Privacy Policy (incorporating Cookie Policy)

Last updated in June 2020.

Travel Content LLC (trading as ReachTV) is committed to protecting and respecting your privacy. This policy describes how we collect, use and otherwise process personal data relating to you, or that you provide to us:

(i) when you visit or use:

(ii) when you contact us (by email or telephone or in person), for example to request ournews and updates or to submit a query or comment regarding the Website or its content; and

(iii) through offline sales and marketing activities.

Personal data is data that can be used on its own or with other data or information to identify, contact, or locate a single person, or to identify an individual in context. Please read this policy carefully to understand our practices regarding personal data.

By visiting the Website, accessing one of our social media pages and/or using the Services, you are accepting to the practices described in this policy.

For the purposes of this policy, all references to the Website shall include a reference to the Apps, and references to “ReachTV”, “we”, “us” or “our” are to Travel Content LLC (trading as ReachTV), a company incorporated in Delaware under File Number 7567788, and having its operating address at 806 Douglas Road, 300 Coral Gables, FL 33134.

1.What personal data do we collect from you?

1.1 Information that we collect from you ####

The type of information we collect from you will depend upon the type of interaction you havewith us.

Broadly speaking, the types of personal data that we collect may include:

(i)your name, address, email address, phone number, age range, gender, details ofemployment, Internet Protocol (IP) address and any other information that you might choose to volunteer, that can be used to identify you, when you:

Additionally, We, our clients, Ad Partners, and affiliates may share information with ussuch as browser cookie IDs, mobile device IDs, IP address, device type, operating system,hashed email address, or hashed mobile ID (e.g., Apple IDFA or Android advertising ID),as well as location-based data such as Wi-Fi, celltower, GPS ordiagnostic location information, contextual information, and demographic information including age, gender, zipcode and precise and historical geographic location (“Precise Location Data”) of your device, derived from your device, and approximate and historical geographic location derived from IP address about the device.

You are under no obligation to provide any such data. However, if you choose to withhold requested information, you may not be able to access all of the Website’s contents and services.

1.2 Publicly Available Information

We may also collect information relating to you that is available on the Internet, such asfrom Facebook, LinkedIn, Twitter and Google, or other publicly available information that we acquire from our service providers.

1.3 Website Navigational Information

We also collect personal data automatically when you use the Website and when you navigate through the Website. Data collected automatically may include:

(i) technical information, including the internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, timezone setting, browser plug-in types and versions, operating system and platform; and

(ii) informationabout your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; pagere sponse times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number. For more information on our use of these technologies, see our Cookies section below.

1.4 Information that we receive from other sources

We may also collect or receive personal data relating to you in the following scenarios:

(i) where we buy in your personal data (name and company or corporate emailaddress from marketing companies or other business partners);

(ii) your personal data is contained in information given to us by our sub-contractorsthat provide technical services to us; and

(iv) your personal data is contained in information given to us by our analytics andsearch information providers.

(v) ReachTV may receive Precise Location Data from third-party partners includingCueBiq.

We do not collect any special categories of personal data about you (this includes detailsabout your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation,political opinions, trade union membership, information about your health and geneticand biometric data). Nor do we collect any information about criminal convictions and offences.

2.How do we use your personal data?

2.1 For the purposes of our legitimate interests.

2.1.1 We use personal data relating to you that we collect from publicly available sources and/or third parties, or that you provide to us, for the purposes of our legitimate interests as follows:

(i) to improve our Website and offering;

(ii) to administer any account or registration you may have with us;

(iii) to carry out our obligations arising from any contracts entered into between you and us;

(iv) to provide you with the information, products and services that you request from us;

(v) to administer your participation in any competitions or prize draws we may run from timeto time;

(vi) to notify you about changes to the Website or any other aspect of our service;

(vii) to communicate with you about any comments, queries or feedback you might haveabout us or the Website;

(viii) for publication on the Website or in our printed publications, but only if you have providedit to us for that purpose; and

(ix)to ensure that content on the Website is presented in the most effective manner for youand for your computer.

2.1.2 We also use the information about you that we collect automatically for the purposes of our legitimate interests as follows:

(i) to administer our site and for internal operations, including troubleshooting, dataanalysis, testing, research, statistical and survey purposes;

(ii) to improve our site to ensure that content is presented in the most effective manner for you and for your computer;

(iii) to allow you to participate in interactive features on the Website, when you choose to doso;(iv)as part of our efforts to keep the Website safe and secure;

(v) to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and

(vi) to make suggestions and recommendations to you and other users of the Website aboutgoods or services that may interest you or them.You have the right to object to this processing if you wish, and if you wish to do so, pleasesend an email or write to us using the details provided in the Contact Us section. Please bear in mind that if you object this may affect our ability to carry out the tasks above for your benefit.

2.2 For marketing purposes

We will use personal data relating to you to provide you with information about products andservices we offer that we feel may interest you by post, telephone, SMS or email. We will send you this information only if:

(i) you have consented to receiving this information:

(ii) the information is about products and services similar to those which were the subject of aprevious sale or negotiation of a sale to you (and you have opted in to receive such marketing messages); or

(iii) where we are permitted to do so by law without consent, for example, if you have or a third party has provided us with a company or corporate email address. If, at any time, you do not want us to use your information in this way, please contact ususing our contact form below or using our contact details in paragraph 11 below).

2.3 If wepurchase information on you from a third party, such as marketing lists, we promise to take all necessary checks to make sure your information was collected legally. We will only use such information for the purposes set out above to provide the Services.

2.4 We do not use automated decision making (including profiling).

3. Cookies

The Website uses cookies to distinguish you from other users of the Website. This helps us to provide you with a more personalised experience when you browse the Website and also allows us to improve the Website.

Cookies are small text files that are sent by a website to a web browser and contain informationthat is transferred to your computer’s hard drive. This enables the website to identify and trackthe web browser. Cookies can, among other functions, enable a website to recognise a deviceeach time it visits, remember user preferences and recommend content. Cookies in themselves do not identify the individual user, but rather the computer used. However, some cookies willcontain personal information such as a username. Our website uses cookies to distinguish youfrom other users of our website. This helps us to provide you with a more personal userexperience when you browse our website and also allows us to improve our website. By continuing to browse and use our website, you are agreeing to our use of cookies. Different cookies do different things, and some are essential to the operation of a website whilst othersare not. The different types of cookie are:

To the extent that any personal information is collected through our use of cookies, this Privacy Policy will apply to our processing of that personal information.

If you leave a comment on our site you may opt-in to saving your name, email addressand website in cookies. These are for your convenience so that you do not have to fill inyour details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to this site, we will set a temporary cookie todetermine if your browser accepts cookies. This cookie contains no personal data and isdiscarded when you close your browser.

When you log in, we will also set up several cookies to save your login information andyour screen display choices. Login cookies last for two days, and screen options cookieslast for a year. If you select “Remember Me”, your login will persist for two weeks. If youlog out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. Thiscookie includes no personal data and simply indicates the post ID of the article you justedited. It expires after 1 day.

4. Children

This Website is not intended for or targeted at children under 16, and we do not knowingly orintentionally collect information about children under 16. If you believe that we havecollected information about a child under 16, please send an email or write to us using the details provided in the Contact Us section below, so that we may delete the information.

5. Disclosure of yourinformation

5.1 We may share your information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

5.2 We may share your information with selected third parties including:

5.2.1 business partners,suppliers and sub-contractors for the performance of any contract we enter into with them or you;

5.2.2 advertisers and advertising networks that require anonymised data to select andserve relevant adverts to you and others. We may provide them with aggregate information about our users (for example, we may inform them that 100 women aged 18–24 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, men in a particular location). We may make use of the information we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;5.2.3analytics and search engine providers that assist us in the improvement and optimisation of the Website; and

5.2.4 credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

5.3 We may disclose your personal information to third parties:

5.3.1 in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business orassets;

5.3.2 if Ink or substantially all of the company’s assets are acquired by a third party, in which case personal data held by the company about our customers will be one ofthe transferred assets; or

5.3.3 if we are under a duty to disclose or share your personal data in order to comply withany legal obligation, or in order to enforce or apply our various terms, policies andother agreements; or to protect the rights, property, or safety of Ink, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

6.User content

6.1 User content is any content submitted to us for the purpose of publication on the Website (including in any public forum we may provide) or in our printed publications. All user content you submit will be treated as non-confidential and may be visible to other registered users as well as to unregistered visitors to the Website, so please do not submit any information about yourself which you would not wish to make public. (For the avoidance of doubt, user content does not include any ot her correspondence between you and us.)

6.2 Once you have submitted user content to us, you may be unable to recall or delete it except inlimited circumstances. If you are unable to edit or delete user content you have submitted, please refer to clause 9.1 and contact us through our contact form below or by using our contact details in paragraph 11 below.

6.3 We do our best to ensure that offensive language and content do not appear on the Website, but we donot routinely monitor or moderate user content and therefore user content may from time to time include language or content which some people may find offensive. If you wish to complain about any user content, please contact us through our contact form below orusing our contact details in paragraph 11 below.

7. Where we store your information

7.1 We have in place a level of security appropriate to the nature of the information storedand the harm that might result from a breach of security. All information that you send viat he Website is encrypted whilst in transit between you and the servers where we store the information. Your information is stored on the secure servers of our web services provider in Ireland.

7.2 Any payment transactions will be encrypted using SSL technology in such a way as to ensure that we are not given your financial or credit card information.

7.3 The information that we collect from you may also be transferred to other destinations outside the United States (US) or the country from which it was provided, where it will be stored by us or by one of our suppliers. It may also be processed by staff operating outside the US who work for us or for one of our suppliers. Such staff maybe engaged in, amongother things, the provision of support services. We will take all steps reasonably necessary toensure adequate security for any of your information transferred outside the US. By using theWebsite and submitting your information to us, you accept that personal data relating toyou may be transferred, stored or processed in this way. 7.4If you use our Services while you are outside the US, your information may be transferredoutside the US in order to provide you with those services.

7.5 Unfortunately, the transmission of information via the internet is not completely secureand, although we will do our best to protect your information, we cannot guarantee thesecurity of any of your information transmitted via the Website. Consequently, any
transmission is at your own risk. If we become aware that the security of your information has been compromised, we will notify you by email or as otherwise requiredby law.

7.6 In the event that a security breach does occur that could adversely affect you, and we have the means to let you know, we will take appropriate steps to notify you how the breach occurred, its nature, the steps we have taken to rectify the issue and the steps you can take to rectify and minimise any adverse impact.

7.7 Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential and you must not share it with anyone.

8. Links to third-party websites

8.1 The Website features third-party advertising which provides links to and from third-party websites. If you follow a link to any of these third-party websites, you should be aware that these websites have their own privacy policies and the operators of those websites will handle your informationin accordance with such policies and not with this Privacy Policy. For example, such operators might contact you or permit third parties to contact you for marketing purposes in accordance with their own privacy policies, unless you opt out of such communications.

8.2 We do not accept any responsibility or liability for third-party websites or their privacy policies and we strongly advise you to check such policies and the reputation of the website before you submit your information to any third-party website, the owners of which do not necessarily have any connection, commercial or otherwise, with us.

We welcome any feedback about third-party websites linked to from the Website.

9. Rights of individuals

9.1 Data Protection legislation gives you the right to access, rectification or erasure of the personal data, data portability, restriction of processing, the right to object to processing ofyour personal data, and the right to lodge a complaint with a supervisory body. You can exercise the above rights by using our contact details in paragraph 11 below.

9.2 We also want to make sure that personal data relating to you that we hold is accurateand up to date. You may ask us to correct or remove any information you think is inaccurate.

9.3 To protect your privacy, we may take steps to verify your identity before taking anyaction in response to any request. You will not have to pay a fee to access personal information relating to you (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, wemay refuse to comply with the request in such circumstances.

9.4 Our legal basis for processing your data is either consent or legitimate interest. Where our legal basis for processing your data is consent, you have the right to withdraw your consent at any time and ask us not to process your personal information, including for marketing purposes. You can exercise your right to prevent such processing at any time eitherthrough the unsubscribe link at the bottom of our marketing emails or by using our contact details in paragraph 11 below.

9.5 We will retain your data for the shortest period of (i) as long as is necessary to carry outthe purpose for which it was collected or (ii) as required by law.

9.6 If you have a concern about the way we are collecting or using your personal information, we request that you raise your concern with us in the first instance. Alternatively, you can contact your relevant supervisory authority.

9.7 If you do not want ReachTV to identify your mobile device, youhave the right to opt-out by: (a) deletingthe ReachTV app or adjusting the in-app settings of the Customer app if the app makes that option available (this will limit data collectionfrom this app alone); or (b) opt-out of sharing your mobile advertiser ID by limiting adtracking on the device.

10. Changes to our Privacy Policy

10.1 By submitting your information, you acknowledge that we will use the information as set out in this Privacy Policy. If we change our Privacy Policy, we may post the changes on this page and may place notices elsewhere within the Website (such as the homepage)for a reasonable period of time, so that you may be aware of the changes.

10.2 In the event of any changes, we will also update the “Last updated” date at the top of this Privacy Policy. You should check our Privacy Policy occasionally to ensure that you are happy with any changes we make. Your continued use of the Website following any changesto this Privacy Policy will mean you accept those changes. This Privacy Policy is governed and construed in accordance with the law of Delaware.

11. Contacting us

If you would like to contact us with any questions, comments or feedback regarding our Privacy Policy or any other aspect of the Website, products or services, you can contact us at:

Travel Content LLC
806 Douglas Road
300 Coral Gables
FL 33134, USA

Alternatively, you can email our Data Protection Officer, James Cridlan at dpo@ink-global.com.
We will usually confirm receipt by using the same method as you used to contact us.