YOUR CALIFORNIA AND OTHER STATE PRIVACY RIGHTS
Overseas Adventure Travel and Grand Circle Travel provide travel services to individuals who are located in the United States and its territories.
Our Privacy Statement, including this State supplement, is intended to inform you about our policies and procedures regarding the collection, use and disclosure of information by Grand Circle LLC, and all affiliated travel brands (collectively “Grand Circle”) such as Overseas Adventure Travel at www.oattravel.com, Grand Circle Travel at www.gct.com and any other websites, features, applications, widgets or online services that are owned or controlled by Grand Circle and that post a link to our Privacy Statement (collectively, the “Site”), as well as any information Grand Circle collects offline in connection with the Site. Our Privacy Statement including this State supplement applies to information collected from the effective date forward; information collected while a previous Privacy Statement was in effect remains subject to the terms of that former policy.
State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information.
To learn more about California residents’ privacy rights, see below.
Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:
- Confirm whether we process their personal information.
- Access and delete certain personal information.
- Data portability.
- Opt-out of personal data processing for targeted advertising and sales
THE SALE OR SHARING OF YOUR INFORMATION.
Colorado, Connecticut, and Virginia also provide their state residents with rights to:
- Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose.
- Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.
Do Not Sell or Share My Information
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If you would like to opt-out of the sale or sharing of your personal information please contact us by email or phone and provide us with your name, customer number and address: [email protected] or by telephone at (800) 321-2835.
CALIFORNIA PRIVACY RIGHTS
California residents have the following rights:
- The right to know the categories of personal information we’ve collected and the categories of sources from which we got the information;
- The right to know the business purposes for sharing personal information;
- The right to know the categories of third parties with whom we’ve shared personal information;
- The right to access the specific pieces of personal information we’ve collected;
- The right to delete your information;
- The right to opt-out of automated decision-making and the sale or sharing of your information.
- The right to correct information;
- The right to limit use and disclosure of sensitive information.
California residents also have the right to not be discriminated against if they choose to exercise their privacy rights.
YOUR PERSONAL INFORMATION UNDER THE CCPA
We collect your personal information as set forth in the below chart.
While we collect information that falls within the sensitive personal information categories listed in below, California law does not treat this information as sensitive because we do not collect or use it to infer characteristics about a person. We collect Sensitive Personal Information from you only in order to provide services to you, such as going on one of our trips. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.
To learn more about the sources from which this personal information is collected, please refer to our Privacy Policy.
To learn more about why this personal information is collected and whom we share this personal information with, please refer to our Privacy Policy.
| Category | Examples | Collected | Sold or Shared? | Retention Period |
|---|---|---|---|---|
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | YES to provide goods and services to you | YES for cross-context behavioral advertising, with our service providers and as required by applicable law | 7 years |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | YES to provide goods and services to you | YES, with our service providers and as required by applicable law | 7 years |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | YES, if any, in connection with employee hiring and/or onboarding | NO | 7 years |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES to provide goods and services to you | YES for cross-context behavioral advertising | 7 years |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO | NO | |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | YES to provide goods and services to you | YES for cross-context behavioral advertising | 7 years |
| G. Geolocation data. | Physical location or movements. | NO | NO | |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO | NO | |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | NO | NO | |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO | NO | |
| K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | YES, to provide goods and services to you | YES for cross-context behavioral advertising | 7 years |
| Sensitive Personal Information Category | Government identifiers (social security, driver's license, state identification card, or passport number) | YES, to provide goods and services to you | NO | 7 years |
| Complete account access credentials (user names, account numbers, or card numbers combined with required access/security code or password) | YES, to provide goods and services to you | NO | 7 years | |
| Precise geolocation | NO | NO | ||
| Racial or ethnic origin | NO | NO | ||
| Religious or philosophical beliefs | NO | NO | ||
| Union membership | NO | NO | ||
| Genetic data | NO | NO | ||
| Mail, email, or text messages contents where we are not the intended recipient of the communication | NO | NO | ||
| Unique identifying biometric information | NO | NO | ||
| Health, sex life, or sexual orientation information | YES, to provide goods and services to you | NO | 7 years |
Right to Opt-Out of Sale of Your Personal Information
Consumers have the right to request that a business that sells the Consumer’s personal information, or that discloses it for a business purpose, inform the Consumer of what has been collected about them and who it has been sold or disclosed to. Consumers also have the right, at any time, to direct a business that sells personal information about them not to sell their personal information.
If you would like to opt-out of the sale or sharing of your personal information please contact us by email or phone and provide us with your name, customer number and address:
[email protected]
Reach us by telephone at (800) 321-2835.
We will process your sales or sharing opt-out request within 15 business days.
You may also opt-out of the sale or sharing of your information by sending an email with the subject line “Opt-out” to [email protected] and include your full name, customer number, mailing address, email address and phone number.
Sales of or Sharing Personal Information
We may sell or share information that we have collected from or about you:
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With third party data brokers, such as with Epsilon, to help us provide you with personalized products or services and for cross-contextual behavioral advertising purposes.
The CCPA prohibits a third party from reselling personal information unless you have received explicit notice and an opportunity to opt-out of further sales. The following businesses receive personal information from us . To opt-out of those sales, please visit the third-party opt-out notices at the links provided below: - Epsilon Data Management LLC: https://www.epsilon.com/us/marketing-data-summary-request
- By disclosing it to a third party for a business purpose or to sell your personal information subject to your right to opt-out of those sales. Our personal information sales do not include information about individuals we know are under age 18.
We may share your personal information with Service Providers, including hotels on our trips, when required by law, and with third party advertisers, analytics, aggregators, and content providers. When we disclose personal information to service providers for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
Sales of Personal Information to Third Parties
In the preceding twelve (12) months, we have sold the following categories of personal information to third parties such as Epsilon:
Category A. Identifiers.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category K. Inferences drawn from other personal information.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category K. Inferences drawn from other personal information.
Sensitive Personal Information
Exercising Your Rights
In order to exercise your California rights, please contact us by email or phone and provide us with your name, customer number and address:
[email protected]
Reach us by telephone at (800) 321-2835
Right to Access/Data Portability
Consumers have the right to request that a business that collects personal information about them disclose the following:
- The categories of personal information it has collected about that consumer;
- The categories of sources from which the personal information is collected;
- The business or commercial purpose for collecting, disclosing or selling personal information;
- The categories of third parties with whom the business shares personal information;
- The specific pieces of personal information it has collected about that consumer.
Our disclosure will cover a 12-month period preceding the date of your request.
Within 45 days, we will provide you with a copy of the information listed in “Right to Access / Data Portability,” above, by mail or electronically. To the extent possible, this information shall be provided in a portable and usable format.
Right to Deletion
Consumers have the right to request that a business delete any personal information about them. However, there are exceptions to this rule. For example, a business does not have to delete information if it is necessary to: a) complete a transaction; b) prevent illegal activity; c) exercise free speech; d) comply with a legal obligation; e) identify or repair errors that impair functionality; or f) otherwise use a Consumer’s personal information, internally, that is compatible with the context in which the Consumer provided that information.
We have created a two-step process for responding to requests for deletion. After you submit the initial request, we will ask that you separately confirm that you would like your information deleted.
If your request does not fall within one of the exceptions to deletion listed in “Right to Deletion,” above, we will confirm deletion within 45 days. If we are not required to delete your account, we also let you know within 45 days.
Right to Correct Information
Consumers have the right to request that a business correct any inaccurate personal information about them.
How to Exercise Your Rights
To exercise your right to access, delete or correct your information, please submit a Verifiable Consumer Request by sending an email to [email protected]. Please include “Consumer Privacy Right” in the subject line.
We will reach out within 10 days to confirm that we have received your request.
We will then take steps to determine whether your request is a valid Verifiable Consumer Request. If you have an account, we may ask you to login to confirm this information. We will not ask you to create an account if you do not already have one. We will only ask for information that is reasonable in light of the nature of your request.
In the event we need additional time, we will inform you within the initial 45-day period of our need for an additional 45 days (for a maximum of 90 days between request and provision of information).
We are not required to provide personal information to a Consumer more than twice in a 12-month period.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
We do not offer consumers financial incentives that can result in different prices, rates, or quality levels.
Other California Privacy Rights
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].
How you can contact us
If you have questions about this privacy policy, or if you believe that this Site is not following its stated Privacy Policy, please contact us at:
[email protected]
Grand Circle LLC
Attention: Privacy
347 Congress Street
Boston MA 02210
Reach us by telephone at (800) 321-2835
