Notice of Privacy

Notice of Privacy

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1. Background and scope

Flight Center Travel Group is one of the largest travel agency groups in the world. We need to collect, use and disclose personal information to carry out our business functions and activities, including making and managing travel reservations on behalf of our clients. We are strongly committed to protecting the privacy and confidentiality of personal information and to maintaining various physical, electronic, and procedural safeguards to protect the personal information in our care.

This Privacy Notice (“Notice”) sets out how this Flight Center Travel Group merchant or application processes and protects the privacy of your personal information. Applies to everyone except California residents (see section 2).

For the purposes of the General Data Protection Regulation 2016/679 (“GDPR”) and other similar laws we are a “data controller” (or equivalent) for the processing of personal information that you provide to us in connection with the following :

• our provision of business travel products and services;

• event management services;

• the provision of leisure travel products and services; and

• the purpose of all our marketing activities.

There may be cases where your local data protection laws impose more restrictive information handling practices than the practices set out in this Notice. When this occurs, we will adjust our information handling practices in your jurisdiction to comply with your local data protection laws.

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2. California Rights and Privacy Notice

California residents should refer to our California Consumer Privacy Act (“CCPA”) Privacy Notice which can be accessed through thislink. Our CCPA Privacy Notice sets out how Flight Center processes personal information in accordance with California law, including the CCPA.

 

3. What personal information do we collect?

Personal information has the meaning given to it by your local data protection law and, where the GDPR applies, the meaning of personal data given under the GDPR. Personal information generally means information that relates to a living person who can be identified from that information or from that information and other information in the possession of a person, including any expression of opinion, whether true or not, and whether recorded in material form or not, about an identified or reasonably identifiable person and any indication of intent with respect to a person.

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In general, the type of personal information we collect about you is information necessary to facilitate your travel arrangements and reservations, and to arrange travel-related products and/or services on your behalf.

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Therefore, we typically process the following types of personal information about you:

• Data that allow identification:

• contact information (such as name, residential/mailing address, telephone number, and email address);

• birthdate;

• passport data, national identification card data, driver's license data;

• data that enables online identification (such as IP addresses, device data, and network information);

• loyalty program/frequent flyer data;

• Commercial Information, including records of products or services purchased, obtained or considered or other purchasing or consuming histories or tendencies;

• Biometric information;

• Internet or other electronic network activity (such as the device and network you use to connect with us), as further described in section 12;

• Geolocation data;

• Audio (such as recordings used for quality control, service improvement, training, and dispute resolution purposes), electronic and visual information (such as video surveillance recordings) used for security purposes;

• Professional or employment related information;

• Payment account information (credit/debit card data, including card type, card number, security number and expiration date, as well as other financial data necessary to process various transactions);

• Health information such as your dietary requirements and health problems (if any); and

• Other data relevant to the organization of the trip or required by the corresponding travel service provider(s) (for example, airlines and accommodation or tour providers).

 

When you contact us for other purposes, we may also collect personal information about you in connection with those purposes. For example, we may collect your personal information so that we can contact you about a contest you have entered (for example, if you win) or to respond to a query or complaint you have made, or comments you have made to us. facilitated. We also collect information necessary for use in the business activities of Flight Center and our related entities, including, for example, financial data necessary to process various transactions and other relevant personal information that you may choose to provide to us.

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In certain cases, we may collect personal information from you that may be considered sensitive information under your local data protection laws. Sensitive information may include (without limitation) your racial or ethnic origin; philosophical or religious beliefs or affiliations; sexual orientation; membership in political, professional or trade associations (for use in booking special rates); biometric and genetic information; passwords and financial and health information. Please note that, where necessary for travel arrangements, we may collect from a responsible adult personal information relating to a child of any age, but we do not knowingly collect such information directly from children.

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We will only collect sensitive information in accordance with your local data protection laws, with your explicit and voluntary consent and when reasonably necessary for, or directly related to, one or more of our functions or activities (for example, to provide products and travel-related services), unless we are required or otherwise authorized by law. To the extent permitted or required under your local data protection laws, you voluntarily consent to our use and disclosure of your confidential information for the purpose for which it was collected. For example, if you provide us with medical information in connection with a request for travel insurance that you would like to make, you voluntarily consent to us using and disclosing that medical information in connection with arranging for that travel insurance on your behalf. Another example is if you disclose your religious beliefs to us because you are interested in, for example, certain vacation packages, in which case you voluntarily consent to our use and disclosure of that information for purposes of facilitating your request. We will not use or disclose confidential information for purposes other than those for which it was collected, unless we subsequently request and receive your voluntary consent to use it for another purpose.

 

4. How do we collect personal information?

We will only collect personal information in accordance with your local data protection laws. We generally collect your personal information directly from you during the course of your relationship with us. We will collect this information directly from you, unless it is not reasonable or practicable to do so.

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Generally, collection is performed in these cases:

• when you deal with us whether in person, by phone, letter or email;

• when you visit any of our websites;

• when you use any of our applications; either

• when you connect with us through social media.

 

We may collect personal information about you:

• when you purchase or inquire about travel arrangements or other travel-related products and services;

• when you enter contests or register for promotions;

• when you sign up to receive marketing from us (for example, email newsletters);

• when you request brochures or other information from us; either

• when you provide information, or use our services, on social networks.

 

Unless you choose to do so using a pseudonym or anonymously, we may also collect your personal information (other than sensitive information) when you complete surveys or provide feedback to us.

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In certain cases, it may be necessary for us to collect personal information about you from a third party. This includes when someone makes a travel reservation on your behalf that includes travel arrangements to be used by you (for example, a family or group reservation, or a travel reservation made for you by your employer). When this occurs, we will rely on the authority that the person making the travel reservation has to act on behalf of any other traveler on the reservation.

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When you make a travel reservation on behalf of another person(s) (for example, a family or group reservation, or a travel reservation made for an employee), you agree that you have obtained the voluntary consent of the / the other person(s) for Flight Center to collect, use and disclose the personal information of the other person(s) in accordance with this Notice and that you have informed the other( s) person(s) on this Notice.

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You must tell us immediately if you become aware that your personal information has been provided to us by another person without your voluntary consent or if you did not obtain voluntary consent before providing us with another person's personal information.

We do our best to maintain the accuracy and completeness of your personal information that we store and to ensure that all of your personal information is up to date. However, you can help us with this considerably by contacting us immediately if there are changes to your personal information or if you become aware that we have inaccurate personal information relating to you (see section 15 below). We will not be liable for any loss arising from any inaccurate, inauthentic, deficient or incomplete personal information provided to us by you, or a person acting on your behalf.

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Where the provision of services or other business processes depend on your voluntary consent to the collection and further processing of your personal data, if you choose not to provide your voluntary consent, it may prevent our ability to provide specific services that rely on the collection of personal data , or otherwise affect the quality of the services we can provide to you.

Similarly, please note that if you request that we restrict or stop using the personal information we hold about you, or withdraw a voluntary consent you have previously given to the processing of such information, this could affect our ability to provide services to you. you or adversely affect the services we are able to provide to you. For example, most travel reservations must be made in the full name of the traveler and must include contact details and proper identification (eg passport details). We cannot make reservations for you without that information.

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Any voluntary consent you provide to us for the collection, use and disclosure of your personal data will remain in effect until such time as you withdraw your consent in writing. You can withdraw your consent and ask us to stop collecting, using and/or disclosing your personal data by submitting your request in writing via the links provided in section 15, or by emailing/writing a letter to our Privacy teams with the contact details provided in section 15. Please note that withdrawal of consent does not affect our right to continue collecting, using and disclosing personal data where such collection, use and disclosure without consent is permitted or required under applicable law .

With regard to the retention of personal data, we may retain your personal data for as long as necessary to fulfill the purposes for which it was collected, or as required or permitted by applicable law. We will stop retaining your personal data, or remove the means by which the data may be associated with you, as soon as it is reasonable to assume that such retention no longer fulfills the purposes for which the data was collected and is no longer necessary for legal or commercial purposes.

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5. How do we use your personal information?

We will only process your information when:

• you have given your voluntary consent to such processing (which you can withdraw at any time, as set out in section 4 above);

• the processing is necessary to provide you with our services;

• the processing is necessary for compliance with our legal obligations and/or

• the processing is necessary for our legitimate interests or those of any third party recipient receiving your personal information (as set out in sections 5 and 6 below).

 

In detail: When you contact us regarding a travel reservation or inquiry, the purpose for which we collect your personal information is generally to provide you with travel advice and/or assist you with the reservation of travel and/or products and travel related services. However, the purpose of the collection may differ depending on the particular circumstances as set out in this Notice (for example, the collection of your personal information for the purpose of your participation in a contest, the submission of comments, etc.).

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When you book or arrange travel-related products and services through us, we often act as agent for the relevant travel service providers (for example, a hotel). In this case, we process your personal information as necessary to provide the services you requested from us. This generally includes the collection of personal information about you for our internal purposes as described in this Notice and for the travel service provider for whom we are acting as agent (for example, to provide you with the booked services). For example, if you book a flight through us, we use your personal information to enable your flight to be booked and disclose it to the airline to enable the airline to provide the flight service to you.

Therefore, we may share your information with our travel service providers, such as hotels, airlines, car rental companies, or other providers that match your travel reservations. Please note that these travel service providers may also use your personal information as described in their respective privacy policies and may contact you as necessary to obtain additional information about you, facilitate your travel reservation, or provide you with the Requested services. We recommend that you review the privacy policies of any third-party travel service providers whose products you purchase through us. We will provide you with copies of all relevant travel service providers' terms, conditions and privacy policies upon request. 

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We act as an agent for, or on behalf of, thousands of travel service providers around the world, so it is not possible for us to list in this Notice all the travel service providers we act for or their locations. For more information on the disclosure of personal information to travel service providers located abroad, please see section 6 below.

If you have any concerns regarding the transfer of your personal information to a travel service provider or would like to contact us for more information, please see the “Feedback/Complaints/Contact” section below (Section 15).

 

Additional purposes for which we process personal information include the following:

• provision of services and tools you choose to use (for example, saving travel preferences on our websites to a wish list or saving personal information to enable online forms to be pre-populated);

• error identification;

• protection against, prevention, detection and investigation of fraudulent, unauthorized or illegal activities;

• regulatory reporting and compliance;

• development and improvement of our products and services, and those of our related entities;

• attention to our relationship with you, among other things, by creating and maintaining a customer profile to allow our brands to better serve you or by presenting options on our website that we think may be of interest to you based on your browsing and preferences;

• participation by you, through us, in market research, measuring customer satisfaction, and seeking feedback about our relationship with you and/or the service we have provided;

• facilitating your participation in loyalty programs;

• research and analysis in connection with our business and services, including, without limitation, trends and preferences in travel sales and destinations and the use of our websites;

• internal accounting and administration;

• compliance with our legal obligations, including compliance with requests from government or law enforcement authorities, and any applicable customs/immigration requirements in connection with your travel;

• compliance with an authorized and valid court order or other valid legal process; and

• other purposes authorized or required by law (for example, to prevent a threat to life, health or safety, or to enforce our legal rights).

 

Where permitted by your local data protection laws, we may use your personal information to send you targeted marketing related to our (and third party) products and services that we think may be of interest to you, unless you have opted out of receiving such information. . These may include, but are not limited to, mailings, electronic marketing and notifications as described below, and telephone calls. We will only use your personal information to send you electronic marketing materials (including email newsletters, emails, text messages, multimedia messages, and instant messages) if you have opted-in or have not opted-out, depending on applicable law. You can sign up to receive newsletters and other promotional/marketing electronic materials by following the relevant links on our website or by having one of our consultants do it for you.

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If you no longer wish to receive marketing/promotional materials from us, participate in market research or receive other types of communication from us, please see the “Feedback/Complaints/Contact” section below (section 15). You can unsubscribe from receiving electronic marketing materials by following the unsubscribe message in your email, text message, multimedia message, instant message, or other forms of electronic marketing. Please also see the “Your Rights” section of this Notice for information about your ability, at any time, to opt out or limit the use of your browsing behavior for online behavioral advertising (section 9 below). ).

 

6. Is personal information disclosed to third parties?

We do not sell, rent, or trade your personal information and will not do so in the future. We will only disclose your personal information to third parties as set out in this Notice, and in particular as set out below and in accordance with your local data protection laws. Please note that in this Notice, when we say “disclose,” this includes transferring, sharing (including verbally and in writing), sending, or otherwise making available or accessible your personal information to another person or entity.

 

Your personal information may be disclosed to the following types of third parties:

• our independent contractors, vendors and service providers, including, but not limited to:

  • each of the cases set out in section 5 (“How do we use your personal information?”);

  • IT-based solution providers who help us provide products and services to you (such as any third-party data hosting providers we may use);

  • publishers, printers and distributors of marketing material;

  • event and exhibition organizers;

  • marketing, marketing research, research and analysis, and communications agencies;

  • mailing companies, freight services, courier services and

  • outside business advisers (such as lawyers, accountants, auditors and recruitment consultants);

• our related entities and brands;

• travel related service providers such as travel wholesalers, tour operators, airlines, hotels, car rental companies, transfer managers and other related service providers;

• any third party to whom we assign, or with whom we renew, any of our rights or obligations;

• financial institutions such as banks, when processing financial transactions;

• creditors, issuers and payment service providers;

• a person who makes a travel reservation on your behalf, when you travel on a reservation made on your behalf by another person (for example, a family member, friend or work colleague);

• your employer, when you are an employee of one of our corporate, business or government clients and you participate in an event or travel for work purposes;

• a person who can verify that they are related to you (for example, a family member) when we cannot contact you, the person correctly answers our required security questions, and the request is, in our opinion, in your best interest ( for example, when the person is concerned about your well-being or needs to take action on your behalf due to unforeseen circumstances);

• as required or authorized by applicable law and to comply with our legal obligations;

• customs and immigration to comply with our legal obligations and any applicable customs/immigration requirements in connection with your travel;

• government agencies and public authorities to comply with a valid and authorized request, including a court order or other valid legal process;

• various regulatory agencies and officials, and law enforcement agencies, including for fraud protection and related security purposes;

• Law enforcement agencies where we suspect involvement in illegal activity or may be involved in illegal activity, and the personal information is a necessary part of conducting our investigation or reporting the matter; and

• third party applications or services when you use them to sign in to your account (for example, if you use a third party application or service (for example, Facebook, Google) to sign in to your Flight Center account, we share certain personal information with that third).

 

When you contract with us to book flights on your behalf, we will provide your personal information (ie name, email address and/or mobile phone number) to the relevant airline. This allows airlines to directly inform passengers about irregularities and interruptions in flight operations (for example, flight cancellations or schedule changes).

Apart from the cases mentioned above, we will not disclose your personal information without your voluntary consent, unless we reasonably believe that the disclosure is necessary to mitigate or prevent a threat to the life, health or safety of another person or to the health or safety public, or for a law enforcement agency to take certain actions (for example, prevention, detection, and investigation of, or prosecution or punishment of, criminal offences), or where such disclosure is authorized or required by law (including applicable privacy/data protection laws).

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On our websites, you may choose to use certain features that are accessible through, or for which we partner with, other entities not otherwise affiliated with us. These features, including social networking and geolocation tools, are operated by third parties, including social networks, and are clearly marked as such. These third parties may use or share personal information in accordance with their own privacy policies. We strongly suggest that you review the privacy policies of third parties if you use the relevant features.

 

7. Is personal information transferred abroad?

We may disclose your personal information to certain foreign recipients, as set forth below. We will ensure that such international transfers are necessary for the performance of a contract between you and the foreign recipient or are made in accordance with appropriate or adequate security measures as required by your local data protection laws (for example, the GDPR, China's cybersecurity law, etc.).

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The information may be transferred to a foreign recipient (other than any of the foreign entities with whom we engage) located in a jurisdiction where you may not seek redress under your local data protection laws and where there is no a level of data protection equivalent to that of your jurisdiction. To the extent permitted by your local data protection laws, we will not be responsible for how these foreign recipients handle, store and otherwise process your personal information.

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 (a) Foreign entities with which we relate

Flight Center operates a global business, including operations in Australia, New Zealand, Canada, United States, United Kingdom, South Africa, Hong Kong, India, China, Singapore, Japan, United Arab Emirates, Kingdom of Saudi Arabia, Ireland, Netherlands , Malaysia, Mexico, Dominican Republic, Costa Rica, Germany, Norway, Sweden, Denmark, Finland, Spain, France and Switzerland. Your personal information may be disclosed to foreign entities with whom we engage in connection with facilitating your travel reservation and/or to enable the provision of administrative, advisory and technical services, including storage and processing of such information. This includes enabling “single sign-on”, which allows you to log into a shared account across all of our brands using a single set of login credentials, allowing us, for example, to display your bookings made through of our group companies' websites, applications and services on your account page, and allows our group companies to display information in their respective accounts with them.

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 (b) Travel service providers located abroad

In providing our services to you, it may be necessary for us to disclose personal information to relevant foreign travel service providers. We deal with many different travel service providers around the world, so the location of a relevant travel service provider for your personal information will depend on the travel services being provided. In most cases, the relevant travel service providers will receive your personal information in the country in which they provide services to you or in which their business or management is based.

 (c) Our third-party service providers located abroad

We may also disclose your personal information to third parties located abroad for the purpose of performing services for us, including storing and processing such information. We will generally only disclose your personal information to these foreign recipients in connection with facilitating your travel booking and/or to enable the provision of administrative and technical services by them on our behalf.

 (d) Chinese Cybersecurity Law Requirements

Personal information that is collected and generated within the territory of the People's Republic of China is stored within the territory of China except in the following situations:

1. when the traveler requests or authorizes the international transfer;

2. We may transfer your personal information abroad when you are using our platform to book hotels, flights, and travel-related products or services abroad.

We will ensure that such international transfers are necessary for the performance of a contract between you and the foreign recipient or are made in accordance with appropriate or appropriate security measures as required by your local laws.

We use key service providers located in India, Indonesia, Philippines, Hong Kong, US, UK, Spain and Australia. We also deal with many different service providers around the world, so it is not possible for us to list in this Notice all the different countries to which we may send your personal information. However, if you have any specific questions about where or to whom your personal information will be sent, please see the “Feedback/Complaints/Contact” section below (section 15).

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8. Information security

We are committed to safeguarding and protecting personal information and will implement and maintain appropriate technical and organizational measures to ensure an adequate level of security in order to protect any personal information provided to us from accidental or unlawful destruction; loss; disturbance; unauthorized disclosure of, or access to, personal information transmitted, stored, or otherwise processed. Flight Center has implemented various physical, electronic and organizational security procedures to protect the personal information it holds from loss and misuse, and from unauthorized access, modification, disclosure and interference. Flight Center regularly reviews security technologies and will endeavor to protect your personal information as fully as we protect our own confidential information. Flight Center is not responsible for the actions of third parties or their security controls with respect to information that third parties may collect or process through their websites, services or otherwise.

 

We will destroy or anonymize personal information once we no longer require it for our business purposes, or as required by law.

 

9. Your rights in relation to the personal information we collect

If you wish to submit a Personal Access Request for these tasks:

• access, update, modify, rectify, delete, object to or obtain a copy of the personal information we hold about you;

• restrict or prevent us from using any of the personal information we hold about you, including by withdrawing any voluntary consent you have previously given to the processing of such information;

• where any type of personal information has been processed based on your voluntary consent or as necessary to perform a contract to which you are a party, request a copy of such personal information in a suitable machine-readable format or for another controller to transmit such information to us us,

you can do this by contacting us as set out in section 15 below. You will receive an acknowledgment of receipt of your request.

We will always process your requests within the timeframes established by applicable privacy laws, and in any event, we strive to respond to and process such requests within one month or less. Please note that we reserve the right to extend this period for complex requests or as otherwise permitted by applicable law.

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We reserve the right to deny you access for any reason permitted under applicable law. Such exemptions may include national security, corporate finance, and confidential references. If we deny access or correction, we will provide you with written reasons for the denial, unless it is unreasonable to do so and, where required by local data protection laws, we will record your request and the denial in our records.

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You have the right to lodge a complaint with a relevant supervisory authority.

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Further correspondence regarding your request should only be sent in writing to the appropriate Privacy Officer, as set forth in section 15 below.

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You must always provide accurate information and you agree to update it whenever necessary. You also agree that, in the absence of any update, we may assume that information submitted to us is correct, unless we subsequently learn that it is incorrect.

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You can tell us not to send you marketing email communications at any time by clicking the unsubscribe link within the marketing emails you receive from us or by contacting us as described below (section 15). .

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In any of the situations listed above, we may ask you to verify your identity by providing us with a copy of a valid means of identification, so that we can comply with our security obligations and prevent unauthorized disclosure of personal information.

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To the extent permitted by law, we reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive request related to access to your personal information, and for any additional copies of personal information you request from us.

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10. Singapore requirements

This section relates only to the processing of personal information that specifically falls within the scope of the Singapore Personal Data Protection Act (“PDPA”).

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Where voluntary consent has not been obtained for the processing of personal data, we will collect, use and disclose personal data pursuant to an exception provided in the PDPA or as required/authorized by any other written law.

Where we receive a written request to withdraw your voluntary consent, we may require a reasonable period of time (depending on the complexity of the request and its impact on our relationship with you) to process your request and to notify you of the consequences (including consequences that may affect your rights and responsibilities towards us) of our processing of said request. We will never delay our processing of such requests and, in any event, we will process them within the timeframes established by the PDPA.

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11. Social media integrations

Our websites and mobile applications may use social media features and widgets (such as the “Like” and “Share” buttons/widgets) (“Social Media Features”). These are provided and operated by third-party companies (for example, Facebook) and are either hosted by a third party or hosted directly on our website or mobile application. The Social Media Features may collect information such as the page you are visiting on our website/mobile application, your IP address and may set cookies to enable the Social Media Feature to perform properly.

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If you are logged into your account with the third party, the third party may be able to link information about your visit to and use of our website or mobile application with the social media account you have with the third party. Similarly, your interactions with the Social Media Features may be recorded by the third party. In addition, the third party may send us information in accordance with its policies, such as your name, profile picture, gender, friend lists, and any other information you have chosen to make available, and we may share information with the third party with the in order to serve you targeted marketing through the third-party company's social media platform. You can manage information sharing and opt out of targeted marketing through your privacy settings for third party social media platforms.

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Your interactions with these Social Media Features are governed by the privacy policy of the third-party company that provides them. For more information about the data practices of these third parties and to learn more about what personal information about you is collected and how the third party uses that personal information, please refer to the third party's privacy policy directly.

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12. IP addresses

When you access our website, use any of our mobile applications, or open electronic correspondence or communications from us, our servers may record data relating to your device and the network you are using to connect to us, including your IP address. An IP address is a series of numbers that identifies your computer and is typically assigned when you access the Internet.

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We may use IP addresses for system administration, investigation of security issues, and the collection of anonymized data regarding the use of our website and/or mobile applications. We may also link IP addresses to other personal information we hold about you and use it for the purposes described above (for example, to better tailor our marketing and advertising materials, provided you have opted-in to receive electronic marketing)._cc781905-5cde-3194 -bb3b-136bad5cf58d_

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13. Tracking Technologies/Cookies

We may use third-party web analytics services on our websites and mobile apps, such as those listed in our Cookie Policy. The analytics providers that administer these services use technologies such as cookies and web beacons to help us analyze how visitors use our websites and applications.

For information about our use of cookies and tracking technologies, please see our Cookie Policy on our website.

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14. Linked Sites

Our websites may contain links to third party websites over which we have no control. We are not responsible for the privacy practices or the content of such websites. We encourage you to read the privacy policies of linked third-party websites you visit, as their privacy policies and practices may differ from ours.

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15. Comments/Complaints/Personal Access Requests/Contact

You may direct any questions or complaints about the use or disclosure of your personal information using the contact information below.

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If you would like to submit a Subject Access Request (“SAR”) to notify us of a change or correction to your personal information, request a copy of the information we collect about you, request deletion of your information, or wish to restrict further processing of your data, please use the appropriate SAR link in the table below. We will respond to these requests within the period required by the applicable jurisdiction.

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Similarly, if you have any questions, comments or complaints about this Notice or our handling of your personal information, please contact your consultant or the Chief Privacy Officer using the details below, and we will respond as soon as possible. may be possible.

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