Privacy Statement

Sept 16, 2022

INNO LIFE LLC values you as our customer and recognizes that privacy is important to you. This Privacy Statement explains how we collect, use, and disclose data when you use our platform and associated services, your rights in determining what we do with the information that we collect or hold about you and tells you how to contact us.

What personal information do we collect and use, and how do we collect it?

We collect personal information when:

      · You give us the information

      · We collect it automatically

      · We receive it from others

When you create an account on one of our sites, sign up to receive offers or information, or make a booking using our platform, you give us your personal information. We also collect such information through automated technology such as cookies placed on your browser, with your consent where applicable, when you visit our sites or download and use our Apps. 

How is your personal information shared?

Your personal information may be when we send information on products and services or enable you to communicate with travel providers and/or property owners, and comply with the law. The Privacy Statement below details how personal information is shared.

What are your rights and choices?

You can exercise your data protection rights in various ways. For example, you can opt out of

marketing by clicking the “unsubscribe” link in the emails, in your account as applicable, or contacting our customer service. Our Privacy Statement has more information about the options and data protection rights and choices available to you.

How to contact us

More information about our privacy practices is outlined below in our full Privacy Statement. You can also contact us as described in the “Contact Us” section below to ask questions about how we handle your personal information or make requests about your personal information.

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CONTENTS FOR PRIVACY STATEMENT

Categories of Personal Information We Collect

Mobile Apps

Use of Personal Information

Sharing of Personal Information

Your Rights and Choices

Security

Record Retention

Categories of Personal Information We Collect

When you use our platform, Apps, or associated tools or services, we may collect the following kinds of personal information from you as needed:

      · Name, username, email address, telephone number, and home, business, and billing addressees (including street and postal code)

      · Government issued Identification required for listing or identity verification, such as driver's license, government redress numbers, country of residence, tax identification number for vacation property owners

      · Payment information such as payment card number, expiration date, billing address, and financial account number

      · Travel-related preferences and requests such as favorite destination and accommodation types, and special dietary and accessibility needs, as available

      · Loyalty program and membership information

      · Birth date and gender

      · Geolocation

      · Images (including facial photographs), videos, and other recordings

      · Social media account ID and other publicly available information

      · Communications with us (such as recordings of calls with customer service representatives for quality assurance and training purposes)

      · Searches you conduct, transactions, and other interactions with you on our online services and Apps

      · Other communications that occur through the platform among partners and travelers, and in-group chat and traveler-collaboration tools 

      · The searches and inquiries conducted through the platform

      · Data you give us about other people, such as your travel companions or others for whom you are making a booking

Mobile Apps

When you download and use any of our mobile apps, we collect certain technical information from your device to enable the app to work properly and as otherwise described in this Privacy Statement. That technical information includes:

      · Device and telephone connectivity information such as your carrier, network type, network operator, subscriber identity module ("SIM") operator, and SIM country

      · Operating system and version

      · Device model

      · Performance and data usage

      · Usage data, such as dates and times the app accesses our servers, the features and links clicked in the app, searches, transactions, and the data and files downloaded to the app

      · Device settings selected or enabled, such as Wi-Fi, Global Positioning System ("GPS"), and Bluetooth (which may be used for location services, subject to your permission as explained below)

      · Mobile device settings

      · Other technical information such as app name, type, and version as needed to provide  you with services

Permissions for Location-Based Services:

Depending on your device's settings and permissions and your choice to participate in certain programs, we may collect the location of your device by using GPS signals, cell phone towers, Wi-Fi signals, Bluetooth or other technologies. We will collect this information, if you opt in through the app or other program (either during your initial login or later) to enable certain location-based services available within the app (for example, locating available lodging closest to you). To disable location capabilities of the app, you can log off or change your mobile device's settings.

Use of Personal Information

We use your personal information for various purposes described below, which depend on the site you visit or the app you use. 

Your Use of Online Sites, Apps, and Services:

      · Provide services related to the booking and/or account

      · Create, maintain, and update user accounts on our platform and authenticate you as a user

      · Maintain your search and travel history, accommodation and travel preferences, and similar information

      · Enable and facilitate acceptance and processing of payments, coupons, and other transactions

      · Administer loyalty and rewards programs

      · Collect and enable booking-related reviews

      · Help you to use our services faster and easier through features like the ability to sign-in using your account within the online services and sites 

Communications and Marketing:

      · Respond to your questions, requests for information, and process information choices

      · Enable communication between you and the travel supplier like hotels and vacation property owners

      · Contact you (such as by text message, email, phone calls, mail, push notifications, or messages on other communication platforms) to provide information like travel booking confirmations and updates, for marketing purposes, or for other purposes as described in this Privacy Statement

      · Market our products and services, optimize such marketing to be more relevant to you, and measure and analyze the effectiveness of our marketing and promotions

      · Administer promotions like contests, sweepstakes, and similar giveaways

Other Business Purposes and Compliance

      · Conduct surveys, market research, and data analytics

      · Maintain, improve, research, and measure the effectiveness of our sites and apps, activities, tools, and services

      · Monitor or record calls, chats, and other communications with our customer service team and other representatives, as well as platform communications between or among partners and travelers for quality control, training, dispute resolution, and as described in this Privacy Statement

      · Create aggregated or otherwise anonymized or deidentified data, which we may use and disclose without restriction where permissible

      · Promote security, verify identity of our customers, prevent and investigate fraud and unauthorized activities, defend against claims and other liabilities, and manage other risks

      · Comply with applicable laws, protect our and our users' rights and interest, defend ourselves, and respond to law enforcement, other legal authorities, and requests that are part of a legal process

      · Comply with applicable security and anti-terrorism, anti-bribery, customs and immigration, and other such due diligence laws and requirements

      · Operate our business using lawful business purposes and as permitted by law

Lawful bases for processing:

We will collect personal information from you only (i) where the personal information is necessary to perform a contract with you (e.g., process payments, or create an account at your request), (ii) where the processing is in our legitimate interests and not overridden by your rights (as explained below), or (iii) where we have your consent to do so (e.g., sending you marketing communications where consent is required). 

Sharing of Personal Information

We share your personal information as described below and in this Privacy Statement, and as permitted by applicable law.

      · INNO GROUP Companies. We share your personal information within the INNO LIFE LLC. INNO LIFE LLC share, access and use your personal information as described in this Privacy Statement.

      · Third-party service providers. We share personal information with third-parties in connection with the delivery of services to you and the operation of our business (for example, to provide credit card processing, customer service, business analytics, and fraud prevention and compliance services, and to serve you with advertising tailored to your interests). These third-party service providers are required to protect personal information we share with them and may not use any directly identifying personal information other than to provide services we contracted them for. They are not allowed to use the personal information we share for purposes of their own direct marketing (unless you have separately consented with the third-party under the terms provided by the third-party).

      · Business partners and offers.  If we promote a program or offer a service or product in conjunction with a third-party business partner, we will share your information with that partner to assist in marketing or to provide the associated product or service.  In most of those cases, the program or offer will include the name of the third-party business partner, either alone or with ours, or you will be redirected to the website of that business with notice. An example of such a business-partner relationship would be a third-party loyalty program for which you could earn points by completing a booking on our platform.

      · Legal rights and obligations. We may disclose your personal information to enforce our policies, or where we are permitted (or believe in good faith that we are required) to do so by applicable law, such as in response to a request by a law enforcement or governmental authority, in connection with actual or proposed litigation, or to protect and defend our property, people and other rights or interests. We may also share your personal information pursuant to a subpoena or other legal request, or as necessary to remit certain taxes in the course of processing payments as required by law or legal process.

      · Corporate transactions. We may share your personal information in connection with a corporate transaction, such as a divestiture, merger, consolidation, assignments or asset sale, or in the unlikely event of bankruptcy. In the case of any acquisition, we will inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Statement.

Your Rights and Choices

You have certain rights and choices with respect to your personal information, as described below:

      · If you have an account with us, you may change your communication preferences by either (1) logging in and updating the information in your account  or (2) contacting us via the options provided in the Contact Us section.

      · You can access, amend, inquire about deletion, or update the accuracy of your information at any time by either logging into your account or contacting us

      · If you no longer wish to receive marketing and promotional emails, you may unsubscribe by clicking the 'unsubscribe' link in the email. You can also log into your account or contacting us. Please note that if you choose to unsubscribe from or opt out of marketing emails, we may still send you important account-related messages from which you will not be able to unsubscribe

      · For our mobile apps, you can view and manage notifications and preferences in the settings menus of the app and of your operating system

      · If we are processing your personal information on the basis of consent, you may withdraw that consent at any time by contacting us. Withdrawing your consent will not affect the lawfulness of any processing that occurred before you withdrew consent and it will not affect our processing of your personal information that is conducted in reliance on a legal basis other than consent

Certain countries and regions provide their residents with additional rights relating to personal information. These additional rights vary by country and region and may include the ability to:

      · Request a copy of your personal information

      · Request information about the purpose of the processing activities

      · Delete your personal information

      · Object to our use or disclosure of your personal information

      · Restrict the processing of your personal information

      · Opt-out of the sale of your personal information

      · Port your personal information

      · Request information about the logic involved in our automated decision-making used in our fraud prevention practices and the result of such decisions

Security

We want you to feel confident about using our platform and all associated tools and services, and we are committed to taking appropriate steps to protect the information we collect. While no company can guarantee absolute security, we do take reasonable steps to implement appropriate physical, technical, and organizational measures to protect the personal information that we collect and process.  

Record Retention

We will retain your personal information in accordance with all applicable laws, for as long as it may be relevant to fulfill the purposes set forth in this Privacy Statement, unless a longer retention period is required or permitted by law. We will deidentify, aggregate, or otherwise anonymize your personal information if we intend to use it for analytical purposes or trend analysis over longer periods of time.

The criteria we use to determine our retention periods include:

      · The duration of our relationship with you, including any open accounts you may have with Expedia Group companies, or recent bookings or other transactions you have made on our platform

      · Whether we have a legal obligation related to your personal information, such as laws requiring us to keep records of your transactions with us

      · Whether there are any current and relevant legal obligations affecting how long we will keep your personal information, including contractual obligations, litigation holds, statutes of limitations, and regulatory investigations