Privacy Policy

Privacy Policy

Private Trade Winds respects your privacy. We recognize the potential of technology to help you communicate with us via our website and through e-mail, and we would like to use this technology over time to develop a relationship with you. The privacy policy below details the measures taken by Private Trade Winds, Inc. (“PTW”) to protect your privacy in connection with your use of www.privatetradewinds.com and other websites owned by PTW (collectively, “Site”), as well as certain information regarding other websites and online services utilized by PTW in conjunction with the Site. Please read the following to learn more about our privacy policy.

This privacy policy is incorporated into and is subject to the PTW Terms of Use. If you do not agree to the terms of this privacy policy or the Terms of Use, please do not provide PTW with any information and do not use the Site. Your continued use of the Site after the privacy policy has been modified will signify your acceptance of the changes for information gathered after the date of the change.

Overview

This policy statement discloses our privacy practices including notification of:

  • Personally identifiable information (“PII”) collected through our Site;
  • Intended usage of this PII;
  • Choices available regarding opt-in/opt-out, data collection, use and distribution of the information;
  • Security measures to protect the loss or misuse of information under PTW’s control; and
  • How to maintain the accuracy of your information.

The Details

In general, you may visit our Site and access information while not revealing any individual user information other than Technology Related Information (defined below). If you upload content to this Site, the content will be governed by the Terms of Use and any other terms or conditions on the upload pages. The types of individual user information collected in the registration process you voluntarily provide to us, whether in person, by telephone, mail or e-mail, or on this Site, may include your name, contact information, billing information (such as credit card number, cardholder name and expiration date), passport number, driver?s license or state identification number, and postal and e-mail addresses) other PII and other information volunteered by you. PTW also may request information about your traveler preferences, including meal requests, seat selection, frequent flyer/hotel/car rental program information booking history, interests, special health accommodations, and ticketing options. You can choose not to provide such information to PTW, but, in general, some information about you is required in order for you to register as a client; purchase products or services; complete a traveler profile; participate in a survey, contest, or sweepstakes; ask us a question; or initiate other transactions on our Site; thus, if you do not provide the requested information, PTW may not be able to provide you all services offered on the Site.

When you make travel or other arrangements for someone else through PTW, PTW will request PII and travel preferences about that individual. You should obtain the consent of all such other individuals prior to providing PTW with their PII and travel preferences, as any access to view or change their information will be available only through your account.

PTW collects PII when you register with PTW, when you visit PTW pages and when you deliver communications or content to the Site. PTW may combine information about you that we have with information we obtain from business associates or otherwise. Without limitation, information collected, including PII, may be used by PTW for general purposes, such as: to provide you with the products and services that you request; to provide you with travel confirmation and updates; to manage your account, including processing bills and providing travel notifications; to communicate with you in general; to respond to your questions and comments; to measure interest in and improve our products, services and our Site; to notify you about special offers and products or services that may be of interest to you; to otherwise customize your experience with PTW; to reward you as part of any reward and recognition program you choose to join; to solicit information from you, including through surveys; to resolve disputes, collect fees or troubleshoot problems; to enforce our Terms of Use; and as otherwise described to you at the point of collection. PTW uses sensitive billing information (such as cardholder name, credit card number and expiration date) for the purpose of completing the purchases and/or other transactions that you conduct on or through our Site.

In certain instances, when you provide personal information to this Site, you are providing it to both PTW and to one of the third-party suppliers or vendors featured on the Site. PTW has provided this structure for your convenience and to ease your use of the Site. For example, in those instances, if you register with PTW and then purchase an item from a third-party supplier or vendor on or through this Site, certain of your information will go to both PTW and that third-party supplier or vendor. In other cases you may get access to a third-party supplier or vendor through a link in which you will be required and directed to register specifically with that third-party supplier. In this situation, PTW will not provide your personal information to the third-party supplier directly. So, to understand how any information collected may be used, you should review both PTW’s privacy policy and the privacy policy of any third- party supplier or vendor that you intend to register with or purchase from.

We encourage you to read the PTW privacy policy, as well as those of the third party sponsors, suppliers or vendors that you register with or purchase from and of the other companies featured on our Site, so that you understand what types of personal information are collected and how this information may be used.

We may make chat rooms, forums, message boards and/or news groups available to you. Please remember that any information disclosed in these areas becomes public information. You should exercise caution when deciding to disclose your personal information.

PTW also may disclose any information that you provide if required to do so by law or pursuant to a request by law enforcement or if we have a good faith belief that disclosure is necessary to (1) comply with the law or with the legal process; (2) protect and defend the rights or property of PTW or third parties; or (3) act in an emergency to protect someone’s safety or legal rights (“Mandatory Disclosures”). As we develop our business, we may buy or sell assets or change our name or form of entity, and, depending upon the transaction, your personal information may be one of the transferred assets; provided, however, we will not sell or transfer PII except subject to the terms of our privacy policy. For instance, in the event that PTW is acquired by another company, your PII may be part of the assets transferred to the acquiring party. PTW will notify you before PII about you becomes subject to a different privacy policy. Products and services provided by third party sponsors, suppliers or vendors are described as such. PTW may share your PII with such third party sponsors, suppliers or vendors as necessary for them to provide such products or services to you. We do not place limitations on such third-party suppliers? or vendors? use or disclosure of your PII. Therefore, PTW encourages you to review the privacy policies of any such third party sponsors, suppliers or vendors whose products or services you purchase or access through PTW. In addition, we may from time to time hire a third party to act on our behalf for projects, services or functions on our behalf such as credit card processing, business analytics, customer service, fraud prevention, marketing, market research surveys, contest entry processing and other distribution. Such third parties have access to PII needed to perform their functions but are not permitted to share or use the PII for any other purpose. The information collected by PTW may be provided in the aggregate to third parties, including potential business partners and advertisers, but this information is not linked to any PII before it is disclosed unless PTW has obtained your consent or except as otherwise set forth in our privacy policy.

Technology-Related Information

To help administer our Site and provide a positive experience while visiting our Site, PTW does collect technology-related information. “Technology-Related Information” may include, without limitation, the following: source IP address, domain name, date and time visited and visited pages. A “cookie” is a small line of text that is stored with your Web browser for record-keeping purposes and to help us provide better service to you. Your browser has options to accept, reject or provide you with notice when a cookie is sent. We use cookies for many purposes, such as to save your password so that you don’t have to re-enter it each time you visit our Site. We also use cookies to deliver content (which may include third party advertisements) specific to your interests. PTW may set and access PTW “cookies” on your computer. PTW lets other companies that show advertisements on some of our pages set and access their cookies on your computer. Advertisers or other companies do not have access to PTW’s cookies. Other companies’ use of their cookies is subject to their own privacy policies, not this one. We may also use “Web beacons” that monitor your use of our Site. Web beacons (or Web bugs) are small strings of code that provide a method for delivering a graphic image on a Web page for the purpose of transferring data, such as the IP (Internet Protocol) address of the computer that downloaded the page on which the Web beacon appears, the URL (Uniform Resource Locator) of the page on which the Web beacon appears, the time the page containing the Web beacon was viewed, the types of browser that fetched the Web beacon and the identification number of any cookie on the computer previously placed by that server. When corresponding with you via HTML capable e-mail, Web beacons let us know whether you received and opened our e-mail. If you choose to furnish the Site with PII, this PII can be stored in or linked to other data stored in the cookies/Web beacons.

PTW has no control over the information collected from or about you by any third party after you have left the Site. By clicking on links to other websites, advertisers and other third parties, you are leaving the Site. Once you have left the Site, PTW does not control the data collection and privacy practices, or other activities, of any third party linked to this Site, and PTW assumes no liability and is not responsible for any practices of such third party websites.

Consent/Opt-Out

PTW may consider requests from unrelated third parties to contact you, but we will not give that third party any PII unless PTW has obtained your consent. You may give this consent by “opting-in” to having your information shared with third parties when you register. Additionally, PTW provides you the opportunity to be sent newsletters and information about content, promotional events, marketing events and opportunities to participate in research studies. If you would like to exercise your right under the CAN SPAM Act to not receive future e-mail correspondence from us, except with respect to your prior financial transactions or communications, regarding Mandatory Disclosures or as otherwise required by law, you may do so by using a link provided at the bottom of these communications. You can also send us an e-mail at test@privatetradewinds.com for any opt-out or opt-in purpose.

How to Access, Update or Correct Information

You may review, change or delete any information that you submitted to PTW by going to your ?My Profile? page, at any time. You must log in, using your login ID and password, to access your profile and once you have successfully logged in you may change any of the information that PTW has on file. However, please note that even if you delete or change some personal information in our registration database, it may still be stored on our, or other third party, databases (including those kept for archival purposes).

Data Security

PTW endeavors to ensure the commercially reasonable protection of the User’s PII. We have implemented security measures to protect PII collected on our Site against loss, misuse or alteration. These measures include the use of secure coding in the assembly of the Site and employing a scanning company to search for security breaches and weaknesses. However, the Internet is an open system and technology and human operators are not infallible. Accordingly, we cannot and do not guarantee that the individual user information you have transmitted, including PII, will not be intercepted by others and/or decrypted or accidentally disclosed. We cannot ensure or warrant the security of any information transmitted to us over the Internet, and we accept no liability for any unintentional disclosure.

Changes to the Privacy Policy

As a User of the Site, please understand that our privacy policy may change from time to time. If we decide to make any material changes, we will post these changes on the Site. Users should periodically review this privacy policy for changes and decide whether, in light of any such changes, PTW may continue to use their PII, but in this different manner, or, if not, elect to opt-out, as provided above.

Your Consent to This Privacy Policy

By providing Personal Information to us, you are giving your consent and permission for any use of the Personal Information that is consistent with the uses stated in this Policy or elsewhere at the Site at the point you submit such Personal Information, and such consent will be presumed by PTW, unless you expressly state otherwise at the time you submit the Personal Information. If you do not agree to the uses stated in this Policy or disclosed elsewhere at the Site, please do not use the Site or provide us with any Personal Information.

A Special Note about Children

PTW does not sell any products or other services for purchase by children. Should a child whom we know to be under 13 years of age send any personally identifiable information (?PII?) to us, we will use that information only to respond directly to that child to inform him or her that we must have parental consent before receiving his or her personal information. If you are the parent or guardian of a child under 13 years of age and believe that he or she has disclosed PII to us without our knowledge, please contact us at test@privatetradewinds.com.

Still have Questions? If you have any questions or believe that PTW is not abiding by our posted privacy policy, you should contact PTW’s privacy manager by e-mail at info@privatetradewinds.com. Alternatively, you can send mail to the following postal address: Private Trade Winds, Inc., 500 Newport Center Drive, #900, Newport Beach, CA 92660 (Attn: Privacy).

Effective Date

This privacy policy was last changed and posted on our Site on September 18, 2007.