BookBetter (the “Company”, “we”, “us”, or “our”) owns and operates the Site (as defined below) which makes available an online marketplace (“Marketplace”) that provides users with the opportunity to purchase travel, merchandise and experiences. The Marketplace is proprietary to the Company.
The Company is committed to protecting and respecting your privacy. This privacy policy (this “Policy”) sets out how we collect and process personal information about you when you visit (a) the website located at www.bookbetter.com and those other websites owned and/or controlled by the Company (collectively, the “Company Websites”), (b) those digital properties (including, without limitation, apps) that provide registered users access to the Company Websites (including the Marketplace) (the “Company Digital Properties”), (c) any successor Company Websites or Company Digital Properties and all other web pages interconnected with, and/or forming a part of, such Company Websites and Company Digital Properties, including, without limitation, the home page and all other sub-pages under the same top-level domain name, and (d) all content and all services available thereon, including, without limitation, the Marketplace (collectively, the “Site”), when you sign up for or use the Marketplace, or when you otherwise do business or make contact with us and/or other users of the Marketplace (collectively, the “Services”).
01Updates to this Privacy Policy
We will update this Policy when necessary to reflect changes to our Services. When we post changes to this Policy, we will revise the “last updated” date at the top of the Policy. If there are material changes to the Policy or in how the Company will use your personal data, we will use reasonable efforts to notify you either by prominently posting a notice of such changes before they take effect or by sending you a notification directly. We encourage you to periodically review this Policy to learn how the Company is protecting your information.
02What Information Do We Collect?
The Company collects personal information when you interact with our Services. Personal information is any information that identifies or makes an individual identifiable. The definition of personal information (used interchangeably in this Policy with the term “personal data”) depends on the applicable law based on your physical location. Only the definition that applies to your physical location will apply to you under this Policy. You provide some of this data to us directly, such as when you register to use the Marketplace, subscribe to a newsletter, respond to a survey, make an enquiry through our website, contact us for support, or contact us as a prospective user, vendor, supplier, or consultant. We get some of your data by recording how you interact with the Marketplace by, for example, using technologies like cookies. We also obtain and process data in the context of making our Services available to you. Additionally, we collect data to enable us to operate the Services effectively, and to provide you with the best experience on the Site and Marketplace.
You have choices about the data we collect. When you are asked to provide personal data, you may decline. But if you choose not to provide data that is necessary to enable us to make the Marketplace and the Services available to you, you may not be able to sign up for or use the Marketplace and/or the Services. The data we collect depends on the context of your interactions with us and the other uses of the Services, and the choices you make (including your privacy settings). The data we collect can include the following: information you voluntarily provide us, information from third parties, and information collected automatically.
(a) Information you voluntarily provide to us
The personal information we collect on or through our Services may include:
- Account registration: information relating to the creation of an account on the Services, such as first and last name, email address, telephone number, and/or a unique individual password.
- Email: we may collect your email address.
- Form submissions: information that you provide by filling in forms that we make available. This includes when making purchases via the Marketplace or requesting information or assistance.
- Newsletter sign-ups: information relating to our newsletter subscription page, including name and email address.
- Technical support: information you provide when you report a problem with our Services or otherwise communicate with us by email, our Site, by telephone, in writing or through other means.
- Customer service: records and copies of your correspondence (including email addresses), if you contact us by telephone or in writing or via chat, including for customer support.
- Promotions and feedback: information relating to your participation in a promotion, or survey that we may ask you to complete for research purposes.
- Payment information: payment card, transaction or financial account information, if you make a purchase online or sign up via our order forms.
- Device permissions: information relating to your use of features of our Services that may ask you to grant us access to location information, photos, microphone, video camera, or media on your computer or mobile device.
Please note: when communicating with us by email or through forms on our Services, we ask that you do not send us any sensitive information pertaining to yourself. The Company does not collect or store sensitive information or special categories of information.
(b) Information from third parties
When you interact with our Services or accounts on a social media platform, we may collect the personal information that you or the platform make available to us on that page or account, including your social media account ID and/or user name associated with that social media service, your profile picture, email address, friends list or information about the people and groups you are connected to and how you interact with them, and any information you have made public in connection with that social media service.
The information we obtain depends on your privacy settings on the applicable social media service; we will comply with the privacy policies of the social media platform and we will only collect and store such personal information that we are permitted to collect by those social media platforms. When you access our Services through social media channels or when you connect our Services to social media services, you are authorizing us to collect, store, and use such information and content in accordance with this Policy.
(c) Information collected automatically
As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
- Information about your use of the Services: when you browse our Site or Marketplace, our systems automatically collect information such as your web request, Internet Protocol (“IP”) address, browser type, browser language, domain names, referring and exit pages and URLs, platform type, pages viewed and the order of these page views, the amount of time spent on particular pages, and the date and time of your request.
- Device information: if you access the Services through a mobile device (e.g., a smart phone or tablet), we may be able to identify the general location of your mobile device, your mobile device’s brand, model, operating system, resolution, screen size, system version, mobile network information, and your mobile device’s advertising ID.
- Performance data: information about your preferences to make your use of the Services more productive, via the use of Cookies or similar tracking technologies. For more information, please see Section 5.
03What Do We Use Your Information For?
We use the data we collect to operate our business and to make the Marketplace and the Services available to you. This includes using the data to improve our Marketplace and the Services and to personalize your experiences. We may also use the data to communicate with you to, among other things, inform you about your account, provide security updates, and give you information about the Marketplace and/or Services. We may also use the data to manage your email subscriptions, improve the relevance and security of our website, respond to user enquiries, and send you periodic marketing communications about our Marketplace and/or Services.
The Company will only use your personal information as described in this Policy or as disclosed to you prior to such processing taking place. The purposes for which we may use your personal information include:
- To provide you our Services: providing any services or products that you request or purchase in connection with the Services. We use data to carry out your transactions with us and to make the Marketplace available to you. In certain cases, the Marketplace may include personalized features and recommendations to enhance your enjoyment, and automatically tailor your experience based on the data we have about you.
- To provide you with service-related communications: contacting you regarding the administration of any features or functions of the Services you have registered to use, and notifying you about changes to our Services, our policies, terms, the Marketplace, or any products or services we offer or provide through our Services.
- To provide customer support or to respond to you: providing you with notices about your account and responding to your questions or other requests.
- To send you marketing and promotional emails: contacting you with newsletters, marketing or promotional materials and other information that may be of interest to you based on the Services that you already use or the offerings that you have already purchased or inquired about, unless you have opted not to receive such information.
- For internal use and services improvement: accumulating and reporting aggregate statistical information in connection with user activity, including determining which features and services users like best to help us operate, enhance, and improve our Site and Marketplace.
- To enforce compliance with our agreements or policies: endeavoring to keep you secure and safe while using our Services, which requires us to process your personal information in accordance with this Policy to combat spam, malware, malicious activities, fraud, or security risks as part of our ongoing maintenance and enforcement of our security measures, and carrying out our obligations and enforcing our rights arising from any contracts entered into between you and us (which include the Terms of Use), including for billing and collection.
- To maintain legal and regulatory compliance: processing personal information to pay our taxes, fulfill our business obligations, for compliance with employment and recruitment laws, or as necessary to manage risk under applicable law.
- For customization: saving your user account, registration and profile data or other personal information (so you do not have to re-enter it each time you visit or use the Services); tracking your return visits to and use of the Services; tailoring your experience on the Services; and/or otherwise customizing what you see when you visit and use the Services.
- For research and reporting: for research and reporting purposes and to provide anonymous reporting for internal and external clients and business partners.
- With your consent: for any other purpose disclosed to you prior to you providing us your personal information or which is reasonably necessary to provide the Site or Marketplace or other related products and/or services requested, with your permission or upon your direction.
06Data Retention
We may retain your personal information as long as you continue to use the Site or Marketplace, have an account with us, or for as long as is necessary to fulfill the purposes outlined in this Policy. You can ask to close your account by contacting us as described below, and we will delete your personal information on request. We may, however, retain personal information for an additional period as is permitted or required under applicable laws, for legal, tax, or regulatory reasons, or for legitimate and lawful business purposes.
We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. Additionally, we will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data or the information you provided to us to comply with applicable laws), resolve disputes and enforce our legal agreements and policies. We will retain your marketing contact information until you unsubscribe from our marketing communications. We will also retain Services usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer periods.
07Communications Preferences
You can choose whether you wish to receive marketing communications from us. If you receive marketing communications from us and would like to opt out, you can do so by following the directions in that communication. You can also make choices about your receipt of marketing communications by signing into your account, and viewing and managing your communication permissions in your account’s user dashboard, where you can update contact information, manage your contact preferences, opt out of email subscriptions, and choose whether to share your contact information with the Company and our partners. Alternatively, you can request that we withdraw your consent to use your personal data by submitting an email to us at support@bookbetter.com and including “Please withdraw my consent for marketing communications” in the “Subject” line. The Company will verify your ability to access that email, then update our systems to remove your email address from the system we use to send marketing communications. We will use reasonable efforts to respond to your request within 30 days of our receipt of verification of the request. Please note that these choices do not apply to mandatory communications that are part of the Marketplace, or to surveys or other informational communications that have their own unsubscribe method.
08How to Access and Control Your Personal Information
You have the right to access, correct, and delete your personal information that you shared with us on our Services or through other written or oral means. We are committed to keeping your personal information accurate and up to date. However, it is up to you to update it with any changes. In most cases, you can review and submit changes to your personal information by logging into the Site or Marketplace and visiting your account profile page. You may also notify us via the information in the “How to Contact Us” section below to request access to, or to correct any personal information that you have provided to us. We may not accommodate a request to delete or change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
If you no longer wish to have your personal information processed, you may request to delete your account (username and password), subject to certain limitations, by contacting us as described below.
09California Privacy Rights
This section applies solely to individuals who reside in the State of California. The purpose of this section is to inform California residents (“consumers” or “you”), at or before the time of collection of personal information, about our data collection practices and your privacy-related rights under California law, including the California Consumer Privacy Act of 2018, as amended (“CCPA”). Your “right to know” about personal information collected, used, and disclosed by the Company includes what categories of personal information we collect from you and the purpose for its collection; how we use those categories of personal information; and how we share the personal information you entrust to us.
In the preceding twelve months we may have disclosed these categories of personal information for a business purpose: identifiers; personal information categories listed in the CCPA; commercial information; internet or similar network activity; geolocation; and inferences drawn.
| Category | Sources | Purpose | How we share it |
|---|---|---|---|
| Identifiers | Information you voluntarily provide and information we collect automatically (Section 2). | To provide our services; to communicate with you, including marketing; research, development and services improvement; legal compliance; enforcing our terms (Section 3). | With service providers; to protect lawful interests; and for any other purpose with your consent (Section 4). |
| Personal information under Cal. Civ. Code §1798.80 | Information you voluntarily provide and information we collect automatically (Section 2). | The purposes outlined in Section 3. | With service providers; to protect lawful interests; and for any other purpose with your consent (Section 4). |
| Commercial information | Information you voluntarily provide (Section 2). | To provide our services; to communicate with you; research, development and services improvement; legal compliance (Section 3). | With service providers; internally; and to protect lawful interests (Section 4). |
| Electronic network activity | Information you voluntarily provide and information we collect automatically (Section 2). | To provide our services; to communicate with you; research, development and services improvement; legal compliance (Section 3). | With service providers; to protect lawful interests; and for any other purpose with your consent (Section 4). |
| Geolocation | Information you voluntarily provide and information we collect automatically (Section 2). | To provide our services and tailored information when you request it (Section 3). | With service providers and for any other purpose with your consent (Section 4). |
| Inferences | Developed from information you voluntarily provide and information we collect automatically (Section 2). | To provide our services; to communicate with you; research, development and services improvement (Section 3). | With service providers and to protect lawful interests (Section 4). |
Sale of personal information under the CCPA
In the preceding twelve months we have not sold your personal information, as that term is generally understood, but we recognize that the CCPA defines “personal information” in such a way that making available identifiers linked to you for a benefit may be considered a “sale.” In addition to the cookie choices described in Section 5, California consumers may also use the Digital Advertising Alliance’s tools to send requests under the CCPA to opt out of the sale of personal information by participating companies.
Rights under the CCPA
- Access to specific information and data portability rights. Subject to certain exceptions, if you are a California resident you have the right to request a copy of the personal information that we collected about you during the 12 months before your request. Once we receive your request and verify your identity, we will disclose to you: the categories of personal information we have collected about you; the categories of sources for that information; our business or commercial purpose for collecting it; the categories of third parties with whom we share it; and the specific pieces of personal information we collected about you.
- Deletion request rights. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.
- Opting out. California residents have the right to opt out of having their personal information sold.
- Non-discrimination. We recognize and respect that you have the right to not receive discriminatory treatment by the business for exercising any of your CCPA rights.
- Exercising access, data portability, and deletion rights. To exercise these rights as a California resident, please submit a verifiable consumer request to us by contacting us as described in the “How to Contact Us” section below.
- Use of an authorized agent. Only you, or a person you formally authorize to act on your behalf, may make a verifiable consumer request related to your personal information. If you use an authorized agent, we will require written proof that the agent has been authorized to act on your behalf or a copy of the power-of-attorney document granting that right.
- Direct marketing. If you are a California resident, you can request a notice disclosing the categories of personal information we have shared with third parties for their direct marketing purposes. To request a notice, please email support@bookbetter.com.
10Important Notice for Non-U.S. Residents
The Services and their servers are operated in the United States. Please be aware that your information, including your personal information, may be transferred to, processed, maintained, and used on computers, servers, and systems located where the privacy laws may not be as protective as those in your jurisdiction. If you choose to use our Services while located outside the United States, such as in the European Economic Area, the United Kingdom, Switzerland, or elsewhere, you hereby irrevocably and unconditionally consent to such transfer, processing, and use of your information in the United States and elsewhere. If you do not wish for your information to be transferred to, processed, or maintained outside of the country or jurisdiction where you are located, you should immediately cease accessing our Services.
11Additional Disclosures for Data Subjects in the EEA, the U.K. and Switzerland
This section provides general information about how the Company collects, stores, uses, transfers and otherwise processes personal data in or from certain countries in the European Economic Area, the United Kingdom, and Switzerland (together, for purposes of this section, “EEA”), in accordance with the General Data Protection Regulation (“GDPR”) and its local implementations.
Lawful bases of processing
Where the Company is acting as a data controller that determines the purposes and means of processing your personal data, such as when we collect, use, and share personal data as described in Sections 2 through 4 above, we must have a lawful processing basis for doing so. Our lawful bases for processing personal data include:
- To conclude or perform a contract with you, for example to process your purchases of or requests for products and services, including through our Marketplace, and to communicate with you about purchases, professional services, accounts, and programs.
- For our legitimate business purposes, including to respond to your customer service inquiries and requests for information; maintain, improve, and analyze our Services, advertisements, and the products and services we offer; detect, prevent, or investigate security breaches or fraud; and facilitate the functionality of our Services.
- To comply with our legal obligations, for example to maintain appropriate records for internal administrative purposes and as required by applicable law.
- On the basis of your consent, for example to send you via email and other electronic means personalized promotions and special offers or informing you about our professional services, offerings, events, or other promotional purposes. You can withdraw your consent at any time by contacting us as described in the “How to Contact Us” section below.
Your EEA data subject rights
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you.
- Request correction of the personal information that we hold about you.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it.
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party), or where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you.
- Request the transfer of your personal information to another party, when possible.
- Not be subject to automated decision-making producing legal or significant effects on an individual, which we do not engage in.
To exercise any of these rights, please contact us as set forth in the “How to Contact Us” section below and specify which GDPR privacy right(s) you wish to exercise. We must verify your identity in order to honor your request, which we will respond to within 30 days of receipt.
- Transfers. When we transfer or receive personal data from the EEA, we do so pursuant to appropriate safeguards or your explicit consent under GDPR Article 49.
- Retention. As described above, as a general rule, we keep your data for only as long as it is needed to complete the purpose for which it was collected or as required by law. We may need to keep your data for longer than our specified retention periods to honor your requests, including to continue keeping you opted out of marketing emails, or to comply with legal, regulatory, accounting or other obligations.
- Complaints. If you have any issues with our compliance, you have the right to lodge a complaint with an EEA supervisory authority. We would, however, appreciate the opportunity to first address your concerns and would welcome you directing an inquiry first to us per the “How to Contact Us” section below.
12How Do We Protect Your Information?
We have implemented reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Any payment transactions will be encrypted using SSL or other encryption technology, or will use our third-party payment processors, who will use appropriate security procedures.
The safety and security of your information also depends on you. Where you have chosen a password for access to certain parts of our Services, you are responsible for keeping this password confidential. You should not share your password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we strive to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services. If you believe that any of your personal information held by the Company has possibly been compromised, please contact us immediately as described in the “How to Contact Us” section below.
13Third Party Links
Occasionally, at our discretion, we may include or offer third party products or services on our website or through our Services. If you access other websites using the links provided, the operators of these websites may collect information from you that will be used by them in accordance with their privacy policies. These third-party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
14Children’s Privacy
The Company Services are not directed toward children under the age of 16, and we do not knowingly collect any personal information from children under the age of 16. If a child under 16 provides our Site or Marketplace with personal information, we ask that a parent or guardian contact us as described below so that we may promptly delete the child’s information from our records.
15How to Contact Us
If you have a technical or support question, please contact support@bookbetter.com.
If you have a privacy concern, complaint, or a question for the Data Protection Officer of the Company, please contact us by sending us an email at support@bookbetter.com. We will respond to questions or concerns within 30 days.