Effective Date: 25 May 2018
We respect the privacy of all our customers and business partners, and treat personal information
(personal data) provided by you to us as confidential. We know that you are concerned how information
about you is collected, processed, used and stored, and we appreciate you trusting that we will do so
with every due care and diligence.
EuroUSA-SEVA and its affiliates (collectively, “ EuroUSA-SEVA”, “we”, “our” or “us”) are committed to
safeguarding your privacy and want you to be familiar with how we collect, disclose and otherwise use
references to the entity responsible for the processing of your personal data, which generally is the
entity that obtains your personal data in the respective case, or the data controller.
• our practices in connection with the information we collect from you when you visit our websites,
• when we communicate with you through e-mail messages (referred to as the “Services”);
• our privacy practices when we communicate with you by offline channels, such as when you provide your
information to our offices, or in person (“Offline Services”); and
• the basis on which we will process personal data we collect from you or that you provide to us, and
your choices with respect to that data.
Our privacy practices may be more or less limited in certain countries in which we operate to reflect
local practices and legal requirements. We will specifically inform you, if this is the case.
By providing your personal data and other information through our Services, you acknowledge that your
1. What Information Does EuroUSA-SEVA Collect and when collected?
2. Why is Personal Data Used and When Do We Disclose Your Personal Data?
3. How Do We Protect Your Personal Data?
4. What Cookies and Other Technologies Does EuroUSA-SEVA Collect?
5. Third-Party Websites and Services
6. Cross-Border Data Transfers
7. How Long is Your Personal Data Retained?
8. How Can You Manage Your References and Information?
9. What Are Your Rights Regarding Your Personal Data?
10. What Information is Collected From Children?
11. What About Policy Modifications?
12. Data Controller and How to Contact Us?
1. WHAT INFORMATION DOES EUROUSA-SEVA COLLECT AND WHEN IS YOUR PERSONAL DATA
1.1 Personal Data
identified or identifiable individual, or as defined under applicable law. We collect Personal Data such
1.2 Sensitive Personal Data
- • Your name, e-mail address, phone number, physical address (billing and shipping), company
- • Demographic information and location, and government-issued identifiers;
- • Your credit card and/or debit card details;
- • Information such as accommodation special requests and preferences (including preferred room type
or floor, spend, vacation preferences, amenities requested, language preferences, ages of children
or companions and any other aspects of the Services used);
- • Frequent flyer and travel partner program affiliations and member number; hotel, airline and
rental car packages booked;
- • Other communications such as in-app messages or SMS text messages, where permitted by applicable
law or based upon consent;
- • Contact details concerning the employees of corporate accounts and vendors and other individuals
with whom we do business (e.g., travel agents, bookers, event planners); and
- • Other types of information that you voluntarily choose to provide to us.
From time to time, you may provide or we may collect what is considered sensitive personal information
or “special categories of personal data” under applicable privacy laws (herein referred to as “Sensitive
Personal Data”). For example, you may disclose your religious affiliation to us when you host or attend
an event or provide your health information or dietary restrictions so that we can accommodate you
during your trip.
We only process Sensitive Personal Data if and to the extent permitted and required by applicable law or
with your express consent. Unless otherwise required by applicable law, you are not required to provide
us with any of your Sensitive Personal Data. Should you choose not to, your decision would not prevent
you from using our Services.
1.3 Personal Data from Third Parties
We may collect Personal Data related to you from third parties such as from airlines, payment card
providers, travel agencies and online booking services, other affiliates and, public databases, and your
social medial sites consistent with your settings on such services.
Additionally, if you submit Personal Data relating to other people – such as your children or other
companions – in connection with the Services, you are also deemed to be representing that you have the
authority to do so and permit us to use their Personal Data for the purposes described in this Privacy
1.4 We collect Personal Data about you in a number of ways, including:
2. WHY IS PERSONAL DATA USED AND WHEN DO WE DISCLOSE YOUR PERSONAL DATA?
- • When you make reservations or plan or attend an event. Visitors or agents in their behalf who
to make reservations using our Services or Offline Services will be asked to supply specific
Data, including name, e-mail address and contact information, as well as information to secure the
reservation, such as a credit card number. We collect your Personal Data to provide you with
including when you purchase goods and services, inform us of any requests. If you plan or host an
we collect meeting and event specifications, such as your name, contact details, date of event,
occasion, number of guest rooms required, and length of stay. We also collect information about
that are a part of your group or event.
- • When you provide your comments and feedback or communicate with us. We also collect your Personal
when you communicate with us via text or e-mail or otherwise, like WeChat.
- • When you share photos. We collect and publish photos and images you voluntarily share with us
your experience with us, which you may post on our Services.
- • From social media. We collect information from social media activity such as when you ‘like’ the
Website, share content or follow us on social media sites like Facebook, Twitter, Instagram, or
- • From other sources. We may receive your Personal Data from other sources, like public databases,
other third parties including travel agencies, airline and credit card partners.
We use your Personal Data in a number of ways as set forth below.
2.1 Performance of a Contract.
We process your Personal Data in order to perform a contract with you,
including to complete your reservation, provide you goods and services that you requested.
2.2 Legitimate Business Reasons.
We use your Personal Data where it has a legitimate business reason to
do so, pursued by a third party or us. This includes providing you with superior customer service and a
personalized experience, keeping our Services safe and secure and to protect our operations or those of
any of our affiliates or other third parties, and distributing and responding to surveys regarding your
experience. We encourage you to read these rules carefully. Such legitimate business reasons also
include providing you with information that you have requested and responding to your inquiries,
development of new features and services.
2.3 To Comply with Legal Obligations.
We process your Personal Data where it is necessary to comply with
legal obligations to which it may be bound. This includes complying with legal processes, responding to
requests from public and government authorities around the world, and pursuing available remedies or
limit damage we or other third parties may sustain.
2.4 With Your Consent.
We process your Personal Data when we have your valid consent to do you,
including to communicate (including by e-mail and SMS) with you during your travel; and to process
Sensitive Personal Data you may have provided us in connection with your stay; for example, any dietary
restrictions or special accommodations for physical and medical conditions.
2.5 Vital Interest.
In certain circumstances when it is not possible to obtain your consent, it may be
necessary for us to process your Personal Data, including Sensitive Personal Data you provided through
our Services, where it is in your vital interest or in the interest of others, for example in the event
of a medical emergency.
2.6 We will not sell, rent, or share your information without your consent except
in accordance with
2.7 We may disclose or share your Personal Data as follows:
3. HOW DO WE PROTECT PERSONAL DATA?
- -Hotels and Other vendors The Personal Data you provide to us in connection with making a
shared with the respective vendor for purposes of meeting your reservation request. After your stay,
retain your Personal Data, including the details of your stay and your preferences (e.g., room,
amenities used) to provide you personalized service during your next stay, subject to your
You can object to the retention of your Personal Data for this purpose by contacting us as described
- - Commercial Service Providers and Suppliers. We may outsource the processing of certain functions
and/or information to third parties that provide services such as Services hosting, data analysis,
payment and credit card processing, order fulfilment, customer service, e-mail delivery, financial
services companies, delivery services, advertising networks, and information technology. We may also
share your Personal Data with third-party providers that provide services such as spa treatment, and
restaurants , transportation companies, or event planners or organizers of any event you plan with
- -External Partners. We may share your Personal Data to other partners, consultants and advisors who
render services to us, including financial institutions, external auditors, lawyers, and credit card
- -Travel-Related Service Partners. We may share your Personal Data with select third parties. For
example, we may help arrange rental cars or hotel accommodation and share Personal Data with them in
order to provide those services. We also may work with third parties, such as travel agencies and
airlines to help provide you with a single source for purchasing travel-related services. Please
- -Social Media and Message Boards. If you connect to one of our social media pages, we may disclose
Personal Data to your friends associated with your social medial account, to other website users,
your social media account provider, in connection with your social sharing activities. We may make
reviews, message boards, blogs and other user-generated content available to users on our Services.
information disclosed in these areas is public information and you should accordingly exercise
when deciding to disclose your Personal Data in this context. We are not responsible for the privacy
practices of other users including web operators to whom you provide information.
- -Legal Obligation. If we are under a duty to disclose or share your Personal Data in order to
with any legal obligation, pursuant to a legal request, subpoena or other legal processes, or in
purposes; or to protect the rights, property, or our safety, our guests, or others. This may include
exchanging information with other companies and organizations for the purposes of fraud protection
credit risk reduction.
We maintain commercially reasonable security safeguards that are designed to protect the Personal Data
we collect against unauthorized use, disclosure, alteration or destruction. However, no method of
transmission over the Internet, or method of electronic storage, is 100% secure and we cannot guarantee
or warrant that your Personal Data is under absolute security with the existing security technology.
Additionally, when requesting information or sending information or forms to us by e-mail, please be
advised that e-mail communication to and from our Services are not secure unless clearly noted
otherwise. This is a risk inherent in the use of e-mail.
4. WHAT COOKIES AND OTHER TECHNOLOGIES DO WE COLLECT?
4.1 Automatic Data Collection.
We are interested in improving our Site and may develop new features. We
may use automatic data collection technologies to collect certain statistical (non-personal) information
about your equipment, browsing actions, and patterns, including details of your visits to our Services,
including traffic data and location data, date and time of access, frequency and other communication
data; and) details of referring websites actions, and patterns. We monitor aggregated data regarding use
of the Site for marketing purposes and to study, improve and promote use of the Site.Aggregated data
does not reveal personal information individuals.
5. THIRD-PARTY WEBSITES AND SERVICES:
5.1 Our Services may contain links to, or have features that are hosted by, other third-party websites
or services that are not owned or controlled by us.
any third parties or any third-party websites or features that are linked to or available from our
Services. If you provide any information to any other third parties, different rules regarding the
collection and use of your Personal Data by such third parties may apply. Please contact these entities
directly if you have any questions about their privacy practices.
6. CROSS-BORDER DATA TRANSFERS:
6.1 The Personal Data and other information that we collect from you will be transferred to, and stored
at, a destination outside the EEA. It also may be processed by staff operating outside the EEA who work
for us or other entities acting as data processors processing data on our behalf. This includes staff
and providers engaged in, among other things, the fulfillment of your request or order and the provision
of support services. More information on to whom your data is disclosed can be found in Section 4.
7. HOW LONG DO WE RETAIN YOUR PERSONAL DATA?
7.1 We retain your Personal Data for the period necessary to fulfill the purposes outlined in this
may need to retain certain information for recordkeeping purposes and/or to complete transactions (e.g.,
when you make a purchase or reservation), and you may not be able to change or delete the Personal Data
you provided until after completion of such purchase or reservation.
8. HOW CAN YOU MANAGE YOUR PREFERENCES AND INFORMATION?
8.1 Commercial E-mails.
You may opt-out of receiving commercial e-mails from us by following the
instructions contained in any of the commercial e-mails. Unsubscribing from one type of communication
may not unsubscribe you from another type. Please note that even if you unsubscribe from commercial
e-mail messages, we may still e-mail you non-commercial (transactional) e-mails related to your account
and your transactions via the Services.
8.2 EU Users and Commercial E-mails.
If you are a user based in the EU, we only send you commercial
e-mails when we have obtained your explicit prior consent, except where we have obtained your e-mail
address in the course of a sale or negotiations for a sale of a product or service and where the
commercial e-mails are only marketing similar products or services.
8.3 Text Messages and SMS.
To opt out of text messages, reply STOP to the message you received or
contact us to inform them you no longer wish to receive text messages.
9. WHAT ARE YOUR RIGHTS REGARDING YOUR DATA?
Under applicable law and regulations, you may, at any time, exercise certain rights, including the
The right to request access to your Personal Data, which includes the right to obtain
confirmation from us as to whether Personal Data concerning you is being processed, and where that is
the case, access to the Personal Data and information related to how it is processed.
9.2 Rectify or Erase.
The right to rectification or erasure of your Personal Data, which includes the
right to have incomplete Personal Data completed.
The right to obtain a restriction of processing concerning your Personal Data, which
includes restricting us from continuing to process your Personal Data under certain circumstances (e.g.,
where you contest the accuracy of your Personal Data, for a period enabling us to verify the accuracy of
the personal data).
The right to object to the processing of your Personal Data under certain circumstances,
including objecting to processing your Personal Data for direct marketing purposes, or objecting to
processing your Personal Data when it is done based upon legitimate interests.
9.5 Data Portability.
The right to data portability, which includes certain rights to have your Personal
Data transmitted from us to you or another controller.
Where we process your Personal Data based on your consent, the right to withdraw consent at
any time with effect for the future. Any requests related to the above rights may be made by contacting
us as set forth in Section12.
In some jurisdictions, you may also have the right to lodge a complaint with a
10. WHAT INFORMATION IS COLLECTED FROM CHILDREN?
10.1 We have not designed the Services for, and do not intend for them to be used by, anyone under age
18. Accordingly, the Services should not be used by anyone under age 18 without adult supervision. If
you are under 18, please do not provide Personal Data of any kind whatsoever.
10.2 Should we inadvertently acquire Personal Data or other information from users under the age of 18,
we will not knowingly provide this data to any third party for any purpose. If a child does provide us
with Personal Data over Services, a parent or guardian of that child may contact us and upon
notification, we will delete from our records any information collected from children under the age of 18.
on this page. If we make material changes to how we treat your Personal Data, we will notify you through
top of the page. It is your responsibility to ensure that we have a deliverable e-mail address for you,
our Services after such amendments will be deemed your acknowledgement of these changes to this Privacy
12. DATA CONTROLLER - HOW TO CONTACT US:
us by email at
by mail at:
Attn: Legal Department
902 South Dixie Hwy
Lantana, FL 33462