This Privacy Policy applies to TravelClick, Inc. and its subsidiaries (collectively, “TravelClick”) and information collected through use of this website (www.travelclick.com/) and online TravelClick products and services related to the hospitality industry (“Services”).

Personal information that we receive, collect or process from or on behalf of third parties, including our customers and business partners, is governed by the privacy policies of those third parties. For example, the personal information that we receive from individuals using our Services to make a hotel reservation at a particular hotel belongs to the hotel property and is governed by its privacy policy. We are not responsible for the policies or actions of our customers, business partners, or other third parties with respect to personal information.

We adhere to the Safe Harbor Principles of the United States Department of Commerce in our handling of personal information transferred from the European Union to the United States. To learn more about the Safe Harbor Program, and to view TravelClick’s certification of adherence to these Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement, please visit  www.export.gov/safeharbor.

#### Notice

We receive personal information, including names and contact information from our customers and business partners and, in some cases, directly from individuals when we act as a contractor for our customers and partners in providing our Services; and from individuals who voluntarily submit it to us by requesting products, services or other information through this website, by participating in surveys or promotions or by engaging in other communications with TravelClick. This information may be combined with information that we receive from other sources, including from third party business partners. For example, we may use third party information to confirm contact information or to better understand your interests by associating demographic information with the information you have provided.

When our customers grant staff administrator rights for TravelClick, then we will also collect some personal information about these administrators in order to provide the services and for security reasons. This will include log-in details such as name, email address and password, IP address, time of access to the service, as well as a record of whether the administrator has accepted TravelClick’s terms and conditions and privacy policy.

When individuals visit this website and the websites of our customers, we utilize cookies, tracking pixels, web beacons and other technologies to collect data that allows us to customize and improve user experience with our website and our Services. For example, these technologies allow us to identify whether an individual is a first time or return visitor and to provide faster data retrieval for return visitors. When an individual voluntarily submits information to us or one of our customers or business partners, we may associate this personal information with information gathered through these technologies so that we can offer increased personalization and functionality services to our customers or business partners.

We use the information we collect to reserve hotel accommodations and to provide related Services to our customers and to individuals on behalf of our customers. We also use the information we collect to offer industry-related analysis, reporting and marketing services to our customers and other third parties in the hospitality industry.

We may further use any information that we collect, including personal information, to administer, operate and improve our website, our Services and our business. We also use information we collect to communicate with individuals and for other marketing purposes.

#### Notice to California Residents

Under California law, California residents may request a list of all third parties to whom we have disclosed certain personal information (as defined by California law) during the preceding year for those third parties’ direct marketing purposes. If you are a California resident and would like to receive such a list, please contact us at 7 Times Square, NY, NY 10036. For any such request, include the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code. Please provide enough information for us to determine if this applies to you. You must also attest to the fact that you are a California resident and provide a current California address for our response. Please note that we will not accept requests via the telephone, email, or by facsimile, and we are not responsible for notices that are not labeled or sent properly or that do not have complete information.

#### Security

No security program is impenetrable and criminals have proven adept at circumventing widely-adopted security safeguards, so we cannot guarantee the security of personal information.  Accordingly, you acknowledge that you provide personal information to us at your own risk.

Any customer, hotel property, reseller, user or other third party accessing TravelClick’s website or Services is responsible for its own use of the website and the Services. TravelClick is not responsible for any third party’s actions or their security controls with respect to information that third parties may collect or process via the website, Services or otherwise. 

#### Onward Transfer

We may utilize third party service providers to help us manage our business and provide goods and services to our customers and business partners. We may also share personal information with our customers, business partners and our affiliates for their own marketing and internal business purposes. If we share personal information with third parties, we require that they only use such information received from us for their intended purpose.

TravelClick also may disclose any personal information as required by law, court order or other valid legal processes or in connection with a merger, acquisition, reorganization or sale of TravelClick, any of TravelClick’s business lines, or all or substantially all of TravelClick's assets or a TravelClick business line’s assets.

#### Choice

Should you sign up for our email list and then change your mind and no longer wish to receive e-mail or periodic mailings from us in the future, please let us know by sending an e-mail to Unsubscribe@travelclick.com with your email address in the subject line.

If you do not want your personal information to be used or transferred to third parties for their own marketing purposes as set forth in this Privacy Policy, you may send an email to cs@travelclick.com.

You can also adjust your Internet browser settings to refuse cookies. However, some TravelClick features and services may not operate properly or as quickly if your cookies are disabled. To find out more about cookies, visit www.aboutcookies.org.

#### Access

We will provide you with access to your personal information stored on our active servers upon request, subject to a reasonable handling charge. You may correct or update such information by sending an email to cs@travelclick.com, with “privacy policy update” in the subject line. We will also delete your personal information from our active servers, upon your written request, unless we are required to retain it by law or other legal obligation. 

#### Do Not Track

Do Not Track (DNT) is a privacy preference that users can set in their web browsers. When a user turns on DNT, the browser sends a message to websites requesting that they don’t track the user. At this time, we ignore these signals.  We do not change our practices, described elsewhere in this privacy policy, in response to Do Not Track browser settings or signals. For information about DNT, visit www.allaboutdnt.org.

In addition, we deploy cookies, tracking pixels, web beacons and other technologies on our websites and those of our customers.  Those tools may be used by us, our customers, and third parties to collect information about you and your internet activity, even if you have turned on DNT.

#### Children's Privacy

We do not knowingly collect personal information from children under the age of 13.

#### Privacy Policy Updates

If we decide to change our privacy policy, we will post those changes on this site and notify you of material changes with an alert on the site or a communication to you.

#### Additional Information/Questions

We will investigate all complaints promptly and diligently to address your concerns and resolve any disputes quickly. If a complaint or dispute cannot be resolved through our internal process, we agree to independent dispute resolution procedures administered by the American Arbitration Association.

Privacy Policy Last Modified May 8, 2015.
