PRIVACY POLICY OF EMERGING TRAVEL GROUP

By using the services of Emerging Travel Group, you entrust us with your personal information. We give you the ability to manage your data and do everything to ensure the security of data storage and transmission. Emerging Travel Group includes Emerging Travel Inc. and its subsidiaries that manage online booking for hotel rooms, flights and other travel services.

Please read our Privacy Policy carefully in order to know what information we collect, for what purposes it is used, and how you can change, export or delete it.

INTRODUCTION

Our online booking services for hotel rooms, flights and other travel services:

At Emerging Travel Group websites, you can manage your personal information in a variety of ways to maintain your privacy. Creating an account or accounts on our services, you provide us with more information about yourself in order to receive more personalized offers and prices.

If you have any questions regarding the Privacy Policy of Emerging Travel Group, please contact us at [email protected]

WHAT DATA WE COLLECT

Types of information

Emerging Travel Group collects user data in order to make our services more convenient for our customers. Thereby, we not only determine in which language you want to search for a hotel, but also solve more complex tasks, for example, we predict which hotels will be of most interest to you. The type of data to be collected depends on how you use the services of Emerging Travel Group.

If you are not logged on the site, we record the information which is collected using unique identifiers associated with browsers, applications and devices. This allows us to remember settings and other data so that you do not have to specify them when you start a new session.

If you are logged in when entering the site, we collect and store information which we process as personal data.

The data you provide

When you create an account on the service, you provide us with personal data including your username and password. You can also specify a phone number or billing information. Also, if you are not logged on the site, you can optionally provide us with some personal information, for example, an e-mail address in order to receive news about our services.

THE INFORMATION WE COLLECT WHEN YOU USE OUR SERVICES

Applications, browsers and devices

We record information about the applications, browsers and devices you use when you enter our sites. We receive unique identifiers and such data as the type and settings of your browser and device, operating system and application version number. We also record information about the interaction of applications, browsers and devices with our services including the IP address, crash reports, information about actions within the system, the date and time of your visit to our resource, and the URL from which you linked (click URL).

We receive these data when Emerging Travel Group service "accesses" our servers from your device, for example, when installing an application or checking for updates.

Your actions

We collect information about the actions performed by you on our sites to provide various useful functions. Such information includes:

Your location

We collect information about your location when you use our services to enable functions such as auto selection of language, displaying of routes to holiday destinations, and searching for sightseeing attractions in the neighborhood.

We determine your location with a certain degree of accuracy considering the following factors:

The types of location data to be collected depend partially on your device and browser settings. For example, you can deactivate or activate geolocation on your smartphone or tablet.

We can also receive information about you from our partners. Among others, they include marketing partners who provide information about potential customers - this information is necessary for conducting market research and displaying ads. Also, they can be our security partners who advise Emerging Travel Group on incident and fraud prevention.

We use various technologies to receive and store data, such as cookies, application caching, databases and server logs.

WHY EMERGING TRAVEL GROUP COLLECTS DATA

User data allow us to make our services more convenient

Thanks to the data we receive, we can maintain and improve existing services and create new ones as well as ensure the safety of Emerging Travel Group and our users.

User data enable the functions of Emerging Travel Group services

User personal information helps us process your searches or prompt addresses that you want to provide access to content.

User data help support and optimize Emerging Travel Group services

User information is also necessary to ensure stable operation of the services (for example, it helps to track failures) and optimize them. In particular, we can determine which search queries for the names of cities or properties are most often erroneous.

User data provide personalization of services including selection of content and ads

We use the collected data to customize services according to the needs of users, to provide personalized recommendations, tailored content and personalized offers, and discounts.

User data help us evaluate effectiveness

We use user information to analyze the statistics of visits to our sites and optimize their internal structure. In turn, advertisers can evaluate the campaign effectiveness based on information concerning the ads you click on.

User data are necessary to communicate with you

We use personal information, such as your email address, to communicate with you. For example, we use personal information to notify you about suspicious attempts to log in to accounts from new devices or about updates to the booking system. We also store your messages in order to resolve issues as quickly as possible.

User data ensure the safety of Emerging Travel Group, users and other persons

The information we collect is critical to the security and reliability of our services. If we have it, we can identify and block threats in a timely manner to prevent attackers from harming Emerging Travel Group, its users and the interests of others.

To perform these tasks, we use a variety of data processing technologies. Our automated systems analyze your data to stop spam and illegal content, as well as prevent other unlawful activities. We also use data mining algorithms. We combine data that come to us from various services and applications that you use.

If we need your data to perform any actions not mentioned in the current Privacy Policy, we always ask for your prior consent to use them.

YOUR ACCESS SETTINGS

You can give directions to Emerging Travel Group on how to collect and use your data.

Viewing and changing personal data

You can manage your personal data stored on the services. For this purpose you need to log in and go to the "Settings".

How you can view and change your data

Personal Area

In your Personal Area you can manage information related to one specific site.

Personal information

You can manage your contact information in your account settings. They include name, email address, phone number, card details for payment, etc.

Deletion of information

According to the law, you have the right to request deletion of content from a particular system of Emerging Travel Group.

You can delete information in the following ways:

Even if you don’t log in, you still have some control over the data we collect. It includes the following:

TRANSFER OF YOUR INFORMATION

When you transfer your personal information

If you use Emerging Travel Group services by logging in to your account, for example, you give comments or submit a review about the application, your name and brief information about the order will be displayed next to them.

When Emerging Travel Group transfers information to third persons

We do not disclose personal information to persons not associated with Emerging Travel Group. The exceptions are the situations listed below.

To process personal data on behalf of Emerging Travel Group

We may share your personal data with our affiliates or other trust and duly authorized companies and individuals for processing on behalf of Emerging Travel Group. Such processing is carried out in accordance with the requirements established by the laws on personal data, our instructions, privacy policy and other applicable privacy and security requirements. In particular, third-party companies (such as properties, car hire companies, airlines or other travel service providers) may provide user support.

At the request of executive authority

We may share your personal information with entities or individuals not associated with Emerging Travel Group if they have the right to receive, use, store or disclose this information on the following grounds:

We may provide your non-personally identifiable information to our partners, such as publishers, advertisers, developers or copyright holders. For example, statistics on the most popular travel destinations based on our users' booking data.

PROTECTION OF YOUR INFORMATION

To protect information in our services we have special means.

Emerging Travel Group uses reliable protection means to keep your data secure. When maintaining online booking systems, we receive information that allows us to detect and automatically eliminate various security problems. If necessary, we will report any problems and tell you how to avoid them.

We do our best to protect our sites and users from unauthorized attempts to access, modify, disclose or destroy the data stored by us:

EXPORT AND DELETION OF YOUR INFORMATION

You can export or delete your information from your account in Emerging Travel Group service at any time.

You can export your information from the personal area of any Emerging Travel Group website: if you need a copy of it or if you plan to use the data on a third party service, you can request such information by e-mail [email protected].

You can delete information in the following ways:

STORAGE OF YOUR INFORMATION

We store the collected data for some period of time. The duration of the storage period depends on the type of information and how we use it.

If you delete any data, we will follow special rules. As a result, your data completely disappear from our servers or they are stored there as depersonalized data. We do all that is necessary to ensure that the personal data of users in our services are not deleted accidentally or as a result of illegal actions. Therefore, information can not disappear from our active services and backup systems immediately after you delete it.

REGULATORY COMPLIANCE AND REGULATORY INTERACTION

We regularly update the Privacy Policy of Emerging Travel Group and process user information accordingly.

Data transfer

Since our servers are located in Europe and Russia, a particular user’s information may be processed not in the country where the user lives. The level of data protection and applicable laws in this area may differ from country to country. Regardless of where your data are processed, Emerging Travel Group uses the same security measures described in this Privacy Policy.

GENERAL INFORMATION ABOUT THIS PRIVACY POLICY

When the Privacy Policy applies

The Privacy Policy applies to all online travel booking systems of Emerging Travel Group and its affiliated companies and services available on third-party sites (for example, advertising services). At the same time, this document does not apply to some services that have their own privacy policy, which complements this Privacy Policy.

The Privacy Policy presented herein does not govern the following:

Changes to the Privacy Policy of Emerging Travel Group

We periodically amend the Privacy Policy; however, we do not intend to limit the user rights described in this policy in the future without their explicit consent. We always give you the date of the most recent changes made to the policy and provide access to its previous versions. If significant changes are made, we will announce them additionally, and in some cases we may send e-mail notifications.

OTHER PRIVACY DOCUMENTS

The links to Emerging Travel Group services where you can find the privacy policies of individual services are given below:

TERMS OF USE OF EMERGING TRAVEL GROUP SERVICES

What is reviewed in these terms?

We know it is not fun to read the Terms of Use. However, it is important that you understand the rules of conduct for using our services, as well as the rights and obligations of Emerging Travel Group.

The Terms of Use reflect the business model of Emerging Travel Group, the applicable laws of the country of incorporation of Emerging Travel Inc. and its affiliated companies, as well as the principles of their work. Thus, these terms govern the relationship with Emerging Travel Group when using our services. The terms include the following sections:

TERMS OF USE

The parent company of Emerging Travel Group is Emerging Travel Inc.:

Emerging Travel Inc.,

incorporated under the laws of Delaware (USA) and operates under the US law.

Mailing Address:

1000 N West Street,

Suite 1200, Wilmington, DE 19801

USA

Legal Address: [ ]

Age restrictions

If you have not yet reached the required age to manage accounts in Emerging Travel Group services, then you can use it only with the permission of a parent or legal representative. For this purpose, the parent or the legal representative is required to read these terms together with you.

If you are a parent or legal representative of a child and allow him/her to use the services of Emerging Travel Group, these terms apply to you, and you are responsible for the child's actions on our sites.

Some platforms of the Emerging Travel Group have special age restrictions. They are specified in additional terms and conditions of use for individual services.

YOUR RELATIONS WITH EMERGING TRAVEL GROUP

These terms govern the relations between you and Emerging Travel Group. It means that we authorize you to use our online booking systems if you accept these terms. When we say “we” or “Emerging Travel Group”, we mean Emerging Travel Inc. and its affiliates.

WHAT WE DO

We provide a wide range of useful services

We provide services to both individuals and organizations for which these terms apply.

We improve Emerging Travel Group services

We keep on using new technologies and functions to improve our services. For example, we invest in implementation of analytics systems and algorithms to detect and block spam and attacks. We regularly add or delete functionality on our sites, and launch new services or stop supporting old ones.

If we make significant changes that adversely affect your use of the services or stop providing any service, we will notify you in advance. Exceptions are situations where there is an urgent need to restrain violations, comply with legal requirements or resolve security and functionality issues.

TERMS OF USE FOR EMERGING TRAVEL GROUP SERVICES

Observe these terms and additional terms that apply to individual services.

You have the right to use the services as long as you comply with the requirements set forth in:

You also have access to various resources where you can find detailed information about our services and answers to frequently asked questions: the Privacy Policy and other resources.

All intellectual property rights in respect of Emerging Travel Group services are reserved by us.

Allow us to use your content

Some of our services allow you to download and store your personal information. You are not obliged to add any content to our services and you may decide for yourself what content to provide. Before downloading it, make sure that you have all the necessary rights to do so and that your actions or content do not violate applicable law.

USE OF EMERGING TRAVEL GROUP SERVICES

Your accounts

If your age meets the established restrictions on the use of Emerging Travel Group services, you can create an account yourself. You need it to use some sites.

You are responsible for all your actions with your account including taking steps to protect it. We recommend you regularly check the security of your devices and browser.

Use of Emerging Travel Group services on behalf of an organization

For you to be able to work with our services on behalf of an organization:

Communication

Emerging Travel Group sometimes sends you notices and other information. For more details on how we communicate with you, see the Privacy Policy.

If you send us feedback, for example, with a suggestion to improve our services, we can use it without assuming any obligation to you.

CONTENT IN EMERGING TRAVEL GROUP SERVICES

Your content

You can make content publicly available, for example, post a review of a service or a hotel, etc.

If you believe that somebody violates your intellectual property rights, you can send us a notice. We will examine your notice and take appropriate measures. For example, if a user repeatedly violates copyright, we will temporarily or permanently block his/her account.

Emerging Travel Group content

Some of our services have the content owned by the Emerging Travel Group, for example, images. You can use this content according to these terms and additional terms of use of individual services. However, all intellectual property rights in this content are reserved by Emerging Travel Group.

Other content

In some of our services, you can have access to the content which belongs to other individuals or organizations (for example, articles in the "News" or descriptions of hotels provided by their owners). You cannot use such content without the permission of that individual or organization unless required by applicable law. The opinions expressed in the materials of other persons or organizations do not necessarily reflect the views of Emerging Travel Group.

SOFTWARE IN EMERGING TRAVEL GROUP SERVICES

Some of our services contain downloadable software. We allow it to be used as an integral part of our services.

The license we grant you is:

You may not reverse engineer or attempt to extract the source code of our software except as required by applicable law or with the written permission of Emerging Travel Group.

If you need to download software for the service to work, it can be automatically updated on your device. In some services, you can configure the automatic update settings.

PROBLEMS AND DISPUTES

According to law, you are entitled to (1) a certain quality of service and (2) troubleshooting mechanisms in the event of a malfunction. These terms do not limit or cancel these rights. For example, if you are a consumer, you continue to use all of the legal rights granted to the consumers under applicable law.

Warranty

We provide our services in accordance with the terms of a given search and availability of inventory. If the level of service quality is lower than the level described in this warranty, please let us know and we will try to resolve the problem.

Disclaimer

All obligations of Emerging Travel Group in respect of our services (including content, functionality, reliability, availability) are: 1) described in the "Warranty"; 2) set forth in the additional terms of use of individual services; or 3) provided in accordance with applicable law. We do not assume any other obligations with respect to our services.

Except as provided by applicable law, we do not give warranties such as marketability (for example, the hotel room itself or the vehicle), suitability for a particular purpose and non-infringement.

Liability

These terms limit our liability only to the extent permitted by applicable law. In particular, these terms do not limit the Emerging Travel Group's liability for fraud, misrepresentation for fraudulent purposes, gross negligence or willful violation.

Apart from responsibility for compliance with the rights and obligations described in this section (Problems and Disputes), Emerging Travel Group is not liable for other damages unless they are caused by our violation of these terms or additional terms of use of individual services.

Actions of Emerging Travel Group in case of incidents

Before taking the measures described below, we will send you a notice in advance, provide an explanation, and give you an opportunity to correct the problem unless we have reason to believe that these measures may:

Deletion of your content

We reserve the right to delete your content partially or completely in accordance with applicable law in cases where we have reason to believe that it: 1) violates these terms or additional terms or rules of individual services; 2) violates the current legislation; 3) may cause harm to users, third persons or Emerging Travel Group. For example, if your content violates the intellectual property rights of other users.

Temporary or permanent blocking of access to Emerging Travel Group services

Emerging Travel Group reserves the right to deny you, temporarily or permanently, access to services or delete your account if:

If you believe that your account is blocked or deleted by mistake, you have the right to appeal against the decision.

Dispute resolution, applicable law and courts

You can find the contacts of the representatives of Emerging Travel Group on our contact page.

All disputes related in any way to these terms, additional terms of use of individual services or services, regardless of conflict of law rules, shall be resolved in accordance with the laws of Delaware (USA). Such disputes shall be under the exclusive jurisdiction of federal or Delaware (USA) courts. You along with Emerging Travel Inc. acknowledge the personal jurisdiction of these judicial authorities.

If applicable law prevents resolving certain disputes in a Delaware court, you may refer these disputes to local courts. Similarly, if applicable law does not allow a local court to apply Delaware law to resolve these disputes, then they will be governed by the applicable local law of your country, state, or other place of residence.

About these Terms of Use

According to law, you have certain rights that cannot be limited by these Terms of Use. These terms are not intended to limit your legal rights in any way.

These terms describe the relations between you and Emerging Travel Inc. They do not create any rights for other persons or organizations, even if the said relations benefit someone else under these terms.

We want to make these conditions clearer so we have added examples from our services. However, not all of the mentioned services may be available in your country.

If these terms conflict with the additional terms of use for a particular service, the latter will prevail over that service.

If any of the provisions of these terms becomes invalid, it will not affect the legitimacy of the remaining provisions.

If you violate these terms or the additional terms of use of certain services and we do not take immediate measures, it does not mean that we waive our rights including the rights to take certain actions in the future.

We may update these terms and the additional terms of use for individual services for the following purposes: 1) to reflect changes in our services or business models, such as adding or deleting functions, technologies, services, prices or benefits; 2) to comply with applicable legal, regulatory or safety requirements; 3) to prevent violations or damage.

If we substantially change these terms or the additional terms for individual services, we will provide you with reasonable advance notice and an opportunity to review the changes except in the following cases: (1) when a new service or function is launched, or (2) in situations of extreme urgency, for example, prevention of ongoing violations or response to requirements of applicable law. In any case, we do not allow worsening the user's position without his/her prior consent. If you do not agree to the new terms, you should stop using the services. Also you have the right to delete your account at any time.