Traveluro

Holisto Ltd. also DBA Traveluro (“Holisto”, “we”) is committed to maintaining the privacy of its users (“user”, “you”). The following information describes how Holisto collects and processes information about you when you use our Services (as defined below). The Services are accessible via our website at www.traveluro.com (the “Website”) or via our mobile and tablet application (the “App”, and together with the Website, the “Platform”).

Our Privacy Policy explains:

• What information we collect and why we collect it.
• How we use that information.
• Your rights with regard to the collection of such information.

By using our Platform, you agree to this Privacy Policy.

Holisto develops and operates a smart online hotel booking platform which provides its users with competitive rates and discounted pricing for hotel bookings (the “Services”).

Using the App or Website on your Device

Users can access the Services only through the App or Website on a “Device” which within this Privacy Policy - means any computer used to access the Platform, including without limitation a desktop, laptop, mobile phone, tablet, or other consumer electronic device. This Privacy Policy describes the practices in which Holisto collects Personal Information through the App or Website in the course of the provision of the Services, and shall apply regardless of the manner in which access to the Services was provided.

Please note that the scope of this Privacy Policy is limited only to information collected by Holisto through your use of its Platform. When you access or use the Platform, whether as a registered user or not, some information may be automatically collected. We use of third party analytics tools to automatically collect information about your use of the Platform. This information includes your session durations, the content you accessed on the Platform, your interactions and user-interface clicks with respect to such content, referring URLs, the frequency and scope of your use of the Platform.

Information from which you may be personally identified (hereinafter: “Personal Information”) may also be collected, as follows:

1. Registration: You may register to the Platform using your full name and email address or using your phone number. We will explicitly indicate the mandatory fields for completion.

2. Registration via SSO: You also may register to the Platform using a Single Sign-On account (SSO) , such as Facebook, Google, Apple etc.. If you choose to register with a SSO account, you give us permission to retrieve the relevant information these SSO services obtain about you, and all in accordance with your specific SSO’s privacy settings. The information we collect in this manner typically includes your full name, email address, profile picture and other profile information such as date of birth or age range, gender, language, country and other public information – to the extent they are included in your SSO account.

3. Travel Information: During your usage of our Services, you will be asked to provide us with the following information: dates of travel, travel destination, hotel class, nightly budget, Tripadvisor rating, neighborhood and choice of hotel.

4. Inquiries: If you contact us for questions or complaints, or for technical support, we will collect the information related to your inquiry. This may include your user account ID, provided for when registering to use the Platform, email address and other contact information, depending on the nature of your inquiry.

Please note that Personal Information shall be collected only if received voluntarily from you, including, without limitation, by registering to the Services, contacting our call centers or an external call center whose details are provided on our Platform (“External Call Center”), or emailing us.

We use the Personal Information we collect from you for a range of different business purposes according to different legal bases of processing. We may use or process your Personal Information for the following purposes. One or more purposes may apply simultaneously.

1. Providing the Requested Services

• We collect Personal Information to process your booking requests, make your reservations and provide you with discounted hotel packages.
• Such collection of information will enable us to provide you with technical and professional assistance, with regard to the Services you use or intend to use.

We process the Personal Information where it is necessary for the adequate performance of the contract regarding the requested Services.

2. Improvement, Development and Protection of the Services

• We collect Personal Information to improve and develop our Services and understand feedback on Holisto's Services and to help provide more information on the use of those Services quickly and easily.
• We collect Personal Information for ongoing review and improvement of the information provided on our Platform to ensure it is user friendly.
• We collect Personal Information to improve the management and administration of our business and maintain compliancy with our internal policies and procedures.
• We conduct surveys and research, test features in development, and analyze the information we have to evaluate and improve our Services, develop new features, and conduct audits and troubleshooting activities.
• We may also collect your Personal Information, such as your audio or video screen use recordings that reflects your use of the Platform, to protect against harm to the rights of Holisto and its business partners, in connection with the provision of the Services. Such collection of information may be conducted, without limitation, for the purpose of conducting investigations of potential violations of our terms of service, as well as for establishing, exercising or defending against claims that may affect the rights of Holisto.

We process this information in light of our legitimate interest in improving the Services, to allow our users to have the best experience.

3. Maintain a Safe and Secure Environment

We may use your information to detect and prevent fraud, abuse and security incidents in the following ways;

• Verify and authenticate your identity and prevent unauthorized or illegal activity;
• Enhance the safety and security of our Services;
• Conduct security investigations and risk assessments;
• Prevent or take action against activities that are, or may be, in breach of our terms of service or applicable law.

We process this information in light of our legitimate interest in improving our Services and enabling our users to browse in a secure environment.

4. Personalize Content, Advertising and Marketing

• If you have used Holisto Services in the past, we have a legitimate business interest for matching the data we collect with other data we had already collected.
• This enables us to understand your needs and interests, optimize the content we send you and make it more suitable and relevant to your needs.
• This also enables us to improve your experience on the Platform by providing you with personalized content, recommendations, and features.

We process this information in light of our legitimate interest to personalize your experience and customize our content.

Except as otherwise provided in this Privacy Policy, we reasonably attempt to ensure that we never intentionally disclose any of your Personal Information, to any third party without having received your permission, except as provided for herein or otherwise as permitted or required under law.

In order to perform our contractual and other legal responsibilities or purposes, we may, from time to time, need to share your Personal Information with third parties, including but not limited to hotels and hotel resellers or providers that have partnered with Holisto to provide hotel rooms (in order to facilitate your interaction with them through the Platform).

In particular, in case the Platform is offered on our partner’s website as an integrated part of their online service, we may provide your Personal Information such as your booking details to enable you to be provided with the Services. Also, whenever you make a booking via the web pages or apps of our business partners, certain Personal Information provided to them by you may be forwarded to us.

We may as well share your Personal Information with our affiliates, subsidiaries or any third party service providers and individuals to facilitate our Services or any portion thereof, such as marketing, data management or maintenance services. We may also share your information with analytics service providers for analytics services such as HotJar and Amplitude. Such analytics service providers set their own cookies or other identifiers on your computer, through which they can collect information about your usage of our Platform.

This helps us compile aggregated statistics about the effectiveness of our Platform and Services. We may use the information we collect, to compile anonymized or aggregated information. Such information can no longer identify or be referenced an individual user. We may share, sell or otherwise communicate and make available such anonymized or aggregated information to any other third party, at our sole discretion.

The above mentioned third parties may be located in countries other than your own, and we may send them information we receive. When such third party service providers process your Personal Information on our behalf, we will assure that they comply with obligations similar to those which are set forth in this Privacy Policy. We will also assure that they will abide by our data privacy and security requirements, and will be allowed to use the Personal Information solely for the purposes we set. We will transfer your Personal Information while using appropriate and suitable safeguards, while using a variety of legal mechanisms, including contracts, to ensure your rights and protections travel with your data.

We may also transfer your information, including Personal Information, in connection with a corporate merger, consolidation, the sale of related assets or corporate division or other fundamental corporate changes. Furthermore, information about you may also be released in order to comply with any valid legal obligation or inquiry or process such as a search warrant, subpoena, statute or court order. We will also release specific information in special cases, such as if you use the Platform to perform an unlawful act or omission or take any act or omission that may damage Holisto, its property and goodwill, or if there is an attempted breach of the security of the Platform or a physical or property threat to you or others. The authority supervising such activities is the Israeli Privacy Protection Authority, and you have the right to file a complaint to it or any other relevant supervisory authority.

You have the right at any time to request to access or modify your information. To exercise these options, please contact us at contactus@traveluro.com

In some jurisdictions, in particular those located within the European Union (the "EU") or within the European Economic Area (the "EEA"), you may be afforded specific rights regarding your Personal Information. Subject to such eligibility, you may have the following rights to:

1. Request a rectification of your Personal Information where the information we hold about you is incorrect or incomplete.
2. Object to the processing of your Personal Information for direct marketing purposes.
3. Object to the processing of your Personal Information where our legal basis for that processing is that such processing is necessary for our legitimate interests.
4. Object to an automated decision-making (including profiling) in certain circumstances.
5. Request the erasure of your Personal Information in certain circumstances, such as where processing is no longer necessary for the purpose it was originally collected for, and there is no compelling reason for us to continue to process or store it;
6. Receive your Personal Information, or ask us to transfer it to another organization that you have provided to us, which we process by automated means, where our processing is either based on your consent or is necessary for the performance of a contract with you.

Generally, with regard to information collected on our Platform, Holisto is a "Data Controller". Therefore, if you wish to exercise the above mentioned rights, please contact us, and we will make our best efforts to fulfill your request.

If you wish to file a request regarding any of the above, you may contact us at: contactus@traveluro.com.

This section is designated for California residents and is provided under the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“California Privacy Laws”). It explains your privacy rights, provides “notice at collection”, and provides certain mandated disclosures about how we handle your Personal Information. This section uses certain terms that have the meanings given to them by the California Privacy Laws, unless otherwise specified. Please note that some of the disclosure obligations required under the California Privacy Laws are satisfied within other sections of this Privacy Policy.

The California Privacy Laws permit some users to request to exercise certain rights. If these rights are applicable to you, you are afforded with the following rights:

1. Right of access

You can request Holisto for certain information about our practices with respect to your Personal Information. In particular, you can request to receive information on the following:

• The categories and specific pieces of your Personal Information that we have collected.
• The categories of sources from which we collected your Personal Information.
• The business or commercial purposes for which we collected or share your Personal Information.
• The categories of third parties with which we shared your Personal Information.

2. Sharing Personal Information

Holisto is committed to provide you with the Services. From time to time, we may share your information, which may include personal identifiers, demographic information, behavioral information or inferences to provide the most relevant recommendation and deliver marketing messages and personalized offers through selected companies (e.g. analytics, advertising, travel and technology companies). Under California Privacy Laws, some of these practices may be considered a “sale” of Personal Information to those selected companies. Those companies help us match your interest with brands who want to send promotions and offers and help you discover new products or services that you may like. When we work with these companies, your privacy, data integrity and security remain a priority. Our ordinary practice is to have contractual limits on their use of your Personal Information by those companies and only provide the minimum data necessary to accomplish the specific goal (e.g. to provide you with personalized offers and deliver a better experience and value to you). Please note that sharing this type of Personal Information is subject to your consent and in case you require us to do so, we will facilitate your right to opt out of such data sharing practices.

1. Right to Limit Use and Disclosure of Sensitive Personal Information

We do not share sensitive Personal Information for cross-context behavioral advertising and we do not sell sensitive Personal Information.

2. Exercising your California Law Rights

Please note that we will be required to verify your identity and request before an action is taken to exercise your rights. As a part of this process, government identification may be required. Moreover, you may designate an authorized agent to make a request on your behalf. We make our best efforts to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide, will only cover the 12 months period preceding your verifiable request’s receipt. If, for some reason, we cannot reply within such time frame, our response will include an explanation for our inability to comply. If you wish to exercise your California Privacy Laws rights, please contact us at: contactus

3. Right of No Retaliation Following Opt-Out or Exercise of your Rights

If you choose to exercise your rights, we will not charge you different prices or provide different quality of our Services, unless those differences are related to your provision of your Personal Information. We will not discriminate against you for exercising any of your rights and unless permitted by the California Privacy Laws, we will not:

1. Deny you goods or services.
2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
3. Provide you with a different level or quality of goods or services.
4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

The CAN-SPAM Act is a Federal US law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out strict penalties for violations.

To be in accordance with CANSPAM, Holisto agrees to the following:

• Not use false or misleading subjects or email addresses.
• Identify the commercial message sent to you as an advertisement when required.
• Include the physical address of our business or site headquarters.
• Monitor third-party email marketing services for compliance, if one is used.
• Honor opt-out/unsubscribe requests quickly.
• Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails, you can email us at contactus@traveluro.com and we will promptly remove you from ALL correspondence.

We may use “cookies” and/or other technologies or files (collectively, “cookies”) to identify how visitors make use of this Platform. This aggregated tracking information may be used to help us improve and enhance the Platform experience for all of our visitors. In addition, cookies are used for adjusting the Platform to your personal preferences. Cookies contain information such as the pages you visited, the length of time you stayed on the Platform, the location from which you accessed the Platform and more. If you would prefer not to have cookies stored on your computer, you may modify your browser settings to reject most cookies, or manually remove cookies that have been placed on your computer. However, by rejecting the cookies, you may be unable to fully access the offerings on this Platform. To find out more about cookies, visit www.allaboutcookies.org.

The Platform may provide links to other websites. Please be aware that these other websites are not covered by our Privacy Policy. This Privacy Policy does not cover the information practices exercised by other providers of services, advertisers or other websites, companies or individuals, which are not owned or controlled by Holisto. We suggest that when linking to another website, you always read that website’s privacy policy before volunteering any personally identifiable information.

Please note that with respect to your commination with the External Call Center whose number is made available on our Platform, Holisto will not collect any information provided to such External Call Center by you. Any communication between you and the External Call Center shall be subject to the External Call Center data protection and privacy practices and representations.

We deploy industry standard, or better measures to ensure the security, confidentiality, integrity and availability of personal data we process. We maintain physical, technical and administrative safeguards, and test and update these periodically. We endeavor to restrict access to Personal Information on a ‘need to know’ basis for the provision of our Services to you. No such measures are perfect or impenetrable. In the event of a security breach, we will take all reasonable action to minimize any harm. Although we will do our best to protect Personal Information, we cannot guarantee the security of data transmitted to our Platform, and transmission is at the users own risk.

You are always in control of your data, and if you choose to receive information from us, or others, you can change your mind later. If, at any time, you would like to stop receiving such information or opt out of a feature, you may notify us by writing to contactus@traveluro.com. You should be aware, however, that it is not always possible to completely remove or modify information in our databases and servers, although we will always make reasonable efforts to do so upon your request.

Generally, Holisto does not retain information longer than necessary to provide its Services and for its reasonable business and lawful needs. If you withdraw your consent to us processing your data, we will erase your Personal Information from our systems, unless the data is required for Holisto to establish, exercise or defend against legal claims or it is necessary for the performance of the requested Services.

The service is not intended for children under the age of 18. We do not, knowingly or intentionally, collect information about children who are under 18 years of age.

IF YOU ARE UNDER THE AGE OF 18 YOU MAY NOT USE THE PLATFORM, UNLESS PARENTAL CONSENT IS PROVIDED ACCORDINGLY

If you have any questions regarding this Privacy Policy or the practices described above, you are always welcome to contact us at contactus@traveluro.com

We reserve the right to revise, amend, or modify this Privacy Policy at any time. When changing the policy, we will update this posting accordingly. Please review this Privacy Policy often so that you will remain updated regarding our current policies

This Privacy Policy will be governed and interpreted pursuant to the laws of the State of Israel without giving effect to its choice of law rules. You expressly agree that the exclusive jurisdiction for any claim or action arising out of or relating to this Privacy Policy shall be to the competent courts in Tel Aviv, Israel, to the exclusion of any other jurisdiction.