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Privacy Policy

Effective Date: April 16, 2015

This Privacy Policy explains the privacy practices of JE Circle, Inc. (“JEC“), operators of the TripCompanion website (the “Website“), application (“App“), and other products, software, and services (referred to collectively as the “Services” or the “TripCompanion Services“) and the information we collect from you and what we do with it. We also want to clarify how this information may be shared with other parties and what controls you have regarding the handling of your information. We encourage you to familiarize yourself with our Privacy Policy.

Our services help individuals (a “Planner“) find and manage travel companionship arrangements for themselves or others traveling on a commercial air flight (a “Traveler“). Neither JEC nor any of its services are designed or intended to attract individuals under the age of 18, and persons under the age of 18 are not authorized to use these Services.

This Privacy Policy is effective as of April 16, 2015. A notice will be posted as part of this Privacy Policy and on the first login whenever this Privacy Policy is materially changed. This Privacy Policy applies only to information collected through the TripCompanion Services that are accessible online.

Information Collected

JEC collects several types of personal and non-personal information either directly from you or through our service providers and partners. JEC also provides information concerning your navigation of our Website to a third party analytics service to support and improve the Services we offer.

The Do Not Track Browser Setting

We support the Do Not Track browser setting. Do Not Track is a preference you can set in your browser to let the websites you visit know that you do not want them collecting certain information about you. If you request us not to track your activities on the Website, we will recommend that you refer to your web browser’s instructions to disable the tracking function. Preventing us from tracking your activity on our Website may disable certain functionality.

Personal Information

Personal Information” is information that can be used to uniquely identify you. We collect such information from you when you create a user account with us. When you ask to subscribe to our newsletter, or send us an inquiry by email, we will collect your email address. When you open an account with us, we collect your name, email address, and cellular phone number. At your option, you can also provide to us your physical address, telephone number, and current physical location. We will also collect the trip plan, basic attributes of the Traveler, the name, physical address, electronic mail address, and telephone number of each Traveler, and the required attributes of the person who will accompany the Traveler (the “Companion“). We also collect and retain any Personal Information that you may provide in any content that you upload to the TripCompanion Services.

If you give us your permission, we also will collect and retain your user name, email address and number of connections from your social media sites including, without limitation, Facebook, LinkedIn, and Twitter.

Non-Personal Information

Non-Personal Information” includes information that we gather as you navigate our Services. We, and our third party analytics service, use log files, cookies, web beacons or other current technology to gather this information. We log this information when you visit and browse our Website and access our App. We record details such as your internet address, attributes of the device you are using to access the services, device types, browser types, domains, and statistics of your visit including page views, and time spent on the website and App. Non-Personal Information includes, without limitation, any information described in Sections 5.2 and 5.3 below, and any information that has been anonymized by removing any data that would allow the information to be reasonably identified with a particular individual.

How We Use Your Information

1. Personal Information

Personal Information is used, among other things, to authenticate your use of our Services, enable you to share information with others, coordinate a trip for yourself or for a Traveler, provide you the information, services, and products that you have requested, and assist in resetting your password. We may aggregate Personal Information with Non-Personal Information to provide services to you, and to manage and improve our Services. We may use Personal Information to administrate a contest, promotion, survey or other feature. We may send emails or text messages with the email and mobile phone number you provide to send you information, respond to inquiries, and/or other requests or questions. We may also use account information from other third parties to verify that you have accounts with such third parties. We may also provide Personal Information to third parties for related services relating to the Services including, without limitation, advertising, general analysis, web analytics, maintenance and improvement of the Services, database management, payment processing, and fraud prevention.

2. Non-Personal Information

We use Non-Personal Information to track and monitor aggregate usage of our Servicesand for internal analysis, quality control, and to improve our services for you and other customers. We also use non-personal information to provide advertising messages to you. We may use this Non-Personal Information to perform the functions described in this Section, or we may transfer it to third parties to perform these functions for us. We retain this information indefinitely.

3. Log Files

JEC gathers certain information automatically and stores it in log files. Information stored in log files is gathered when you or anyone else accesses the Services. This information includes, among other items, internet addresses, browser type, the identity of the internet service provider you use, referring/exit pages, operating system, date/time stamp, time spent on the site, the country in which the user purports to be located, and click stream data (i.e., a list of pages or websites visited). We use this information to analyze trends, administer the Services, and for general marketing research. We may, in some circumstances, need to review this automatically collected data in combination with specific account information to identify and resolve issues for individual users. We do not treat log file information as Personal Information or use it in association with other Personal Information. We may, however, aggregate, analyze and evaluate such information for the same purposes as stated above regarding other Non-Personal Information.

4. Cookies

We also use cookies, web beacons, or other technology to record your activities on the Services. A cookie is a small file that is stored on a user’s computer when you visit our Website, or any other website, through your device. Cookies may link to your account information. We use temporary cookies, among other things, to make it easier for you to navigate our site, improve the security of your personal information, enhance the functionality of certain features, and improve performance. Temporary cookies will typically be deleted from your device after you leave our Services or turn off your device.

We also use persistent cookies to make it easier for you to log on to our Services, enhance the functionality of certain features, and improve performance. Persistent cookies are not deleted from your device after you leave our Services or turn off your device. If you request, for the purpose of logging in (e.g., by checking “Remember Me” or similar item), JEC will deposit a persistent cookie that will remain on your device after you leave the TripCompanion website. Persistent cookies may be stored on your device as well by analytic companies retained by JEC to monitor your activity on our Services.

Information Retention, Sharing and Disclosure

We may retain any information or content you provide, even after you have closed your account. The Companion will determine the amount of Companion’s Personal Information to be shown to the Planner or any other individuals involved in the trip. The Planner will choose the Companion, and access the information shared by the Companion. The Planner will also determine the amount of Personal Information about the Traveler that will be shown to the Companion, or any other individuals involved in the trip.
We provide Personal Information to third parties who assist us in operating the TripCompanion Services, conducting our business, or servicing you, as long as those parties agree to keep this information confidential. However, Non-Personal Information may be provided to other parties for marketing, advertising, and analytical purposes.

1. Disclosure Required By Law

Please be aware that under certain circumstances Personal Information may be subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders. If we are legally compelled to disclose your Personal Information to a third party, we will disclose the information as required by law, but exercise commercially reasonable efforts to notify you of the disclosure unless doing so would violate the law or a court order.

2. Business Transitions

In the event that JEC goes through a business transition such as a merger, acquisition by another company, or sale or other transfer of all or a portion of its assets, your Personal Information and Non-Personal Information will likely be among the assets transferred.

3. Other Jurisdictions and Services

Personal Information and Non-Personal Information you provide to the TripCompanion Services may be stored on servers outside of the jurisdiction in which you reside. Privacy laws in such jurisdictions may be different or weaker than privacy laws in the jurisdiction in which you reside. By submitting any Personal Information to theTripCompanion Services, you consent to the transfer to another jurisdiction of any information you provide. We are not responsible for the information practices of any website or App which is linked to our TripCompanion Services, and you should review carefully the privacy policy of any website or App you access.

4. Third Party Links

At our discretion, we may include or offer third party products or services on our TripCompanion Services. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites and you should consult the privacy policies of those sites to determine their information collection practices.

Security

JEC uses a range of commercially reasonable physical, technical and administrative procedures to safeguard the information we collect. This includes, among other things, password protected access, and encrypting data using at least 128 bit SSL encryption when the data is transmitted and when the data is at rest. No procedure, however, is completely secure, and absolute security is not guaranteed.

Your Choices and Privacy Preferences

If your Personal Information changes, or if you would like to review the Personal Information that JEC has on you, then you may view, correct, update, or delete your account by making the change via your account page, or by sending a request to our Customer Support at support@tripcompanion.com. You may also delete all Personal Information you have provided to us by deleting the information from your account page. We may retain an archived copy of this information, and this information may be retained in previously backed up copies of the Website. Deletion of your Personal Information, however, may result in your account being deactivated.

Please recognize that protecting your Personal Information is also your responsibility. We ask you to be responsible for safeguarding your password, and other authentication information you use to access our services. You should not disclose your authentication information to any third party and should maintain and operate your computing equipment in a secure manner. We cannot secure Personal Information that you release on your own or that you request us to release, and that is retrieved or intercepted by individuals or entities deliberately seeking to circumvent our security procedures.

Despite JEC’s efforts to protect your Personal Information, there is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your information over the Internet could be intercepted.

Contact Information

If you have questions about this Privacy Policy, or any complaints about how your Personal Information may have been handled, please send an e-mail to our privacy administrator at privacy@jecircle.com

Privacy Administrator
JE Circle, Inc.
3000 El Camino Real, Building 4 Suite 200
Palo Alto, CA 94306