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PRIVISA LLC — PRIVACY POLICY

Last Updated: Jully 10th, 2025 Effective for: Privisa LLC, and affiliated SaaS systems Privisa LLC (“Privisa”, “we”, “our”, or “us”) is a travel-technology company operating reservation platforms, software-as-a-service (“SaaS”) solutions for hospitality operators, and global property-management technology for hotels, condos, and short-term vacation rentals. We take the privacy of our users, partners, suppliers, and guests extremely seriously. This Privacy Policy explains—in clear, detailed, and transparent terms—how we collect, use, share, and protect your information when you use any of our websites, mobile applications, or SaaS platforms. This Privacy Policy applies to: • Visitors of our websites (Privisa etc.) • Users of our reservation platforms • SaaS customers using our hospitality systems • TravelPass™ service users • MemberDeals™ program members • Partners who operate properties listed on our platform

1. Information We Collect

We collect information to operate our reservation systems, maintain our SaaS products, process travel-related transactions, prevent fraud, and deliver customer services. Information You Provide Directly This includes data you manually submit when creating an account, entering a booking, or contacting us: • Personal Identification: name, email, phone, address, age (if required by travel regulations). • Account Credentials: username, password (encrypted), security preferences. • Payment Information: credit card data, billing address, payment confirmations. o Note: Payment card information is never stored directly by Privisa LLC. We use PCI-DSS compliant external processors. • Travel Information: reservation dates, preferences, guest details, property selection. • Business Information (for property partners): hotel/condo/vacation rental data, property ownership details, accounting contact, tax IDs where applicable. • Communication Data: emails, support requests, chat messages, call logs (when permitted and securely stored). • Uploaded Content: property photos, verification documents, business licenses, identity proofs (KYC/AML when required). Information Collected Automatically When using our SaaS or reservation platforms, we automatically collect: • Device and Browser Data: IP address, device type, OS version, browser, screen resolution. • Usage Activity: pages visited, features used, clicks, search queries, session duration. • Location Data: approximate location derived from IP (for fraud protection and pricing compliance). • Cookies & Tracking Technologies: preference cookies, session identifiers, analytics metrics. • Application Logs: error logs, system performance data, API calls, and operational metrics. Information from Partners & Third-Party Sources We may receive information from: • Payment processors • Identity verification services • Hospitality partners using our PMS/SaaS • GDS and OTA systems (if connected) • Marketing partners and affiliate networks • Government/immigration databases (when legally required for travel screening)

2. How We Use Your Information

We use your data strictly to operate and improve our services. To Provide Reservation and SaaS Services • Process and manage hotel, condo, and vacation rental bookings • Sync availability, pricing, and property content • Provide secure account access to dashboards and portals • Deliver Travel and Deals benefits • Manage partner property data and financial settlements To Improve Platform Functionality • Enhance search results and booking experiences • Personalize user interfaces • Analyze system performance and fix errors • Launch new hotel or vacation rental tools For Security and Fraud Prevention • Monitor suspicious behavior • Validate transactions and prevent illegal activity • Protect partner properties and guests For Compliance with Laws • Tourism regulations • Anti-money laundering (AML) laws • Payment compliance and chargeback dispute processes • Requests from governmental authorities For Customer Communications • Sending reservation confirmations, updates, or reminders • Providing customer support • Sending important operational notices (policy updates, security alerts) • Marketing communications (only with user consent) ________________________________________

How We Share Your Information

We do not sell personal information. We share data only when necessary: With Travel & Property Partners To complete a reservation or support a SaaS customer, we share: • Guest name and booking details • Check-in/check-out dates • Payment confirmation status • Preferences for accommodations Partners must comply with strict privacy obligations. With Authorized Service Providers These include: • Payment processors • Cloud hosting providers • Analytics systems • Customer support tools • Identity verification providers Each provider is contractually required to secure your data. Legal Compliance We may disclose information if required by: • Court orders • Immigration or border authorities • Tax or enforcement agencies • Fraud or cybersecurity investigations Business Transactions If Privisa LLC undergoes: • Merger • Acquisition • Business restructuring User data may be transferred, always under strict confidentiality agreements.

3. Legal Basis for Processing

4. Data Sharing & Third-Party Partners

How We Share Your Information We do not sell personal information. We share data only when necessary: With Travel & Property Partners To complete a reservation or support a SaaS customer, we share: • Guest name and booking details • Check-in/check-out dates • Payment confirmation status • Preferences for accommodations Partners must comply with strict privacy obligations. With Authorized Service Providers These include: • Payment processors • Cloud hosting providers • Analytics systems • Customer support tools • Identity verification providers Each provider is contractually required to secure your data. Legal Compliance We may disclose information if required by: • Court orders • Immigration or border authorities • Tax or enforcement agencies • Fraud or cybersecurity investigations Business Transactions If Privisa LLC undergoes: • Merger • Acquisition • Business restructuring User data may be transferred, always under strict confidentiality agreements.

We never sell personal data to unrelated third parties.

5. Cookies & Tracking Technologies

We use cookies to: • Maintain secure sessions • Enable login • Keep booking information during navigation • Analyze platform activity • Personalize user experience Types include: • Essential Cookies: required for reservations and login • Performance Cookies: analytics and load measurement • Preference Cookies: store language, currency, search filters • Security Cookies: fraud protection and account integrity Users may disable cookies at any time, but essential services may stop functioning.

6. Data Retention Policy

We keep data only as long as needed for operational, legal, or security purposes. Including: • Reservation data: retained for regulatory compliance • Payment logs: retained for fraud and dispute management • Partner property data: retained during the business relationship • Support communications: retained to maintain service quality After retention deadlines, data is securely deleted or anonymized.

7. Data Protection & Security

We apply strict technical and organizational measures:

8. Your Privacy Rights

Depending on your location, you may have rights such as:

  • Access your data
  • Correct inaccurate information
  • Request deletion (when allowed by law)
  • Opt-out of marketing
  • Restrict processing
  • Receive a copy of your data (data portability)________________________________________
  • Children’s Privacy
  • Our services are not intended for minors under 16.
  • We do not knowingly collect minor data.
  • If discovered, we will delete such information immediately.

    • 9. International Data Transfers

    Privisa LLC operates globally. Data may be processed in the United States or other regions where our partners or cloud servers operate. We ensure: • GDPR-compliant transfer mechanisms • Standard contractual clauses (SCCs) where required • Protection equal to U.S. and international standards

    And

    10. Policy Updates

    Links to External Websites Our sites may include links to external pages (hotels, partners, suppliers, travel resources). We are not responsible for external privacy practices.

    Changes to This Policy

    We may update this Privacy Policy periodically. The “Last Updated” date always indicates the latest version. Users will be notified of significant modifications.We regularly review and update our privacy practices. Please check this page periodically.

    PRIVISA - COOKIES POLICY

    Effective for: Privisa LLC and all affiliated platforms Privisa LLC (“Privisa”, “we”, “our”, or “us”) uses cookies and similar technologies on our websites, SaaS platforms, and mobile applications to provide a seamless and secure experience for our users, guests, partners, and employees. This Cookie Policy explains in detail: • What cookies are • How we use them • The types of cookies we use • How you can manage or disable cookies ________________________________________

    What Are Cookies?

    Cookies are small text files stored on your device (computer, tablet, smartphone) when you visit a website or use an online service. Cookies allow a website to: • Recognize your device or browser • Remember your preferences (language, currency, login details) • Improve user experience • Track website usage for performance analytics • Enable secure transactions and login authentication Similar technologies include: • Local Storage & Session Storage: store temporary or permanent data on your device • Pixels/Beacons: small invisible images that track activity • Scripts: embedded tracking functions to analyze user behavior ________________________________________

    How We Use Cookies

    PrivisaGroup uses cookies for multiple purposes aligned with our SaaS and online reservation operations: Essential / Necessary Cookies • Required for website functionality and SaaS platforms • Enable login and session management • Maintain shopping cart / booking session continuity • Prevent fraud and unauthorized access Examples: session ID cookies, authentication cookies, security tokens Performance & Analytics Cookies • Collect information about how visitors use our platforms • Monitor page visits, navigation patterns, and feature usage • Help us optimize platform speed, content layout, and SaaS operations Examples: Google Analytics, server performance logs Functionality & Preference Cookies • Remember your selected language, currency, time zone, or booking preferences • Allow customized display of content Examples: saved property search filters, preferred payment method selections Marketing & Advertising Cookies • Track user interaction with our marketing campaigns • Allow targeted promotions for Travel, accommodation, Deals, or partner properties • Measure effectiveness of email campaigns or display ads Examples: retargeting tags, social media pixels, affiliate program tracking Security Cookies • Protect user accounts and partner dashboards • Detect suspicious activity or login attempts • Ensure transaction integrity for hotel, flight, and car rental bookings ________________________________________

    Third-Party Cookies

    Some cookies are placed by third-party partners, vendors, or services used by Privisa: • Payment processors for transaction completion • Cloud analytics and SaaS monitoring tools • Social media and marketing platforms • Advertising networks and affiliate programs We require third parties to comply with privacy and security standards, and their use of cookies is governed by their own policies. ________________________________________

    Managing and Disabling Cookies

    You have the right to control cookies: • Most browsers allow you to accept, reject, or delete cookies • You can disable tracking for third-party cookies in browser settings • Note: disabling essential cookies may affect login, booking, or SaaS functionality • For device-specific management: o Chrome: Settings → Privacy and Security → Cookies o Firefox: Options → Privacy & Security → Cookies o Safari: Preferences → Privacy → Cookies & Website Data o Mobile Apps: adjust device-level privacy settings For enhanced privacy, you may also use tracker-blocking tools or browser extensions. ________________________________________

    Cookie Duration

    Cookies may be: • Session Cookies: deleted when you close your browser • Persistent Cookies: remain on your device for a defined period to remember preferences or login details We specify cookie duration in each case (e.g., 30 days for preferences, 12 months for analytics). ________________________________________

    Legal Basis for Cookies

    PrivisaGroup relies on legitimate interests and user consent: • Essential cookies: necessary for performance and SaaS operation (no consent required) • Performance, marketing, and analytics cookies: based on user consent • GDPR-compliant mechanisms are in place for EU/EEA users • CCPA-compliant mechanisms are in place for California residents ________________________________________

    Updates to This Policy

    PrivisaGroup may update this Cookie Policy periodically to reflect new technology, partnerships, or legal requirements. • “Last Updated” date reflects the latest version • Users will be notified for significant changes via website banners or platform notifications

    11. Contact Information