Effective Date: September 1, 2022
California Privacy Notice
Your privacy is important to Classic Journeys LLC (“Classic Journeys” or “we” or “us”). This California Privacy Notice explains how Classic Journeys collects, shares, uses and protects personal information relating to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”) over the past twelve (12) months. Any terms defined in the CCPA have the same meaning when used in this Notice.
Collection of Information
In the preceding twelve (12) months, we have collected the following categories of personal information:
- Identifiers, such as name, postal or electronic address, phone number, government-issued identifiers (e.g., passport details), account name (for our booking/guest portal) and social media account;
- Personal information as defined under the California Consumer Records statute (Cal. Civ. Code § 1788.80(e)) such as contact information, medical information, financial information and insurance information;
- Characteristics of protected classifications under California or federal law, such as age, gender, national origin and religion (as it pertains to guests’ dietary restrictions);
- Sensory and biometric information, such as photos and videos of you, audio recordings of phone calls (when permitted under law), and copies of passports and IDs;
- Commercial information, such as transaction history, account data and information about bookings or other products and services purchased or considered;
- Internet or network activity information, such as browsing history and interactions with our website, mobile application and/or services;
- Geolocation data, such as precise geolocation data from your device or Internet Protocol address;
- Professional or employment-related information (to the extent you submit a job application);
- Sensitive personal information, including—
- government identifiers (e.g., passport details);
- contents of mail, emails and text messages, blogs or other social media postings;
- health data and medical conditions (e.g., allergies, accessibility accommodations);
- religious beliefs (as it pertains to guests’ dietary restrictions) and
- Inferences drawn from any of the foregoing information.
Please be advised that “personal information” does not include information which is publicly available, anonymized or aggregated, nor other information which is excluded from the CCPA’s scope (e.g., information covered by other privacy laws such as the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act or California Financial Information Privacy Act, and the Driver’s Privacy Protection Act).
Sources of Information
- From third parties that interact with us in connection with the services we perform;
- From marketing partners and commercially available third-party sources; and
- From publicly available databases.
Use of Information
We may keep the personal information we collect until we no longer need the information to provide services to you, complete our transaction with you, to enable us to communicate with you about our service, for troubleshooting purposes, for our analysis to improve quality of our services, or to satisfy our legal, regulatory, insurance or contractual obligations.
Sharing of Information
To perform the functions and provide the services described above, we may share your personal information with our affiliates and certain trusted third parties, such as:
- Our parent, affiliates or subsidiaries (including Lindblad Expeditions LLC, Natural Habitat Adventures, DuVine Cycling + Adventure Co., and Off the Beaten Path LLC) in an effort to bring improved products and services across our family of products and services, when permissible under relevant laws and regulations;
- Co-branded partners (e.g., Inspirato, Hyatt Hotels and National Geographic), service providers and vendors to perform functions and provide services, including (without limitation) booking reservations and arranging travel and accommodations, payment processing, and other activities relating to customer service, website/application and database hosting and maintenance, data analytics, call monitoring, email delivery and related communication infrastructure, marketing and marketing research, error monitoring, debugging, and information technology and related infrastructure;
- Other third parties to whom you authorize us to share personal information in connection with services provided by us; and
- Governmental authorities or other entities as required by law or regulation.
We may also disclose your name, address and purchase data with third party data brokers and for list exchange purposes with other companies as part of a list cooperative membership environment, such as with Epsilon Data Management, to enable them and us to provide you with information about products or services.
We require these third parties to maintain the privacy and security of the personal information they access and process on our behalf. Other than the disclosure of your name, address and purchase data information with Epsilon Data Management as part of our membership in Epsilon’s list cooperative, we do not sell or rent your personal information to unaffiliated third parties, such as sellers of goods or services, for their own business or commercial purposes. We may share anonymous or aggregated information with third parties to help deliver products, services and content and for other purposes.
Access. As a California resident, you have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and verify your request, we will disclose to you:
- the categories of personal information that we have collected about you;
- the categories of sources from which the personal information was collected;
- the purpose for collecting your personal information;
- the categories of third parties to whom we disclosed your personal information, the categories of personal information that we disclosed (if applicable) and the purpose for disclosing your personal information; and
- the specific pieces of personal information we collected about you (also referred to as a “data portability” request).
Deletion. You have the right to request that we delete the personal information that we collected from you and retained, unless the CCPA recognizes an exception. We may maintain a confidential record of deletion requests solely for the purpose of preventing your personal information from being sold, for compliance with applicable law, or for other purposes permitted under the CCPA.
Correction. You may at any time direct us to correct any inaccuracies in the personal information that we maintain about you. Upon receiving and verifying your request to correct inaccurate personal information, we will use commercially reasonable efforts to correct the inaccuracy.
Restrict Use or Disclosure of Personal Information for Advertising & Marketing. We may use, or share to our affiliates and service providers, personal information about you for advertising and marketing purposes. You have the right, at any time, to request that we not use your sensitive personal information or disclose it for advertising and marketing purposes. Once we receive and verify your request, we will no longer use or share your personal information for advertising or marketing purposes.
Opt Out of Personal Information Sales. We may sell your name, address and purchase data to third parties that host and operate list exchanges and cooperative databases, such as Epsilon Data Management, LLC. You have the right to opt out of this sale of your personal information at any time.
How to Exercise Your Rights
If you are a California resident, you may submit a request by:
- Calling toll-free at 800-200-3887;
- Submitting an online request via email to firstname.lastname@example.org;
Only you, or a person legally authorized to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child. You may only make a request for access or data portability twice within a 12-month period.
Your request must (1) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, and (2) describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identify or authority to make the request and confirm the requested personal information relates to you. Making a request does not require you to create an account with us. We will only use personal information provided in a request to verify the requester’s identity or authority to make the request.
Any disclosures we provide will only cover the 12-month period preceding our receipt of the request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your rights under California law. Unless permitted by applicable law, we will not deny you services, charge you different rates for services, provide you with a different level or quality of services, or suggest that you may receive a different rate for services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted under California law that can result in different prices, rates, or quality levels. Any legally-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describes the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
If you have any questions or concerns about this California Privacy Notice, the ways in which Classic Journeys collects and uses your information described above, or your choices and rights regarding such use, please do not hesitate to contact us at:
Classic Journeys, LLC
7855 Ivanhoe Ave., Suite 220
La Jolla, CA 92037