Privacy Policy

INTRODUCTION

The sole operator, Universalholidays Inc. (also known as "Universalholidays," "we," "us," or "our"), appreciates your trust and wants you to understand how we gather, use, and share information. This Privacy Policy outlines our policies regarding the information we gather when you visit or utilize any of our websites (such as www.cheapoair.com), software applications we make available for use on mobile devices (the "Apps"), or services we offer through our various channels, such as our Websites, Apps, and contact centers (collectively, the "Websites"). You accept the terms and conditions of this Privacy Policy and the related Terms and Conditions by accessing or using any of our websites, applications, or services in any other way.

PERSONAL INFORMATION

Personal Information We May Collect

""Personal Information" is any information that can be used to identify you personally or that is connected to a specific individual, including:

• Name
• Postal addresses
• Telephone number
• Email address
• Credit and debit card number and related information
• Social media account ID
• Passport number
• Number given forth by a transportation organization, like a recognized traveler number from the Transportation Security Administration
• Demographic information
• Analytics/Advertising Data (such as where tied to a user/device ID)
• Inferences about you
• Any other details you give us when you contact or make a trip reservation, such as your dietary requirements and other preferences, together with details about your reservations, such as your departure and destination points

In connection with the Services, you signify that you have the legal right to provide any Personal Information about other persons to us or our service providers, and that you agree to allow us to use the information in accordance with this Privacy Policy.

How We May Collect Personal Information

Personal Information may be gathered by us and other third parties in a number of ways, such as:

• Whenever you make a reservation, sign up for a promotion, provide a preferred method of communication, or make special travel requests (like those pertaining to a disability or dietary restriction), among other actions, we may obtain Personal Information through the Services (e.g., when you provide it to us or where such information is collected automatically).
• When you contact customer care, for example, we might gather Personal Information from you offline.:
• If permitted by relevant legislation, we may obtain your Personal Information from additional sources, including public databases, joint marketing partners, social media platforms (including from friends and other related parties), and other third parties.

Analytics/Advertising Data

Like many other digital properties, we and our third-party partners might automatically gather and use information that you give us, as well as information about your device and how you use the Services. The following (together, "Analytics/Advertising Data") could be among the categories of information:

• Information about the browser and device (such as the IP address, the kind and version of the browser or device, other user agent string data, and geolocation information), as well as other digital user IDs.
• Usage information about our services, including the route taken to get to, through, and out of them, the page you are on or have visited, the links you have clicked, the videos or other content you have viewed, email open rates, mouse movements, scrolls, clicks, keystroke activity, browsing, search, or purchase behavior, and the use of our chat function.
• Measurement data related to advertising and advertising: information about how you view or click on ads on our services; cookie IDs or other digital or proprietary IDs (like Google AAID or iOS IDFA) linked to that device; the kinds of data mentioned above; purchases or other conversions related to ads on other properties; hashed emails or phone numbers.

While we shall use such data as we see fit in accordance with existing legislation, in certain circumstances the aforementioned may not be deemed "Personal Information" in and of itself under applicable law. But we may combine Analytics/Advertising Data with Personal Information; in that case, we'll treat the combined data as Personal Information covered by this Privacy Policy.

How We May Collect Analytics/Advertising Data

Analytics and advertising data may be gathered by us and our third-party service partners in a number of ways, such as:

• Most browsers collect certain information automatically through your device or through your computer, such as your Media Access Control (MAC) address, computer type (e.g., Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, type and version of Internet browser, and the name and version of the Services (e.g., App) you are using.
• Upon downloading and using an App or Website, we, along with our third-party partners, may monitor and gather usage data about the App or Website, including the time and date the App or Website on your device accesses our servers and the files and information that have been downloaded to or from the App or Website depending on your device.
• Cookies are kind of data files that are kept on your computer immediately. Cookies, in general, enable us to gather or read data about the type of browser used, the amount of time spent using the Services, user IDs, pages seen, preferred language, and other traffic data that is anonymous or pseudonymous. For further details, please refer to our Cookie Policy here.
• In connection with certain Services, pixel tags—also referred to as web beacons and clear GIFs—may be used for a variety of purposes, such as tracking user behavior on the platform (including email recipients), dropping cookies, delivering and evaluating the effectiveness of our (or other advertisers') marketing campaigns, and gathering data regarding response rates and service usage.
• We might gather and keep data about how you use the Services via Flash LSOs and other technologies, among other things. Using the options in the Website Storage Settings Panel, you can modify your Flash player's settings to prevent Flash LSO storage if you do not want it stored on your computer. Alternatively, you can manage Flash LSOs by accessing the Global Storage Settings Panel and following the prompts. These might include instructions on how to exclude Flash LSOs from being installed on your computer without your consent, how to remove existing Flash LSOs (called "information" on the Macromedia site), and (for Flash Player 8 and later) how to block Flash LSOs that are not being delivered by the operator of the page you are currently on.

(It should be noted that certain Flash applications, particularly those used in conjunction with the Services, may become less functional if the Flash Player is configured to prohibit or limit acceptance of Flash LSOs.)

• Your Internet Service Provider assigns a number known as your IP address to the computer you are using automatically. Whenever a user visits the Services, their IP address, the time of the visit, and the sites they saw may all be automatically detected and recorded in our server log files. Using your IP address, we could also be able to determine your general location.
• We might use WiFi, mobile phone tower, satellite, or other signals to determine the precise position of your device. We might deliver customized location-based services and content to you by utilizing the actual location of your device. Additionally, we might offer our marketing partners access to the physical location of your device so they can serve you with geo-targeted ads or more broadly targeted ads.
• Depending on your device's settings, you might be able to approve or disapprove of these uses or sharing of your device's location. If you do, you might not be able to receive the relevant tailored services and content from us or our marketing partners.
• While we may aggregate Personal Information to determine the proportion of users with a specific phone area code, Aggregated Personal Information does not directly identify you or any other user of the Services.

How We May Use Personal Information

Below, we have mentioned how we can use your personal information -

• To fully fulfill your reservation or purchase, including handling payment processing, keeping in touch with you on your reservation or purchase, and offering you any necessary customer support. In order to make travel arrangements, we utilize passport information.
• To answer your questions and carry out your requests, including sending you newsletters.
• To offer you with administrative updates, including details about the Services and modifications to our terms, conditions, and policies.
• To provide you with customized goods and offers, send you marketing messages that we think you might find interesting, or otherwise customize your experience using our Services.
• To permit you to take part in and manage sweepstakes, competitions, and related promotions. There may be additional regulations for certain of these activities that provide more details about how we use and share your personal information. As you will be bound by any such regulations if you want to participate, we advise you to carefully read them.
• To make social sharing easier.
• To enable you to use the Services to send communications to another individual. By utilizing this feature, you are granting us permission to obtain your friend's name and email address.
• For business purposes, including data analysis, audits, fraud monitoring and prevention, crash or other error remediation and prevention (e.g., "bug" fixes), developing new products, enhancing, improving, or changing our Services, identifying usage trends, delivering and evaluating the efficacy of our promotional campaigns (e.g., ads on our or third-party platforms, marketing emails, and measuring efficacy and attribution in relation thereto), and operating and expanding our business activities.
• To combine such data such that, after being rendered non-personal information, it can be utilized for any reason as long as it complies with current laws.
• As may be otherwise revealed to you with your permission or upon notification.

In our opinion, the following situations call for our attention:

(a) in accordance with applicable law, including laws that do not apply to your state or country of residence;

(b) in order to obey legal process and to stop, detect, or prevent abuse, fraud, or criminal activity;

(c) in response to requests from public and government authorities and self-regulatory organizations, including those that do not apply to your state or country of residence;

(d) in order to enforce our terms and conditions;

(e) in order to safeguard our operations, assets, or interests, or those of any of our affiliates;

(f) in order to preserve our rights, privacy, cybersecurity, safety, or property, or that of our affiliates, you, or others; and

(g) in order to permit us to pursue available remedies or limit the damages that we may suffer.

How Confidential Information Can Be Shared?

The following organizations may receive a disclosure or transfer of your personal information. These organizations are not under our control, with the exception of our corporate affiliates and service partners, and any Personal Information you provide to them is governed by the security procedures and privacy policies of that particular organization. For this reason, we advise you to check the privacy policies of any company whose goods or services you buy through the Services:

• To our third-party travel-related suppliers, including hotels, airlines, and vehicle rental firms permit them to offer the goods and services that you reserve or pay for through the Services.
• To corporate affiliates, parent companies, subsidiaries, joint ventures, and other businesses that share global control with us for the reasons outlined in this privacy statement. The administration of the jointly used Personal Information is within the purview of Fareportal Inc.
• In reference to other travel-related businesses that we collaborate with to offer certain Services, including airline consolidators or aggregators, other travel agencies that grant access to their travel-related inventory through the Services, and travel insurance organizations.
• To our partners, whose goods or services might be made available through the Services (for example, through adverts); to them, who might run advertisements on their own services; to them, who directed you from one website or online service to another; or to whose website or online service the Services link. Examining the privacy statement of every website or online service of this kind is something we highly recommend.
• They can be our third-party service providers that offer services including email delivery, customer support, website hosting, data analysis, advertising technology, payment processing, order fulfillment, information technology and related infrastructure providing, and other services. We have confidentiality requirements regarding the information we give third-party service providers, and it is only supposed to be used for the purpose(s) that are allowed by those commitments.
• Other sponsors or organizers like doing surveys, competitions, giveaways, and related activities.
• Anyone you send communications over the Services, in order to verify your identity. Message boards, chat rooms, profile pages, blogs, and other sites where you can submit content are other places where you might decide to share your Personal Information. It is important for you to be aware that any information you share or post on these platforms will be visible to other users as well as the broader public. When determining what information to disclose on the Services, we strongly advise you to proceed with caution.
• Regarding your social sharing activity, it is possible for your social media account provider, other website users, friends connected to your social media account, and your own social media account settings to be affected. This could happen if you link your social media account to your Services account or access your Services account through your social media account.
• You agree that we may share information about you with the provider of your social media account by linking your Services account with your social media account. You also acknowledge that the social media site's privacy policy will control how the information we share is used. Please refrain from linking your social media account to your Services account and from using the Services for social sharing if you do not want your Personal Information to be shared with other users or your social media account provider.
• Should a merger, reorganization, dissolution, or other comparable corporate event occur, or if all or nearly all of our assets are sold, we anticipate that the data we have gathered—including Personal Information—will be given to the acquiring entity or the surviving entity in the merger. All such transfers will be governed by our agreements, as outlined in our Privacy Policy, regarding the privacy and confidentiality of such Personal Information.

In our opinion, the following situations call for our attention:

• Compliance with applicable law, including laws from countries other than your own;
• Following the law and preventing, detecting, or suppressing abuse, fraud, or criminal activity;
• Responding to requests from public and government authorities and self-regulatory organizations, including those from countries other than your own;
• Enforcing our terms and conditions;
• Safeguarding our operations, assets, or interests, or those of any of our affiliates;
• Safeguarding our rights, privacy, safety, or property, or that of our affiliates, you, or others; and
• Enabling us to pursue available remedies or limit the damages that we may suffer.

THIRD-PARTY SERVICES

Any third party that operates a website or service that the Services link to, any third party that includes a widget on the Services (like the Facebook Like or share buttons), or any third party that is not affiliated with us is not covered by this Privacy Policy and we are not liable for their privacy, information, or other practices. When a link is included on the Services, it does not mean that we or our affiliates support the website or service connected to.

Furthermore, other organizations like Facebook, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer are not subject to our control over the information collection, use, disclosure, or security policies and practices. This also applies to any Personal Information you may disclose to other organizations via or in connection with the Services.

MORE ON ADVERTISING

In order to serve advertisements more relevant to your interests, the content on which the ads will appear, or audiences similar to you, as well as to optimize advertising campaigns, we, along with third-party advertising companies (such as advertising technology companies like ad servers, retargeting providers, or measurement providers, social media platforms), may use information about you that we receive (such as information you provide to us or that is collected about your use of the Services, or that we receive from third parties). In general, we and these third parties may use the information we gather to better understand your preferences and areas of interest.

Tracking technologies like cookies, web beacons/pixels, SDKs, and APIs are commonly used to gather information for advertising purposes. This information is then used to uniquely identify you across various devices. As part of these processes, we may occasionally also provide a common identifier, like an email address, to third-party advertising partners (usually in hashed or encrypted format).

SECURITY

We endeavour to safeguard Personal Information within our organization by implementing appropriate administrative, technical, and organizational safeguards. Regretfully, no data transfer or storage mechanism can provide a 100% secure assurance. If you feel that your account security has been breached or you have other cause to think that your relationship with us is no longer safe, please report us right away using the information provided in the "Contacting Us" section below.

OPT-OUT OF MARKETING EMAILS

Going ahead, you can choose not to receive marketing-related communications from us by either contacting us using the details listed in the "Contacting Us" section below, or by following the instructions in each email. You have the ability to disable our push notifications by going into your device's settings.

We will make every effort to accommodate your request as soon as it is practically possible. It should be noted that even if you choose not to get emails from us about marketing, you might still receive crucial administrative or transactional notifications, from which you are unable to unsubscribe.

How you can access, correct, or delete your Personal Information

Please email to us with your request to view, update, or remove any Personal Information you may have previously given to us. Then, reply to that email with the necessary instructions to complete the requested action. To safeguard you, we might only fulfill requests pertaining to the Personal Information linked to the specific email address you used to submit the request, and we might need to confirm your identity before fulfilling the request. We will make every effort to accommodate your request as soon as it is practically possible.

RETENTION PERIOD

Unless a longer retention period is needed or authorized by law, we will keep your Personal Information for as long as we think it's necessary to accomplish the goals stated in this Privacy Policy.

USE OF THE SERVICES BY MINORS

People under the age of eighteen (18) are not intended for use of the Services, and we ask that they refrain from providing Personal Information via the Services.

IMPORTANT NOTICE TO ALL NON-US RESIDENTS

We have servers here in the United States. Please be informed that any information you submit to us—including personal information—will be transferred from your country of origin if you are not based in the United States. Your choice to give such data to us or permit us to collect such data through our Services represents your agreement to this data transfer, with the exception of GDPR-related data transfers.

YOUR U.S. STATE PRIVACY LAW RIGHTS

U.S. State Privacy Laws: Please read this notice regarding state privacy laws if you live in California, Colorado, Connecticut, Utah, or Virginia.

"Shine the Light" Law: If you live in California, you have the right to know whether your personal information has been given to our affiliates or other third parties for their own direct marketing use. Please get in touch with us using the information in the "Contacting Us" section below to make such a request.

Do Not Track: We do not respond to Do Not Track (DNT) signals or comparable signals, with the exception of Global Privacy Control (see U.S. State Privacy Law Notice above).

YOUR CANADIAN PRIVACY RIGHTS

You have the right to inquire about the disclosure of your Personal Information to third parties and our affiliates for their own direct marketing purposes if you live in Canada. Please use the information in the "Contacting Us" section below to get in touch with us in order to make such a request.

SENSITIVE INFORMATION

We kindly request that you do not submit to us or reveal to us any sensitive Personal Information (such as Social Security numbers, details about racial or ethnic origin, political opinions, religious or other beliefs, health, biometrics or genetic traits, criminal history, or trade union membership) via the Services or in any other way.

UPDATES TO THIS PRIVACY POLICY

This Privacy Policy, including any of its component sections, is subject to change. The most recent revision date of this privacy policy is indicated by the "Effective Date" at the top of this page. Any updates will take effect as soon as we publish the updated Privacy Policy on the relevant Websites, Apps, and Services. After these modifications, you agree to the updated Privacy Policy by using the Websites, Apps, or Services, as applicable.