Privacy Policy

Mindtrip, Inc.

Last Updated: January 1st, 2025

This Privacy Policy describes the privacy practices of Mindtrip, Inc., a Delaware corporation (“Mindtrip”, “we”, “us”, or “our”) and how we handle personal information that we collect through our mobile applications, our website located at mindtrip.ai (the “Site”) and through any other applications, websites or services that we own or control and that link to this Privacy Policy (collectively, the “Service”). The Service is designed to be an AI-powered platform for vacation and travel planning, recommendations, and booking. The Service enables users to create and share travel itineraries and plans as well as browse and book itineraries and plans as well as browse and book flights, lodgings, vacation packages and other travel-related products and services.

We care about the protection and confidentiality of your personal information and have developed this Privacy Policy to describe the information we collect through the Service and to explain how it is used and to whom it may be disclosed.

This Privacy Policy does not apply to any products, services, websites, or content that are offered by third parties which are governed by their respective privacy policies and practices.

PLEASE READ CAREFULLY PRIOR TO CONTINUING TO VIEW OUR SITE OR USING OUR SERVICE. BY ACCESSING THE SITE AND/OR USING OUR SERVICE, YOU AFFIRM THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO ABIDE TO THIS PRIVACY POLICY AND OUR TERMS OF SERVICE. IF YOU DO NOT AGREE TO ABIDE BY THIS PRIVACY POLICY, YOU MAY NOT ENTER, ACCESS, OR OTHERWISE USE OUR SERVICES. IF YOU USE THE SERVICE ON BEHALF OF SOMEONE ELSE, YOU REPRESENT TO US THAT YOU ARE AUTHORIZED BY SUCH INDIVIDUAL TO ACCEPT THIS PRIVACY POLICY AND YOU DO ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S BEHALF.

Personal Information We Collect

You do not need to provide us with any information just to view the Site If you do provide us with information, we will use it as follows.

Information you provide to us:

  • Contact and account information, such as your first and last name, email address, phone number and password. If you create an account or log into the Service using third-party services, such as Google, we will receive personal information about you (such as your name, email address and/or phone number) as permitted by your profile settings on the third-party service in order to authenticate you. The information we receive when you authenticate through a third-party service depends on the settings, permissions and privacy policy controlled by that third-party service. You should always check the privacy settings and notices in the relevant third-party services to understand what data may be disclosed to us or shared with our Service.
  • Travel program memberships. You will be invited to store information about your frequent flyer accounts, hotel loyalty program memberships and similar travel programs with our Service.
  • Information about your reservations for flights, lodgings, vacation packages and other travel-related products and services, and related itineraries.
  • Payment information needed to complete your transactions with us, including name, payment card information, and billing information. This information is processed by third-party payment processors. The third-party payment processors will handle your payment information in accordance with their own privacy policy. We do not have access to your full payment card information.
  • Content and metadata of any messages that you send using the Service or to us directly.
  • Communications that we exchange with you, including when you respond to our surveys or contact us with questions, feedback or otherwise.
  • Interests and preferences. In creating your account, you will have the option to share information about your travel preferences so that we may offer you a more customized experienced. We also learn about your interests and your preferences over time through your use of the Service to personalize the features of the Service.
  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Automatic data collection. We and our service providers may automatically log and combine information about you, your computer or mobile device, and your interaction over time with the Service, online resources, and our communications, such as:

  • Device data such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings and general location information such as city, state, or geographic area.
  • Online activity data such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access, and whether you have opened or otherwise engage with our communications.

We use the following tools for automatic data collection:

  • Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand user activity and patterns. Please see our Cookie Policy for additional information.
  • Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
  • Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

How We Use Personal Information

We use personal information for the following purposes or as otherwise described at the time of collection:

Provide our Service. We use personal information to operate, maintain, and provide you with our Service, including to facilitate your bookings.

Communicate with you about our Service. We use personal information to respond to your requests, provide user support, communicate with you about our Service, including by sending announcements, surveys, reminders, updates, security alerts, and support and administrative messages.

Improve, monitor, personalize, and protect our Service. We use your personal information, including sensitive information, to improve and keep our Service safe for our users, which includes:

  • Ensuring you’re over 18 years to use the Service.
  • Understanding your needs and interests, and personalizing your experience with the Service and our communications.
  • Improving and adding features to our services.
  • Troubleshooting, testing and research, and keeping the Service secure.
  • To ensure our training models are based on data that is representative of the population and to mitigate bias in the AI.

Research and development. We may use personal information for research and development purposes, including to analyze trends, usage, activities and statistics, and to improve the Service and our business. As part of these activities, we may create or use aggregated, de-identified or other anonymized data from personal information we collect.

Compliance and protection. We may use personal information to comply with legal obligations, and to defend us against legal claims or disputes, including to:

  • Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims).
  • Audit our internal processes for compliance with legal and contractual requirements and internal policies.
  • Enforce the terms and conditions that govern the Service.
  • Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
  • Comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

Consent To Electronic Communications and SMS

By using the Services, you consent to receiving certain recurring electronic communications from us as further described in this Privacy Policy. You agree that any referrals, notices, agreements, disclosures, or other communications that we send to you electronically will satisfy any legal communication requirements, including that those communications be in writing. We will send recurring ‘SMS’ messages to you via ‘SMS’ in accordance with this Section.

You may receive an ‘SMS’ from us in relation to use of the Service. You can stop receiving ‘SMS’ messages at any time by replying ‘STOP’ to the message.

As always, message and data rates may apply for any messages sent to you from us and to us from you. Message frequency depends on your interaction. You should contact your wireless provider with any questions. Please keep all information accurate and up to date. For all further questions about the electronic communications and ‘SMS’, please send an email to [email protected].

How We Disclose Personal Information

We may disclose your personal information to third parties as described below:

  • Service providers. We may rely on third-party service providers in furtherance of the purposes described above. In these cases, personal information may be accessed by these third parties and processed or stored on our behalf. These service providers can include hosting services, cloud computing and storage services, maintenance services, security services, and user support services. To enable us to provide you with relevant responses, we will also disclose some of your information to AI technology providers that power our Service. For example, we will disclose conversations and chat history to AI technology providers to generate intelligent and personalized responses in conversations with users. We require our AI service providers to use your information only for the purpose of generating responses to your chats, and we do not allow those providers to train their AI models using your data.
  • Travel partners. When you request to make a reservation for flights, lodgings, vacation packages and other travel-related products and services, we may disclose personal information to third-party travel partners who provide such products and services to facilitate your reservations.
  • Professional advisors. We may disclose personal information to professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.
  • Authorities and others. Law enforcement, government authorities and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
  • Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Mindtrip (including, in connection with a bankruptcy or similar proceedings).

How You Disclose Personal Information:

  • Other users. When you establish an account on Mindtrip, you disclose certain of your information provided on the Service to the Mindtrip community. This information may include your profile information, interests, itineraries, reviews and other information or content you may elect to share in accordance with the privacy settings you establish on the Service.

Third Party Login and Social Networking Services

We allow you to log in to the Service via various third party and/or social networking services like Facebook, Apple, Instagram and Google (“Social Networking Service(s)”). By directly integrating these services, we make your online experiences richer and more personalized. To take advantage of this feature, we will ask you to log into or grant us permission via the relevant Social Networking Service. When you add a Social Networking Services account to the Services or log into the Services using your Social Networking Services account, we will collect relevant information necessary to enable the Service to access that Social Networking Service and your data contained within that Social Networking Service. As part of such integration, the Social Networking Service will provide us with access to certain information that you have provided to the Social Networking Service, and we will use, store and disclose such information in accordance with this Privacy Policy.

You may also have the option of posting your activities to Social Networking Services when you access content through the Site (for example, you may post to Facebook that you visited a location or ate at a restaurant or stayed at a hotel recommended by the Service); you acknowledge that if you choose to use this feature, your friends, followers and subscribers on any Social Networking Services you have enabled will be able to view such activity. Because we use social media plugins, if you visit our Site while logged in to a social networking account, personally identifiable information about your browsing activities on this Site may be transferred to the third party who operates that account. See the third party’s terms of service and privacy policy for more information on what information may be transferred and what you can do to avoid or limit the transfer of information.

Privacy Choices

Delete your account. You may request that we delete your account by contacting us as provided in the “How to Contact Us” section below.

Personal information requests. Where applicable, you may request the following in relation to personal information:

  • Information about how we have collected and used personal information. We have made this information available to you by including it in this Privacy Policy.
  • Access to a copy of the personal information that we have collected about you.
  • Correction of personal information that is inaccurate or out of date.
  • Deletion of personal information that we no longer need to provide the Service or for other lawful purposes.

To make a request, please email us or write to us as provided in the “How to Contact Us” section below. We may ask for specific information from you to help us confirm your identity. Depending on where you reside, you may be entitled to empower an authorized agent to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

Opt-out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions in the emails you receive from us. You may also opt out of receiving marketing communications from us by contacting us as provided in the “How to Contact Us” section below. Even if you opt out of marketing communications, you will continue to receive Service and account related and other non-marketing communications.

Third-party opt-out. There are a number of ways to limit online tracking, which we have summarized below. Please note that these opt-out tools are not associated with Mindtrip and we cannot guarantee that these tools work as their providers advertise them:

  • Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit https://www.allaboutcookies.org/.
  • Using privacy plug-ins or browsers. You can block our websites from setting cookies by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt out of our analytics tracking via Amplitude by following the instructions at https://amplitude.com/privacy and Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Security

Security plays a crucial role in the effectiveness of conversational AI: it is essential for individuals to have confidence in the responsible and secure management of their data to truly reap the benefits of our Services. We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information.

Job Applicants

When you apply for one of our open positions, we collect the information that you provide in connection with your job application. This includes but is not limited to business and personal contact information, professional credentials and skills, educational and work history, and other information that may be included in a resume or that you may provide during the interview process. This may also include demographic or diversity information that you voluntarily provide. We may also conduct background checks and receive related information. We also collect personal information from other sources where relevant for your application, such as employment research firms, recruiters, identity verification services, and information that you make publicly available on websites or social media platforms (for example, LinkedIn). Throughout the recruitment process, we may supplement your personal information in connection with the assessment of your application. For example, we may record the views of those considering your application about your suitability for the role for which you have applied and retain interview notes. If you accept an offer from us, your personal information will be incorporated into and used as part of your employee record.

We use applicants’ information to facilitate our recruitment activities and process employment applications, including evaluating candidates and monitoring recruitment statistics. We also use successful applicants’ information to administer the employment relationship. We may also use and disclose applicants’ information to improve our Service and for the compliance and protection purposes described above.

Other Sites and Services

Our Service may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions. This Privacy Policy does not apply to such third-party sites or services.

Use of the Service by Minors

Our Service is not intended for individuals under the age of 18. If you have reason to believe that a minor under the age of 18 has provided personal information to us through the Service, please contact us, and we will endeavor to delete that information from our databases.

Retention of Personal Information

Mindtrip will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. Generally, Personal information is stored encrypted on AWS servers in the United States.

Mindtrip will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of the Service, or we are legally obligated to retain this data for longer time periods.

Visitors to the Site Outside of the United States

If you are visiting the Site from a location outside of the U.S., your connection will be through and to servers located in the U.S. All information you receive from the Site will be created on servers located in the U.S., and all information you provide will be maintained on web servers and systems located within the U.S. The data protection laws in the United States may differ from those of the country in which you are located, and your information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Site or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information in the United States and in other countries, as set forth in this Privacy Policy.

Updating Personal Information

We prefer to keep your personal information accurate and up to date. If you would like to change your contact information, please contact us at [email protected] or through your account.

If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons, such as a legitimate business reason.

In addition, please note that if you implement a deletion request but later sign up for information or Services, your most recent request will control our information relationship with you.

International Data Transfers

Because Mindtrip works with global companies and technologies, we may transfer your personal information outside of the country in which it was originally provided. This may include transfers to third parties located outside the United States, developers, service providers or affiliated entities who are located outside the United States or the European Union, where data protection laws may not offer the same level of protection as those in the U.S., E.U. or European Economic Area (“EEA”). When we transfer personal data outside of these areas, we take steps to make sure that appropriate safeguards are in place to protect your personal information. Our transfers of your personal data outside of the E.U. are safeguarded by data processing agreements (“DPAs”) incorporating Standard Contractual Clauses. You may request a copy of the relevant portions of such agreements by contacting us at[email protected]. Please include the nature of your request in the subject line.

GDPR Privacy Rights

If you are a resident of or located within the EU or European Economic Area (“EEA”), you have certain additional data protection rights under the General Data Protection Regulation (“GDPR”). These rights include:

  • The right to access, update or delete the information we have on you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your personal information.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine- readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.

Legal Basis for Processing Personal Information under GDPR

Our legal basis for collecting and using the personal information described in this Privacy Policy depends on the personal information we collect and the specific context in which we collect it.

We may process your personal information because:

  • We need to perform a contract with you;
  • You have given us permission to do so;
  • The processing is in our legitimate interests, and it is not overridden by your rights; or
  • To comply with the law.

Disclosure of personal information under GDPR-Legal Requirements

Mindtrip may disclose your personal information in the good faith belief that such action is necessary to:

  • To comply with a legal obligation;
  • To protect and defend our rights or property;
  • To prevent or investigate possible wrongdoing in connection with the Service;
  • To protect the personal safety of users of the Service or the public;
  • To protect against legal liability.

Disclosure for Law Enforcement

Under certain circumstances, we may be required to disclose your personal information if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

If you are a resident of the EU or EEA, you may initiate a request to access, reject, correct, restrict, or erase your personal information, or where you may initiate a request for transfer of your personal information or initiate a request that we refrain from sending you marketing information by sending us a request at [email protected] and write “GDPR Request” in the subject line.

Please note that the above individual rights are not absolute, and we may be entitled to refuse requests where certain exceptions apply. Please note that where our processing of your personal information relies on your consent and where you then withdraw that consent, we may not be able to provide all or some aspects of our services to you and/or it may affect the provision of those services. Should you wish to raise a concern about our use of information (without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time and from time to time without prior notice. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service, or as otherwise required by law.

How to Contact Us

If you have any questions about this Policy or our privacy practices, or to submit a personal information request, please contact us by email at [email protected].

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