Privacy Policy
Introduction
Sogno Tours LLC d/b/a VacationVIP.com, its affiliates and
subsidiaries ("Company," "We," “Us,” and “Our”) respects your privacy and are committed to protecting it
through our compliance with this policy. This policy describes the
types of information we may collect from you or that you may
provide when you visit the website (our
"Website") or social media sites we
control and our practices for collecting, using, maintaining,
protecting, and disclosing that information.
This policy applies to information we collect:
- On or through this Website.
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Over the phone, email, text, and other electronic messages
between you and Us.
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Through mobile and desktop applications you download from this
Website, which provide dedicated non-browser-based interaction
between you and this Website.
-
When you interact with our advertising and applications on
third-party websites and services, if those applications or
advertising include links to this Website.
Information we collect about you and how we collect it
Please read this policy carefully to understand our policies and
practices regarding your information and how we will treat it. If
you do not agree with our policies and practices, your choice is
to not use our Website. By accessing or using this Website, you
agree to this privacy policy. This policy may change from time to
time (see Changes to Our Privacy Policy). Your continued use of
this Website after we make changes is deemed to be acceptance of
those changes, so please check the policy periodically for
updates.
We collect several types of information from and about users of
our Website, including the following categories of
information:
-
Purchasing Information. This is information
that we may collect about your transactions in our stores, on
our websites or via our mobile applications including what
products you purchase, how frequently you purchase them, any
rewards or promotions associated with a purchase.
-
Personal Information. This is information by
which you may be personally identified, through your account
with us or otherwise, such as name, postal address, e-mail
address, telephone number, address, or any other identifier by
which you may be contacted online or offline (“Personal Data”).
The collection of such personal information is necessary for Us
to provide you with our services.
-
Device and Usage Information. This is
information about your internet connection (ISP), IP address,
device and mobile ad identifiers, the website that referred you
to our website, the subject of the ads you click or scroll over,
Cookies, Analytics, the equipment you use to access our Website
and usage details. To collect this information, we use automatic
data collection cookies, web beacons and similar technologies.
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Location information. This is information about
the location of your device, including GPS location, for
purposes of enhancing or facilitating our services, such as
enabling the functionality of our websites or mobile
applications that provide you with information about offers near
you, enabling you to remotely order and pay for our products and
services, or have certain products delivered by a third-party
vendor. If you want to opt out of the collection of this
location information, please see the section below titled
Choices on How We Use and Disclose Your Information or by
contacting us as detailed under Contact Information.
-
Public information. Some information we gather
is publicly available. We may also gather information about you
from third-parties and other companies.
We collect this information:
- Directly from you when you provide it to us.
-
Some information such as your internet connection and equipment
you use to access our Website and usage details is automatically
collected as you navigate through the site. Information
collected automatically may include usage details, IP addresses,
location and information collected through cookies and other
tracking technologies.
-
We use third party analytics providers and products, such as
Google Analytics, to obtain, compile and analyze information
about how users are using and interacting with the Website. In
order to collect this information, such providers may set
cookies on your browser or mobile device or read cookies that
are already there. Google Analytics may also receive information
about you from apps you have downloaded, that partner with
Google. We do not combine the information collected through the
use of Google Analytics with personally identifiable
information. You can control the information provided to Google
and opt out of certain ads provided by Google by using one of
the of the methods set forth in
https://www.google.com/policies/privacy/partners.
-
From third parties, for example, our business partners,
affiliates and agents.
Information You Provide to Us.
The information we collect on or through our Website may
include:
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Certain general data and Personal Data (“Personal Data”) that
identifies our customers, that you provide or give us in another
way. This may include your first and last name, postal address,
telephone number, email address, date of birth, citizenship, and
passport details, and if you make a purchase, your credit/debit
card details in order to make a payment and confirm the
purchase.
-
Information that you provide by filling in forms on our Website.
This includes information provided at the time of registering to
use our Website, subscribing to our service, posting material,
or requesting further services. We may also ask you for
information when you enter a contest or promotion sponsored by
us, and when you report a problem with our Website.
-
Records and copies of your correspondence including email
addresses, if you contact us.
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Your responses to surveys that we might ask you to complete for
research purposes.
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Details of transactions you carry out through our Website and of
the fulfillment of your travel and purchases. You may be
required to provide financial information including credit or
debit card information before placing an order through our
Website.
-
Your search queries or preferences through use of the Website,
including the election to share location information with us and
our website applications.
You also may provide information, or comments, or photographs to
be published or displayed (hereinafter,
"posted") on public areas of the
Website or transmitted to other users of the Website or third
parties (collectively,
"User Contributions"). Your User
Contributions are posted on and transmitted to others at your own
risk. Although we limit access to certain pages/you may set
certain privacy settings for such information by logging into your
account profile, please be aware that no security measures are
perfect or impenetrable. Additionally, we cannot control the
actions of other users of the Website with whom you may choose to
share your User Contributions. Therefore, we cannot and do not
guarantee that your User Contributions will not be viewed by
unauthorized persons.
Information We Collect Through Automatic Data Collection
Technologies.
As you navigate through and interact with our Website, we may use
automatic data collection technologies to collect certain
information about your equipment, browsing actions, and patterns,
including:
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Details of your visits to our Website, including traffic data,
logs, and other communication data and the resources that you
access and use on the Website.
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Information about your computer and internet connection,
including your IP address, operating system, and browser type.
The information we collect automatically is statistical data and
does not include personal information, but we may maintain it or
associate it with personal information we collect in other ways or
receive from third parties. It helps us to improve our Website and
to deliver a better and more personalized service, including by
enabling us to:
- Estimate our audience size and usage patterns.
-
Store information about your preferences, allowing us to
customize our Website according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Website.
The technologies we use for this automatic data collection may
include:
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Cookies (or browser cookies). A cookie is a
small file placed on the hard drive of your computer. You may
refuse to accept browser cookies by activating the appropriate
setting on your browser. However, if you select this setting you
may be unable to access certain parts of our Website. Unless you
have adjusted your browser setting so that it will refuse
cookies, our system will issue cookies when you direct your
browser to our Website.
-
Flash Cookies. Certain features of our Website
may use local stored objects (or Flash cookies) to collect and
store information about your preferences and navigation to,
from, and on our Website. Flash cookies are not managed by the
same browser settings as are used for browser cookies.
Information on how to disable or remove flash cookies can be
found below under the section titled Choices on How We Use and
Disclose Your Information.
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Web Beacons. Pages of the Website and our
e-mails may contain small electronic files known as web beacons
(also referred to as clear gifs, pixel tags, and single-pixel
gifs) that permit the Company, for example, to count users who
have visited those pages or opened an email and for other
related website statistics (for example, recording the
popularity of certain website content and verifying system and
server integrity).
-
Java Scripts. Java scripts are code snippets
embedded in various parts of websites and applications that
facilitate a variety of operations including accelerating the
refresh speed of certain functionality or monitoring usage of
various online components.
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Entity Tags. Entity Tags are HTTP code
mechanisms that allow portions of websites to be stored or
“cached" within your browser and validates these caches
when the website is opened, accelerating website performance
since the web server does not need to send a full response if
the content has not changed.
-
HTML5 Local Storage. HTML5 local storage allows
data from websites to be stored or “cached" within your
browser to store and retrieve data in HTML5 pages when the
website is revisited.
We do not collect personal information automatically through the
above technologies, but we may tie this information gathered to
personal information about you that we collect from other sources
or you provide to us.
Third party cookies and other tracking technologies
Some content or applications, including advertisements, on the
Website are served by third-parties, including advertisers, ad
networks and servers, content providers, and application
providers. These third parties may use cookies alone or in
conjunction with web beacons or other tracking technologies to
collect information about you when you use our website. The
information they collect may be associated with your personal
information or they may collect information, including personal
information, about your online activities over time and across
different websites and other online services. They may use this
information to provide you with interest-based (behavioral)
advertising or other targeted content.
We do not control these third parties' tracking technologies
or how they may be used. If you have any questions about an
advertisement or other targeted content, you should contact the
responsible provider directly.
How we use your information and legal base for processing
We only process your information where it is necessary for:
-
Our legitimate interests to establish and manage our
relationship with you, for administrative purposes, and other
legitimate business interests such as credit assessment,
marketing, presenting and improving our website;
-
Flash Cookies. Certain features of our Website
may use local stored objects (or Flash cookies) to collect and
store information about your preferences and navigation to,
from, and on our Website. Flash cookies are not managed by the
same browser settings as are used for browser cookies.
Information on how to disable or remove flash cookies can be
found below under the section titled Choices on How We Use and
Disclose Your Information.
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Fulfilling our contractual obligations towards you (e.g.,
sending confirmations, invoices, and travel documentation to
you), our affiliated or related entities, associates, partners,
and the customers of such affiliated or related entities,
associates and partners; and
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Compliance with applicable laws and regulations and our legal
obligations, such as accounting and tax requirements.
There may be occasions where we request your consent to process
your personal data. Where applicable, you may withdraw consent
subsequently at any time by contacting us as detailed under
Contact Information, below, without affecting the
lawfulness of processing based on consent before its withdrawal.
For example, we may use your information to contact you about our
own and third-parties' goods and services that may be of
interest to you. We may use the information we have collected from
you to enable us to display advertisements to our
advertisers' target audiences. Even though we do not disclose
your personal information for these purposes without your consent,
if you click on or otherwise interact with an advertisement, the
advertiser may assume that you meet its target criteria.
Information on how to opt-out of interest-based advertising can be
found under the section titled Choices on How We Use and Disclose
Your Information or by contacting us as detailed under Contact
Information.
Disclosure of your information
We may disclose aggregated information about our users, and
information that does not identify any individual, without
restriction. We may disclose personal information that we collect
or you provide as described above (How We Use Your Information and
Legal bases for Processing) to the following:
- To our subsidiaries and affiliates.
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To contractors, service providers, and other third parties we
use to support our business and who are bound by contractual
obligations to keep personal information confidential and use it
only for the purposes for which we disclose it to them.
-
To a buyer or other successor in the event of a merger,
divestiture, restructuring, reorganization, dissolution, or
other sale or transfer of some or all of VVIP's stock or
assets, whether as a going concern or as part of bankruptcy,
liquidation, or similar proceeding, in which personal
information held by VVIP about our Website users is among the
assets transferred.
-
To third parties, including but not limited to suppliers,
third-party vendors, business partners, and corporate affiliates
for the same legitimate purposes as detailed above.
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To fulfill the purpose for which you provide it. For example, if
you give us an email address to use the "email a
friend" feature of our Website, we will transmit the
contents of that email and your email address to the recipients.
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For any other purpose disclosed by us when you provide the
information, with your consent, as applicable.
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To comply with any court order, law, or legal process, including
to respond to any government or regulatory request. When the
disclosure of such personal information is required to be made
to a governmental or regulatory agency, we will ensure that such
personal information will only be shared with the relevant
governmental or regulatory agency and not released to the
general public. However, you will hold Us harmless if the
personal information is disclosed by the governmental or
regulatory agency to any third party or the public.
-
To enforce or apply our terms of use of or terms and conditions
posted on the Website and other agreements, including for
billing and collection purposes.
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If we believe disclosure is necessary or appropriate to protect
the rights, property, or safety of VVIP, our customers, or
others. This includes exchanging information with other
companies and organizations for the purposes of fraud protection
and credit risk reduction.
Choices about how we use and disclose your information
We strive to provide you with choices regarding the personal
information you provide to us. Below are some of the mechanisms
available to change control over your information automatically
provided when visiting the Website:
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Tracking Technologies and Advertising. You can
set your browser to refuse all or some browser cookies, or to
alert you when cookies are being sent. To learn how you can
manage your Flash cookie settings, visit the Flash player
settings page on Adobe's
website. If you disable or refuse cookies, please note that some parts
of this site may then be inaccessible or not function properly.
-
Google Analytics. You can control the
information provided to Google and opt out of certain ads
provided by Google by using one the of the methods set forth in
https://www.google.com/policies/privacy/partners.or use the Google Analytics opt out browser add-on at
https://www.google.com/policies/privacy/partners
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Cookies; Web Beacons; Entity Tags; and HTML5 Local Storage;
and other similar technologies.
Persistent cookies can be removed by following your web
browser’s directions. A session cookie is temporary and
disappears after you close your browser. You can reset your web
browser to refuse all cookies or to indicate when a cookie is
being sent. However, some features of the Site may not function
properly if the ability to accept cookies is disabled. Turning
off the browser's cookies will prevent web beacons from
tracking your specific activity. The web beacon may still record
an anonymous visit from your IP address, but unique information
will not be recorded. If you do not want to receive tracking
pixels, you will need to disable HTML images in your email
client, and that may affect your ability to view images in other
emails that you receive. Each browser is different, but many
common browsers (Internet Explorer, Chrome, Firefox, and Safari)
have preferences or options that may be adjusted to allow you to
either accept or reject cookies and certain other technologies
before they are set or installed or allow you to remove or
reject the use or installation of certain technologies
altogether. To find out how to see what cookies have been set
and how to reject and delete the cookies, please visit:
https://www.aboutcookies.org
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Opting out of sharing location information. You
may be able to adjust the settings of your device so that
information about your physical location is not sent to us or
third parties by (a) disabling location services within the
device settings; or (b) denying certain websites or mobile
applications permission to access location information by
changing the relevant preferences and permissions in your mobile
device or browser settings. Please note that your location may
be derived from your WiFi, Bluetooth, and other device settings.
See your device settings for more information.
We do not control third parties' collection or use of your
information to serve interest-based advertising. However, these
third parties may provide you with ways to choose not to have your
information collected or used in this way. You can opt out of
receiving targeted ads from members of the Digital Advertising
Alliance or the Network Advertising Initiative ("NAI")
on the NAI's website or by visiting
www.AboutAds.info
Information sent abroad
VVIP is a global organization and provides global services. In
certain circumstances, sharing data cross-border is essential to
the services you receive from Us.
I. Special Requirements under EU Data Protection Laws
(GDPR):
In order to complete your booking, complete analysis, or for other
legitimate purposes we transfer, process and store information
about you outside of the EEA on servers located in the United
States by Sogno Tours LLC d/b/a VacationVIP.com and its affiliates
located at 5900 Lake Ellenor Drive Suite 300, Orlando, FL 32809.
Therefore, your information may be transferred to, stored, or
processed in the United States. We will ensure that in terms of
Data Security Standards of our systems in the US will have the
same level of data protection that is adhered to by Us. If we
transfer your Personal Data to agencies or third parties outside
the EEA, we require similar, binding EU Standard Contractual
Clauses, and we monitor compliance with such. Our affiliated or
related entities, associates and partners have also agreed to
adopt equivalent measures. Copies of these measures can be
obtained by contacting Us as detailed under Contact Information
below. You may lodge a complaint with the UK Information
Commissioner’s Office if you consider that our processing of your
Personal Data infringes applicable law.
II. Special Requirements under Mexican Data Protection
Laws
In accordance with the requirements of the Mexican Federal Law on
the Protection of Personal Data Held by Private Parties ( Ley
Federal de Protección de Datos Personales en Posesión de los
Particulares ) (the “Mexican DP Law”), We inform our users and
subscribers located in Mexico of Our compliance with this Law.
Under Mexican DP Law, we do not need to obtain your consent for
the processing of your personal data for the purposes that give
rise and are necessary for the fulfillment of our relationship
(e.g. personal information required in order for you to subscribe
to our vacation programs). In case you do not agree with the
processing of your personal information for such purposes and as
described in this policy, please abstain from acquiring or using
our services.
Our Website users and subscribers located in Mexico should note
that:
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The personal data provided by you to Us through email, fax,
websites, online services, enrollment or subscription forms and
agreements, telephone calls or any other means, is processed by
Us for the purposes set forth in section How We Use Your
Information; in the understanding that, in order to comply with
the Mexican DP Law, below we have set forth those purposes that
are not required to fulfill the relationship between us,
commonly known as “additional or secondary purposes”:
-
To provide you with updates about discounted availability,
special offers, new services and products which may be of
interest to you and other noteworthy news items.
- Send advertisements, promotions and brochures.
-
To contact you about our and third parties’ goods and services
that may be of interest to you.
- To ask for ratings and reviews of services or products.
-
Should you not wish that your personal information be used for
the purposes listed immediately above, please send an email to
[email protected] with subject line “Request for Restriction on
the use of My Personal Information for Secondary Purposes /
Mexico”.
-
That this privacy policy applies to all your personal
information that We may have access to, including: name,
nationality, birthdate and birthplace, age, address, telephone
number, cell phone number, email, tax identification number,
handwritten signature, as well as personal information that may
be considered sensitive and related to recorded video or
photographs, health condition, economic and financial data,
including your bank account information and information of your
credit or debit cards, as well as other personal data listed in
the section Information We Collect About You and How We Collect
It.
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As described above (see Information We Collect Through Automatic
Data Collection Technologies), We also collect information using
various technologies, such as cookies and web beacons.
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That your personal information will be solely treated in
accordance with the terms and conditions of this privacy policy.
-
In order for you to: (i) exercise your rights to Access,
Rectify, Cancel, and Object to the use of your personal
information (known as “ARCO Rights”), and (ii) to limit the use
and disclosure or to revoke your consent to the use of your
personal information for the secondary purposes described above,
please send an email to
[email protected] with subject line “Exercise of ARCO Rights /
Mexico”. The request should include, as minimum:
-
Copy of your official ID and/or of your legal representative.
Such documents should be scanned and attached to the
corresponding email communication. For legal representative,
please also attach a copy of his/her power-of-attorney.
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Clear and precise description of the personal information about
which the ARCO Rights are to be exercised, as well as the right
or rights you wish to exercise. This description could be
included in the email cover letter or in a document attached
thereto, scanned and initialized in each of its pages.
-
Expressly state your agreement to receive our response through
an email communication, specifying the corresponding email
address.
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Any other data that allows US to locate your personal data.
We will issue a response within the following 20 business days
after we receive your request. Once you receive our response, you
will have a 15 business day period to respond to our
communication. In case you do not reply to our response within the
mentioned period, we will understand in good faith that you agree
with our response. We may refuse the exercise of your ARCO Rights
in the cases permitted by applicable law, and shall inform you
about such decision. The refusal may be partial, in which case We
will carry out the access, rectification, cancellation or
objection in the corresponding part.
As mentioned below, you can also review and change your personal
information by logging into the Website and visiting your account
profile page.
See the section Disclosure of Your Information for information
regarding the manner in which we share your personal information
with third parties and data-processors. Please note that we
require your consent to transfer your personal data to third
parties to market their own products or services to you.
Should you not wish that your personal data be transferred to
third parties for their own marketing purposes please send an
email to
[email protected]
line “Request for Restriction on the Transfer of Personal Data to
Third Parties for their Own Marketing Purposes / Mexico”.
This privacy policy may be modified as described in the section
“Changes to the Privacy Policy” set forth below.
Your rights to accessing and correcting your information
You can review and change your personal information by logging
into the Website and visiting your account profile page. You have
the right to ask VVIP not to process your Personal Data for
marketing purposes. You also have the right to access Personal
Data about you by VVIP and to correct inaccurate Personal Data.
Please ensure that we have an up-to-date active and deliverable
email address for you. In accordance with applicable law, you may
also have the right to object to or request restriction of the
processing of your Personal Data and to request erasure and to
port Personal Data about you.
Should you wish to exercise your rights, or to unsubscribe please
contact
[email protected] or Attn: Privacy Policy Manager, Sogno Tours
LLC d/b/a VacationVIP.com at 5900 Lake Ellenor Drive Suite 300,
Orlando, FL 32809 or via our toll-free number:
800-266-0602.
Access to your Personal Data will be granted in accordance with
the requirements of applicable national legislation. The
information will be forwarded to you within an appropriate period
of time in accordance with applicable law, and where any
discrepancies are discovered following your enquiry, we will take
immediate steps to validate and, where appropriate, correct our
records.
Retention of data
We will retain your personal information during the term of the
provision of the services availed by You only for so long as
reasonably necessary for the purposes set out herein, in
accordance with applicable laws.
Marketing Consent
Upon contacting Sogno Tours LLC d/b/a VacationVIP.com. (VVIP) and
providing PII such as your full name, e-mail address, and/or
contact number, You expressly authorize and consent to receive
autodialed and/or pre-recorded telemarketing calls, as well text
messages and emails, from or on behalf of Sogno Tours LLC d/b/a
VacationVIP.com at the telephone number(s) provided. You hereby
understand that your permission overrides your listing on any
state, federal or company do not call list. You also understand
that your consent is not a condition of purchasing any good or
service. You agree to waive your rights under TCPA. You agree to
receive communication via SMS, email and telephone on an ongoing
basis and understand that you can opt-out of these communications
at any time. You understand that this means both marketing and
informational communication. You understand that message and data
rates may apply to any communication via SMS.
Children under the age of 16
Our Website is not intended for children under 16 years of age. No
one under age 16 may provide any personal information to Company
or on the Website. We do not knowingly collect personal
information from children under 16. If you are under 16, do not
use or provide any information on this Website or on or through
any of its features/register on the Website, make any purchases
through the Website, use any of the interactive or public comment
features of this Website or provide any information about yourself
to us, including your name, address, telephone number, email
address, or any screen name or user name you may use. If we learn
we have collected or received personal information from a child
under 16 without verification of parental consent, we will delete
that information. If you believe we might have any information
from or about a child under 16, please contact us as detailed
under Contact Information, below.
Data security and retention
We have implemented measures designed to secure your personal
information from accidental loss and from unauthorized access,
use, alteration, and disclosure. All information you provide to us
is stored on our secure servers behind firewalls. Any payment
transactions provided therewith will be encrypted.
The safety and security of your information also depends on you.
Where we have given you (or where you have chosen) a password for
access to certain parts of our Website, you are responsible for
keeping this password confidential. We ask you not to share your
password with anyone. We urge you to be careful about giving out
information in public areas of the Website like message boards.
The information you share in public areas may be viewed by any
user of the Website.
Unfortunately, the transmission of information via the internet is
not completely secure. Although we do our best to protect your
personal information, we cannot guarantee the security of your
personal information transmitted to our Website. Any transmission
of personal information is at your own risk. We are not
responsible for circumvention of any privacy settings or security
measures contained on the Websit
Your Personal Data will be retained only for so long as reasonably
necessary for the purposes set out above, in accordance with
applicable laws.
Your California privacy rights
California Civil Code Section § 1798.83 permits users of our
Website that are California residents to request certain
information regarding our disclosure of personal information to
third parties for their direct marketing purposes. To make such a
request, please contact us as detailed under Contact Information.
Click
here
to see your rights as a resident of California under the
California Consumer Privacy act (CCPA).
Your Nevada privacy rights
Residents Notice to Nevada: If you are a
resident of Nevada, under certain circumstances, Nevada Civil Code
Section NRS 603A.340 allows you to request operators of websites
not to sell your Personal Information. To make such a request,
please send an email to our Privacy Policy Manger at
[email protected]
or send a letter to:
Vacation VIP, LLC
5900 Lake Ellenor Drive Suite 300,
Orlando,
FL 32809
Attn: Privacy Policy Manager
It is our policy to post any changes we make to our privacy policy
on this page with a pop-up notice that indicates the privacy
policy has been updated on the Website home page. The date the
privacy policy was last revised is identified at the top of the
page. Please visit our Website and this privacy policy
periodically to check for any changes.
Contact Information
To ask questions or comment about this privacy policy and our
privacy practices, or request that we remove or opt-out any
information gathered about you, that we actually control, please
email or write to us at:
[email protected]
or Attn: Privacy Policy Manager, Sogno Tours LLC d/b/a
VacationVIP.com
5900 Lake Ellenor Drive Suite 300, Orlando, FL 32809 or via our
toll-free number:
800-266-0602. The Privacy Policy Manager would also act as a designated
grievance officer and shall address any discrepancies and
grievances that you may have with respect to this Privacy Policy.
Effective as of: 4/20/2020
