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1. Our Collection of Personal Data .

We collect personal data about you in a variety of ways. Sometimes we collect personal data automatically when you interact with the Services, and sometimes we collect the personal data directly from you. At times, we may collect personal data about you from other sources and third parties, even before our first direct interaction. We may link or combine your activities and information collected from you on our website and mobile applications with information we have collected from you offline (e.g., at an event), information we receive from third parties, as well as information we collect automatically through tracking technologies (as discussed in our Cookie Notice located at the bottom of our homepage).

• Contact Information, such as your name, telephone numbers, email address, and billing and mailing address.
• Content You Choose to Upload to Our Websites or Mobile Applications, such as text and images along with the metadata associated with the files you upload.
• Feedback or Correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
• Marketing Information, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications.
• Profile Information, such as your username and password that you may set to establish an online account with us, your photograph, personal bio, your interests, travel preferences, activities, lifestyle preferences, and favorite hotels or destinations.
• Payment Information, such as credit or debit card details and billing address. Payments may be processed by third-party payment processors.  Please refer to the applicable processor’s terms and privacy notice for more information about how payment information is processed and stored.
• Publicly Available Information, including comments describing support for and experience with our websites or mobile applications and information that you or others publish on social media, testimonials, blogs or other forums, such as tweets, comments, photographs, or video or audio content.
• Transaction Information based on your activities on our website, such as details about reservations you make through Tablet or your travel plans.
• Registration Information, details about your participation in loyalty or awards programs (such as hotel rewards programs) and applicable membership numbers.

• Our Affiliates. We may receive information about you from our affiliates, so that information you provide to one affiliate may be used by us to provide you Services, communicate with you, or provide you advertisements or other personalized content.
• Hotel Partners. If you make a hotel booking through Tablet or through one of our hotel partners directly, we may receive information from our hotel partner, such as your reservation details.
• Service Providers. Our service providers that perform services on our behalf, such as our call center operations vendors, identity verification providers, payment processors, third party dealers that deliver products and services on our behalf, and analytics providers.  For example, we may receive personal data from our service providers that conduct call center support, marketing, or analytics activities.
• Business / Promotional Partners. Our business and promotional partners whom we partner with to provide our contests, sweepstakes or other joint promotional activities or co-branded services may collect personal data in connection with these activities and may share some or all the information with us.
• Social Networks. When you interact with the Services through various social media networks, such as when you “Like” us on Facebook or when you follow us or share our content on Facebook, Pinterest, Twitter, Instagram, YouTube, LinkedIn or other social networks, we may receive some information about you that you permit the social network to share with third parties.  The data we receive is dependent upon your privacy settings with the social network.  You should always review and, if necessary, adjust your privacy settings on third party websites and social media networks and services before linking or connecting them to the Services.
• Other Third Parties and Publicly Available Sources. From time to time, we may receive information about you from third parties.  For example, we may obtain information from our marketing partners or from third parties to enhance or supplement our existing user information.  Where permitted by applicable law, we may also collect information about you that is publicly available, including contact information and travel interest information.  We may combine this information with the information we collect from you directly.

1.3   Business Representatives Data Collection Practices.  We also may collect professional personal data about representatives of third-party businesses, including representatives of our business, hotel, and enterprise customers and our hotel and other business partners, in connection with our Services and the operation of our business, which may include.

• Contact Information: Including full name, email address, mailing address and telephone number.
• Professional Information: Including job title, job function, company name and characteristics, professional background, and nature of the relationship with us.
• Tax and Payment Information: Including a personal tax identification number, bank account information, and payment information where the individual is a representative of a sole proprietor or similar legal structure that uses personal tax and account information in lieu of separate business information.
• Contract Information: Including any information relating to our contractual relationship.
• Inquiry Information: Including the contents of emails, texts, and other communications and, where permitted by law, recordings of calls with us.
• Feedback Information: Including information provided in response to surveys we may conduct with customers or business partners, or unsolicited feedback received regarding our services and business.

If you engage in our Services or interact with us through your employer, company or organization, we may receive the above information from the company.

We, our service providers, and other third parties may automatically collect information about you, your computer or mobile device, and activity occurring on or through our websites and mobile applications.  The information that may be collected automatically includes:

• Device Data, such as your device’s hardware, model and screen resolution, your browser type, device identifier (e.g., Google Advertising ID or Apple ID for Advertising), your IP address and general location information such as city, state, or geographic area.
• Online Activity Data, such as pages you viewed, how long you spent on a page, navigation paths between pages, information about your activity on a page, links you click, access times, and length of access; the website that referred you to Tablet, if applicable, and whether you opened our email and how long you had it open.
• Location Information.  If you have enabled location services on your phone and agree to the collection of your location when prompted in the Tablet mobile application, Tablet will collect your location information when you use the mobile applications; for example, to locate restaurants and hotels near you.  If you do not want Tablet to collect this information, you may decline the collection of your location when prompted or adjust the location services settings on your device.

For information about our and our third-party partners’ use of cookies and related technologies to collect information automatically, and the choices you have in relation to its collection, please see our Cookie Notice.  Please see the “Your Choices About Online Ads” section of the Cookie Notice for information about how to exercise choice regarding the use of browsing behavior for purposes of targeted advertising.

2. Our Use of Personal Data

We may use your personal data for the following purposes and as otherwise described in this Privacy Notice or at the time of collection:

• To Facilitate Your Hotel Booking, including to collect your name, payment card information and other details and provide this information to the hotel or hotel’s service provider.

• To Operate Our Services, Including to:

• make hotel reservations and communicate with you about your reservations;
• establish and maintain your account and user profile on our websites or mobile applications;
• provide services and customer support you request;
• personalize your experience and customize content on the Services relevant to your interests;
• resolve disputes and troubleshoot problems.

• To Communicate With You, including to:

• inform you about our services, updates, and promotional offers based on your communication preferences;
• send you announcements, updates, security alerts, and support and administrative messages;
• respond to your requests, questions and feedback;
• send you marketing communications.

• For Compliance, Fraud Prevention, and Safety, including to:

• prevent potentially prohibited or illegal activities such as negligence, breach of contract or fraud, and enforce our Terms of Use and other notices;
• audit compliance with our notices and contractual obligations;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• enforce the terms and conditions that govern our websites and mobile applications;
• protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

• For Research and Development.  We analyze use of our websites and mobile applications to analyze, improve our websites and mobile applications, and to develop new products and services, including by studying user demographics and use of our websites and mobile applications.

• To Display Advertisements.  We work with advertising partners to display advertisements across the web.  These advertisements are delivered by our advertising partners and may be targeted based on your use of Tablet or your activity elsewhere online.  To learn more about your choices in connection with advertisements, please see the “Your Choices About Online Ads” section of our Cookie Notice.

• To Comply With Law.  We use your personal data as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

• With Your Consent.  In some cases, we may specifically ask for your consent to collect, use or share your personal data, such as when required by law.

• To Create Anonymous, Aggregated or De-Identified Data.  We may create anonymous, aggregated or de-identified data from your personal data and other individuals whose personal data we collect.  We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve our website and mobile applications, analyze user demographics and use of the websites and mobile applications, and promote our business.
• For purposes disclosed at the time you provide your personal data or as otherwise set forth in this Privacy Notice.

We may provide additional privacy disclosures where the scope of the inquiry/request and/or personal data we require fall outside the scope of this Privacy Notice.  In that case, the additional privacy disclosures will govern how we collect, use and disclose the information you provide at that time.

3. Our Disclosure of Personal Data

We may disclose your personal data in the following circumstances or as described in this Privacy Notice:

• Affiliates.  We may share your personal data with our corporate parent, subsidiaries, and affiliates.
• Hotels.  We may share your personal data with the hotels where you make bookings through Tablet (or the hotels’ service providers and/or channel partners and/or 3rd party travel agencies with access to hotels inventory),; the hotels’ privacy notices and those of their 3rd party partners such as Booking.com’s privacy statement govern their handling of your information; our Privacy Notice does not govern the hotels’ privacy practices.
• Service Providers.  We may employ third party service providers to perform services on our behalf such as, couriers or shippers, credit card processors, marketing or research providers, web hosting and email service providers, and other data processors.
• Online Advertising Partners. We may also share personal data with advertising networks or permit these partners to collect information from you directly on our websites to facilitate online advertising, such as search engines and social network advertising providers to serve targeted ads to you or to groups of other users who share similar traits, such as likely commercial interests and demographics, on third-party platforms.  For more information, including how to opt out of interest-based advertising, please see our Cookie Notice.
• Other Users of Our Services and The Public.  We may provide functionality that enables you to disclose personal data to other users of Tablet or the public.  For instance, you may maintain a user profile with information about yourself that you can make available to other users or the public.  You may also be able to submit content to Tablet (such as comments, reviews, and photos), and we will display your name, username, and a link to your user profile along with the content you submit.
• Professional Advisors.  We may disclose your personal data to professional advisors, such as lawyers, bankers, auditors and insurers, in the connection with the professional services that they render.
• For Compliance, Fraud Prevention and Safety.  We may share your personal data for the compliance, fraud prevention and safety purposes described above.
• Business Transaction or Reorganization.  We may disclose or transfer your personal data in connection with or during the negotiation of a financing, merger, acquisition, dissolution or similar corporate event, or the sale of all or some of Tablet’s assets. The information that Tablet has collected, including personal data may be transferred as a business asset. Personal data may also be disclosed in the event of insolvency, bankruptcy, or receivership, in compliance with applicable law.
• Legal Obligations or Rights.  We may disclose personal data to third parties, such as legal advisors and law enforcement:
• in connection with the establishment, exercise, or defense of legal claims;
• to comply with laws or to respond to lawful requests and legal process;
• to protect the rights and property of Tablet, our agents, customers, and others, including to enforce our agreements, notices, and our Terms of Use;
• to detect, suppress, or prevent fraud;
• to reduce credit risk and collect debts owed to us;
• to protect the health and safety of us, our customers, or any person; or
• as otherwise required by applicable law.
• With Your Consent or At Your Direction. We may disclose personal data about you to certain other third parties with your consent or at your direction.

4. Choices and Control Over Your Data

Depending on the jurisdiction in which you are located, you may be able to submit the following requests:

• Access and Amend Your Information.  You can access your personal data in your account.  You can change at any time your preferences for receiving or not receiving our emails and e-newsletters.  If you wish to modify your personal data or close your account, you can do so by contacting us as indicated in the “Contact Information” section below.  Once your account is closed, however, you will not be able to use many of the services available on our websites and mobile applications, unless you re-register.
• Cookies and Browser Web Storage.  We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across Tablet and third-party websites.  Please see our Cookie Notice for more information on the choices and controls you may have with cookies and similar technologies.

• Targeted Online Advertising.  Please refer to our Cookie Notice to learn more about how we work with third party partners to collect data through tracking technologies for various purposes, including analytics, advertising, and to understand your choices.
• Opting Out of Marketing Communications.  You may opt out of receiving marketing-related emails from us or change the volume of marketing-related emails you receive from us by following the update settings or unsubscribe instructions at the bottom of the email or by changing your preferences in the email preference center accessible through your account settings.  You may continue to receive service-related and other non-marketing emails from us.
• Opting Out of Location Tracking.  If you initially consented to the collection of geo-location information through the Tablet mobile application, you could subsequently stop the collection of this information at any time by changing the preferences on your mobile device.  Please note, however, that if you withdraw consent to Tablet’s collection of location information, you may no longer be able to use some Tablet features.

5. Third Parties

Tablet may contain links to other websites, mobile applications, and other online services operated by third parties.  These links are not an endorsement of, or representation that we are affiliated with, any third party.  Different rules may apply to other websites, mobile applications, or online services.  This Privacy Notice does not apply to, and we are not responsible for, any personal data practices of third-party websites and online services or the practices of other third parties. Tablet does not control the privacy notices of third parties.  We encourage you to review the privacy notices of the websites, mobile applications, or online services that you use or visit.

6. International Data Transfers

We are headquartered in the United States and have service providers in other countries, and your personal data may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.

7. Children’s Personal Data

Tablet is not directed to, and we do not knowingly collect personal data from, anyone under the age of 16.  If we learn that we have collected personal data of a child under the age of 16, we will promptly delete such information.  If a child under the age of 16 has provided personal data to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal data from our systems.

8. Updates To This Privacy Notice

We may amend this Privacy Notice at any time by posting the amended terms on this website.  In addition, we will notify you of material changes, such as with an alert on the Tablet website or a communication to you via email (at the e-mail address specified in your account). All changes shall be effective from the date of publication unless otherwise provided.

9. Contact Information

Should you have any questions or concerns regarding this Privacy Notice, please contact us at privacy@tablethotels.com or the following address:

Tablet Inc.
6 West 18th Street, 5th Floor
New York, NY 10011 USA

1.  Personal Data

References to “personal data” in this Privacy Notice are equivalent to “personal data” governed by European data protection legislation.

2.  Controller and Processor

• Tablet is a controller with respect to the personal data we collect to create and maintain consumers’ Tablet accounts or memberships, or when we interact with consumers about Tablet’s own services.
• Tablet is a processor and service provider to hotels in facilitating your bookings.  When you book a hotel through Tablet, you also direct us to share your details with the hotel to facilitate the booking.  You should refer to the hotel’s privacy notice for information about the hotel’s privacy practices because this Privacy Notice does not govern the hotel’s handling of your information.

3.   EU Representative.

VeraSafe has been appointed as Tablet’s representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union.  VeraSafe can be contacted on matters related to the processing of personal data using one of the following methods:

• via web form:  https://www.verasafe.com/privacy-services/contact-article-27-representative
• via telephone at:  +420 228 881 031

4.   Legal Bases for Processing.

We use your personal data only as permitted by law.  Our legal bases for processing the personal data described in this Privacy Notice are described in the table below.

5.  Use for New Purposes .

We may use your personal data for reasons not described in this Privacy Notice where permitted by law and the reason is compatible with the purpose for which we collected it.  If we need to use your personal data for an unrelated purpose, we will notify you and explain the applicable legal basis.

6. Sensitive Personal Data .

We ask that you not provide us with any sensitive personal data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through our websites and mobile applications, or otherwise to us.  If you provide us with any sensitive personal data to us when you use Tablet, you must consent to our processing and use of such sensitive personal data in accordance with this Privacy Notice.  If you do not consent to our processing and use of such sensitive personal data, you must not submit such sensitive personal data through our websites and mobile applications.

7.  Retention .

We retain personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

8.   Your Rights .

European data protection laws give you certain rights regarding your personal data.  If you are located within the Europe, you may ask us to take the following actions in relation to your personal data that we hold:

• Access.  Provide you with information about our processing of your personal data and give you access to your personal data.
• Correct.  Update or correct inaccuracies in your personal data.
• Delete.  Delete your personal data.
• Transfer.  Transfer a machine-readable copy of your personal data to you or a third party of your choice.
• Restrict.  Restrict the processing of your personal data.
• Object.  Object to our reliance on our legitimate interests as the basis of our processing of your personal data that impacts your rights.

You may submit these requests by email to privacy@tablethotels.com or our postal address provided above.  We may request specific information from you to help us confirm your identity and process your request.  Applicable law may require or permit us to decline or limit your request.  If we decline your request, we will tell you why, subject to legal restrictions.  If you would like to submit a complaint about our use of your personal data or our response to your requests regarding your personal data, you may contact us or submit a complaint to the data protection regulator in your jurisdiction.  You can find your data protection regulator here.

9. Cross-Border Data Transfer

If we transfer your personal data out of Europe to a country not deemed by the European Commission to provide an adequate level of personal data protection, the transfer will be performed:

• Pursuant to the recipient’s compliance with standard contractual clauses, EU-US Privacy Shield (or Swiss-US Privacy Shield, as applicable), or Binding Corporate Rules
• Pursuant to the consent of the individual to whom the personal data pertains.
• As otherwise permitted by applicable European requirements.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Europe.

1. Scope of Disclosures

For Nevada Residents: Chapter 603A of the Nevada Revised Statutes permits Nevada residents to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please email privacy@tablethotels.com

For California and Virginia Residents: These Additional U.S. Privacy Disclosures (the “U.S. Privacy Disclosures”) supplement the information contained in our Privacy Notice regarding the Tablet websites, products and service offerings, mobile applications and services that post or link to these U.S. Privacy Disclosures and apply solely to individual residents of the State of California and Virginia (“data subjects” or “you”).

These U.S. Privacy Disclosures provide additional information about how we collect, use, disclose and otherwise process personal data of individual residents of the State of California and Virginia, either online or offline.

Unless otherwise expressly stated, all terms in these U.S. Privacy Disclosures have the same meaning as defined in our Privacy Notice.

2. Personal Data Disclosures

Personal Data

We collect various categories and types of personal data from a variety of sources and for a variety of purposes. We also disclose personal data to a number of recipients. Please review the Our Collection of Personal Data, Our Use of Personal Data, and Our Disclosure of Personal Data sections of our Privacy Notice to learn more. While we do not “sell” personal data in the traditional sense, we do, however, sell or share personal data for the purpose of displaying advertisements that are selected based on personal data obtained or inferred over time from an individual’s activities across businesses or distinctly branded websites, applications, or other services (otherwise known as “targeted advertising” or “cross-context behavioral advertising”).

Sensitive Information

The following personal data elements we collect may be classified as “sensitive” under certain privacy laws (“sensitive information”):

• Account name and password;
• Credit/debit card number plus expiration date and security code (CVV);
• Precise geolocation data.

As described in our Privacy Notice, we use account name and password, as well as payment card information, to provide certain of our products and services. We also use precise geolocation data to provide our Services with geolocation capabilities.

We do not sell sensitive information, and we do not process or otherwise share sensitive information for the purpose of targeted advertising.

Deidentified Information

We may at times receive, or process personal data to create, deidentified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by law.

3.   Your Privacy Rights

Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

4. How to Exercise Your Privacy Rights

To Exercise Your Privacy Rights

Please subject a request by:

• Filling out our online form;
• Calling 1-888-971-3804; or
• Emailing privacy@tablethotels.com with the subject line, “U.S. Data Subject Request.”

We will need to verify your identity and confirm you are a resident of a state that offers the request right(s) before processing your request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. As a result, we require requests to include name, email address, and state of residency. Although we try to limit the personal data collected in connection with a request to exercise any of the above rights, certain requests may require us to obtain additional personal data from you. In certain circumstances, we may decline a request, particularly where we are unable to verify your identity or locate your information in our systems, or where you are not a resident of one of the eligible states.

To Exercise the Right to Opt Out of the Selling or Sharing of Personal Data for Targeted Advertising Purposes

We may sell or share personal data (including Identifiers, Commercial Information, Internet/Network Information, and Inferences) to certain third-party ad networks, social networks and advertising partners to deliver targeted advertising (also known as “cross-context behavioral advertising”) and personalized content to you on our Services, on other sites and services you may use, and across other devices you may use, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

The third parties to whom we sell or share personal data may use such information for their own purposes, in accordance with their own privacy statements, which may include reselling or sharing this information to additional third parties.

To facilitate these targeted advertising purposes, we and our third-party providers use cookies and related technologies to collect personal data about users of our Services. To exercise your right to opt-out as it relates to the use of cookies and related technologies that involve the sale of personal data or the use of personal data for targeted advertising purposes on our Services, please click the link at the bottom of our homepage to adjust your cookie preferences.

Please note these cookie options may be unchecked or opted out by default. In addition, this opt-out tool is device and browser specific, so you will need to change your preferences on each device and browser you use to interact with the Site or Service you are visiting.

You can also opt out of cookie-based sales by businesses that participate in the DAA’s CCPA Opt-Out Tool by visiting https://www.privacyrights.info/. In addition, you may follow the other steps set forth in our Cookie Notice to further exercise control over cookies and related technologies. Lastly, you may exercise your non-cookie-related rights by following the instructions provided at the beginning of this “How to Exercise Your Privacy Rights” section.

Authorized Agents

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.

Appealing Privacy Rights Decisions

Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted by emailing us at privacy@tablethotels.com with the subject line, “Privacy Request Appeal.”

Minors Under Age 16

We do not sell the personal data of consumers we know to be less than 16 years of age. Please contact us at privacy@tablethotels.com to inform us if you, or your minor child, are under the age of 16.

5.   California-Specific Privacy Disclosures

The following disclosures only apply to residents of the State of California:

Personal Data Collection

In the last 12 months, we may have collected the following categories of personal data:

• Identifiers, such as name, email address, telephone number, address, zip code, account username and password, or other similar identifiers.
• California Customer Records (Cal. Civ. Code § 1798.80(e)), such as driver’s license information, credit/debit card information, bank account information or other payment information.
• Protected Classification Characteristics, such as age.
• Commercial Information, such information about products or services purchased or considered, whether you used a particular coupon code or promotion, information about the hotel for which you booked a reservation, reservation details, and information about your use of the Services.
• Internet/Network Information, such as your browsing history, log and analytics data, search history and information regarding your interaction with our website and platform.
• Geolocation Data, such as information about your physical location collected from geolocation features on your device, including your IP address and GPS (e.g., latitude and/or longitude).
• Sensory Information, such as pictures you provide or upload in connection with the Services, and the content and audio recordings of phone calls between you and Tablet and/or you and our service providers, that we record where permitted by law.
• Professional/Employment Information, such as job title, department, employer or business.
• Other Personal Data, such as information and content you upload or post to the Services and other information you submit to us, including inquiry, feedback and communication information when you contact us, and your profile information.
• Inferences, including information generated from your use of the Services reflecting predictions about your interests and preferences.

For more information about our collection of personal data, the sources of personal data, and how we use this information, please see the Our Collection of Personal Data and Our Use of Personal Data sections of our Privacy Notice.

Disclosure of Personal Data

As described in the Our Disclosure of Personal Data section of our Privacy Notice, we disclose personal data with a variety of third parties for business purposes or we may sell or share your personal data to third parties for targeted advertising purposes, subject to your right to opt out of selling or sharing (see “How to Exercise Your Privacy Rights” above).

In the previous 12 months, we have sold or shared for targeted advertising purposes all of the categories of personal data we collect, explained above, to third parties.

Data Retention

We retain personal data only for as long as is reasonably necessary to fulfill the purpose for which it was collected. However, if necessary, we may retain personal data for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator or other government authority.

To determine the appropriate duration of the retention of personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting and other applicable obligations.

Therefore, we retain personal data for as long as the individual continues to use our services for the purposes explained in the Our Use of Personal Data section in our Privacy Notice. When an individual discontinues the use of our services, we will retain their personal data for as long as necessary to comply with our legal obligations, to resolve disputes and defend claims, as well as, for any additional purpose based on the choices they have made, such as to receive marketing communications. In particular, we will retain call recordings, the personal data supplied when joining our services, including complaints, claims (for insurance products) and any other personal data supplied during the duration of an individual’s contract with us for the services until the statutory limitation periods have expired, when this is necessary for the establishment, exercise or defense of legal claims.

Once retention of the personal data is no longer necessary for the purposes outlined above, we will either delete or deidentify the personal data or, if this is not possible (for example, because personal data has been stored in backup archives), then we will securely store the personal data and isolate it from further processing until deletion or deidentification is possible.

Notice of Financial Incentives

We offer various programs, promotions and other financial incentives that may result in differences in our prices or services offered to consumers. For example:

• Discounts, coupons or other benefits in connection with a contest or sweepstakes or similar promotions;
• Rewards or coupons when you refer a friend to use our service;
• Loyalty and member programs, where you earn or receive certain rewards or benefits; or
• Discounts, coupons, cash back, and other special offers for making reservations with our hotel partners.

To obtain access to certain of these programs and other offerings, we may collect and retain personal data, such as, but not limited to name, contact information, billing information, and account information. We may sell or share personal data with our business and marketing partners who may use this information to send you promotional communications and targeted advertising.

We have determined that the value of these programs and other incentives are reasonably related to the value of the personal data we receive and otherwise process in connection with these programs and offerings, based on our reasonable but sole determination. We estimate the value of the personal data we receive and otherwise process in connection with these programs and offerings by considering the expense we incur in collecting and processing the personal data, as well as the expenses related to facilitating the program or offering.

The material aspects of any financial incentive will be explained and described in its program terms or in the details of the incentive offer. Participating in any financial incentive program is entirely optional and participants may withdraw from the program at any time. To opt-out of the program and forgo any ongoing incentives, please follow the instructions in the program’s terms and conditions or contact us using the contact information below.  Participating individuals may also opt out of receiving marketing communications by following the instructions set forth in the Choices and Control Over Your Information section of our Privacy Notice.

6. Updates to These U.S. Privacy Disclosures

We will update these U.S. Privacy Disclosures from time to time. When we make changes to these U.S. Privacy Disclosures, we will change the “Last Updated” date at the beginning of these U.S. Privacy Disclosures. If we make material changes to these U.S. Privacy Disclosures, we will notify you by email to your registered email address, by prominently posting on our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.

7. Contact Us

If you have any questions or requests in connection with these U.S. Privacy Disclosures or other privacy-related matters, please send an email to privacy@tablethotels.com.