffic patterns throughout their online session, including which pages, information and advertisements a Member views while using the Website.
We use your IP address to diagnose problems with our servers, software, to administer the Website and to gather demographic information.
Cookies and Action Tags/Web Beacons
To find out what cookies, action tags or web beacons are and how they are used, please see section 8 below.
Other Parties Generally
We may provide Profile Data about users’ traffic patterns, and related site information to third parties, but these statistics do not include any Personal Information that may be linked to specific Members.
We may disclose Personal Information to third parties if we believe that such disclosure is reasonably necessary to enforce or apply any applicable terms and conditions or to protect the rights, property, and safety of HappyHolidayTime, the Website, other Members, users or Product Providers or others. We may also share your Personal Information with third parties who provide services to us in connection with our supply of services to you.
Marketing Partners, Co-Branded Services
We may run promotions for third-parties such as other service providers whose websites you may also visit. In some of those promotions, a window or frame containing the service provider’s website may appear.
Links to Third-Party Sites
Advertisement & Content Servers, Advertisers, Image Servers and Website Analysis Agents
We may use Advertisement & Content Servers, Advertisers, Image Servers and Website Analysis agents to serve advertisements and graphics that Members see on the Website more quickly, send promotional e-mails and help manage our internet business and marketing by measuring the effectiveness of our advertising and how Members use the Website.
These third parties use their cookies’ identification numbers and internal web site tracking features to serve advertisements on the Website and to collect aggregated information to create statistics about our Members, traffic patterns, and related site information. To find out more information about Advertisement & Content Servers, Advertisers, Image Servers and Website Analysis agents see section 8 below.
Legal Proceedings and Law Enforcement
Occasionally HappyHolidayTime may be asked by regulators, law enforcement or judicial authorities to provide Personal Information on Members. We will disclose such information upon receipt of a court order, subpoena, or request from a regulatory or law enforcement authority, and we may do so without prior notice to you. HappyHolidayTime will fully co-operate with law enforcement agencies to identify those who use the Website for illegal activities. We reserve the right to report to law enforcement agencies any activities that we believe to be unlawful.
Sale of the business
We reserve the right to disclose and transfer your Personal Information in the event that HappyHolidayTime or the business activities relating to the operation of the Website are sold or transferred, in whole or in part to another person or entity.
The Personal Information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA“). It may also be processed by staff operating outside the EEA who work for us or any of our agents, suppliers or Product Providers located outside the EEA.
Such staff and third parties may be engaged in, among other things, the provision of our services to Members. By submitting your Personal Information, you agree to this transfer, storing and processing.
We encourage you to promptly update your Personal Information if it changes. You may ask to have the information on your account deleted or removed; however, because we “back up” the data stored on our systems, as a security measure, such prior information cannot be completely removed from our databases. As a result, although efforts will be made to ensure that data is not kept for longer than is necessary, you should not expect that all of your Personal Information will be completely removed from our backed-up databases.
Subject to some exceptions, you may upon written request and payment of a fee, receive from us a copy of any of your Personal Information we hold. You should contact us at email@example.com to make such a request or if at any time you want to change your preferences about how we use or share Personal Information for marketing purposes. Please contact us at firstname.lastname@example.org with any changes to your personal details.
We will not send you, and we shall procure that third parties to whom we provide your Personal Information do not send you, e-mails or other promotional material in electronic form (including through the Website messaging system(s)) if you have not “opted-in” to that service (unless the e-mail or other promotion relates to products or services similar to those you ordered from us).
You may advise us that you do not wish to receive such e-mails or promotional materials from us by following the “unsubscribe instructions” in any e-mail, or promotional material you receive from us, or by sending an e-mail to email@example.com. After doing so, if you have opted out of receiving all promotional e-mails or material you will not receive future promotional e-mails or material from us, unless you open a new account, or otherwise subsequently sign up to receive, such e-mails or material.
We are committed to ensuring appropriate security for your Personal Information as required by relevant data protection legislation. Although absolute security cannot be guaranteed, the Website has in place measures to protect your Personal Information. So that you can send your details to us with confidence, all the information above is transmitted using SSL encryption.
Your Personal Information is kept on password protected, limited access servers. Wherever possible and applicable, HappyHolidayTime servers reside behind a corporate firewall that maintains controls on access to the system from both our internal network and the Internet. Access to your Personal Information is allowed only to our staff and third parties that require such access and we require our staff and such third parties to keep that information in confidence and to keep it secure. We require any third party that receives your Personal Information to maintain adequate technical and organisational measures to ensure the security of the information.
A cookie is a small data text file, which a website stores on your computer’s hard drive (if your Web browser permits) that can later be retrieved to identify you to the website operator. Cookies enable the sender to identify, authenticate and maintain information about the way visitors use websites.
a) to retain information for the duration of your visit so you can conveniently move between pages on the Website;
c) if you register your details with us, to gather and store information about how you use the Website each time you visit. This helps us build on ongoing picture of your needs and preferences so that we can tailor future visits to the Website according to your particular usage.
Cookies enable us to make your use of the Website easier and bring you enhanced Website functions and services, enable the website to run more smoothly and help us to maintain a secure website.
We use the following types of cookie on the Website:
a) Advertisement Server and Content Server Cookies: We may use an outside ad serving company or content server to display banner advertisements and other information on the Website or to serve promotional e-mails or personalised on-line advertisements. As part of their service, they place a separate cookie on your computer. Except for the entity that serves our promotional e-mails and personalised on-line advertisements, HappyHolidayTime does not provide third-party advertisement servers with any of your Personal Information. HappyHolidayTime and its third party advertisement servers do collect and use Profile Data which may include your computer’s IP address, browser type, the URLs from which you came, referring site’s domain types (e.g., .com), operating system, the country, the server your computer is logged onto, where the servers that your computer is logged onto is located, the pages of the Website and products that Members viewed during their visit, where an advertisement was placed on a specific Website page, the time and date particular advertisements were served, the post code associated with your server and whether you responded to a particular advertisement, and a receipt identifier.
b) Image Server Cookies: As part of the advertisement-serving process, a third party may serve graphics upon the Website. In order to customise their service, they may also place a cookie upon your computer.
c) Website Analysis Agent Cookies: We may use a third party to analyse what our visitors find to be most interesting on the Website. To do that, they will place a cookie on your computer with a randomly assigned unique number in order to track the pages you view on the Website, along with other Profile Data.
d) Action Tags, Web Beacons and other Data Collection Methods: An action tag or a web-beacon (also known as a clear gif or a pixel tag) is a method used to track responses or actions by customers who view certain advertisements or other information on a website. Action tags are 1×1 pixel images embedded in a website page that are used to transparently collect information. Our advertisement server, content servers, affiliate program manager and website analysis agents may use action tags to count the number of times that visitors click on a particular banner ad or visit the pages of the Website and to provide information about what products are viewed. Without collecting any personal Information, they use that data to tell us (and other advertisers) which advertisements are the most effective on particular sites.
e) E-mail Distributor’s Use of Action Tags: Our third-party e-mail distributor may also use action tags. They may, for example, keep track of when a promotional e-mail is opened and provide HappyHolidayTime with ongoing aggregated reports of how many customers have responded. We share with them anonymous or aggregated Profile Data about Members who have received a promotional e-mail or other targeted promotional campaign. They use the information for the purpose of targeting future campaigns and upgrading Member information used in reporting statistics. For this purpose, we and our third-party e-mail distributor note some of the pages you visit on the Website through the use of action tags.