Last updated: May 9, 2022
INFORMATION WE COLLECT
Below, we describe the different ways we might collect information from you if you are a Consumer.
Information You Provide to Us
We collect information you provide directly to us. For example, you share information directly with us when you create an account on our Platform, express an interest in obtaining information about us or our Platform, when you participate in activities on our Platform, or otherwise communicate with us.
- Personal details: We may collect information about you such as your name, phone number, date of birth, email address, home address, passport or license number, contact preferences, names of the people travelling with you, and travel preferences, such as dietary or accessibility needs. If you’re booking with others or for someone else, you will have to give us their information as well. It is your responsibility to ensure that they are aware that you have done so, and that they accept how we use and process their information as well as yours.
- Account information: If you create an account or sign up for a subscription with us, we collect your name, login ID, and password.
- Payment information: We collect payment information, which may include your credit, debit, or other payment card information, and the security code associated with your payment instrument at the time of your transaction in order to process your payment.
Information We Collect Automatically When You Interact with Us
When you access or use our Platform or otherwise transact business with us, we automatically collect certain information, including:
- Log Information: We collect information related to your access to and use of our Platform, including the type of browser you use, access times, pages viewed, your IP address, and your activity on our Platform.
- Device Information: We collect information about how you access our Platform, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity on our Platform, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Platform.
- Location Information: In accordance with your device permissions, we may collect information about the precise location of your device. You may stop the collection of precise location information at any time (see the Your Choices section below for details).
Information We Collect from Other Sources
We obtain information from third-party sources, such as from third parties from whom you direct us to obtain data in connection with your use of our Platform. Additionally, if you create or log into your Xeni account through a third-party platform (such as Facebook, Google, or Twitter), we will have access to certain information from that platform, such as your name, email address, and profile picture, in accordance with the authorization procedures determined by such platform.
Information We Derive
We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address or infer that you are looking to purchase certain products based on your browsing behavior and past purchases.
Aggregated or De-identified Information
Aggregated or de-identified information that cannot reasonably be used to identify an individual is not considered personal information. We do not limit the ways we use or share aggregated or de-identified information or information we aggregate or de-identify collected through our Platform, and we do not limit our third-party providers from using, selling, licensing, distributing, or disclosing aggregated or de-identified information.
How We Use Google Analytics
For analytics, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics may set cookies on your browser or mobile device or read cookies that are already there to collect information. Google Analytics may also receive information about you from apps you have downloaded that partner with Google. Google Analytics collects information such as how often you use our Platform and how you use our Platform. We use the information provided by Google Analytics to improve our Platform. We do not combine the information collected through the use of Google Analytics with personally identifiable information.
USE OF INFORMATION
We use the information we collect to administer your account. We also use the information we collect to:
- Provide, maintain, and improve our Platform;
- Process transactions and send you related information, including confirmations, travel updates, receipts, invoices, customer experience surveys, and recall notices;
- Enable user-to-user communications with each user’s consent;
- Personalize and improve your experience on our Platform;
- Send you technical notices, security alerts, and support and administrative messages;
- Respond to your comments and questions and provide customer service;
- Communicate with you about products, services, and events offered by Xeni and others and provide news and information that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time);
- Monitor and analyze trends, usage, and activities in connection with our Platform;
- Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Xeni and others;
- Debug to identify and repair errors in our Platform;
- Comply with our legal and financial obligations;
- Carry out any other purpose described to you at the time the information was collected; and
- Fulfill any other purpose for which you provided consent.
SHARING OF INFORMATION
We may share information about you as follows or as otherwise described in this Policy:
- We share personal information with vendors, service providers, and consultants that need access to personal information in order to perform services for us, such as companies that assist us with web hosting, customer service, payment processing, and fraud prevention.
- We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
- We may share personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Xeni, our users, the public, or others.
- We may share personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
- Personal information is shared between and among Xeni and our future parents, affiliates, subsidiaries, and other companies under common control and ownership.
- We share personal information with your consent or at your direction.
We also share aggregated or de-identified information that cannot reasonably be used to identify you.
Browser Do Not Track
Our Platform does not support Do Not Track (DNT) at this time. DNT is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit www.donottrack.us.
HOW WE PROTECT INFORMATION
We limit access to Personal Information about you to those affiliated who we believe reasonably need to come into contact with that information to provide products or services to you in order to do their jobs.
We will protect personal information by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Our data security protections meet the “reasonable security requirements” of the New York “Shield Act”. Unless required by law or to establish or exercise our legal rights or defend against legal claims, we do not rent, sell, or share Personal Information about you with other nonaffiliated companies. Please understand, not all security system is fail-proof. We cannot guarantee that its servers are impenetrable, nor can we promise that your information will not be intercepted as it is being transmitted over the Internet. We’ll only retain your information for a reasonable period, or for so long as either you or the law allows.
YOUR LEGAL RIGHTS
You have the following rights in relation to the personal information that we hold about you:
You may request a copy of the personal information we are keeping about you by submitting a request to us at the below address.
You may ask that we correct any inaccuracies in the data, ask us to transfer it to another party or provide it to you for transfer it to another party yourself.
You can ask us not to process your personal information for marketing purposes at any time by sending a request to the below address or clicking ‘unsubscribe’ on any of the emails that we send to you. Alternatively, you can also email firstname.lastname@example.org and it will be done for you. We will let you know if we intend to use your data for marketing purposes.
You have the right to request that we delete all personal information that we hold about you. If there is no other reason beside you providing your consent for us to hold your data, we will delete it upon receiving your request.
We may not delete your personal information if one of the following exceptions exists:
- Information is necessary to complete the transaction;
- Information is necessary to detect security incidents;
- Information is necessary to protect against deceptive, fraudulent, or illegal activity;
- Information is necessary to identify and repair errors;
- Information is necessary to promote free speech;
- Information is necessary for scientific, historical, or statistical research in the public interest;
- Information is necessary for internal uses of the company if those uses are reasonably expected by consumers;
- Information is necessary to comply with a legal obligation; or
- Information is used internally in a manner that is compatible with the context of the collection.
You may contact us at email@example.com to exercise any of these rights free of charge and we will respond within 1 month of the receipt of the request. We may need to ask for additional information in order to confirm your identity.
DATA THAT IS COLLECTED THROUGH A MOBILE DEVICE
Mobile devices can be used to access our services, as well as versions of our regular website. These mobile sites work in a similar way to our main website. Sometimes we make use of something known as cross-device tracking, which allows us to track user behavior across different devices. We use this to improve the service that we provide you and for marketing activities, so advertisements shown to you on other websites may be offered based on your activities on linked devices.
TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES
Xeni is headquartered in the U.S., and we have operations and service providers in the U.S. However, we process and store information in the U.S. and other jurisdictions. Therefore, we and those that perform work for us may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction.
We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access our Platform. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your location setting on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of our Platform.
You may opt out of receiving text messages or promotional emails from Xeni by following the instructions in those communications. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
Links to other Websites and Services
We are not responsible for the practices employed by websites or services linked to or from our Platform, including the information or content contained in such websites or services, and this Policy does not apply to them. Your browsing and interaction on any third-party website or service, including those that have a link on or to our Platform, are subject to that third party’s own rules and privacy policies. Please read the terms of such websites and applications carefully and exercise care when providing your personal information.
We control the processing of data over our sites – in legal terms, this means that Xeni is the Data Controller for the purposes of EU Data Protection laws.
If you have any questions about this Policy, please contact us by email at firstname.lastname@example.org, by phone at 1 800 481 5180 , or by post to:
New York, NY 10023