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)
• Billing and other payment information (such as your bank account information, credit card number, cardholder name, expiration date, authentication code and billing address)
• Documentation to support travel and planning
• Username and password
• Details relating to your membership with Tripadvisor
• Photos, reviews, forum and social posts, and videos you may have provided to us
• Geolocation information
• Device information, such as when you accessed our Services and information about the Device used (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).

In addition to the categories noted above, we may also collect certain location information if you have instructed your Device to send such information via the privacy settings on that Device, or, for example, if you have uploaded photos tagged with location information.

To the extent possible, we want to provide you with relevant content and a tailored experience when you use our Services, and we use information about you to do that, including in the following ways:

Registration, membership, and other contracts

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

Improve our Services

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

Personalization and customization

• Notify you about special offers and products or services available from us, our affiliates, or our partners that may be of interest to you
• Tailor your experience, including by making inferences about your interests and preferences based on your activity and 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; for example, your communications with our customer service or sales teams, or through our use of pixels and similar technologies to monitor how you interact with our emails to you, such as whether you open or click on content in our emails
• 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 to detect and prevent money laundering, fraud and security incidents, to comply with legal obligations, and to enforce any applicable terms of service

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

In order to provide some of our Services and processing activities, we use service providers and may need to make available each category of information that we collect to these service providers, and certain other third parties, including our group of companies, in the following circumstances:

• Our Group of Companies. We may share information with certain companies in our corporate family so we can provide you with information about products and services, both travel-related and others, which might interest you and to provide payment services. This sharing also allows us to better understand how you interact with the websites, apps and services of our group companies. These companies will comply with this Statement and all applicable laws governing the transmission of promotional communications.
• Suppliers. We may share information with certain suppliers used to facilitate our Services, including where relevant to help with transactions.
• Business Partners. We may share information about you, your Devices and your use of our Services with our trusted business partners. For example, we may share information so that we can facilitate payment for products or services you may purchase on the websites of our partners. This sharing is generally pursuant to written agreements which include confidentiality, privacy, and security obligations; please note, however, that we do not control the privacy practices of these third-party business partners.
• Social Media Websites. When you use our Services and elect to share information with third-party social media websites, the information you share will be governed by the privacy policies of those social media websites and the privacy settings you have set with those social media websites.
• Advertising Networks. We sometimes collect and share information about your interests with advertising networks and data aggregators. Some of these companies are members of the Network Advertising Initiative or the Digital Advertising Alliance, which offer a single location to opt out of ad targeting from member companies. To learn more about the Digital Advertising Alliance, please click here.
• Fraud Detection Companies. Third parties may assist us by providing us with their fraud detection technologies.
• Trusted third parties. Third parties may also assist us in collecting information by, for example, operating features of our website or facilitating the delivery of online advertising tailored to your interests. We may share audience segments and other information, such as hashed email addresses, with third parties that use that information for tailored advertising to you. Other third parties may also provide us with their content and contract generation, management, and hosting tools. Third parties may only collect or access information as needed to perform their permitted functions. If and to the extent these third parties only assist us to perform our processing operations, we have bound them contractually to only act on our behalf as so-called data processors.

Certain Device operating system versions permit you to opt out of certain types of information sharing, including to certain advertising networks. You can change the privacy settings of your Device at any time in order to turn off the functionality that collects and shares location information. Please check your Device settings if you want to limit such tracking. However, turning off location-sharing may affect certain features that we offer. If you have any questions about the privacy settings of your Device, we suggest you contact the manufacturer of your Device or your mobile service provider for help.

We also may share your information if we believe, in our sole discretion, that such disclosure is necessary:

• To comply with legitimate and enforceable subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we reserve the right to raise or waive any legal objection or right available to us.
• To investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of Tripadvisor, our customers, or others; and in connection with our Terms of Use and other agreements.
• In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

Certain disclosures may be considered “sales” or “shares” under applicable U.S. state privacy laws. Details on how to exercise your legal rights with respect to such “sales” or “shares” can be found below in Section 13.

You have options with respect to the processing and use of your information by us. You can access, update, and even close your account by visiting the “Member Profile” section on our website or app. In addition, you can do the following:

• Choose the way we communicate with you.
• Choose not to provide us with certain information, although it may be needed to take advantage of certain features offered on our websites.
• Prevent the collection of certain geolocation information (e.g. by switching off location services for our app in the settings of your phone), but note that turning off location sharing may affect certain features of our Services.
• Close your account directly from within your Member Profile. Note that if you close your account, we will deactivate your account and remove your profile information from active view. We may retain some information associated with your account (including past transactions) for internal purposes including backups, fraud prevention, dispute resolution, investigations, our own legitimate business interests, and legal compliance for the period necessary to fulfil the purposes outlined in this Statement.
• As a registered member, you can modify your marketing subscriptions, including email subscription choices, at any time, within your member settings.
• Unsubscribe from promotional messages, including emails with travel-related opportunities, in any such email we send.

Our Services are not intended for children, which we consider to be: (i) individuals that are 13 years of age or under, or the age of privacy consent in your jurisdiction; or (ii) when processing data on the basis of a contract, the age of legal capacity to enter into the agreement.

We will only collect or process information belonging to children under very limited circumstances. We might need to collect personal information belonging to children as part of our Service if, for example, the personal information is required as part of a travel-related reservation. We will only collect personal information belonging to children if it is provided by and with consent of a parent or guardian. If we become aware that we have processed the personal information of a child without the valid consent of a parent or guardian, we will delete the personal information.

We offer our Services to users located in many different jurisdictions. If we transfer your information to other countries, we will use and protect that information as described in this Statement and in accordance with applicable law.

We have implemented appropriate administrative, technical, and physical security procedures to help protect your information. We only authorize specific personnel to access personal information and they may do so only for permitted business functions. We use encryption when transmitting your information between your system and ours, and between our system and those of the parties with whom we share information. We also employ firewalls and intrusion detection systems to help prevent unauthorized access to your information. However, we cannot guarantee the security of information from unauthorized entry or use, hardware or software failure, or other circumstances outside of our control.

We will retain copies of your information for as long as you maintain your account or as necessary in connection with the purposes set out in this Statement, unless applicable law requires a longer retention period. In addition, we may retain your information for the duration of any period necessary to establish, exercise, or defend any legal rights.

We want your access to our Services to be as easy, efficient, and useful as possible. To help us do this, we use cookies and similar technologies to improve your experience, to enhance website security, and to show you relevant advertising.

Cookies are small text files that are automatically placed on your Device when you visit almost any website. They are stored by your internet browser and contain basic information about your internet use. Your browser sends the information from these cookies back to a website every time you revisit it, so it can recognize your Device and improve your experience by, among other things, providing you with personalized content. We also use other tracking technologies, such as pixel, SDKs, or server logs, that have a similar functionality. We also use cookies and tracking technologies to remember your login details, so you don’t have to re-enter them repeatedly when you use our Services or to help us understand your preferences.

To give you control, we provide you with a Cookie Consent Tool which allows you to adjust and customize your cookie settings. You can access the Cookie Consent Tool by clicking the “Cookie consent” link at the bottom of every page and modify your preferences in our cookie banner. In addition, you can manage cookies through the settings of your internet browser. You have the right to withdraw your consent to cookies at any time by clicking on the “Cookie consent” link and modifying and saving your preferences. In the settings of your Internet browser, you can choose which cookies to accept and reject.

We allow third parties to collect and use information obtained during your browsing activities in order to deliver tailored advertisements to you (from us and from third parties across the Internet), to analyze activity and engagement on our website or app, and to provide you with enhanced Services. These parties are listed in our Cookie Consent tool, where we provide you with their details and links to their privacy notices. When we disclose your information to these third parties, this may be considered a “sale” or “share” under the applicable U.S. state privacy laws. Details on how to exercise your legal rights with respect to such “sales” or “shares” can be found below in Section 13.

When you enter your email address on our website (either to log in, or to sign up to a newsletter, or similar) or when you use our app, we may share personal data or other information that we collect from you, such as your email (in hashed, pseudonymous form), mobile advertising identifier, IP address, or information about your browser or operating system, with our advertising partners, like LiveRamp and the Trade Desk and their group companies, acting as joint controllers. LiveRamp and the Trade Desk use this information to create an online identification code for the purpose of recognising you on your devices. The online identification code does not contain any of your identifiable personal data and will not be used by LiveRamp or the Trade Desk to re-identify you. We place the online identification code in our first-party cookie, a LiveRamp or the Trade Desk cookie, and allow it to be used for online and cross-channel advertising. It may be shared with our advertising partners and other third-party advertising companies globally for the purpose of enabling interest-based content or targeted advertising throughout your online experience (e.g. web, email, connected devices, and in-app, etc). These third parties may, in turn, use the online identification code to link to demographic or interest-based information that you have provided in your interactions with them. You can find detailed information on LiveRamp’s data processing activities, including how to opt-out in their privacy here and for the LiveRamp privacy policy with other available country links here. You can also learn more about how Trade Desk uses unique identifiers, your rights, and how to contact them here.

Most advertising networks offer you a way to opt out of advertising cookies. See www.aboutads.info/choices/ and www.youronlinechoices.com for useful information on how to do this.

If you decline certain cookies, your access to some functionality and areas of our Services might be degraded or restricted.

Our use of any information we collect through cookies is subject to this Statement, which is linked on every page of our website.

We may update this Statement in the future. If we believe any changes are material, we will let you know by doing one or more of the following: sending you a communication about the changes, placing a notice on the website and/or posting an updated Statement on the website. We will note at the top of this Statement when it was most recently updated. We encourage you to check back from time to time to review the most current version and to periodically review this Statement for the latest information on our privacy practices.

This GDPR Statement applies to persons in the European Economic Area (“EEA”), including those based in the United Kingdom. This GDPR Statement supplements our Statement; however, where the Statement conflicts with the GDPR Statement, the GDPR Statement will prevail as to persons located in the EEA.

Tripadvisor LLC is the controller of personal information we collect; however, in accordance with applicable data privacy law, we have appointed representatives within the European Union and United Kingdom.

The contact details of our European Union representative are:

Tripadvisor Ireland Limited

C/O Matheson

70 Sir John Rogerson's Quay

Dublin 2

D02 R296

Ireland

The contact details of our United Kingdom representative are:

Tripadvisor Limited

7 Soho Square

London

W1D 3QB

United Kingdom

Attn: Privacy Officer

Tripadvisor Ireland Limited and Tripadvisor Limited’s roles in this respect are limited solely to being a contact point for questions on data protection from European (including UK) residents and data protection supervisory authorities. For the avoidance of doubt, neither Tripadvisor Ireland Limited nor Tripadvisor Limited can field other communications or legal process on behalf of Tripadvisor LLC.

You have certain rights regarding your personal information.

Your rights with respect to your own personal information include the following:

• The right to request access to your personal information. This enables you to receive a copy of the personal information we hold about you.
• The right to request correction of your personal information if it is inaccurate. You may also supplement any incomplete personal information we have, taking into account the purposes of the processing.
• The right to request deletion of your personal information if:

• your personal information is no longer necessary for the purposes for which we collected or processed them; or
• you withdraw your consent if the processing of your personal information is based on consent and no other legal ground exists; or
• you object to the processing of your personal information and we do not have an overriding legitimate ground for processing; or
• your personal information is unlawfully processed; or
• your personal information must be deleted for compliance with a legal obligation.

• The right to object to the processing of your personal information. We will comply with your request, unless we have a compelling overriding legitimate interest for processing or we need to continue processing your personal information to establish, exercise, or defend a legal claim.
• The right to restrict the processing of personal information, if:

• the accuracy of your personal information is contested by you, for the period in which we have to verify the accuracy of the personal information; or
• the processing is unlawful, and you oppose the deletion of your personal information and request restriction; or
• we no longer need your personal information for the purposes of processing, but your personal information is required by you for legal claims; or
• you have objected to the processing for the period in which we have to verify overriding legitimate grounds.

• The right to data portability. You may request that we send this personal information to a third party, where feasible. You only have this right if it relates to personal information you have provided to us where the processing is based on consent or necessity for the performance of a contract between you and us, and the processing is conducted by automated means.
• You also have the right to lodge a complaint before your national data protection authority.

You will not usually have to pay a fee to access your personal information (or to exercise any of the other rights described in this Statement). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights).  To the extent you use a third party to submit a data request on your behalf, we may need to take reasonable steps to verify the authenticity of the request. These are security measures to ensure that personal information is not disclosed to any person who has no right to receive it. In an effort to speed up our response, we may also contact you to ask you for further information in relation to your request. You can exercise several of your rights through the personal information section of your account. To exercise your other rights you can file a request by clicking here.

We will only use your personal information under the circumstances permitted by the law or you.

Pursuant to GDPR, we will use your personal information in one or more of the following circumstances:

Your personal information may be stored or transferred to countries outside the EEA and the UK for the purposes described in this Statement. When we store or transfer your personal information outside the EEA and the UK, we take the following precautions to ensure that your personal information is properly protected.

Whenever we store or transfer your personal information outside the EEA and the UK, we will do so in accordance with applicable law, and we will ensure a similar degree of protection is afforded to it by implementing appropriate safeguards. Transfers of personal information are made:

• to a country recognised by the European Commission as providing an adequate level of protection; or
• to a country which does not offer adequate protection but whose transfer has been governed by the standard contractual clauses of the European Commission or by implementing other appropriate cross-border transfer solutions to provide adequate protection.

By using our Services, you understand that your personal information may be transferred to our facilities and those third parties with whom we share it, as described in this Statement.

Depending on your U.S. state of residence, you may have certain rights in relation to your personal information that we collect, use, or disclose in accordance with this Statement, including:

• Right to know. You may have the right to request that we disclose to you the categories and specific pieces of personal information that we have collected about you, the categories of sources from which we collected your personal information, our business or commercial purpose for collecting, selling, or sharing your personal information, the categories of personal information that we have disclosed for a business purpose, any categories of personal information about you that we have sold, and the categories of third parties with whom we have disclosed your personal information, if applicable. You may have the right to request your personal information in a portable format.

• Deletion. You may request that we delete your personal information that we maintain about you, subject to certain exceptions. As described in more detail in our Statement, there are some reasons for which we will not be able to fully address your deletion request, such as if we need to complete a transaction for you, to detect and protect against fraudulent and illegal activity, to exercise our rights, or to comply with a legal obligation. You can also access, update, and remove your information by visiting the Member Profile page on our website.

• Correction. You can request that we correct inaccurate personal information that we maintain about you.

• Opt Out of Sales, Sharing, and Targeted Advertising. Depending on the local laws in the state you reside in, you may request to opt out of our sale or sharing of your personal information to third parties, or the use and disclosure of your personal information for targeted advertising. To effect the opt out, please click on the “Do Not Sell or Share My Personal Information” link on our homepage/app. You may also use a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control (“GPC”). We will process the GPC signal as a request to opt out.

To take advantage of any of these rights, please contact us via our dedicated privacy portal by clicking here or contact us toll-free at tel:+18339305755. You may designate an authorized agent to make a request on your behalf. When submitting the request, please ensure the authorized agent is identified as an authorized agent. We may need to verify your identity or elements of the request to enable us to process your request. We will take reasonable steps to verify your identity when you submit a right to know, delete, or correct request; these verification steps will vary depending on the sensitivity of the personal information and whether you have an account with us. We may deny certain requests, or fulfil a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests. We value your privacy and will not discriminate against you in response to your exercise of privacy rights.

Depending on your U.S. state or residence, you may have the right to appeal a decision we have made in connection with your privacy rights request. To appeal a decision, please submit your request here.

We may collect your personal information in connection with certain special offers, discounts, sweepstakes, contests, or other promotions (collectively, “promotions”) that we may make available to you. For example, we may collect your biographical information/identifiers (e.g. name, contact details, etc), commercial information, internet or other electronic network activity information, characteristics of protected classifications under California or U.S Federal law, visual and audio information, or inferences drawn from the above. Because these promotions may involve the collection of personal information, they may be interpreted as a “financial incentive” under California law or a “bona fide loyalty program” under Colorado law. We use the personal information that we collect as described in the Notice and in Section 2 of the Statement, and we may sell, share, or disclose the personal information that we collect as described in the Notice and in Section 3 of the Statement.

When you sign up for a promotion, we will provide you with relevant terms that apply to your participation in the promotion. To stop receiving promotions by email, you may unsubscribe by clicking the “unsubscribe” button at the bottom of any email. If you decline to provide your personal information or ask us to delete your personal information, we may not be able to provide you with access to these promotions.

The value of any financial incentive or bona fide loyalty program we offer is reasonably related to the value of any personal information that you provide to us. We estimate the value of your personal information by considering, without limitation, the expenses we incur from collecting your personal information and/or providing the promotions to you, and/or the revenue generated through the promotions.

This Korea Statement applies to persons in the Republic of Korea. This Korea Statement supplements our Statement; however, where the Statement conflicts with the Korea Statement, the Korea Statement will prevail as to persons in Korea.

We process the personal data we have collected for the purposes set forth below. We will retain your personal data in accordance with the Statement and as described in further detail below.

You have certain rights regarding your personal data. Your rights with respect to your own personal data include those under the Statement and the following:

• The right to consent to the collection of your personal data. When we request your personal data, the data that is mandatory for the services that are being provided will be marked accordingly. You can choose not to provide us with the requested data but this may impede your use or access of the relevant services.
• The right to consent to the sharing of your personal data, delegation of processing of your personal data or international transfer of your personal data.
• The right to request access, correction, deletion and suspension of processing of personal data to the extent permitted under Article 35, Section 5 and Article 37, and Section 2 of the Personal Information Protection Act.
• You can exercise your rights by filing a request here. You may also appoint an attorney-in-fact to exercise your rights by submitting a power of attorney to us in the form of Appendix 11 prescribed under the Regulations of the Personal Information Protection Act. We reserve the right to request specific information from you to help us confirm your identity or verify the identify and relationship of your attorney-in-fact and ensure your right to access your personal data (or to exercise any of your other rights).

We may share information with third parties, such as those listed below, in order to facilitate some of our Services and products. There may also be legal reasons for which we have to share your personal data. Some of our Services and products require that we share information with the third parties listed below. There may also be legal reasons that we have to share your personal data.

To efficiently provide our Services to you, we have delegated certain processing functions as described below to the third parties listed below. We will obtain your consent when you provide your information and delegate processing to such third parties pursuant to the agreements in place with such third parties.

Your personal data may be stored or transferred to countries outside Korea for the purposes described in this Statement. When we store or transfer your personal data outside Korea, we will notify you and request your consent unless such transfer is being made for the purpose of performing the services requested by you and to further your convenience.

We want you to feel confident about using our Services so we are committed to protecting the information we collect. We have implemented the following administrative, technical, and physical security procedures to help protect the personal information that you provide us.

• Administrative Security Procedures: Only a limited number of authorized workers are permitted access to personal data in accordance with internal access controls. Access is granted on a role permission basis only for permitted business functions.
• Technical Security Procedures: Personal data is encrypted when it is transmitted. We use firewalls and intrusion detection systems to help prevent unauthorized persons from gaining access to personal data. Certain user data may be hashed depending on its sensitivity.
• Physical Security Procedures: Data is secured in lockdown restricted cages. This data is stored in restricted data centres. Hard drives are physically destroyed when replaced and we have internal procedures in place to secure access to restricted server rooms and physical assets.

We will destroy or delete your data when the data retention period has lapsed, when you no longer maintain your account or if the purpose of data collection has been achieved.

The procedure and method of destruction and deletion is as follows:

• Procedure: Personal Information is disposed of, destroyed, or deleted for the protection of information in accordance with our internal company policy and other applicable laws, after the purpose of its collection has been fulfilled.
• Method: Personal Information in paper format will be destroyed using paper shredder, and Personal Information stored in electronic format will be destroyed using technical methods which make the records unrecoverable.

You can exercise several of your rights through the personal information section of your account. To exercise your other rights, you can file a request by clicking here, or you can contact our representative in Korea, who has been appointed in accordance with the applicable Korean law for the purpose of handling personal data protection questions or requests in Korea.

The contact details of our representative are:

LAB Partners (Managing Partner: Youngju Kim)

Tel: 02-6956-6311

Email: tripadvisor@labpartners.co.kr

Address: 8th Floor, VPLEX, 501 Teheran-ro, Gangnam-gu, Seoul, Korea 06168

LAB Partner’s role in this respect is limited solely to being a contact point for questions or requests on personal data protection from persons in Korea and data protection supervisory authorities. For the avoidance of doubt, LAB Partners cannot field other communications or legal process on behalf of Tripadvisor LLC.

This LGPD Statement is applicable whenever you access our website and application provided in Brazil. This LGPD Statement supplements our Statement; however, where the Statement conflicts with the LGPD Statement, the LGPD Statement will prevail as to persons in Brazil.

This LGPD Statement is intended to help you understand what information is collected, why we collect it, whether we share it, and with whom. In addition, this LGPD Statement is intended to inform you of your rights in connection with this information and how to exercise them.

Tripadvisor LLC is the data controller of personal information we collect; however, in accordance with applicable Brazilian data privacy law, we have appointed a Data Protection Officer (“DPO”) in Brazil:

Opice Blum, Bruno e Vainzof Advogados Associados

tripadvisor@opiceblum.com.br

We will only use your personal data when the law allows us.

Pursuant to LGPD, we may use your personal information in one of or more of the following circumstances:

• Meet the purpose given at the time of collection, including to allow the performance of the contract we have entered into with you.
• Comply with legal or regulatory obligations, regulations of government agencies, tax authorities, judiciary, and/or other competent authorities.
• Allow the regular exercise of our rights guaranteed by law, including as evidence in judicial, administrative, or arbitration proceedings.
• Enable the necessary activities for our operations involving the continuity of our operations whilst balancing against your interests and expectations so as not to cause a detriment to your interests, rights and fundamental freedoms.
• Fulfill the purpose for which the information was provided or for other purposes compatible with them and informed to you at the time of collection of your data. For example, we may process your data when contacting our service channels, including for information about our products or for your feedback.
• Based on our legitimate interests, we may also process your personal information, for example, to enable our communication and marketing activities and improve our products, services, and relationships with our customers and partners whilst balancing against your interests and expectations so as not to cause a detriment to your fundamental rights or freedoms.
• Prevent fraud and ensure your safety to detect, prevent, and investigate fraudulent activity.

You have the following rights relating to your services:

• Know if we process any of your personal information, including the types of personal information.  
• Correct incomplete, inaccurate, or outdated personal information.
• Request anonymization, blocking or deletion of unnecessary, excessive, or perhaps unlawful information.
• Request the portability of your information to another service provider or product.
• Request the deletion of the data processed with your consent.
• When the processing activity requires your consent, you may refuse to provide your consent, and we will inform you of the consequences of your refusal.
• When the processing activity requires your consent, at any time you can revoke it.

You may exercise these rights directly on our website and application, for example by editing your registration information directly in your member profile. You can also submit a request directly on our privacy portal by clicking here.

You may also contact our DPO, whose contact details are made available at the beginning of this LGPD Statement.

You will not have to pay fees to access your personal information (or to exercise any of the other rights described in this LGPD Statement).

We may need to request specific information from you to confirm your identity and secure your right to access your personal information (or exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to anyone who does not have the right to receive it. In an effort to speed up our response, we may also contact you to request more information regarding your request.

In specific cases, your request may not be fulfilled. In these cases, we will explain the justifications for our refusal. For example, requests involving personal information and/or documents of other individuals will not be shared so as to protect the privacy of those individuals unless permitted by applicable law.

In the case of request for deletion, we may keep your personal information if there is a legal basis that authorises us to do so, as in the case of mandatory storage for a minimum period determined by applicable laws.

We may share information with third parties in order to facilitate some of our services and products. There may also be legal reasons that we have to share your personal information. Some of our services and products require that we share information with third parties. There may also be legal reasons that we have to share your personal information.

To efficiently provide our Services to you, we have delegated certain processing functions to third parties. Please see “Information Sharing” section above for more information.

Your personal information may be stored or transferred to countries outside Brazil for the purposes described in this Statement. Such transfers are generally made for the purpose of performing the Services made available to you and are made in accordance with any applicable legal requirements, including with the relevant safeguards and security.

We have implemented the following administrative, technical, and physical security procedures to help protect your personal information.

• Administrative security procedures: a limited number of authorized workers have access to personal data in accordance with internal access controls. Access is granted based on role permission only for allowed business roles.
• Technical security procedures: The personal information is encrypted when it is transmitted. We use firewalls and intrusion detection systems to help prevent unauthorized people from accessing personal data. Certain user data can be hashed or encrypted depending on its sensitivity or processing activity.
• Important security procedures: the data is protected and stored in restricted data centers. Hard drives are physically destroyed when replaced, and we have built-in procedures to ensure access to restricted server rooms and physical assets.

We may retain your information if it is necessary to comply with a legal or regulatory obligation or for our legitimate interests in connection with the purposes set out in this Statement. In addition, we may retain your information for the duration of any period necessary to establish, exercise or defend any legal rights.

The procedure and method of destruction and exclusion are as follows:

• Procedure: Personal information is deleted, destroyed, or deleted in accordance with our company's internal policy and other applicable laws.
• Method: Personal information in paper format will be destroyed securely, such as using paper shredders. Personal information stored in electronic format will be destroyed using technical methods that make records unrecoverable.