In this Policy, references to “we,” “us,” “our,” or “GL” are references to Greenlight Tour & Travel, Inc.
d/b/a GL Travel, including all its affiliates and subsidiaries.
PURPOSE
At GL, we are mindful and committed to maintaining meaningful privacy protections for our customers.
This privacy policy describes GL’s practices regarding personally identifiable information (“Personal
Information”) that we: collect from you, or that you provide or make available to us, when you make a
booking with us, use our website, or use our social media pages (our “Platforms”); collect from third
parties including our affiliated entities, advertising and business partners, and data providers; collect
automatically from your computer or mobile device, including IP address and browser information, or
through the use of cookies or similar tracking technologies on the Platforms or third-party platforms.
We will only collect and use your Personal Information where we have lawful grounds and legitimate
business reasons to do so.
COLLECTION AND USE OF PERSONAL INFORMATION
In General. We receive and store information about you when you: visit our Platforms; visit third-party
platforms; open or respond to our emails; contact us; register for services on our Platforms; connect or
link to any Platform via social networking sites; and/or provide information to our suppliers, advertising
and business partners.
Personal Information collected may include:
• first and last name;
• gender;
• telephone number;
• postal address, including street name and name of city or town;
• email addresses;
• data of birth;
• government identification number; and
We may also request information regarding your insurance and medical coverage options, and/or hotel
room preferences. You can choose not to provide Personal Information to us, but, in general some
Personal Information about you is required for you to: register for our programs; book travel; complete
a program profile; ask us a question; or initiate other transactions on the Platforms.
As part of its execution of a client trip, GL may collect additional personally identifiable information
about persons participating in our services. The use of that information will be limited to the execution
of GL’s obligations under the contract and for no other purpose and will be treated as personally
identifiable information consistent with this policy. These special categories of Personal Information,
include information about any relevant medical conditions, diseases, or disabilities you may have and
which we need to enable us to meet your particular needs in relation to the booking(s). We will only
collect and use these special categories of Personal Information with your explicit consent and for its
limited purposes. We may also use your Personal Information to help us support other business functions,
such as fraud prevention, marketing, and/or legal.
INFORMATION FROM OTHER SOURCES
We also may periodically obtain both personal and non-personal information about you from affiliated
entities, advertising and business partners, data providers, and other third-party sources and add it to
our information. Examples of information we may receive include: name, educational institution, email
address, physical address, and phone number. If you use your social media to interact with GL’s
Platforms, we may access Personal Information about you via those social media platforms (depending
on your privacy settings on those third-party social media platforms). This information may include your
name, profile picture, gender, location, and list of friends.
AUTOMATIC COLLECTION
We automatically collect some information about your computer when you visit our Platforms. For
example, we may collect information about your IP address, web browser, Internet Service Providers
(ISPs), operating systems, date/time stamps, number of clicks to analyze trends, etc. This information is
used to administer the Platforms and track user movements. We also may collect information about
your online activity, such as views and registrations completed. This automatic information is used only
on an aggregated, anonymous basis and is not used with, or linked to, any personally identifiable
information.
HOW WE SHARE YOUR INFORMATION
Suppliers
We share your Personal Information, when necessary, with hotel, airline, coach & bus, car rental,
insurance, medical and activity providers, to fulfill your program requirements and reservations. By
enrolling in our programs, through any Platform, you are authorizing us to disclose to our suppliers the
information required to complete the program requested and fulfill related requirements such as
insurance and medical coverage. We do not control the privacy practices of our suppliers.
Third-Party Vendors
We share your information with third-party vendors who provide services or functions on our behalf.
These third-party vendors include credit card processing companies, business analytics platforms,
advertising and business partners, distributers of surveys programs, and fraud prevention firms. We
may also authorize third-party vendors to collect information on our behalf as necessary to operate
features of our Platforms.
Please note that third-party vendors, such as hotels, airlines, and other travel partners, may have access
to and collect your Personal Information to perform their own functions and deliver their own services.
We do not control these additional practices of third-party vendors – please refer to the third-parties’
own privacy notices for information about how they treat your Personal Information.
Sale of Personal Information
We do not sell, rent, distribute, or share Personal Information we collect directly from you or about you
with third-party Advertisers for their own marketing purposes.
No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties
Requesting Information and Referring Friends
When you refer a friend using the Platforms, Personal Information may be requested about that
individual. You should obtain the consent of other individuals prior to providing us with their Personal
Information.
Future Business Transactions
As our business is constantly changing, we may transfer your Personal Information as part of a business
transaction, including merger, sale of assets, or acquisition.
Legal Disclosures
GL may be required to disclose Personal Information to the authorities, law enforcement agencies,
government agencies, or legal entities. We may disclose information by law to: a) comply with valid
legal process including subpoenas, court orders or search warrants, and as otherwise authorized by law
b) in the event of an emergency that threatens an individual’s life, health, or security; or c) to the extent
permitted by applicable law in special cases in which we believe it is reasonably necessary to investigate,
identify, or take preventive measures or bring legal action against someone who may commit or cause
harm, fraud, abuse, or illegal conduct, such as a threat of harm to you or anyone else, interference with
our rights or property, or interference with U.S. homeland or national security or public safety anywhere
in the world.
USING OUR PLATFORMS OUTSIDE OF THE UNITED STATES
GL is a California-based company. When visiting our Platforms from outside the United States, please be
aware that we may process your Personal Information within, or transfer your Personal Information to,
the United States. We may also transfer your Personal Information to third parties in the United States
for processing. If you do not wish your Personal Information to be processed in, transferred to, and
stored in, the United States, please do not provide your Personal Information when using our Platforms
in locations outside the United States.
HOW WE PROTECT YOUR PERSONAL INFORMATION
We want you to feel confident about using our Platforms to register with our programs and make travel
arrangements. We are committed to protecting the Personal Information we collect. While no Platform
can guarantee security, we use commercially reasonable safeguards to assist us in preventing
unauthorized access, use, and disclosure of your Personal Information. We have also implemented
appropriate technical and organizational measures to ensure that your Personal Information is kept in a
secure environment and access to it is restricted to a ‘need to know’ basis.
Storing Your Information and Security
We will use and store your Personal Information only for as long as necessary, bearing in mind the uses
of your Personal Information as described in this privacy policy and otherwise communicated to you,
and any mandatory legal requirements governing storage and reporting of information, which we are
subject to. We review the Personal Information we hold at regular intervals and delete permanently or anonymize any Personal Information which is no longer necessary.
COOKIES AND TRACKING TECHNOLOGIES
GL, and third parties, may use cookies and tracking technologies for the following purposes when you
visit our Platforms:
• To track new visitors to our Platforms;
• To operate, maintain and improve our Platforms;
• To facilitate and fulfill travel program requirements and services requests;
• To help us recognize your browser as a previous visitor. This includes saving and remembering
any preferences that may have been set while your browser was visiting our Platforms;
• To store your username and password if you are registered with us;
• In addition, we and third parties may also collect and store your Personal Information via web
beacons, remarketing pixel tags, and Flash cookies which are placed in the code of a web page
or email, or which access your browsing activity. Where cookie technologies may not be
available (for example in mobile applications), GL and third parties may use technologies that
perform functions similar to cookies that link identifiers used for advertising on mobile
applications to an advertising cookie to coordinate ads across your mobile apps and mobile
browser.
Opting Out of Cookies
We provide you with choices regarding cookies and tracking technologies. The toolbar on most
browsers will tell you how to prevent your browser from accepting new cookies, how to have the
browser notify you when you receive a new cookie, or how to disable cookies altogether. Please keep in
mind that, without cookies, you may not have access to certain features on our Platforms.
Managing “Do Not Track” Signals
Some browsers have a Do Not Track (“DNT”) feature that lets you tell websites that you do not want to
have your online activities tracked. Our Platforms do not currently respond to DNT signals.
Email Notifications
With respect to email notifications, we will only contact you with marketing information and offers
relating to our products or services where you have consented to receive such information. You will be
given the opportunity to opt in to receiving certain types of communication when you register with us,
book a trip with us, or otherwise provide us with your Personal Information. If you have opted-in, you
can still choose not to receive commercial emails from us by following the unsubscribe instructions
contained in the emails we send you. You may also email us directly at info@gltravelco.com to
unsubscribe from our email service. Please note that even if you do not opt in to receiving commercial
email messages, or you opt-in but subsequently choose to opt-out , we may still email you regarding
your account and your transactions.
HOW YOU ACCESS AND CONTROL YOUR INFORMATION
You can inquire as to your Personal Information by contacting us via email at info@gltravelco.com to:
• Learn what Personal Information we have about you (if any), including why we are holding it and
who it could be disclosed to;
• Request to change/correct any Personal Information we have about you;
• Request to delete any Personal Information we have about you;
• Request to restrict the processing of your Personal Information;
• Express any concerns you may have about our use of your Personal Information; and
If you choose not to provide certain information or ask us to delete or restrict the use of your Personal
Information, some of the services we provide to you may be affected, and in some cases, we may be
unable to deliver the services you have requested.
Information Submitted by Children
We only collect Personal Information from children under 13 after verifiable parental consent has been
obtained in accordance with the Children’s Online Privacy Protection Act (“COPPA”).
If a parent or guardian becomes aware that his or her child has provided us with Personal Information
without their consent, he or she should contact us. If we become aware that a child under 13 has
provided us with Personal Information without verifiable parental consent or if we receive Personal
Information from other Platforms, we will delete such information from our Platforms.
Third-Party Links
We may collect your Personal Information from third parties, including when you log in using a thirdparty platform, such as Facebook, Instagram, and Twitter. We do not control the privacy practices of
the third-party platforms and encourage you to review its privacy policies for more information.
Your California Privacy Rights
As provided by California Civil Code Section 1798.83, a California resident who has provided Personal
Information to a business with whom they have established a business relationship for personal, family,
or household purposes (“California customer”) is entitled to request information about whether the
business has disclosed Personal Information to any third parties for the third parties’ direct marketing
purposes. In general, if the business has made such a disclosure of Information, upon receipt of a
request by a California customer, the business is required to provide a list of all third parties to whom
Information was disclosed in the preceding calendar year, as well as a list of the categories of
information that were collected and/or disclosed. To request such information, please submit your
request by email to info@gltravelco.com, or in writing to 8780 Auburn Folsom Road, Granite Bay, CA
95746. Please allow 30 days for a response. Please note that we are only required to respond to one
request per customer each year and you will not be charged for this request.
GL does not allow for public forum postings, as defined by Cal. Bus. & Prof. Code § 22581(f), on any of its
Platforms. California and other customers may request further information about our compliance with this law by emailing GL at info@gltravelco.com.
Changes to Privacy Policy
Any material changes to this policy will be posted on our webpage to keep you aware of what Personal
Information is collected, how it is used, and under what circumstances it will be shared. It is your
responsibility to review GL’s Privacy Policy each time you provide Personal Information to us as the
policy may have changed since the last time you used our Platforms.
How You Can Contact Us
If you have questions about this Privacy Policy (or your program registrations or travel planning) please
email us at info@gltravelco.com