INKALAND GROUP PRIVACY POLICY

Last updated: June 2, 2022.

Inkaland.com (hereinafter, “Inkaland Group”) values its users and undertakes to protect their personal information and privacy. In order to fulfill this commitment, Inkaland Group has prepared this privacy policy (hereinafter the “Privacy Policy” or the “Policy”) describing Inkaland Group’s practices in the processing of personal data, in accordance with the legal provisions in force.

Whenever you use the Inkaland Group services through any of our sales channels operated under any of our trademarks (“Inkaland Group”, “Inkaland Travel”, “Hiking Inca Trail”, “Latin America Trips” or any other trade names) –i.e. websites or apps for mobile phones and other devices, call centers, branches or kiosks or any other points of sales (the “Sales Channels”)– Inkaland Group collects certain personal data to use it later on. This Privacy Policy is intended to help you understand how we process such personal data.

By accepting this Privacy Policy, you consent for Inkaland Group to use your personal data for each and every purpose provided in this Policy.

Inkaland Group may revise this Policy at any time, and you shall be notified whenever Inkaland Group makes any material change. Please check in the heading of this Policy the date of its last update. If you have any questions about this Policy and/or Inkaland Group’s practices on the issue, please contact us at “My account” or “My reservation”.

Our commitment to your privacy.
At Inkaland Group we are committed to protecting your privacy and ensure that your personal data is managed in accordance with applicable law and the best market practices. We are transparent about our practices and we are available to answer any queries about them.

The following is a detailed description of Inkaland Group privacy practices regarding the processing ofyour personal data:
● Any personal data collection and processing shall be performed in accordance with this Privacy Policy and for the purposes prescribed herein.
● Your personal data shall not be transferred, sold, leased or disclosed in any way other than the one specified in this Privacy Policy.
● Whenever certain personal data is no longer necessary and we do not have a legal obligation to store it, it shall be deleted, destroyed or anonymized.
● We pretend to collect the least amount of personal data necessary, gathering only those relevant to fulfill the purposes set forth in this Policy.

Important definitions.
Listed below are some important terms for you to understand the protection we give to your personal data, the scope of our process and your rights.

● Owner: you are the owner of your personal data.
● Personal data: any information that identifies or leads to the identification of its holder. Examples of personal data are full name, phone number, personal ID number and mail address.
● Controller: a person responsible for making decisions about the processing of personal data of the holders. For the purposes of the Policy, it shall be Inkaland Group.
● Processing: any operation performed using your personal data, which may include collection, access, analysis, transfer, storage, anonymization, removal, etc.
● Anonymization: process of depersonalization of personal data by removing any association of this information with the holders to whom they refer.

Your rights.
The law recognizes certain rights in relation to your personal data, which may be exercised as set forth in this Policy.

The following are your main rights in relation to your personal data:
● Inquire if your personal data is being processed by Inkaland Group.
● Obtain information about the manner in which your personal data is processed.
● Correct incomplete, inaccurate or outdated data.
● Request the anonymization, blocking or elimination of unnecessary or excessive personal data or that is being used in violation of the law.
● Learn about which public and private entities have access to your personal data through Inkaland Group.
● Withdraw your consent for the processing of your personal data and be notified about the consequences of such withdrawal.
● Withdraw your consent for the collection of new personal data.

1. What personal data do we collect?
2. What is our cookies and web beacons policy?
3. What do we use the personal data we collect for?
4. With whom do we share the personal data we collect?
5. Where do we store and how do we protect the personal data collected?
6. How can you access, delete, change and/or update the personal data collected?
7. How does Inkaland Group interact with your social networks?
8. General information.
9. Special sections for the United States of America.

1. What personal data do we collect?
Inkaland Group collects and stores a) personal data provided by the user, b) personal data obtained from third parties, including public data, and c) personal data automatically collected by our platform, as described below:

a) Personal data provided by the user.
In order to make tourist reservations through our Sales Channels, you need to provide us with certain personal information including, but not limited to, full name, ID or valid identification number, nationality, tax ID number and contact information (such as phone number, address and/or e-mail address). With the purpose of making tourist reservations, probably you may also need to provide us with information about your debit or credit card (e.g., credit card number, security code, holder’s name and expiration date). Personal data will only be collected through the Sales Channels listed above.

At its sole discretion, Inkaland Group may verify the personal data provided by you by consulting public entities, specialized risk consultants or credit risk centers, for which you expressly authorize us. The information that Inkaland Group obtains from those entities shall be treated confidentially, in accordance with applicable law and this Policy.

You may always opt out of providing us with your personal data, though usually such information is requested to confirm bookings. If you decide not to give us certain information you probably will not be able to contract our services.

In the event that you make a reservation on behalf of a third party, you must first get the consent of said person before providing us with his/her personal data. In the event that such person is a minor, as per the laws in force, you represent and warrant that you have the consent given by at least one of the child’s parents or legal guardian to provide his/her personal data and accept this Private Policy on his/her behalf.

You may also send opinions, comments and suggestions by voluntarily participating in surveys and/or answering questions sent by emails or other channels (the “Opinions”). In this case, with the purpose of sharing real opinions on travel experiences with other users, you hereby agree and accept that all Opinions received from you may be published in any of our Sales Channels and/or in any other web sites and/or applications with whom Inkaland Group has agreements. In such case, you may be identified with full name, nickname, photograph, comment, nationality and/or any other personal information. By giving us your Opinion, or uploading multimedia content through any of our Sales Channel, you hereby agree that such content shall not be treated confidentially and may be freely used by Inkaland Group for business purposes. Subject to the limitations prescribed by applicable laws, you hereby waive all rights to use that material, including privacy rights, ownership rights and the rights of publicity and the right to object regarding the way in which that material is used. Moreover, you hereby grant a non-exclusive, unrestricted, perpetual and free license in favor of Inkaland Group and it affiliate companies to use, assign, copy and/or exhibit the Opinions in any media. No compensation shall be paid for Opinions or multimedia material.

Let us remind you that you can give your opinion anonymously or delete it by setting your preferences in “My account” or “My reservation”.

Please note that when you post information or multimedia material in a public section of any of Inkaland Group’s website or app, you are making it available to other users and to the public in general; therefore, it will be beyond Inkaland Group´ scope of control. Please consider the above and be careful about the information you decide to disclose.

b) Personal data obtained from third parties, including public data.
To the extent permitted by law, and in particular personal data protection laws, Inkaland Group may collect personal data about you from Inkaland Group’s affiliate companies, business partners, suppliers and other third party sources, such as public databases, information collected during a telephone conversation with the customer service center and/or through interactive applications.

Personal data collected from third parties shall be pooled with your other personal data which we may have.
All personal data obtained by Inkaland Group from third parties shall be processed in accordance with this Privacy Policy and applicable law.

c) Personal data automatically collected by our platform.
Inkaland Group automatically collects and stores certain user browsing data. Browsing data includes:
IP addresses, uniform resource identifier (URI), application times, methods used to send applications to the server, size of files received in response, numeric codes that indicate the status of the server response and other parameters related to the operating system and the user’s computing environment.

Computer systems and software designed to browse websites collect certain data while in use, the transmission of which is necessary for the use of internet communication protocols. As a general rule, this information is not collected to identify users, but considering its nature, such identification may occur by association with other data.
Additionally, in order for our websites to operate properly, Inkaland Group uses its own and third-party cookies.

2. What is our cookies and web beacons policy?
Inkaland Group recommends that when browsing our website you allow the use of cookies to fulfill certain functions. Cookies are specific pieces of information that a website transmits to the user’s computer hard drive or other device for the purpose of tracking records. Cookies may be useful to facilitate the use of a website by saving your settings and preferences while the user navigates through the internet.

Inkaland Group cannot access other information stored on your device through cookies, even if they are downloaded from our website. Cookies cannot execute malicious codes of any kind or virus or malware, and they do not harm the user’s device.

Furthermore, web beacons are images inserted on a website or in an email used to monitor the activity of users, as well as to store information about users’ IP addresses, the length of interaction time with the website and the type of browser used, among other functions.

Through cookies and web beacons, Inkaland Group collects information on users’ activity while using its websites. Such information may include the referring URL (whether or not they are on a Inkaland Group website), which URL they access later, the browser they are using, IP addresses, websites visited, searches performed at our websites and identification of devices used, among others.

Even though the majority of browsers automatically accept cookies and web beacons, you may set up your web browser to reject them. Please note that cookies preferences must be configured for each browser (Internet Explorer, Google Chrome, Mozilla Firefox, Safari, Opera, Vivaldi or any other one).

Our websites use different types of cookies and web beacons:

● Technical cookies: they are necessary to guarantee the functioning of the website and cannot be deleted. They are determined in response to actions taken by you, such as your privacy preferences, login, service requests, or form filling. These cookies do not store identifying information about the user.
● Functional cookies: their function is a more advanced personalization of the user’s session than that allowed by technical cookies.
● Analytical cookies: allow us to track the browsing behavior of visitors on a website, with the aim of improving the user experience. Data collected is aggregated and anonymized.
● Advertising cookies: they are third party cookies (e.g., Google and Facebook) that collect information about your preferences and choices on our websites. They are intended for marketing networks, which are later use that data to show you tailored advertising on other websites.

3. What do we use the personal data we collect for?
Inkaland Group uses the personal data collected for the following purposes:
● Arrange your tourist reservation, complete transactions you have initiated and process invoices or other tax documentation related to your reservation. In addition, we keep the reservation history in our database.
● Offer products and services, individually or jointly with third parties.
● Manage your requests and answer to your inquiries or comments.
● Perform internal analysis regarding sales and/or consumption patterns.
● Measure client satisfaction with our products, services and attention.
● Comply with our legal obligations, including cooperating with any request from public bodies as prescribed by law.
● Send you confirmation and updates about your trip, as well as any relevant information in this regard. This information may be sent via email, SMS, WhatsApp or any other instant messaging service to the contact informed by you. These messages may contain (without being limited to) information about Inkaland Group’s services, as well as contact information of providers that could contribute to your travel experience.
● Contact you to provide customer service, carry out surveys, statistics or analysis on consumption habits or preferences.
● Facilitate special offers and information to participate in contests and sweepstakes, in our loyalty program or in our co-branded credit card issuance program.
● In order to offer better services or provide users with information related to their preferences, Inkaland Group may also develop internal studies on the interests, behaviors and demographics of users, to better understand your needs and interests, improve our business and promotional initiatives, personalize your content, your presentation and services and/or show advertising or promotions of interest to users, for which purpose Inkaland Group shall only use anonymized data.
● Also, Inkaland Group uses the information of the debit or credit cards (such as the name of the cardholder, card number and its expiration date) only to arrange the travel reservations that you make, including sharing your data with final service providers to manage your reservations and/or purchase orders. You can opt to have Inkaland Group remember certain information about your card and billing, which will appear automatically when logging into Inkaland Group’s online Sales Channels.
● Finally, Inkaland Group may use the user’s personal data to provide payment processing or fraud prevention services in favor of its affiliate companies or third parties.

4. With whom do we share the personal data we collect?
You hereby grant your unequivocal consent for Inkaland Group to share your personal data with service providers for the management of your reservations or purchase requests. Such providers may be airlines, hotels, destination services, car rental companies, travel assistance service providers, wholesale operators and other providers of products and services that you contract through our Sales Channels.
Moreover, you hereby agree that Inkaland Group may share your personal data with providers that render services to Inkaland Group, including credit card acquirers, business analytics, customer service, marketing, payment processing, and/or fraud prevention. These third parties may use your personal data to offer you products and services or to provide their services.

Consequently, by accepting this Privacy Policy the user acknowledges and accepts that Inkaland Group, as data controller, may share your personal and transaction data with third parties, including without limitation the data of your reservations or purchase requests, so that Inkaland Group and/or said third parties, individually or jointly, may offer products and services that fit your profile, improve transaction security, prevent fraud, perform credit risk analysis and improve existing products and services provided, in accordance with applicable law. Said third parties will be subject to contracts and policies prohibiting the unauthorized use or disclosure of the personal data to which they have access, as well as preventing them from being used in breach of any applicable law.

Inkaland Group may authorize service providers to collect personal data on your behalf, including as necessary to operate certain elements of our online Sales Channels, or to facilitate the delivery of online advertising tailored to your interests.

Finally, Inkaland Group may also share your personal data to its affiliate companies within the Inkaland.com Group that operate under any of the group’s trademarks (i.e. “Inkaland”, “Inkaland Travel”, “Hiking Inca Trail”, “Latin America Trips” and others). When personal data is transferred, the recipient of the personal data shall have the same obligations asthe transferor.
Please note that if you provide personal data on your own initiative and directly to service providers (whether or not they are service providers at Inkaland Group), said providers may collect, process and keep said information in accordance with their own privacy policies. Inkaland Group shall not be liable for the unlawful use by third parties of personal data.

5. Where do we store and how do we protect the personal data collected?
All personal data is collected and stored on servers physically located in the United States of America. Inkaland Group may relocate these servers to any other country and may store personal data in the United States of America or in other countries, for backup purposes.

By accepting this Policy, you give your unequivocal consent for Inkaland Group to transfer your personal data to any country in the world. We guarantee that any personal data transferred abroad shall be protected.

In any case, Inkaland Group hereby agrees to ensure that the legally required standards for the protection and safeguarding of your personal data are met by entering into agreements for the protection of the privacy of your data.
Inkaland Group has tools to protect your personal data from third-party unauthorized access. We take appropriate security measures to prevent unauthorized access, alteration, disclosure or destruction of your data. These measures include internal analysis of our data collection, storage and processing practices.

With the measures we take, we can ensure that we will avoid security breaches that affect your personal data to the greatest possible extent. However, we are aware of the risks inherent in using the internet and we understand that we cannot fully eliminate them. In any case, we guarantee that the protection of your personal data is one of our priorities and that, in the event of an incident, we shall take all possible measures to minimize any damage.

6. How can you access, delete, change and/or update the personal data collected?
6.1. Opt out.
Whenever you make purchases or log in as a user in Inkaland Group, you may choose to receive promotional newsletters, messages or alerts about offers. In every message we send you, you will have the chance to unsubscribe.
Please consider that the exercise of the right to opt out applies to promotional newsletters, messages and/or alerts about offers. Notwithstanding, you will continue receiving communications regarding the status of your active reservations. Additionally, Inkaland Group will keep certain personal data of yours in order to settle disputes or answer claims, detect problems or incidents and solve them, and comply with the provisions of the General Terms and Conditions for the statutory term. Furthermore, it may occur that a user’s personal data cannot be immediately removed from our files for technical reasons, including security support systems.
6.2. How can you exercise the rights of access, change, delete and object to the processing of your personal data?
You may exercise them by any of the options below:
● By sending an email request to the address sales@inkaland.com. In your request you must indicate your full name and prove your identity. Moreover, if you send the request on behalf of a third party, you must prove that you have authority to do so.
Inkaland Group may request additional information or documentation to verify your identity or to specify your request, such as a copy of your national identity document, your email and the postal address that you choose for notices and a contact telephone number; and a clear and accurate description of the personal data with respect to which you intend to exercise the right, as well as any documents that support the request. Once all mentioned requirements have been fulfilled, and whenever appropriate, Inkaland Group shall inform you if it has proceeded to fulfill your request or if it has been rejected. Unless a different term is indicated in the special sections for your country, Inkaland Group shall have 10 (ten) business days as from receipt of the complete request to send a response in the case of an access request, and 5 (five) business days if you request the change, update or deletion of personal data.
● Additionally, you may enter, update and correct your log in information at any time by logging into “My Profile” in “My Account” or “My Inkaland Group” on our website or application. In turn, by entering “Emails and Alerts” in “My account” or “My Inkaland Group”, you can choose which emails you wish to receive.
Please note that you are responsible for providing up-to-date, correct and authentic personal data.

7. How does Inkaland Group interact with your social networks?
When registering with Inkaland Group, you are asked to choose a user ID and password (that is, to access a personal account). Also, Inkaland Group allows you to enter your personal account through your Facebook account or other social networks that may be compatible in the future (the “Social Networks”).

Also, as part of the functionality of the online Sales Channels, and to provide a more personalized experience, you can link your account to Social Networks by providing the login information of your Social Network account through the Inkaland Group website or application, or allowing Inkaland Group to access your Social Network account, as provided in the applicable terms and conditions that govern the use of each Social Network.

You hereby represent that you are entitled to reveal the login information of your Social Network to Inkaland Group and/or grant Inkaland Group access to your account, without this implying a breach on your part of any of the terms and conditions that govern the use of the corresponding Social Network and without Inkaland Group being liable to pay any fee or follow any limitation of use imposed by external service providers of the Social Network.
Upon granting Inkaland Group access to any Social Network, you understand that Inkaland Group shall access, make available and store (if applicable) all contents of the Social Network that you have authorized to be available on our websites and/or applications.

Depending on the Social Networks that you choose and subject to the privacy settings that you have established in said accounts, the personal identification information shared on your Social Networks will be available in your Inkaland Group account and through it on our websites and/or applications. Please consider that if a Social Network is no longer available, or if the external service provider blocks Inkaland Group’s access to said Social Network, the contents of the Social Networks will no longer be available on our websites and applications.
If you register on the Inkaland Group website through your personal social network account (the “Personal Account”), you agree that Inkaland Group accesses the information contained in your Personal Account, including your personal data, information about your interests, preferences, contacts and/or any contents available in your Personal Account.

8. General information.
PLEASE NOTE THAT YOUR RELATIONSHIP WITH EXTERNAL ASSOCIATED SERVICE PROVIDERS IS EXCLUSIVELY GOVERNED BY ANY AGREEMENTS YOU MAY HAVE WITH SUCH EXTERNAL PROVIDERS.
Inkaland Group’s websites and/or applications may contain links to other websites that have their own privacy policies. Therefore, we recommend that if you visit other websites, carefully review their privacy and confidentiality policies, since this Policy does not encompass third party practices or policies, including those that may disclose and/or share information with Inkaland Group.
Should you lose control of your account or password to the Social Networks, you may lose control of your personal data and may be subject to legally valid transactions performed in your name. Therefore, if for any reason your password is at risk, you must immediately: (i) change it, changing your log-in information, and (ii) contact us by any channel.

9. Special sections applicable to the Peru.
The data controller responsible for your personal data and for the performance of this Privacy Policy in the Peru shall be Inkaland.com PE, Inc. domiciled at Pje 18 Mayo, G1 – 09 , Urb Ttio, Cusco. Notwithstanding the provisions of article 6.2 of the Policy, you shall also be entitled to exercise your rights by submitting a written and executed request with a copy of a personal ID to said address.