Personal Data Protection Policy

Trawell owns and operates an online platform that provides users with information, recommendations and services related to travel, excursions and activities. In the context of this Policy, we refer to these services as “Services”.

At Trawell, we place great importance on respecting your privacy and strictly comply with the Personal Data Protection Law (known as “Law 29733”). Any information provided that is considered personal data, as established by Law 29733, will be treated and stored responsibly under our custody in computer systems, both in Peru and in other countries. It may also be stored on cloud computing systems.

The information you and others entrust to us allows us to improve our ability to offer more relevant, personalized and useful Services. We are aware that sharing your information with us is a matter of trust. We take that trust placed in us seriously and are committed to providing you with useful information, products and services, selected based on the information you have shared with us. Additionally, we consider it essential to respect your privacy when you visit our website or use our Services, and we strive to be transparent about our use of the information you entrust to us.

This Policy describes how we obtain, use and process your information; We do it in a clear and transparent way, so that it is easily understandable. We inform you about the rights you have, how to exercise them and how to communicate with us. We encourage you to read this Policy carefully to understand our information and privacy practices. By visiting our website and our social networks, whether through a computer, mobile phone, tablet or other similar device (which we collectively refer to as “Device”), you acknowledge and confirm that you have read this Policy.

1.- Information collected and processed

When you access or use our Services, we collect and process information you provide to us to offer our Services to you in a more personalized and relevant way. We obtain some of the data passively, through our servers, cookies or other similar tracking technologies.

The processed information may include the following data:

• Contact information, such as name, telephone number, mailing address, and email address (both in encrypted and unencrypted form).

• Billing information and other payment information, such as your bank account information, credit card number, cardholder name, expiration date, authentication code, and billing address.

• Documentation that supports travel and planning.

•  Username and password.

• Photos, opinions, posts on forums and social networks, and videos that you have provided to us.

• Geolocation information.

• Device information, such as the date and time of access to our Services, and details about the device used (for example, IP address, software or Internet browser used, preferred languages, unique device identifiers and advertising identifiers).

• Other information about you that you have voluntarily provided to us.

• Purchase and reservation history.

• Communications when you contact our customer service team, including inbound and outbound calls.

In addition to the categories listed above, we may also collect certain location information if you have set your device to send such information or if you have uploaded photos tagged with location information.

2.- Uses and purposes of the information

We want to provide you with relevant content and a personalized experience when using our Services. To achieve this, we use your information in the following ways:

Registration, membership and other contracts:

• Register and manage your account to allow you to access and use our Services.

• Facilitate your reservations and process payments or credits.

• Offer you promotional programs that may include contests, gift cards, rewards, cash back and discounts.

Improvement of our Services:

• Use your information for analytical purposes to improve our Services.

• Provide you with a personalized and optimized experience by grouping users based on their usage, interests and demographics.

• Send you invitations to surveys, market studies or panel interviews for analytical purposes.

Individualization and personalization:

• Send you notifications about special offers, products or services available from us, affiliates or partners that may be of interest to you.

• Tailor your experience, including making inferences about your interests and preferences based on your activity, and personalizing the ads shown to you on and off our website.

Communication:

• Communicate with you or facilitate communication between you, our partners and affiliates.

• Record and monitor your calls or interactions with us, including communications with our customer service or sales teams.

• Contain your opinions, forum posts, photos, videos and other content.

• Respond to your questions and comments, as well as resolve disputes or problems.

Fraud prevention and legal compliance:

• Prevent fraudulent activities and other potentially prohibited or illegal activities.

• Comply with applicable laws, respond to legal requests, prevent harm and protect our rights.

• Provide payment services, including the detection and prevention of money laundering, fraud and security incidents, to comply with legal obligations and enforce relevant terms of service.

Please note that if we use automated decision-making to process your personal information, we will implement appropriate measures to protect your rights and freedoms, including your right to intervene in the decision-making process through human intervention.

3.- Information security

We implement appropriate administrative, technical, and physical security procedures to help protect your information. We only authorize specific members of staff to access personal information, and they may do so only for permitted business functions. We use encryption when we transmit 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 your information from unauthorized access or use, hardware or software failures, or other circumstances beyond our control.

4.- Elimination and retention of information

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

We understand the importance of protecting your information and ensure that any data retention is in accordance with applicable laws and regulations. In the event that you no longer wish us to retain your personal information, you may request deletion of your account or contact us to request deletion of your specific personal data, provided that there is no legal obligation or legitimate reason to retain such information. .

Please note that even after deletion of your account or personal data, we may retain certain information in an anonymous or aggregated form for statistical or analysis purposes, provided that it is not possible to identify you personally from such information.

We are committed to managing your information responsibly and ensuring that it is retained in accordance with applicable laws and regulations, respecting your privacy and data protection rights.

5.- Your rights

We value your rights and offer you the opportunity to exercise control over your personal information. You have the right to access, correct, update or delete the personal information you have provided to us. If you wish to exercise any of these rights or have any questions or concerns related to the use of your personal information, please do not hesitate to contact us through the contact methods provided at the end of this policy. We are committed to responding to your request in a timely manner and in accordance with applicable laws and regulations.

6.- Policy modifications

We reserve the right to make modifications or updates to this Data Protection Policy at any time. Any changes we make will be effective immediately upon posting on our website. We encourage you to periodically review this policy to stay informed about how we protect and use your personal information. If you continue to use our Services after any changes to this policy, you will be deemed to have accepted the changes made.

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