Effective on December 31, 2019
Thank you for using the SmarterTravel.com website or mobile websites and other platforms, including related applications (collectively, the “Site”), which are provided by Smarter Travel Media LLC (“SmarterTravel”). The terms “we”, “us”, “our” and “SmarterTravel” refer collectively to Smarter Travel Media LLC and/or our affiliates and subsidiaries. The term “you” refers to the customer visiting the Site and/or contributing content on this Site.
SmarterTravel is committed to safeguarding your privacy. We do not rent or sell our customer database or newsletter subscriber list to third parties. We do not share customer information in ways different from what is disclosed in this statement.
SmarterTravel’s registration form requires members to provide basic contact and demographic information. We receive and store any information you enter on our Site or give us in any other way. This includes information that can easily identify you (“personal information”), including your first and last name, telephone number, postal and email addresses, user name and password. If SmarterTravel offers or facilitates any transactional services, this may also include billing information (such as your credit card number, cardholder name, and card expiration date). We may also request information about your travel plans, style, and preferences, including meal requests, seat selection, frequent flyer/hotel/car rental program information, and flight class, luggage, and ticketing options. You can choose not to provide information to us, but in general some information about you is required in order for you to receive relevant offerings from TripAdvisor and SmarterTravel and its partners and enjoy other benefits of being a registered member. We use or may use your contact information (such as email address) from the registration form to send you newsletters and occasional information about our services and partners, inform you if you are the potential winner of a contest or promotion, personalize your experience with SmarterTravel, or investigate cases of suspected fraud or abuse. You may opt out of receiving future communications; see the Opting Out of Further Communications section below.
In order to customize your experience with our email newsletters we may receive a confirmation when you open email from SmarterTravel if your computer supports such capabilities. Clicking on a link in a SmarterTravel newsletter may also be tracked on a per-user basis to allow us to present content which closely matches your interests. Demographic and profile data (such as state, zip code, age, or gender) may be used to customize your experience at our site or in our email newsletters, showing you content and advertising that may best suit your needs. This information is shared with advertisers and other third parties on an aggregate or non-identifiable basis only.
If you enter SmarterTravel via a reward or incentive program, SmarterTravel may share your email address with the program through which you entered SmarterTravel to ensure you are credited with your incentive.
If you access third party services, such as social media services, through SmarterTravel.com or before coming to SmarterTravel.com, we may collect information such as your user name, password, and other information made available to us through those services in order to improve and personalize your use of SmarterTravel.
In order to better communicate with registered users about their registration status, SmarterTravel may acquire information about users from third-party sources, including but not limited to a users mailing address. The information collected will only be shared, if at all, on an aggregate basis only with third parties.
Information About Others
If SmarterTravel offers or facilitates any transactional services, you will have the opportunity to provide contact and travel-related information for other people through our Site. If you make a reservation for someone else through SmarterTravel, you will need to submit that individual’s personal information. You must obtain the consent of other individuals prior to providing us with their personal information, as any access to view or modify their information will be available only through your account.
Information from Other Sources
We also may periodically obtain both personal and non-personal information about you from affiliated entities, business partners and other independent third-party sources and add it to other information about you. For example, if you visit SmarterTravel by “clicking through” from a site operated by one of our business partners, and you have registered with that partner, then information about you that you have provided to that partner may be shared with us, such as contact information and demographic information. As another example, if you access third party services, such as social media services, through our Site or before coming to our Site, we may collect information such as your user name, password, and other information made available to us through those services. We will work with our existing partners and potential future partners to improve and personalize your use of our Site in accordance with the practices outlined in this section and Policy.
We automatically collect some information from your computer or Device when you visit SmarterTravel. For example, we will collect session data, including your IP address, Web browser software, and referring website. We also may collect information about your online activity, such as content viewed, pages visited, and searches and/or reservations facilitated or made. One of our goals in collecting this automatic information is to help us understand the interests and preferences of our users and customize your user experience.
SmarterTravel uses IP addresses to analyze trends, administer our website, and help diagnose problems with our servers. IP addresses are also used to gather broad demographic information and to prevent, investigate, and take actions in the case of suspected fraud or abuse.
How we use your information
SmarterTravel may share your information with the following entities:
- Third-party vendors who provide services or functions on our behalf, including business analytics, payment processing, customer service, marketing, public relations, distribution of surveys or sweepstakes programs, and fraud prevention. We may also authorize third-party vendors to collect information on our behalf, including, for example, as necessary to operate features of our Site or to facilitate the delivery of online advertising tailored to your interests. Third-party vendors have access to and may collect information only as needed to perform their functions and are not permitted to share or use the information for any other purpose.
- Business partners with whom we may offer products or services in conjunction. You can tell when a third party is involved in a product or service you have requested because their name will appear either with ours or separately. If you choose to access these optional services, we may share information about you, including your personal information, with those partners. Please note that we do not control the privacy practices of these third-party business partners.
- Referring Websites. If you were referred to SmarterTravel from another website, we may share your registration information, such as your name, email address, mailing address, telephone number and travel preferences, about you with that referring website. We have not placed limitations on the referring websites’ use of personal information and we encourage you to review the privacy policies of any website that referred you to SmarterTravel.
- Social Media Services. You can choose to access certain third party social media websites and services through our site (such as Facebook). When you do so, you are sharing information with those sites, and the information you share will be governed by their privacy policies. You may also be able to modify your privacy settings with these third party social media websites.
We also may share aggregate or anonymous information with third parties, including advertisers and investors. For example, we may tell our advertisers the number of visitors our Site receives or the most popular hotels and vacation destinations. This information does not contain any personal information and is used to develop content and services we hope you will find of interest. We also may share your information if we believe, in our sole discretion, that such disclosure is necessary:
- To comply with legitimate and enforceable subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us.
- In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
Other than as set out above, you will be notified when personal information about you will be shared with third parties, and you will have an opportunity to choose not to have us share such information.
We also may share aggregate or anonymous information with third parties, including advertisers and investors. For example, we may tell our advertisers the number of visitors our Site receives or the most popular hotels and vacation destinations. This information does not contain any personal information and is used to develop content and services we hope you will find of interest.
If SmarterTravel offers or facilitates any transactional services, we will collect payment information from you, including your credit card number, cardholder name, expiration date, authentication code, and billing address. We will securely transmit this information to the supplier of the travel reservation to complete the transaction. Please note that the supplier processes your payment, not SmarterTravel, unless otherwise specified. You agree to review and be bound by the supplier’s policies and procedures before making a reservation through SmarterTravel.
SmarterTravel.com is a product managed by SmarterTravel Media LLC. SmarterTravel Media LLC, from time to time may compare, merge, or append information collected on SmarterTravel.com with data from one or more other sites managed by SmarterTravel Media LLC. Similarly, information you provide on other SmarterTravel Media LLC, managed sites may be compared, merged, or appended to information you provide via SmarterTravel.
Sweepstakes, Online Surveys, and Order Forms
SmarterTravel occasionally runs sweepstakes, hosts online surveys, or uses order forms on our Site in which we ask for contact and demographic information. Participation in sweepstakes and surveys and usage of order forms is completely voluntary and the user therefore has a choice whether or not to disclose this information. We use or may use your contact information (such as email address) from your sweepstakes entry, survey registration, or order form to inform you if you are the potential winner of a contest or promotion, personalize your experience with SmarterTravel, send you newsletters (should you opt in for these newsletters) and occasional information about our services or partners, or investigate cases of suspected fraud. You may opt out of receiving future communications; see the Opting Out of Further Communications section below.
Demographic and profile data (such as zip code, age, or gender) may be used to customize your experience at our site, showing you content and advertising that may best suit your needs. This information is shared with advertisers and other third parties on an aggregate basis only. In the event that SmarterTravel partners with a third party to run a sweepstakes, SmarterTravel may share demographic and profile data with such third party only as indicated in the official sweepstakes rules.
Tell-a-Friend and Email This Deal
SmarterTravel offers services to allow our users to send information about our site to their friends. If a user elects to use our Tell-a-Friend referral service for informing a friend about our site, or elects to use our Email This Deal service to inform a friend about deals on our site, we ask them for the friend’s email address. We will automatically send the friend a one-time email inviting them to visit our site. We store this information for the purpose of sending this one-time email and investigating suspected fraud.
Children Under 13 Years Old
SmarterTravel and its affiliated sites do not knowingly collect, maintain or use personal information from our websites about children under age 13. Children under the age of 13 may not participate in any online activities on SmarterTravel Media LLC’s web sites. If a child whom we know to be under age 13 sends personal information to us online, we will only use that information to respond directly to that child, notify parents, or seek parental consent.
SmarterTravel uses a web analytics company to track and generate reports on visitor use of SmarterTravel. We use the web analytics company to analyze visitor activity so that we may better understand how visitors make use of SmarterTravel, and so that we may better tailor content to meet our visitors’ needs. This data may include individual visitor click behavior. However, no personally identifiable information is shared with the web analytics company. Although our web analytics company logs the information coming from SmarterTravel on our behalf, we control how that data may and may not be used. Visitors who wish to opt-out of this website analysis tool may do so by clicking here (This is an external link to our web analytics company and will open in a new window.).
Location Information and Other Information from Devices
When you use an Application on a Device, we will collect and use information about you in generally similar ways and for similar purposes as when you use the SmarterTravel Site. In addition, we may collect information about your location if you have instructed your Device to send such information to the Application via the privacy settings on that Device, or if you have uploaded photos tagged with location information. We may use the location information collected from your Device or photos to enhance your use of the Application by providing you with relevant content and contextual advertising. For example, we may use your location to show you reviews of hotels or restaurants near you when you are traveling. You can change the privacy settings of your Device at any time, in order to turn off the functionality to share location information with the Application and/or the functionality to tag your photos with location information. Please note that turning off location sharing may affect certain features of our App. If you have any queries about the privacy settings of your Device, we suggest you contact the manufacturer of your Device or your mobile service provider for help.
Furthermore, SmarterTravel uses outside media companies to display advertisements on our site. These ads may contain cookies, which are collected and tracked by the outside media company. SmarterTravel has no access to or control over these cookies.
This Site participates in exchanges of anonymous information about user browsing behavior on the Site. This non-personally identifiable information is collected by cookies and other similar technologies and segmented into different anonymized groups. We may share these types of anonymous information with third parties to facilitate the display of targeted advertisements. Please click here or here to learn more about these types of exchanges, including how to access information about the topics of interest associated with cookies and your options with regard to participation in these programs (including opting-out).
Our sites also may use Web beacons (also known as clear gifs, pixel tags or Web bugs), which are tiny graphics with a unique identifier, similar in function to cookies, that are placed in the code of a Web page. We use Web beacons to monitor the traffic patterns of users from one page within our sites to another, to deliver or communicate with cookies, to understand whether you have come to our site from an online advertisement displayed on a third-party website, and to improve site performance. We also may allow our service providers to use Web beacons to help us understand which emails have been opened by recipients and to track the visitor traffic and actions on our site. This helps us measure the effectiveness of our content and other offerings.
Links to Other Sites
SmarterTravel contains links to other websites. We are not responsible for the privacy practices or the content of such websites. We encourage you to be aware when you leave our site and to read the privacy statements of every website that collects personally identifiable information.
Display of Advertising/Your Choices
Data collected to serve you with relevant advertising
SmarterTravel and its affiliated websites are committed to providing you with relevant content and information across our sites. To do this, we may collect information about your travel-related searches and other site activities, such as whether you are looking for airline flights or hotels, and use this information to serve you with ads on our sites or elsewhere online that match your apparent interests. So, for example, if you search for a flight to Florida on TripAdvisor, you may see an ad for a Florida travel package on SmarterTravel.com or on another website you visit.
We do not share your personal information (such as email addresses) with unaffiliated third parties so they can serve you with advertisements. You can choose not to receive relevant online advertising on other websites, based on your travel-related searches on SmarterTravel by clicking here.
Data collected by business partners and ad networks to serve you with relevant advertising
Many of the advertisements you see on the SmarterTravel and TripAdvisor family of sites are served by TripAdvisor or its service providers. But we also allow third parties to collect information about your online activities through cookies and other technologies. These third parties include (1) business partners, who collect information when you view or interact with one of their advertisements on our sites, and (2) advertising networks, who collect information about your interests when you view or interact with one of the advertisements they place on many different websites on the Internet. The information gathered by these third parties is used to make predictions about your characteristics, interests or preferences and to display advertisements on our sites and across the Internet tailored to your apparent interests.
Response to Do Not Track signals
Your web browser may transmit a “Do Not Track” (“DNT”) signal to SmarterTravel and other websites. Because of differences in web browsers’ default settings and the manner in which browsers incorporate DNT signals, it is sometimes unclear to site operators whether site visitors have selected the DNT setting themselves, or whether they are aware that they have a choice in determining the setting. SmarterTravel does not currently respond to DNT signals. Once the Internet industry has settled on standards related to this issue and SmarterTravel recognizes such standards, we may reevaluate this approach.
Security, Fraud, and Abuse
This site has security measures in place to protect the loss, misuse, and alteration of the information under our control. SmarterTravel regularly reviews these measures to better protect users. While no website can guarantee security, we have implemented appropriate administrative, technical and physical security procedures to help protect the personal information you provide to us. For example, only authorized employees are permitted to access personal information, and they only may do so for permitted business functions. In addition, we use encryption when transmitting your personal information between your system and ours, and between our system and those of the parties with whom we share sensitive information, and we employ firewalls and intrusion detection systems to help prevent unauthorized persons from gaining access to your information.
Occasionally information may be provided to SmarterTravel fraudulently or by an individual unauthorized to provide such information. SmarterTravel may use all information it collects for reasonable investigation and prosecution of suspected fraud and/or abuse. SmarterTravel may provide all information it collects to third parties as necessary to comply with law enforcement requests or other legal requirements.
SmarterTravel does not ensure or warrant the security of any information transmitted to us over the Internet.
Service and Partner Updates
We send our users service and partner announcements from time to time. Members are not able to unsubscribe from service announcements, which contain information about our services and partners, without opting out of all SmarterTravel newsletters. You may opt out of receiving future communications; see the Opting Out of Further Communications section below.
We communicate with our users to provide requested services and in regards to issues relating to their account via email, telephone, or postal mail.
Opting Out of Further Communications and Updating Personal Information
SmarterTravel subscribers may opt out of receiving future SmarterTravel communications or update their personal information using any of the following methods:
- Email: email@example.com or firstname.lastname@example.org.
- Fax: 617-886-5501
- Mail: SmarterTravel Media LLC, 226 Causeway Street, Third Floor, Boston, MA 02114 attn: SmarterTravel Customer Service
To opt out of future communications from SmarterTravel’s partners, please contact the partner directly. For assistance with this, please contact SmarterTravel Customer Service: email@example.com.
Visiting our Site from outside the United States
If you are visiting our Site from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, but please be assured that TripAdvisor does take steps pursuant to laws in the United States to ensure that your privacy is protected. By using our services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Policy.
California Consumer Privacy Act Privacy Statement (“CCPA Statement”)
This CCPA Statement is provided pursuant to the California Consumer Privacy Act (“CCPA”) and applies to California residents and supplements our overall Privacy Statement with additional disclosures and rights.
Your rights under CCPA
As of January 1 2020, California law permits residents of California to request certain details about how their personal information is shared with third-parties or affiliated companies for direct marketing purposes.
California residents may also take advantage of the following rights:
- You may request, up to two times each year, that we disclose to you the categories and specific pieces of personal information that we have collected about you, the categories of sources from which your personal information is collected, the business or commercial purpose for collecting your personal information, the categories of personal information that we disclosed for a business purpose, any categories of personal information about you that we sold, the categories of third-parties with whom we have shared your personal information, and the business or commercial purpose for selling your personal information, if applicable.
- You may request that we delete any personal information that we have collected from or about you. As described in more detail in our Privacy Statement, there are some reasons we will not be able to fully address your deletion request, such as if we need to complete a transaction for you, to detect and protect against fraudulent and illegal activity, to exercise our rights, or to comply with a legal obligation.
- You may request to opt out of our sale of your personal information to third-parties for their direct marketing purposes. This means that, if you opt out, going forward, we will not share your information with such third-parties to use for their purposes unless you later direct us to do so. To effect the opt out, please click on the Do Not Sell My Personal Information link on our website footer or submit a request in writing to the contact information below.
To take advantage of your disclosure and deletion rights, please contact us via email at firstname.lastname@example.org. We may need to verify your identity to enable us to process your request. We value your privacy and will not discriminate in response to your exercise of privacy rights. We will respond to your request within 45 days of receipt of your request, after proper verification, unless we need additional time, in which case we will let you know.
For purposes of compliance with the CCPA, in addition to the further details as described in the Statement, we make the following disclosures:
- We collect the following categories of personal information: Identifiers/Contact Information, transactional information, Internet or other electronic network activity information, geolocation, visual and audio information, and inferences drawn from the above.
- We sell the following categories of personal information: Identifiers/Contact Information, Internet or other electronic network activity information, and inferences drawn from the above.
We disclose the following categories of personal information for a business purpose: Identifiers/Contact Information, commercial information, Internet or other electronic network activity information, geolocation, visual and audio information, and inferences drawn from the above.
Notification of Changes
As part of operations, SmarterTravel may sell, transfer, or merge particular businesses, newsletters, and/or other assets to a third party. As part of such a transaction, personal information users have provided to SmarterTravel may be given to a third party.
SmarterTravel attempts to comply with all legislative and judicial orders. These orders will take precedence over the details stated in the policy above.
SmarterTravel Media LLC
226 Causeway Street, Third Floor
Boston, MA 02114