Privacy Policy

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short:  We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Website, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Website (such as by posting messages in our online forums or entering competitions, contests or giveaways) or otherwise when you contact us, including by phone or text message.

The personal information that we collect depends on the context of your interactions with us and the Website, the choices you make and the products and features you use. The personal information we collect may include the following:

Personal Information Provided by You. We collect names; phone numbers; email addresses; mailing addresses; job titles; passwords; contact preferences; billing addresses; and other similar information.

Booking and Traveler Information. When you make or request a booking, we collect travel dates, destinations and itineraries; the names of people traveling with you; date of birth, gender, passport or other government ID details, Known Traveler and Redress numbers, frequent traveler and loyalty numbers; and any special requests, which may include accessibility, dietary or medical needs. If you give us information about other travelers, you confirm that you have their permission to do so. We collect sensitive information, such as passport numbers or health-related details in special requests, only with your consent where the law requires it, and use it only to provide the bookings you request.

Call Recordings and Communications. When you speak with us by phone, we record the call and use artificial intelligence (AI) tools to transcribe and summarize it. We also keep copies of emails, text messages and other communications with you.

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is collected and stored by our payment processor, Stripe. We do not store your full card number or security code. You may find their privacy notice link(s) here: https://stripe.com/privacy.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short:  Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Website.

We automatically collect certain information when you visit, use or navigate the Website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Website and other technical information. This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).

• Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.

• Location Data. We collect location data such as information about your device’s approximate location (such as your country, region or city), based on your IP address. We do not collect precise geolocation, such as GPS data, from your device.
  

2. HOW DO WE USE YOUR INFORMATION?

In Short:  We process your information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations.

We use the information we collect or receive:

• To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.

• To post testimonials. We post testimonials on our Website that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at membership@mondelux.travel and be sure to include your name, testimonial location, and contact information.

• Request feedback. We may use your information to request feedback and to contact you about your use of our Website.

• To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent.

• To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.

• To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

• To protect our Services. We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).

• To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.

• To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

• Fulfil and manage your orders. We may use your information to fulfil and manage your orders, payments, returns, and exchanges made through the Website.

• Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in our competitions.

• To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service.

• To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.

• To record, transcribe and summarize calls. We record calls with you and use artificial intelligence (AI) tools to transcribe and summarize them, so that we can keep accurate records, monitor quality and train our team.

• To send you marketing and promotional communications. We may use the personal information you send to us for our marketing purposes, including by email, phone and text message, if this is in accordance with your marketing preferences and any consent the law requires. For example, when expressing an interest in obtaining information about us or our Website, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails, texts and calls at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS?” below).

• Deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. You can opt out of targeted advertising at any time (see Section 15 below).

• For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Website, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

We may use personal information, including call recordings, transcripts and summaries, to train and improve artificial intelligence (AI) models, including large language models.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short:  We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share your data that we hold based on the following legal basis:

• Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.

• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

• Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfil the terms of our contract.

• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, text messaging and telephony, call recording and AI transcription, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Website, which will enable them to collect data on our behalf about how you interact with our Website over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages or features, and better understand online activity. Unless described in this notice (see Section 15), we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

• Business Partners. We may share your information with our business partners, such as hotels, airlines, cruise lines and other travel suppliers and our travel insurance partner, to provide the bookings, products and services you request. They use your information under their own privacy notices. We do not share your information with business partners for their own marketing.

• Other Users. When you share personal information (for example, by posting comments, contributions or other content to the Website) or otherwise interact with public areas of the Website, such personal information may be viewed by all users and may be publicly made available outside the Website in perpetuity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Website, and view your profile.

4. WHO WILL YOUR INFORMATION BE SHARED WITH?

In Short:  We only share information with the following categories of third parties.

We only share and disclose your information with the following categories of third parties. If we have processed your data based on your consent and you wish to revoke your consent, please contact us using the contact details provided in the section below titled “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?“.

• Data Analytics Services

• Payment Processors

• Sales & Marketing Tools

• Retargeting Platforms

• Social Networks

• User Account Registration & Authentication Services

• Travel Suppliers and Booking Platforms
• Travel Insurance Providers
• Text Messaging, Telephony and AI Transcription Providers

• Website Hosting Service Providers

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short:  We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out below.

We use analytics cookies, such as Google Analytics, to understand how the Website is used, and advertising cookies and pixels, such as the Meta Pixel, Google Ads, the LinkedIn Insight Tag, the Reddit Pixel and the Pinterest Tag, to show you Mondelux ads on other websites and measure how well they work. You can manage non-essential cookies through the cookie settings on our Website and through your browser, and opt out of targeted advertising as described in Section 15.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short:  We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than twelve (12) months past the termination of the user’s account, except that we keep booking, payment and transaction records for as long as tax and accounting laws require, and records of your marketing consents and opt-outs for as long as needed to show that we complied with telemarketing and text messaging laws. We keep call recordings, transcripts and summaries for twelve (12) months past the termination of the user’s account or, if you never become a member, twelve (12) months after the call.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short:  We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short:  We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Website, you represent that you are at least 18. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If a member gives us information about a child traveling with them, we use it only to make and manage that booking. If you become aware of any data we may have collected from children under age 18, please contact us at membership@mondelux.travel

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short:  Depending on the US state where you live, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

Residents of many US states, including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia, have certain rights under applicable data protection laws, and we honor these requests from all US residents. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to opt out of the sale or sharing of your personal information, targeted advertising, and profiling that produces legal or similarly significant effects; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to obtain a list of the third parties to which we have disclosed your personal information. To make such a request, please use the contact details provided below, email us at membership@mondelux.travel or call +1 504 504 9566. We will consider and act upon any request in accordance with applicable data protection laws.

We will verify your identity by matching information you give us with information we hold. You may use an authorized agent to make a request; we may ask the agent for proof of your permission and ask you to confirm your identity directly. We will respond within 45 days, or tell you if we need up to 45 more days where the law allows. We will not discriminate against you for exercising your rights. Nevada residents may also ask us not to sell their personal information by emailing membership@mondelux.travel.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If we decline your request, you have the right to appeal by replying to our decision or emailing membership@mondelux.travel with the subject “Privacy Appeal”. We will respond to your appeal within the time required by your state’s law. If you are unhappy with the outcome, you can contact your state Attorney General.

If you have questions or comments about your privacy rights, you may email us at membership@mondelux.travel

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update your user account.
    

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Website. To opt-out of interest-based advertising by advertisers on our Website visit http://www.aboutads.info/choices/.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may:

• Access your account settings and update your preferences.
   

Opting out of text messages and calls: Reply STOP to any text message from us to stop receiving texts. To stop receiving marketing calls, tell the person who calls you or email us, and we will add you to our internal do-not-call list.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals. However, we do treat a Global Privacy Control (GPC) signal from your browser as a valid request to opt out of the sale or sharing of your personal information and targeted advertising for that browser (see Section 15). If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short:  Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Website, you have the right to request removal of unwanted data that you publicly post on the Website. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Website, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

12. DO WE MAKE UPDATES TO THIS NOTICE? 

In Short:  Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and, except for material changes, the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we will notify you either by prominently posting a notice of such changes or by directly sending you a notification before the changes take effect, and where the law requires, we will ask for your consent before applying them to personal information we have already collected. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact us at 

[Legal name of UTC Florida entity], trading as Mondelux Travel
[US mailing address]
Email: membership@mondelux.travel
Phone: +1 504 504 9566

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of the US state where you live, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please email membership@mondelux.travel or call +1 504 504 9566. See Section 9 for more about your rights.

15. DO WE SELL OR SHARE YOUR INFORMATION?

In Short:  We do not sell your information for money, but we allow advertising partners to collect information through cookies and pixels on our Website, which some US state laws treat as a “sale” or “sharing”. You can opt out at any time.

We allow advertising partners, such as Meta, Google, LinkedIn, Reddit and Pinterest, to collect information through cookies and pixels on our Website so they can show you Mondelux ads on other websites and measure the results. Under some US state laws, this may be considered a “sale”, “sharing” or “targeted advertising”.

You can opt out at any time by clicking “Your Privacy Choices” in the Website footer or changing your cookie settings. We also treat a Global Privacy Control (GPC) signal from your browser as a valid request to opt out for that browser. We do not sell or share sensitive personal information, and we do not knowingly sell or share the personal information of anyone under 16.

In the last 12 months, we have collected the following categories of personal information. The sources are described in Section 1, the purposes in Section 2, and the categories of third parties we disclose it to in Sections 3 and 4.

• Identifiers, such as name, email address, phone number, postal address, account ID, IP address, and cookie and device IDs. Online identifiers (cookie and device IDs, IP address) are sold or shared with advertising partners; other identifiers are not.
• Customer records, such as billing address and limited payment details. Not sold or shared.
• Characteristics, such as date of birth, age and gender, where needed for a booking. Not sold or shared.
• Commercial information, such as membership tier, bookings, and purchase and renewal history. Limited information (for example, that a sign-up or purchase occurred) is shared with advertising partners through pixels. [Confirm.]
• Internet and network activity, such as pages viewed, links clicked and referring URLs. Sold or shared with advertising partners.
• Approximate location, based on your IP address. Sold or shared with advertising partners.
• Audio and electronic information, such as call recordings, AI-generated call transcripts and summaries, emails and text messages. Not sold or shared.
• Professional information, such as job title. Not sold or shared.
• Inferences, such as travel preferences and interests. Not sold or shared.
• Sensitive personal information, such as account login details, passport or other government ID numbers, and health, accessibility or dietary details you give us for a booking. Not sold or shared, and used only to provide the Services you request.

16. DO WE SEND TEXT MESSAGES OR MAKE PHONE CALLS?

In Short:  Yes, with your permission where the law requires it. Calls are recorded, and you can opt out of marketing texts and calls at any time.

Text messages. If you opt in to receive text messages from Mondelux, we will send you messages about your membership, your bookings, offers, and other marketing purposes. Message frequency varies. Message and data rates may apply. Reply STOP to unsubscribe or HELP for help. Consent to receive marketing texts is not a condition of any purchase. Mobile information will not be shared with third parties or affiliates for marketing or promotional purposes. Text messaging opt-in data and consent will not be shared with any third parties, except the aggregators and providers that deliver our text messages.

Phone calls. We may call you about your membership, your bookings, offers, and other marketing purposes. Calls are recorded for quality, training, compliance and record-keeping, and we will tell you at the start of the call. We use AI tools to transcribe and summarize calls, and we may use call recordings and transcripts to train and improve AI models. To stop receiving marketing calls, tell the person who calls you or email membership@mondelux.travel, and we will add you to our internal do-not-call list.

17. DO WE TRANSFER YOUR INFORMATION OUTSIDE THE UNITED STATES?

In Short:  Yes. Your information may be processed in the United Kingdom and other countries.

Mondelux is part of a group based in the United Kingdom. Your personal information may be transferred to, stored and processed in the UK and other countries where we or our service providers operate, including by [name of UK group company]. Those countries may have different data protection laws from your state.