The Costas owns and operates an online platform that provides users with information, recommendations, and services related to travel and leisure, including tools for researching other leisure-related services and trades. In this Statement, we refer to these as our “Services”.

The information that you and others entrust us with enhances our ability to provide more relevant, personalized, and helpful Services. We know that sharing your information with us is based on trust. We take your trust in us seriously and are committed to providing you helpful information, products, and services, curated based on the information you have shared with us. Equally, and perhaps more importantly, we are committed to respecting your privacy when you visit our website or use our Services and being transparent about how we use the information you have entrusted to us.

This Statement describes how we obtain, use, and process your information – hopefully, in an easily understandable and transparent manner. It informs you of the rights you have, how you can exercise them, and how you can contact us. Please review this Statement carefully to learn about our practices with respect to information and privacy. By visiting our websites and related mobile applications, as well as other online platforms such as our affiliated partners’ websites, apps, and social media, whether on a computer, phone, tablet, or similar device (each of these is referred to as a “Device”), you acknowledge and confirm that you have read this Statement.

We offer our Services to users in a number of countries and territories where the laws and customs differ. This Statement provides a general overview of our privacy practices. In addition, Sections 12 through 15 of this Statement provide specific information relevant to users residing in certain regions or countries.

1. Information Collected and Processed When you access or use our Services, we collect and process information from and about you to provide the Services in a more personalized and relevant way. Some information we collect passively, for example, with our servers or with cookies or other similar tracking technologies. Some information we collect from different sources, including from you, affiliated entities, business partners, and other independent third-party sources. When you use our Services by “clicking-through” from a third-party website or when you visit third-party websites via our Services, those third-party websites may share information with us about your use of their service. Any information that we receive from third-party websites may be combined with the information provided by you.

Information processed may include the following:

Contact information, including name, phone number, and postal and email addresses (both hashed and unhashed)  Documentation to support travel (for example, IP address, software or internet browser used, preferred languages, unique Device identifiers, and advertising identifiers) Online activity, including pages you have visited, content reviewed, and apps reviewed Other information about yourself that you have voluntarily disclosed Purchasing and booking history Information about your travel, experience and dining plans and preferences Communications when you contact our customer service team, including inbound and outbound calls Information that you have provided to other third party companies for the purposes of logging in to social media. This includes publicly available information, such as name, age-range as well as email addresses. We may also collect – in instances where you have provided it – information about other travellers or guests, including their email address and other travel, dining, or experience-related information. If you are sharing information with us about other individuals, you must obtain their consent and ensure that they have understood and accepted how we will use their personal information (as described in this Statement)

2 The Costas is committed to providing you with relevant content and a tailored experience when you use our Services. We utilize information about you in various ways, as outlined below:

Registration, Membership, and Other Contracts:

• Register and manage your account, allowing access to and use of our Services.
• Facilitate your bookings.
• Process payments or credits.
• Offer promotional programs, including competitions, gift cards, rewards, cash back, and discounts.

Improve Our Services:

• Use your information for analytical purposes to enhance and improve our Services.
• Provide a tailored/optimized experience by grouping users based on usage, interests, and demographics.
• Send survey, market research invitations, or panel interviews for analytics purposes.

Individualization and Customization:

• Notify you about special offers and products or services available from us, our affiliates, or partners that may be of interest.
• Tailor your experience by making inferences about your interests and preferences based on your activity.
• Customize the ads shown to you both on and off our website.

Communication:

• Communicate with you or facilitate communication between you and our partners and/or affiliates.
• Conduct, monitor, and record your calls or interactions with us, including communications with our customer service or sales teams.
• Use pixels and similar technologies to monitor how you interact with our emails, such as whether you open or click on content.

Host Your Content:

• Host your reviews, forum posts, photos, videos, and other content.
• Respond to your questions and comments.

Legal Compliance:

• Resolve disputes or troubleshoot problems.
• Prevent fraud and other potentially prohibited or unlawful activities.
• Comply with relevant laws, respond to legal requests, prevent harm, and protect our rights.
• Provide payment services, including detecting and preventing money laundering, fraud, and security incidents, complying with legal obligations, and enforcing any applicable terms of service.

Please note that if automated decision-making is used to process your personal information, we will implement appropriate measures to safeguard your rights and freedoms, including your right to obtain human intervention.

3 The Costas recognizes the importance of information sharing to provide our Services effectively. We may need to share information with service providers and certain third parties under specific circumstances, as outlined below:

Our Group of Companies:

• We may share information with companies in our corporate family to provide information about products and services, including travel-related offerings. This sharing helps us understand how you interact with the websites, apps, and services of our group companies. These companies adhere to this Statement and applicable laws.

Suppliers:

• Information may be shared with suppliers to facilitate our Services, particularly in transactions.

Business Partners:

• We share information about you, your Devices, and your use of our Services with trusted business partners. This may include facilitating payment for products or services you purchase on our partners’ websites. This sharing is governed by written agreements with confidentiality, privacy, and security obligations.

Social Media Websites:

• When you choose to share information with third-party social media websites through our Services, their privacy policies and your privacy settings with those websites apply.

Advertising Networks:

• We collect and share information about your interests with advertising networks and data aggregators. Some are members of organizations like the Network Advertising Initiative or the Digital Advertising Alliance, offering opt-out options for ad targeting.

Fraud Detection Companies:

• Third parties may assist us with fraud detection technologies.

Other Third Parties:

• We may engage third parties to assist in collecting information, operating features of our website, and delivering tailored advertising. These third parties act as data processors, collecting or accessing information as necessary for their functions.

Device Privacy Settings:

• Certain Device operating systems allow you to opt out of specific information sharing, including with advertising networks. Adjust your Device’s privacy settings to control location information sharing, keeping in mind that this may impact certain features.

We may also share your information under the following circumstances:

• Legal Compliance: To comply with subpoenas, court orders, or legal processes; to establish or exercise legal rights; to defend against legal claims; or as required by law.

• Investigation and Prevention: To investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of The Costas, our customers, or others; and in connection with our Terms of Use and other agreements.

• Corporate Transactions: In connection with corporate transactions such as divestitures, mergers, consolidations, asset sales, or in the unlikely event of bankruptcy.

4 Information Choices

At The Costas, we respect your choices regarding the processing and use of your information. You have the following options:

1. Account Management:

   • Access, update, and close your account through the “Member Profile” section on our website or app.
   • Closing your account deactivates it, removing your profile information from active view. Some information may be retained for internal purposes such as backups, fraud prevention, dispute resolution, investigations, legitimate business interests, and legal compliance.

2. Communication Preferences:

   • Choose the way we communicate with you.
   • Modify your marketing subscriptions, including email choices, within your member settings.

3. Providing Information:

   • Choose not to provide certain information, though it may be necessary for specific features on our websites.

4. Geolocation Information:

   • Prevent the collection of certain geolocation information by adjusting location services in your phone settings. Note that turning off location sharing may impact certain features of our Services.

5. Unsubscribing:

   • Unsubscribe from promotional messages, including travel-related opportunities, by using the unsubscribe option in any email we send.

Information on Children

Our Services are not intended for children, defined as individuals 13 years of age or under, or the age of privacy consent in your jurisdiction. In cases where personal information of children is necessary, such as for a travel-related reservation, we will only collect it with the consent of a parent or guardian. If we inadvertently process a child’s personal information without valid consent, we will promptly delete it upon awareness. Your child’s privacy and protection are paramount to us.

5 Information Security

At The Costas, we prioritize the security of your information and have implemented comprehensive measures across administrative, technical, and physical domains to protect it. Our security procedures include:

1. Authorization:

   • Only specific authorized personnel have access to personal information, and such access is limited to permitted business functions.

2. Encryption:

   • We use encryption protocols when transmitting your information, both between your system and ours, and between our system and the parties with whom we share information.

3. Firewalls and Intrusion Detection:

   • Firewalls and intrusion detection systems are employed to prevent unauthorized access to your information.

However, it’s important to note that despite these measures, we cannot guarantee the absolute security of information due to factors such as unauthorized entry or use, hardware or software failure, or other circumstances beyond our control.

Information Deletion and Retention

We will retain copies of your information for the duration of your account maintenance or as required for the purposes outlined in this Statement. Unless applicable law mandates a longer retention period, we will retain your information. Additionally, we may keep your information for the duration necessary to establish, exercise, or defend any legal rights. Rest assured, our retention practices align with legal requirements and ethical standards to ensure the responsible handling of your information.

6 Information from Cookies

To enhance your experience on our Services, improve website security, and provide you with relevant advertising, we utilize cookies and similar technologies. Cookies are small text files automatically placed on your Device when you visit our website, storing basic information about your internet use. Your browser sends this cookie information back to our website each time you revisit, allowing us to recognize your Device and enhance your experience by providing personalized content. Additionally, we use other tracking technologies like pixels, SDKs, or server logs with similar functionality. Cookies and tracking technologies help us remember your login details, eliminating the need for repeated entries and aiding in understanding your preferences.

Control and Consent:

• We offer a Cookie Consent Tool for you to adjust and customize your cookie settings.
• Access the Cookie Consent Tool by clicking the “Cookie consent” link at the bottom of each page and modify preferences in our cookie banner.
• Manage cookies through your internet browser settings.
• You have the right to withdraw your consent to cookies at any time through the “Cookie consent” link.

Third-Party Advertisement:

• We allow third parties to collect and use information from your browsing activities for tailored advertisements.
• Third-party details are provided in our Cookie Consent tool, including links to their privacy notices.

Email Address Usage:

• When you provide your email address on our website or app, we may share hashed, pseudonymous personal data with advertising partners (e.g., LiveRamp and the Trade Desk).
• This information is used to create an online identification code for recognizing you on your devices, without containing identifiable personal data.
• The online identification code is placed in our first-party cookie and may be shared globally for interest-based content or targeted advertising across your online experience.

Your privacy is important to us, and we provide tools and options for you to control your cookie preferences and understand how your information is utilized for a personalized online experience.

7 Information on Statement Changes

The Costas may update this Statement in the future. If we consider the changes to be material, we will inform you through one or more of the following methods:

1. Sending you a communication detailing the changes.
2. Placing a notice on our website.
3. Posting an updated Statement on the website.

We will indicate the most recent update date at the top of this Statement. We encourage you to check back periodically to review the latest version and stay informed about our privacy practices. Your understanding and continued awareness of our Statement contribute to a transparent and trustworthy relationship.