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Introduction

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At Spellbound Leisure ("Company" or "we"), we respect your privacy and are committed to protecting it through our compliance with this policy. We understand that you care about how information about you is collected, used, and shared. Keeping you informed about the data we collect and the choices you may have regarding your information is our top priority.

This policy describes the types of information we may collect from you or that you may provide when you visit the website www.spellboundleisure.com or any other sites or services hosted at the spellboundleisure.com domain names (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information. By using our Website or providing information to us in any other way, you agree that your information will be used in the manner described in this privacy policy.

This policy applies to information we collect:

• While you interact with the Website.

• In email, text, chat, and other electronic messages between you and this Website.

• Through advertising hosted on third-party websites.

• Information you supply while interacting with our social media accounts on services such as Facebook, Instagram, etc.

This policy does not apply to information collected by:

• Us offline or through any other means; or

• Any third party (including our affiliates and subsidiaries), including through any application or content that may be accessible on the Website.

Third-Party Links

This Website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

It is our goal to be transparent about the use of your information, so please read this policy carefully to understand our policies and practices. If you do not agree with our policies and practices, your choice is not to use our Website. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information by which you may be personally identified, such as your name, email address, online identifiers, and, if applicable, personal information required for the purchase or provisioning of travel services or personal information required to enable you to sell travel. Our Website also automatically collects certain information about its users, including information about your use of our Website, your internet connection, the device you use to visit our Website, and other usage details.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, and gender.

• Contact Data includes billing address, delivery address, email address, and telephone numbers.

• Financial Data includes bank account and payment card details.

• Transaction Data includes details about payments to and from you and other details of travel services you have purchased from us.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, and platform, and other technology on the devices you use to access this Website.

• Profile Data includes your username and password, details of previous inquiries, itineraries, or bookings made by you, your interests, preferences, feedback, and survey responses.

• Usage Data includes information about how you use our Website, products, and services.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this privacy policy.

Special Category Data: Health/mobility data: When you make an inquiry for a travel booking with us, we will ask you to disclose any medical conditions, health issues, or any restrictions on your mobility. This is to enable us (and the operators/suppliers of your vacation) to provide for your health, safety, and welfare during your trip, which is our legal responsibility.

We do not sell or otherwise share personal information about you, except as described in this Privacy Policy. We share the personal information we obtain with third parties who perform services on our behalf, such as ad network vendors, data analytics vendors, survey platforms, cruise lines (in connection with bookings), and email and print marketing vendors. These third parties are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. In addition, we share consumer personal information with partner suppliers to collaborate on special offers for our clients.

We collect this information:

• Directly from you when you provide it to us, for example, when you interact with our Website, correspond with a member of our company, or provide information in connection with any request or inquiry.

• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.

The technologies we use for this automatic data collection include, but are not limited to:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

• Analytics Tools. We use analytics tools to collect information about the usage of our Website. These tools collect information about how often users visit our Website, what pages they visit and when they visit, as well as what other websites they used prior to landing on our Website, among other additional information. We use this information to improve our Website and our services. We do not combine the information collected through the use of analytics tools with Personal Information.

• Tracking Pixels or Web Beacons. Pages of our Website and certain correspondence you receive from us may contain small electronic files known as web beacons that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics.

• Other Javascript tracking tools. We also use other third-party tools that automatically collect data about the performance of our site and behavior in the browser to assist us with monitoring the performance and functionality of our site, tracking attribution, enabling A/B testing, monitoring site usability, etc.

Personal Information from Other Sources

Spellbound Leisure may collect information, including personal information, from other third-party sources such as travel agents and travel or other hospitality service providers.

Third-Party Use of Tracking Technologies

We do not control any third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information, to:

• Present our Website and its contents to you.

• Provide you with information, products, or services that you request from us.

• Fulfill any other purpose for which you provide it.

• Process payments and deliver your bookings, including sharing your data with third-party travel suppliers.

• Administer your participation in prize draws, competitions, or surveys.

• Personalize content, features, and advertisements we show you.

• Improve our Website, products, services, marketing, customer relationships, and experiences.

• Perform data analytics regarding usage of the Website (including market and customer research, trend analysis, and financial analysis).

• Guard against, identify, and prevent fraud and other criminal activity, claims, and other liabilities.

• Comply with applicable legal requirements and respond to law enforcement requests.

• Carry out, evaluate, and improve our business (which may include developing new features for the Website, assessing marketing effectiveness, and managing communications).

Disclosure of Your Information

We may disclose personal information that we collect, or you provide as described in this privacy policy to:

• Our subsidiaries and affiliates.

• Service providers and other third parties we use to support our business.

• A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of assets.

• Public authorities, if required by them in order to fulfill your travel booking or as required by law.

• With your consent, for any other purposes disclosed at the time you provide the information.

Additionally, we may also disclose your personal information to comply with any court order, law, or legal process, including to respond to any government or regulatory request or if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Spellbound Leisure, our customers, or others.

We may disclose aggregated information that does not identify any individual without restriction.

Choices About How We Use and Disclose Your Information

• Tracking Technologies and Advertising: You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may become inaccessible or not function properly.

• Promotional Offers: If you do not wish to receive promotional communications from us, you can opt out by clicking "Unsubscribe" at the bottom of any electronic communication you receive from us, or by contacting us. This opt-out does not apply to information provided to the Company as a result of a booking inquiry, travel-related transaction, or other business need to communicate relating to a transaction, product, or service.

• Third-Party Marketing: We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Your Nevada Privacy Rights

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to support@spellboundleisure.com. Please note, however, we do not currently sell data triggering that statute’s opt-out requirements.

Data Security

We have implemented physical, electronic, and managerial procedures designed to secure your information from accidental loss and from unauthorized access, use, alteration, and disclosure.

• SSL Certificate: We employ secure web servers hosted in a certified data center. The "s" in the "https" address of our web pages indicates that SSL encryption is in use, which helps safeguard personal information.

• Firewall Protection: Once we have your information, we store it behind a firewall barrier designed to obstruct unauthorized access to or from our network.

• Password and Username Verification: For Website components requiring authentication, we use a unique username and password for your account.

Unfortunately, the transmission of information via the Internet cannot be guaranteed to be 100% secure. Although we do our best to protect your personal information, the transmission of personal information is at your own risk. We urge you to take precautions to protect your personal data when using the Internet, such as using strong passwords and not sharing your login information.

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Children Under the Age of 13

Our Website is not intended for children under 13 years of age. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information.

How We May Use Information We Collect

We, and our third-party partners and service providers, may use the information gathered on the Website for various purposes, including the purposes listed below. For example, if you were to contact us with a question and provide your email address, we would use the email address you provided to respond to your inquiry. In addition, we use information we collect from you and through the Website to:

• Provide information, products, and services you request.

• Respond to requests, questions, complaints, and provide other types of user support.

• Direct you to portions of the Website or third-party websites or services that may interest you.

• Customize content, features, advertisements, or other marketing messages.

• Communicate about and administer your participation in events, programs, contests, sweepstakes, and promotions.

• Carry out, evaluate, and improve our business.

• Perform data analytics regarding Website usage (including market and customer research, trend analysis, and financial analysis).

• Guard against, identify, and prevent fraud and other criminal activity.

• Comply with applicable legal requirements, law enforcement requests, and our company policies.

Purpose and Lawful Basis for Processing

Include a table specifying the purpose of data processing and the lawful basis. Here’s an example based on common travel website activities:

Purpose/Activity

Type of Data

Lawful Basis for Processing (Including Basis of Legitimate Interest)

To register you as a new customer

(a) Identity (b) Contact

Performance of a contract with you

To process and deliver your booking

(a) Identity (b) Contact (c) Financial (d) Transaction

(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts)

To manage our relationship with you

(a) Identity (b) Contact (c) Profile (d) Marketing and Communications

(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated)

To administer and protect our business and this website (troubleshooting, data analysis, etc.)

(a) Identity (b) Contact (c) Technical

(a) Necessary for our legitimate interests (for running our business) (b) Necessary to comply with a legal obligation

How We May Share Information

Our agents, vendors, consultants, and other service providers may have access to information we collect through the Website to carry out work on our behalf. In addition, certain service providers may collect or access information through the Website to enable or provide services, tools, or other features available on the Website. We also may share information:

• With our affiliates for internal business purposes.

• With third parties for marketing purposes, including social media networks, data management platforms, and other advertising technology providers.

• If we are required by law, regulation, or legal process (such as a court order or subpoena).

• In response to government requests, such as law enforcement authorities.

• With advertisers and other partners to inform them about the nature of our user base.

• With your consent or at your discretion.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional Offers from Us
We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have previously opted into receiving them from us, or if you have previously asked for a quote or made a booking with us, and you have not opted out of receiving that marketing.

Profiling: As indicated in the above table, we may use your personal data to personalize and tailor your experience by using your previous requests for quotes, previous purchases, communications with Spellbound Leisure staff, your browsing activity, and other publicly available information to make recommendations and special offers to you. If you do not want us to profile and process your information in this way, please contact our Data Privacy Manager.

Third-Party Marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes

SPAM PROTECTION
This site is protected by reCAPTCHA, and the Google Privacy Policy and Terms of Service apply.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us directly at any time, telephoning us, or writing to us. The contact details are in Section 1 of this policy.

Where you opt out of receiving marketing messages, we will still process your personal data for fulfilling your inquiry or booking and for the other activities indicated in the table above, except for marketing.

Should you wish to unsubscribe from marketing communications via email, you may opt-out by clicking on the clearly marked ‘unsubscribe’ button at the bottom of any Spellbound Leisure newsletter or marketing email. Should you wish to unsubscribe from marketing communications via e-mail, you can contact us by e-mail at support@spellboundleisure.com(please write “unsubscribe” in the subject line and provide each email address you would like us to remove).

COOKIES

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

For more information about the cookies we use and what we use them for, please see our cookie policy at spellboundleisure.com/cookie-policy.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table above and otherwise in this privacy policy:

Internal Third Parties:

• Other companies in the Spellbound group acting as joint controllers or processors who are based inside and outside of the US and assist with the arrangement of travel services for customers.

External Third Parties:

• Travel product and services suppliers based inside and outside the US who provide travel services to fulfill the itineraries and bookings that we provide (e.g., airlines, destination management companies, hotels, and other accommodation providers).

• Public authorities such as customs and immigration, security and/or credit checking companies, credit and debit card companies, and government and enforcement agencies if required by them in order for us to fulfill your booking, or as required by law.

• Law enforcement or crime prevention agencies.

• Service providers acting as processors based in both inside and outside the US who provide marketing services, data management, or data analytics services.

• Commercial partners who provide our travel services as part of competitions, prize draws, and similar (subject always to customer consent to such data being shared).

• Professional advisers acting as processors or joint controllers, including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.

• Regulators and other authorities who require reporting of processing activities in certain circumstances.

• Third parties to whom we may choose to sell, transfer, or merge parts of our business or assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. Note, however, that no system is 100% secure or error-free. Therefore, we do not, and cannot, guarantee the security or accuracy of the information we gather.

One way we protect your personally identifiable information is through usernames and passwords. This safety measure is only effective if you protect the secrecy of both your username and password. If you ever suspect your username or password may have been compromised or subject to unauthorized use, contact us immediately.

In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

How Long Will You Use My Personal Data For?

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, as well as any applicable legal, regulatory, tax, accounting, or other requirements.

In some circumstances, you can ask us to delete your data: see “Your legal rights” below for further information.

In some circumstances, we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data.

• Request correction of the personal data that we hold about you.

• Request erasure of your personal data.

• Object to processing of your personal data.

• Request restriction of processing of your personal data.

• Request the transfer of your personal data to you or a third party.

• Withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of the rights set out above, please contact our Data Privacy Manager via the contact details provided.