Privacy Policy

Smart Travel Advisor (includes “us,” “we,” or “our”) is a portfolio of brands and digital platforms (such as mobile and/or TV applications) that connect people with information to help make some of life’s most important decisions. For the purposes of this Privacy Policy, the websites, apps, and products provided by Smart Travel Advisor will be referred to as the “Services.” Certain Services have different privacy policies , you should check each Service for its specific policy before use.

This Privacy Policy describes the type of personal information that we may collect for our own purposes; how we use, protect, and share that information; and the choices that you have. By using the Services, you acknowledge the information collection practices and purposes outlined in this Privacy Policy. Any capitalized terms used, but not defined, in this Privacy Policy have the meanings provided in the Terms of Use of the applicable Services.

In some circumstances, a Smart Travel Advisor company may receive or process Personal Information on behalf of a client. In those situations, the privacy policy of the client will apply.

Types of Information We Collect

The following are examples of the types of information that we may collect directly from you, about you, and/or from other sources, including third parties, business partners, our affiliates, or publicly available sources.

Information collected directly from you:

Account Registration. Your name, email, phone number and other relevant information when you create an account. We also may collect information relating to the actions that you perform while logged into your account. The purpose for collection and use of this data is that we have a business need to provide account related functionalities to our users. Accounts can be used for easy checkout, save your preferences, select areas of interest, and transaction history.
Information You Post on the Services. When available on the Services, we may collect Personal Information from you when you provide or post information to our Services, including your username, comments, likes, interests, status, pictures, and references to your online presence. We may use this information for our purposes and/or make this information available to others as you request.
Information You Provide About Others. Sometimes, you may provide information about others- for example, to refer a friend for a newsletter. We may use this information to make our Services available to the people you refer.
Feedback/Support. If you provide us feedback or contact us for support, we may collect your name and e-mail address, as well as any other content that you send to us, to reply. The purpose for collection and use of this data is that we have a business need to receive and act upon your feedback or issues.
Mailing List. If you sign up for one of our mailing lists we collect your email address and/or postal address. The purpose of collection and use of this data is that we have a business need to share information about our products or services.
Order Placement. When you place an order, we collect at a minimum your name, billing address, shipping address, email address, phone number, and payment information (e.g., credit card number). The purpose of collection and use of this data is that we use your information to perform activities associated with a contract to provide you with products or services.
Partner Promotion. We collect information that you may choose to provide as part of a promotion with another company. The purpose of collection and use of this data is that we have a business need to fulfill our promotions.
Surveys. When you participate in a survey, we collect information that you provide through the survey. If the survey is provided by a third-party service provider, the third party’s privacy policy also applies to the collection, use, and disclosure of your information. The purposes of collection and use of this data are that we have a business need to understand your opinions and collect information relevant to our organization.
Sweepstakes or contests. When you choose to participate in a sweepstakes or contest, we collect information about you, which includes contact information to notify you if you are selected. The purpose of collection and use of this data is that we have a business need to operate the contest or sweepstakes. In some contexts, we are also required by law to collect information about those that enter our sweepstakes, and we have a business interest in complying with those laws.
Employment-related data (directly from you): When you choose to apply for employment with a Red Ventures Company, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your resume or CV, Social Security Number, and other information you provide during the application and recruitment process. The purpose of collection is to help us match you to open positions, facilitate the recruiting process, and perform our contract of employment or the anticipation of employment with you.

Information collected Automatically:

E-mail Interconnectivity. If you receive email from us, we may use tools to capture data related to when you open our message, click on any links or banners it contains and make purchases. The purpose for collection and use of this data is that we have a business need to understand how you interact with our communications to you.
Mobile Devices (such as Phones, Tablets, Connected TVs, Gaming Consoles, and Other Digital Media Streaming Devices). We may collect information from your Mobile Device, such as unique identifying information broadcast from your device when visiting one of our Services. The purposes of collection and use of this data are that we have a business need to identify unique visitors and understand how users interact with us on their devices.
Website interactions. We use technology to discover how you interact with our website (e.g., session replay). This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser. The purposes of collection and use of this data are that we have a business need to understand how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a business need to secure our Services and detect and prevent fraud.
Location Data. When you use certain of our Services, we may solicit your permission to collect your location data.. Some features within our Services (such as location-based offers) may only function upon confirmation of your location, and therefore such features will not be available if you choose not to provide your location data. The specificity of the location data may depend on several factors, including the device you are using and how your connected to the Internet. If you ebale location services for our Services, we may collect location data periodically as you use or leave open our Services. Depending on the platform you use to access our Applications (e.g., Apple;s iOS, Google’s Android) you may be able to control whether location data is collected from with the controls on your device.
Cookies, generally. We and our service providers operating on our behalf, and other businesses who collect information on our pages may automatically collect or receive certain information associated with you and/or your device(s) as part of your use of the Services through device-based tracking technologies such as cookies, pixels, tags, beacons, scripts or other technology. The purposes for collection and use of this data is that we have a business need to make our website operate efficiently, provide you with different website experiences, and to provide you with ability to save your preferences such as login and preferred language. See our Cookie Policy for more information.
Cookies, for advertising. Some of our Services participate in behavior-based advertising, which means that technology (e.g., a cookie) is used to collect information about your use of our Services to provide advertising about products and services tailored to your interests on our Services , or on other websites. The purposes for collection and use of this data are that we have a business need to engage in behavior-based advertising and capture analytics on our Services. The information we collect may include geolocation data, such as (a) information that identifies the precise location of your mobile device (when you agree to allow an app or Service to collect this) and (b) your IP address, which may be used to estimate your approximate location. We use this information to ensure that the Services work properly, and to deliver customized content and advertising, including personalized ads, to you. See our Cookie Policy for more information.
Cross-Device Tracking. We and our service providers may collect and store information about users’ interactions with unaffiliated websites and applications that use our technologies, including cookies and similar tracking technologies. This allows us to infer the presence of a common user or household behind multiple devices or browsers, for instance, and then link those browsers and devices into a device graph. The purposes for collection and use of this data are that we have a business need to understand our users’ use of our sites across devices in order to allow users to use our services on one device and pick up seamlessly where they left off on another device. We also have a business need to provide personalized advertising on each device that is inferred from the browsing patterns on all of the devices.
Data Analytics. We use certain web analytics services, including third-party services such as Google Analytics, to help us understand and analyze how visitors use our Services. We may collect information, including your browser type, operating system, Internet Protocol (IP) address, domain name, click-activity, referring website, and/or a date/time stamp for visitors. The purpose for collection and use of this data is that we have a business need to monitor our networks and the visitors to our websites. We may receive reports based on the use of these technologies on both an individual and aggregated basis. These analytics services, including third-party services such as Google Analytics, also use this information to place advertisements for our products on other websites that you visit after your use of the Site. These advertisements may be based on actions such as the pages you visited and actions you take during your use of the Site. You also may choose to install the Google Analytics Opt-Out Browser Add-on to opt out of Google Analytics data collection.

Information we may collect from other sources:

Client Information. We may collect contact information such as name, e-mail, address and/or phone number of our business clients and their employees with whom we may interact. The purposes for collection and use of this data is that we have a business need to make our website operate efficiently and to provide our business clients with ability to save preferences such as login and preferred language.
Demographic Information. Personal Information such as your age, gender, family size, and/or educational level. The purpose for collection and use of this data is that we have a business need to customize content, advertising and learn about our audiences.
Activity and usage information. including information about your interests, purchase behavior, and other navigation data, such as websites visited and advertisements viewed or clicked on, used to customize content and advertising.
Publicly-observed data. Such as activities on blogs, videos, and other online postings used to customize content and advertising.
Social Media Platforms and Other Third-Party Services. Some of our Services may include features that are designed to interact with social media platforms and other third-party services (e.g., Facebook, Twitter, Instagram). If you access the Services using one of these social media platforms or other third-party services, we may receive information about you from those third-parties such as account and profile data. For more information, please refer to the “Social Features” section below.

We may also collect information about you through interactive applications (e.g., mobile devices, third party social networking services, and embedded audio and video players), from co-branded partners and websites (e.g., on our Facebook pages), from our advertisers, and from commercially available sources (e.g., data aggregators and public databases). This Privacy Policy does not cover the practices of third parties, including those that may disclose information to us.

Employment-related data When you choose to apply for employment with a Smart Travel Advisor Company, including information from a recruitment agency. The purpose of collection is to help us match you to open positions and facilitate the recruiting process.

Use and Processing of Information

In addition to the purposes and uses described elsewhere in this policy, we may use information in the following ways:

To identify you when you engage with us and our Services.
To provide content recommendations based on your interactions and interests.
To make our Services available to you and to complete orders placed in our Services and with our Clients.
To process transactions associated with your use of Services for which there is a charge, including to process payments and verify your identity or payment information for your security and protection.
To communicate with you (e.g., about your account or updates to our terms) and to respond to inquiries related to support, employment opportunities, or other requests.
To deliver marketing and promotional materials related to our Services in accordance with applicable laws, including information relating to our products, services, sales, marketing research or promotions.
To provide you with personalized advertising on our Services based on your online activity. We use the information we have to improve our advertising systems so we can show you relevant interest-based advertising, measure the effectiveness and reach of advertisements and services, verify delivery and track performance of an advertising campaign, and ensure that an ad is only delivered when a real person is visiting the site and that the same users don’t see the same ads too frequently. You may update your preferences regarding personalized advertising by visiting the Cookie Settings link in the footer of each site to manage your settings.
To verify your entry into and eligibility to participate in contests, giveaways, or sweepstakes and inform you if you’ve won. If your entry information will be used for any other purposes, we will disclose that in the applicable rules governing that contest, giveaway, or sweepstakes.
To monitor, improve, and conduct analytics on our Services and advertiser product offerings.
For internal administrative purposes, such as safety and security of our Services, and to manage our relationships.
To permit you to participate in social sharing, including live social media feeds and to implement Social Features you choose to use.
The Apps in our Services may request to send you push notifications from time to time in order to update you about any events or promotions that we may be running. The Apps may also ask for your permission to access your camera and your photos. If you no longer wish to receive these types of communications, or if you’ve initially agreed for the application to access your camera and photos and you would like to stop the Apps from accessing them, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.
To detect security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity, including attempts to manipulate or violate our policies, procedures, and terms and conditions.
To comply with legal obligations, to establish or exercise our rights, to defend against a legal claim, and to investigate, prevent, or take action regarding possible misconduct.
For such other purposes not described in this Privacy Policy as you may consent (from time to time) and as otherwise permitted by law.

Although the sections above describe our primary purpose(s) in collecting your information, in many situations we have more than one purpose. For example, if you complete an online purchase we may collect your information to perform our contract with you, but we also collect your information as we have a business need in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about your order. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our need to conduct our business.

Social Features

Some of our Services may include features that are designed to permit interactions that you initiate between our site and third-party websites or services, including third-party social networks (collectively, “Social Features”). For example, you may be able to “like” or “share” content from our Services on other websites or services, such as Facebook/Instagram, Twitter, YouTube/Google, and LinkedIn. By choosing to like or share information from our Services through these services, you should review the privacy policy of that service.
If you use Social Features on our Services or access our Services from Social Features, both 99games and the social media services that operate those Social Features may have access to certain information about you and your use of both our site and theirs. If you are a member of a social media site and logged in, the interfaces configured on our Services may allow the social media site to connect your site visit and browsing behavior to the personal data held on your social media site. We may use this information on an aggregate basis to place ads that are based on your interests on these social media sites. These practices are governed by the privacy statements of these social networking sites and you are advised to review these separately.
In addition, we may request your permission to a) access and collect information available from your social networking account; and b) post information to your friends on your behalf. When you connect your social networking service with your 99games account, you authorize us to access certain information about you from your social networking service to provide content and services, including to help us tailor our communications to you and to develop rich online content and services across the Services. The information we may access from your social networking services is governed by the privacy policies and settings of those third-party services.
The information collected and stored by the social media sites remains subject to those sites’ privacy practices, including whether they continue to share information with us, the types of information shared, and your choices with regard to what is visible to others on those third-party websites or services.

How We Protect Personal Information

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your Personal Information from unauthorized access, use, or disclosure, we cannot guarantee the security of your Personal Information. If we are required by law to inform you of a breach to your Personal Information, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Some of our websites permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password or device, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.