Privacy Policy

12. Supplemental Privacy Notice to California Residents

This Supplemental Privacy Notice supplements the information in our Privacy Policy
above, and except as provided herein, applies solely to California residents.

Types of Personal Information We Collect

If you are a California resident, California law requires us to provide you with some
additional information regarding how we collect, use, and disclose your “personal
information” and “sensitive personal information” (as defined in the California Consumer
Privacy Act (“CCPA”)).

Throughout our Privacy Policy, we describe the specific pieces of personal information
and sensitive personal information we collect, the sources of that information, and how
we disclose it. Under the CCPA, we also have to provide you with the “categories” of
personal information we collect and disclose for “business purposes” (as those terms
are defined by applicable law). Those categories are identifiers (such as name, address,
email address, phone number, other account information, and cookies); commercial
information (such as transaction data); financial data (such as credit card and other
financial account information); internet or other network or device activity (such as IP
address or service usage); geolocation information (general location); inference data
about you; sensory information (such as audio recordings if you call customer service);
professional or employment related data; education data; insurance (including health
insurance) information; medical information; physical characteristics or description;
legally protected classifications (such as gender); other information that identifies or can
be reasonably associated with you. The categories of sensitive personal information are
account log-in, financial account information, and password or other credentials allowing
access to your account.

We collect the categories of personal information identified above from the following
sources: (1) directly from you; (2) through your interaction with/use of our Website
and/or Services; (3) affiliates; and (4) third parties such as social networks.

We may collect and disclose the above categories of information for the purposes
described in our Privacy Policy. This includes the following business or commercial
purposes (as those terms are defined in applicable law):

•   Our operational purposes;

•   Auditing consumer interactions on our site;

•   Detecting, protecting against, and prosecuting security incidents and fraudulent
or illegal activity;

•   Bug detection and error reporting;

•   Customizing content that we or our service providers display on the Service;

•   Providing the Service (e.g., account servicing and maintenance, order processing
and fulfillment, customer service, advertising and marketing, analytics, and
communication about the     Service);

•   Improving the Service and developing new services (e.g., by conducting research
to develop new products or features);

•   Other uses that advance our commercial or economic interests, such as third
party advertising and communicating with you about relevant offers from third party
partners;

•   Other uses about which we notify you.

We may also use the above categories of personal information for compliance with
applicable laws and regulations, and we may combine the information we collect
(“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent
identification of any particular user or device.

We describe our information disclosure practices in our Privacy Policy. We may disclose
certain categories of personal information with third parties (as defined by the CCPA) for
the business purposes described above. For example, we may disclose identifiers with
our marketing partners, and we may also disclose any of the categories described
above with our subsidiaries and affiliates. If you connect your account with social media
services or interact with social media plugins or links on the Service, we may disclose
identifiers, commercial information, internet or other network or device activity, or
general location with those social media services.

Consumer Rights

If you are a California resident, you may have certain rights. California law may permit
you to request that we:

•   Provide you the categories of personal information we have collected or
disclosed about you; the categories of sources of such information; the business or
commercial purpose for “collecting,” “selling,” or “sharing” your personal information; the
categories of third parties to whom we disclose or “sell,” or with whom we “share,”
personal information; and the categories of personal information we “sell.”

•   Provide access to and/or a copy of certain information we hold about you.

•   Delete certain information we have about you.

•   Correct inaccurate personal information that we maintain about you.

You may have the right to receive information about the financial incentives that we
offer to you (if any). You also have the right to not be discriminated against (as provided
for in applicable law) for exercising certain of your rights. Certain information may be
exempt from such requests under applicable law. We need certain types of information
so that we can provide the Service to you. If you ask us to delete it, you may no longer
be able to access or use the Service.

In instances where we process personal information on behalf of a person or entity that
we provide our Services to, rights requests should be directed to the our
partner/customer. Any request sent directly to us that pertains to information collected
on behalf of a customer will be forwarded on to that customer.

If you would like to exercise any of these rights, you can submit a request at
dataprotection@tripmatrix.com, and call +385 1 8000 950. You will be required to
verify your identity before we fulfill your request. To do so, you will need to provide
information to match with our existing records to verify your identity, depending on the
nature of the request and the sensitivity of the information sought. You can also
designate an authorized agent to make a request on your behalf. To do so, you must
provide us with written authorization or a power of attorney, signed by you, for the agent
to act on your behalf. You will still need to verify your identity directly with us.

“Sale” of Personal Information

California residents may opt out of the “sale” of their personal information. The CCPA
broadly defines “sale” in a way that may include allowing third parties to receive certain
information such as cookie identifiers, IP addresses and/or browsing behavior to add to
a profile about your device, browser or you. Such profiles may enable delivery of
interest-based advertising by such third parties within their platform or on other sites.

We do not sell your personal information.

“Sharing” of Personal Information

California residents may opt out of the “sharing” of their personal information. The
CCPA defines “sharing” as the targeting of advertising to a consumer based on that
consumer’s personal information obtained from the consumer’s activity across websites.
We “share” information for these purposes to provide more relevant and tailored
advertising to you regarding our Service. As part of this advertising, we may “share”
identifiers (such as IP address, device identifiers, and cookies) and internet and device
activity with advertising platforms and advertising networks. To opt out of such
“sharing,” please submit a request to dataprotection@tripmatrix.com.

Children Under 16

We do not knowingly “sell” or “share” the personal information of children under 16.

Sensitive Personal Information

The CCPA also allows you to limit the use or disclosure of your “sensitive personal
information” (as defined in the CCPA) if your sensitive personal information is used for
certain purposes. Please note that we do not use or disclose sensitive personal
information other than for purposes for which you cannot opt out under the CCPA.

Retention of Your Personal Information

Please see the ” Personal Data Storage and Duration” section above.

California Shine the Light

We do not disclose personal information to third parties for their direct marketing
purposes.