Scope of this Policy
This privacy policy describes the treatment of information provided or collected on the sites and applications where this privacy policy is published, whether on our digital properties or in applications we make available on third-party sites or platforms. It also describes the treatment of guest information that we provide or collect offline, in actions we may develop in person or through our customer service centers.
Please note that when you provide us with information on a third-party site or platform (for example, through our applications), the information you provide may be collected separately by the third-party site or platform. The information we collect is covered by this privacy policy, and the information collected by the third-party site or platform is subject to the privacy practices of that site or platform.
The privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our applications. Also, please note that our sites and applications may contain links to other sites that are not owned or controlled by us, and we are not responsible for the privacy practices of those sites. We encourage you to be aware when you leave our sites or applications and to read the privacy policies of other sites that may collect your personal information.
Who We Are
Our group includes many different brands. Semper Ad Astra LLC and American Digital Growth LLC are part of ADS GROUP. When you visit, purchase, or create an account with us, or use sites and applications, your information is controlled by a member of ADS GROUP. The list of relevant data controllers can be found here.
Types of Information We Collect
We collect two basic types of information: personal information (as defined in this policy) and anonymous information (as defined in this policy), and we may use personal and anonymous information to create a third type of information, aggregated information (also defined in this policy).
Specifically, we collect:
- Registration information you provide when you create an account, participate in a promotion, or link your profile on a third-party site or platform with your registration account, such as your first name, last name, country of residence, gender, date of birth, email address, username, and password;
- Transaction information you provide when you request information, contact customer service, or purchase, return, request, or exchange a product or service from us, such as your postal address, phone number, and payment information;
- Information you provide in public forums on our sites and applications, such as your public posts;
- Information sent individually or within a limited group through our messaging, chat, posting, or similar functions, where applicable law permits us to collect this information;
- Information we obtain from third parties, such as a site or platform provider, regarding the use of our applications on third-party platforms or devices;
- Location information, including precise or approximate location information provided by a mobile device or other device interacting with one of our sites, applications, or physical properties (including via beacon technology), or associated with your IP address or another online or device identifier, where the law allows us to process this information;
- Activity information about your use, and the use by any person(s) you authorize through your account, of our sites and applications, such as the content you view or post, the frequency with which you use our services, and your preferences;
- Usage, viewing, technical, and device data when you visit our sites, use our applications on third-party sites or platforms, open emails we send you, or connect with our wireless internet access services and other similar technologies, including your browser or device version, unique device identifier, and IP address;
- Call recordings when you connect to individual or group sessions, call our reservation centers, or other customer service numbers.
How We Collect Your Information
We collect the information you provide when you request or purchase products, services, or information from us, register with us (including when you link your profile on a third-party site or platform with your registration account), participate in public forums, chats through any messaging application, owned or third-party, or other activities on our own or third-party sites and applications, respond to customer surveys, call or use messaging with our customer service numbers, or otherwise interact with us using one or more devices. You may provide information in various ways, including by typing or using voice commands.
We collect information through various technologies, such as cookies, Flash cookies, pixels, tags, software development kits, application programming interfaces, and web beacons, even when you visit our sites and applications or use our applications on third-party sites or platforms using one or more devices, whether you are logged in or registered. You can always use Do Not Track options and disable cookies and make choices regarding such data collection.
We collect information using analytics tools, even when you visit our sites and applications or use our applications on third-party sites or platforms.
Use of Your Information by ADS GROUP
The member of ADS GROUP (the "Group") that is the data controller for your information is responsible for and may use your information for the purposes described in this policy. Other members of the Group may access your information where they perform services on behalf of data controllers (such as data processors) and, unless prohibited by applicable law, for their own use (as data controllers) for the purposes described in this policy.
In accordance with applicable law and the choices and controls that may be available to you, we may use the information collected from you, or from devices associated with you, to:
- Provide you with the experiences, products, and services you request, view, use, or purchase;
- Communicate with you about your account or transactions with us and send you information or solicit feedback about features on our sites and applications or about changes to our policies;
- Send you offers and promotions for our products and services or for products and services of third parties;
- Personalize content and experiences;
- Provide you with targeted advertising based on your activity on our sites and applications and on third-party sites and applications;
- Operate, understand, optimize, develop, or improve our sites, applications, products, services, and operations, including through the use of analytics tools and customer surveys;
- Detect, investigate, and prevent activities that may violate our policies, pose security issues, or be fraudulent or illegal;
- Notify you about product recalls or safety issues.
Sharing Your Information with Other Entities
We will not share your personal information with third parties outside the Group and its affiliates and/or associates, except in limited circumstances, which include:
- When you allow us to share your personal information with another company, choosing to share your personal information with carefully selected companies so that they can send you offers and promotions about their products and services;
- When you tell us to share your personal information with another company to fulfill your request, such as:
- When booking travel packages, retreats, or experiences with us that include goods or services provided by third-party partners, such as airlines, ground transportation providers, hotels, and travel insurance providers; and
- When you book restaurant reservations through us for restaurants operated by third parties;
- When you tell us to share your personal information with third-party sites or platforms, such as social networking sites;
- When we work with service providers who perform services on our behalf; however, these companies are prohibited from using your personal information for purposes other than those requested by us or required by law;
- When we provide you with relevant advertising on third-party sites and applications, we may share limited personal information about you, such as certain identifiers or an encrypted email address, with third parties. We may also share such information to provide and measure relevant third-party advertising on our sites and applications;
- When we share your personal information with third parties in connection with a business sale, to enforce our Terms of Use or rules, to ensure the safety and security of our guests and third parties, to protect our rights and property and the rights and property of our guests and third parties, to comply with legal process, or in other cases if we believe in good faith that disclosure is required by law.
Please note that, unless otherwise stated above, once we share your personal information with another company under the above circumstances, the information received by the other company is controlled by that company and is subject to its privacy practices.
Your Controls and Choices
We provide you with the ability to exercise certain controls and choices regarding the collection, use, and sharing of your information. In accordance with applicable law, your controls and options may include:
- Correcting, updating, and deleting your registration account;
- Choosing or changing your preferences for subscriptions, newsletters, and alerts;
- Choosing whether to receive offers and promotions from us for our products and services or for products and services that we believe may be of interest to you;
- Choosing whether we share your personal information with other companies so that they can send you offers and promotions about their products and services;
- Controlling targeted advertising by clicking "Do Not Sell or Share My Personal Information" or "Manage Cookie Settings" in the footers of our website or app settings;
- Controlling targeted advertising from many advertising networks and partners; data exchanges; and analytics and digital marketing service providers;
- Choosing to control targeted advertising you receive within applications using the settings and options available through your devices, for example, opting out of receiving interest-based ads;
- Requesting the removal of your personal information from a public forum on one of our sites or applications; and
- Requesting access to the personal information we hold about you and that we modify or delete it.
You can exercise these controls and choices in various ways, including those described above, by contacting Customer Service, or by following the instructions provided in the communications we send you. You can also opt-out of receiving targeted or interest-based ads by using the opt-out mechanism on the link "Interest-Based Ads" in the footer of the site you are visiting.
Please note that if you do not allow us to collect personal information about you, we may not be able to offer you certain experiences, products, and services, and some of our services may not be able to consider your interests and preferences. If personal information collection is mandatory, we will make this clear at the point of collection so that you can make an informed decision about whether to participate. If you have questions about the specific personal information we process or retain about you, and your rights regarding that personal information, please contact Customer Service.
Security, Integrity, and Data Retention
The security, integrity, and confidentiality of your information are extremely important to us. We have implemented technical, administrative, and physical security measures designed to protect guest information against unauthorized access, disclosure, use, and modification. We regularly review our security procedures to consider new technologies and appropriate methods. Please note that, despite our best efforts, no security measure is perfect or impenetrable. We will retain your personal information for as long as necessary to fulfill the purposes described in this privacy policy, unless a longer retention period is required or permitted by law.
Data Transfer, Storage, and Processing Worldwide
We operate globally and may transfer your personal information to individual Group entities or third parties in locations around the world for the purposes described in this privacy policy. Wherever your personal information is transferred, stored, or processed by us, we will take reasonable steps to protect the privacy of your personal information. These measures may include implementing standard contractual clauses where legally recognized, obtaining your consent, or other legal means of transferring personal information.
Changes to this Privacy Policy
From time to time, we may change this privacy policy to adapt to new technologies, industry practices, regulatory requirements, or other purposes. We will notify you if these changes are material and, when required by applicable law, obtain your consent. The notification may be made by email to the last email address you provided to us, by posting a notice of such changes on our sites and applications, or by other means, in accordance with applicable law.
Comments and Questions
If you have a comment or question about this privacy policy, please contact Customer Service at legal@ads-group.xyz.