Effective Date: September 1st, 2024

DreamGuest, Inc. (“DreamGuest”, “we”, us” or “our”) is committed to protecting the privacy and security of your personal information.  This DreamGuest Privacy Policy (“Privacy Policy”) describes the types of personal information and other information we collect from and about you when you interact with us or when you use our platform, websites, apps, or other services (collectively, the “Services”), and how we use and share your personal information.

Personal Information We Collect

The types of information that we may collect and receive from you while you use the Services are described in this section and include both information that you provide to us, information that we collect automatically when you use the Services, and information that we collect from third-party sources.

Personal Information: Personal information is information from which an individual can be identified directly or indirectly. We may collect personal information that you provide to us through our Services. For example, you may provide your personal information to us: (1) through your completing forms or setting up accounts on our platform, apps and websites; (2) through an enrollment form to register for one of our programs or services; (3) through your requests to receive marketing materials and information about our products or services; (4) by contacting the DreamGuest customer service department; or (6) by responding to DreamGuest questionnaires or surveys.

Personal information may include information such as:

• Name, username, email address, telephone number, and home, business, and billing addressees (including street and postal code);
• Government issued identification such as driver’s license number, government or national ID number, country of residence and tax identification number;
• Payment information, such as bank account and routing numbers, credit card number, billing address, or other financial account information;
• Travel-related preferences and requests, such as favorite destination and accommodation types, and special dietary and accessibility needs;
• Loyalty program and membership information;
• Birth date and gender information;
• Geolocation information;
• Biometrics, such as facial, fingerprint, voice or other biometric information;
• Images, including facial photographs, videos, voice and other recordings;
• Social media account information;
• Communications with us, such as recordings of calls with our customer service representatives for quality assurance and training purposes;
• Searches you conduct, transactions, and other interactions with you on our Services;
• Other communications that occur through our Services among partners and travelers,

             and in-group chat and traveler-collaboration tools;

• Data you give to us about other people, such as your family members, travel companions or others; and
• Information we receive about you from third parties, such as our business and affiliate partners and authorized service providers which may include updated contact information, demographic information, interests, and purchase history, which we may add to your account or profile and use for market research and analysis

Technical Information: When you install any of our apps or use our platform or websites, we automatically collect the following types of information from your device:

• IP address
• Device type
• Unique device identification numbers
• Internet browser-type, such as Firefox, Safari, Chrome, and Internet Explorer
• Internet Service Provider
• Operating System
• Mobile carrier
• How your device has interacted with our online services, including the pages accessed, links clicked, trips viewed, and features used, along with associated dates and times
• Details of any referring website or exit pages, as well as general geographic location (such as at the country or city-level)

Cookies and other similar technologies: When you use our Services, we may also collect information relating to your usage or visits to our platform, websites, apps and your devices. This information is generally collected using server log files, cookies, “pixel tags,” and Google Analytics.

Server Log Files: Your Internet Protocol (IP) address is an identifying number that is automatically assigned to your computer by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever you visit our websites, along with the time(s) of your visit(s) and the page(s) that you visited. We use the IP addresses of all visitors to our websites to calculate our websites’ usage levels, to help diagnose problems with website servers, and to administer the websites. We may also use IP addresses to communicate with or block access by visitors who fail to comply with our Terms of Use. Collecting IP addresses is standard practice on the Internet and is carried out automatically by many websites.

Cookies: Cookies are data that a web server transfers to an individual’s computer for record-keeping purposes. Cookies are an industry standard used by most websites and help facilitate users’ ongoing access to and use of a particular website. Cookies do not cause damage to your computer systems or files, and only the website that transferred a particular cookie to you can read, modify, or delete such cookie. If you do not want information collected using cookies, there are simple procedures in most browsers that allow you to delete existing cookies, to automatically decline cookies, or to be given the choice of declining or accepting the transfer of cookies to your computer (see our on-line Cookie Policy about our use of cookies). You can set your browser to refuse cookies, but some portions of our websites may not work properly if you refuse cookies. A session cookie is one that exists for the time-period that your browser is open. A persistent cookie is one that is saved on your device/computer even after the browser is closed.  Like many websites, we may use both session cookies and persistent cookies.  To find out how to see what cookies have been set and how to reject and delete cookies, please visit //www.aboutcookies.org.

Pixel Tags: Our websites may use so-called “pixel tags”, “web beacons”, “clear GIFs” or similar means (collectively, “pixel tags”) to compile aggregate statistics about website usage and response rates. Pixel tags allow us to count users who have visited certain pages on our websites, to deliver branded services, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, Pixel Tags can tell the sender whether and when the email has been opened.

Google Analytics: We may use Google Analytics, a web analysis service provided by Google, to better understand website usage. Google Analytics collects information such as how often users visit websites, what pages they visit and what other websites they used prior to visiting. Google uses the data collected to track and examine the use of the websites, to share such data with other Google services, or to personalize the ads of its own advertising network. Google’s ability to use and share information collected by Google Analytics is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. To opt-out of analysis by Google Analytics on our websites, please visit //tools.google.com/dlpage/gaoptout.

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 Policy. 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 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;
• 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.

Our Uses of Your Personal Information

The personal information that is collected in connection with our Services may be used in any of the following ways:

• Help you to use our Services through features like the ability to sign-in using your account within our online services and websites;
• To respond to your requests for information about our products or services;
• To provide you with marketing communications whether about a particular DreamGuest product or service or concerning general services information;
• 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);
• Create, maintain, and update user accounts on our platform and authenticate you as a user;
• To determine if you are eligible for certain products, services, or programs (such as loyalty programs);
• Administer loyalty and rewards programs;
• Administer promotions like contests, sweepstakes, and similar giveaways;
• Collect and enable reviews;
• Maintain your search and travel history, accommodation and travel preferences, and similar information about your use of our platform and Services;
• To manage or develop our business relationship with you (e.g., to respond to questions, invite you to events, comply with regulatory obligations, or determine eligibility for DreamGuest programs);
• To recruit and/or consider you for employment;
• Create aggregated or otherwise anonymized or deidentified data, which we may use and disclose without restriction where permissible;
• For our research, development, and collaboration efforts; and
• For business purposes, such as payment processing and financial account management, product or service development, contract management, website administration, fulfillment, analytics, fraud prevention, corporate governance, reporting, and legal compliance.

The information that we collect from your devices is used to better design our websites. We analyze the information we collect to enhance our websites’ security and to track the popularity of certain pages on the websites, the success of our email notifications, traffic levels on the websites, and other usage data, all of which helps us to provide content tailored to your interests and improve our websites and related Services.

How We Share Your Personal Information

Third-Parties: We share personal information with third-parties in connection with the delivery of our Services to you and for 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 the 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 and you should review their Privacy Policies for further information on their handling of your personal information). We may also share your personal information with third parties with whom we have contracted, as well as affiliates and business partners. We will require these recipients to use your personal information only for appropriate purposes and take appropriate measures to protect your personal information.

Travel suppliers: We share personal information with travel-related suppliers such as hotels, airlines, car-rental companies, insurance, vacation-rental property owners and managers, and where available, activity providers, rail, or cruise lines. Please note that travel suppliers may contact you to obtain additional information if and as required to provide travel or associated services.

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 on our platform.

Mergers or Acquisitions: In the event that we sell or transfer all or a portion of our business or assets to a third-party, such as in the event of a corporate sale, merger, reorganization, dissolution or similar event, we may transfer information that we have collected to such third-party.  We will require such a third-party to continue to comply with this Privacy Policy.

Compliance with Applicable Laws: We may disclose information if we believe it is necessary: (a) to comply with any law applicable to us, a request from law enforcement, a regulatory agency, or other legal process; (ii) to protect the legitimate rights, privacy, property, interests, or safety of DreamGuest, our business partners, personnel, or the general public; (iii) to pursue available remedies or limit damages; (iv) to enforce our Terms of Use; or (v) to respond to an emergency. We reserve the right to disclose personal information when we believe in good faith that such action is necessary to comply with a legal obligation.

Other Parties With Your Consent or At Your Direction: In addition to the disclosures described in this Privacy Policy, we may share information about you with third-parties when you consent to or request such sharing.

Third Party Advertising

DreamGuest has relationships with third-party advertising companies to place advertisements on its website and other websites, and to perform tracking and reporting functions for its websites. These third-party advertising companies may place cookies on your computer when you visit our websites or other websites so that they can display targeted advertisements to you. These third-party advertising companies do not collect personal information in this process, and we do not give any personal information to them as part of this process. However, This Privacy Policy does not cover the collection methods or uses of the data collected by these third-parties. For more information about third-party advertising, please visit the Network Advertising Initiative (NAI) at www.networkadvertising.org.

Links To Other Websites

Our websites may contain links to third-party websites, which are not operated or controlled by DreamGuest and for which DreamGuest is not responsible. The links from the websites do not imply that DreamGuest endorses or has reviewed the third-party websites. Once you have left one of our websites, we are not responsible for the protection and privacy of any information you provide.  We suggest contacting those third-party websites directly for information on their privacy practices.

Global Access and Data Transfers

Our websites are owned and operated by DreamGuest in the United States.  However, your personal information may be accessible or transferred to our affiliates, business partners, suppliers and vendors who are located in other countries. If you are visiting our websites from a country other than the United States, your communication with us will necessarily result in the transfer of information across international borders.  We have implemented reasonable measures to help protect your personal information; for example, intended recipients are contractually bound to comply with certain data protection standards.  However, certain countries and territories may not provide a similar or adequate level of protection as that provided by your home country or region.  Therefore, by using our websites or Services or you are otherwise providing information to us, you hereby expressly consent to the transfer of your personal information outside your country or region.

Children’s Privacy Protection

Protecting the privacy of children is especially important to us. We take seriously our obligations under applicable laws concerning the collection of personal information from children. Our Services are not directed at children and we do not knowingly allow children to communicate with us or use any of our websites or Services.  We request that children not provide any personal information through our websites or in connection with the Services.  If you are a parent and become aware that your child has provided us with personal information, please contact us at [email protected].

Your Choices and Rights

If you have an account with us, you may change your communication preferences by logging in and updating the information in your account.  If you would like your personal information removed from our database, changed or updated, you can contact us at: [email protected]. If requested, we will promptly verify and delete your account and you will no longer receive emails, texts or other communications from DreamGuest.

Your removal from the mailing list or database will not remove records of past transactions or delete information stored in our data backups and archives where we are required to keep your data for legitimate business or legal requirements. Data on past transactions and data stored in backups and archives will be deleted in the normal course of our business.

You have the right to access or, if required by applicable laws, receive a copy of your personal information held by us by making a written request by sending an email to: [email protected].

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 to change communication settings or contacting us at [email protected]. Please note that if you choose to unsubscribe from or opt out of marketing emails, we may still send you important transactional and 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 at [email protected]. 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

We will respond to your request within 30 days after we have verified that you are the data subject or are authorized to make the request on behalf of the data subject. If necessary, we may extend our response time by an additional 60 days to respond properly, but we will notify you if that is the case. If we decide not to fulfill your request, we will tell you the reasons why.

For questions about privacy, your rights and choices, and in order to make a request to amend or update your information, or to inquire about deletion, please contact us at [email protected].

In addition to the above rights, you may have the right to complain to a data protection authority about our collection and use of your personal information. However, we encourage you to contact us first so we can do our best to resolve your concern. You may submit your request to us at [email protected]. We respond to all requests we receive from individuals wanting to exercise their personal data protection rights in accordance with applicable data protection laws.

Data Security

DreamGuest stores personal information and other data using reasonable physical, technical and administrative safeguards to secure data against foreseeable risks, such as unauthorized use, access, disclosure, destruction or modification.  Please note, however, that while DreamGuest has endeavored to create secure and reliable websites for our users, the confidentiality of any communication or material transmitted to or from one of our websites, texts or via e-mail cannot be guaranteed.

You should take special care in deciding what information you transmit, upload, send, or otherwise submit to DreamGuest.

In case of a personal information security incident, as required by applicable laws, we will inform you in a timely manner and report the incident to the relevant regulatory authorities.

We retain your information for as long as it is necessary for the purposes set out in this Privacy Policy, unless required by our legal obligations to retain it for a longer period.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. At a minimum, we will post an updated version here. DreamGuest encourages you to review this Privacy Policy regularly for any changes. Any changes will be effective immediately upon posting of the revised Privacy Policy, and your continued use of our platform, websites, apps or our Services will be subject to the then-current Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy or about our handling of your personal information, please contact us at [email protected].

Residents of the European Economic Area (EEA)

DreamGuest is a data controller for purposes of the General Data Protection Regulation (EU) 2016/679 or “GDPR”.

The GDPR requires that we inform you of the legal bases we rely on to process your personal data. The legal bases for which DreamGuest processes personal data are set forth below:

• DreamGuest’s legitimate interests: For example, to maintain system security, communicate with you and fulfill your requests, assess a job applicant eligibility, conduct surveys, improve our products and services, and protect our rights and the rights of others.

• Performance of a contract with you: For example, when you submit an application, enroll in a program, or register for a program or service.

• Compliance with laws: For example, to comply with legal and regulatory requirements or respond to a court order or legal request.

• Consent: Where we rely on consent to process your personal information, you can withdraw your consent at any time.

The servers where your personal data are stored may be located in the United States and other countries that have not been deemed by the European Commission to provide an adequate level of protection for personal data. In addition, we may share personal data with our affiliates and external service providers and third parties located outside of the EEA. When we transfer personal data out of the EEA to other countries that have not been deemed adequate, we will implement one or more of the safeguards deemed to provide appropriate safeguards by the European Commission, which may include EU Standard Contractual Clauses, transfers to organizations that protect personal data under binding corporate rules, or transfers to organizations that operate under an approved code of conduct or certification mechanism.

Our Data Protection Representative for the EEA and UK

We have appointed a Data Protection Representative (DPR) for the EEA and UK. Our DPR is DPO Consultancy. If you have any questions about our Privacy Policy, if you wish to exercise your rights, or if you wish to lodge a complaint, you may either contact Marinus directly at: [email protected] or contact our DPR at: [email protected] or by sending mail to the following addresses:

DPO Consultancy (EEA)

Australiëlaan 12A

5232 BB ‘s-Hertogenbosch

The Netherlands

DPO Consultancy (UK)

19 The Square

RETFORD Nottinghamshire DN22 6DQ

England