Effective Date: December 23, 2023 Last Updated: August 1, 2026 This Privacy Policy explains how Crewfare®, Inc, a Delaware corporation (“Crewfare,” “we,” “our,” or “us”) collects, uses, and discloses information relating to individuals (“Personal Data”) when you access or use our products and services (collectively, the “Services”). This Privacy Policy applies to all information collected through our website, mobile applications, and any other online or offline interactions you may have with Crewfare. We take your privacy seriously. If you are an administrator on behalf of an organization, your acceptance of this Privacy Policy indicates acceptance and compliance on behalf of the organization, including its employees. We will update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, and other factors. If we do, we will update the “last updated” date at the top. If we make a material update, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our website or by contacting you directly, or where required under applicable law and feasible, seek your consent to these changes. We encourage you to periodically review this Privacy Policy to stay informed about our collection, processing and sharing of your Personal Data. Privacy contact. For questions about this Privacy Policy or to exercise your rights, contact privacy@crewfare.com.

A. PROCESSING ACTIVITIES COVERED

This Privacy Policy applies to the processing of Personal Data collected by us when you:

• Visit our websites that display or link to this Privacy Policy;
• Visit our branded social media pages;
• Visit our offices;
• Receive communications from us, including emails, phone calls, texts or fax;
• Use our cloud products and services as an authorized user (for example, as an employee of one of our customers who provided you with access to our services) where we act as a controller of your Personal Data;
• Register for, attend or take part in our events; or
• Are named in a reservation, rooming list, or booking record submitted to us by one of our customers or by a third party acting on a customer’s behalf, including as a guest, roommate, staff member, vendor, artist, or production crew member.

Processing of Personal Data is required for receiving certain products or services. Where a customer or a third party acting on a customer’s behalf submits your Personal Data to us in connection with a reservation, we generally process that data as a processor on behalf of that customer, who is the controller. In that case, the customer is responsible for providing you with notice and for establishing a lawful basis for the processing. See Section G(2) below for how to exercise your rights in that situation. Where you book directly with Crewfare, we act as controller. Our websites and services may contain links to other websites, applications, and services maintained by third parties. The information practices of other services, or of social media platforms that host our branded social media pages, are governed by their privacy policies/statements, which you should review to better understand their privacy practices.

B. COLLECTION OF INFORMATION

1. PERSONAL DATA WE COLLECT DIRECTLY FROM YOU

We collect information you provide directly to us. For example, we collect information when you sign up to receive updates, request information, fill out a form, communicate with us via third party social media sites, request support, send us an e-mail, or otherwise communicate with us. The types of information we may collect include identifiers, professional or employment-related information, financial account information, commercial information, visual information, internet activity information, and any other information you choose to provide. We collect such information in the following situations:

• If you express an interest in obtaining additional information about our services; request customer support (including accessing the Help & Chat options); use our “Contact Us” or similar features; register to use our websites; sign up for an event; or download certain content, we may require that you provide to us your contact information, such as your name, address, phone number, email address;
• If you make purchases via our websites or register for an event, we may require that you provide to us your financial and billing information, such as billing name and address, credit card number or bank account information;
• If you make or are named in an accommodation reservation, we collect reservation details including guest names, roommate or room-sharing assignments, arrival and departure dates, room type and preferences, number of nights, rate, confirmation numbers, special requests, accessibility requirements, and, where applicable, payment card information;
• If you register for an online community that we host, we may ask you to provide a username, photo or other biographical information, such as your occupation, location, social media profiles, company name, areas of expertise and interests;
• If you interact with our websites or emails, we automatically collect information about your device and your usage of our websites or emails (such as Internet Protocol (IP) addresses or other identifiers, which may qualify as Personal Data using cookies, web beacons, or similar technologies);
• If you use and interact with our services, we automatically collect information about your device and your usage of our services through log files and other technologies, some of which may qualify as Personal Data;
• If you communicate with us via a phone call from us, we may record that call;
• If you voluntarily submit certain information to our services, such as filling out a survey about your user experience, we collect the information you have provided as part of that request; and
• If you visit our offices, you may be required to register as a visitor and to provide your name, email address, phone number, company name and time and date of arrival, and to comply with any then-present health requirements.

In addition to the data we collect as listed, we may also gather demographic information such as age, gender, and preferences to better understand our customers and tailor our services. Also, we may collect your geolocation data, personal tastes, and preferences related to travel and entertainment, and images or videos where applicable. We advise against sharing sensitive personal information, such as health details, unless explicitly required or consented to for the provision of our services. Special requests. Special requests submitted in connection with a reservation may include information about health, mobility, accessibility needs, or dietary requirements. Where you or a customer submits such information, we process it solely to transmit it to the applicable accommodation provider so that the request can be accommodated. We do not use it for analytics, profiling, or marketing. Please do not include sensitive information in a special request beyond what is necessary for that purpose. Payment card information. Where you provide payment card information in connection with a reservation, that information is transmitted to and stored in tokenized form by a PCI DSS-validated third-party vault provider. Depending on the reservation type, payment card information may be (i) transmitted to a payment processor to complete a charge by Crewfare, or (ii) where the reservation is to be paid at the property, made available to authorized personnel of the applicable accommodation provider through a controlled, logged reveal function requiring secondary verification. We log each access to payment card information, including the identity of the accessing user and the time of access. Accommodation providers are independently responsible for their handling of payment card information after it is made available to them. We process your Personal Data based on various legal grounds, depending on the nature of the data and how we interact with you. This includes processing based on your consent, for fulfilling our contractual obligations to you, for compliance with our legal obligations, to protect your vital interests, or for our legitimate interests. If you provide us or our service providers with any Personal Data relating to other individuals, you represent that you have the authority to do so, and where required, have obtained the necessary consent, and acknowledge that it may be used in accordance with this Privacy Policy. If you believe that your Personal Data has been provided to us improperly, or want to exercise your rights relating to your Personal Data, please contact us at privacy@crewfare.com.

2. PERSONAL DATA WE COLLECT FROM OTHER SOURCES

We may also collect information about you from other sources including third parties from whom we may purchase Personal Data and from publicly available information. We may combine this information with Personal Data provided by you. We use the collected information to provide and improve our services, respond to your requests, and for marketing purposes, ensuring a customized experience for each user. This helps us update, expand, and analyze our records, identify new customers, and create more tailored advertising to provide services that may be of interest to you. The Personal Data we collect from other sources includes identifiers, professional or employment-related information, education information, commercial information, visual information, internet activity information, and inferences about preferences and behaviors. In particular, we collect such Personal Data from the following sources:

• Third-party providers of business contact information, including mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, LinkedIn URLs and custom profiles, for purposes of targeted advertising, delivering relevant email content, event promotion and profiling, determining eligibility and verifying contact information;
• Another individual at your organization who may provide us with your business contact information for the purposes of obtaining services;
• Our customers and their authorized agents, where an event organizer, production company, agency, or other customer submits a reservation, rooming list, or booking record that names you;
• Accommodation providers, which may transmit confirmation numbers, reservation changes, and cancellations back to us in connection with your reservation;
• Platforms such as GitHub to manage code check-ins and pull requests. If you participate in an open source or community development project, we may associate your code repository username with your community account so we can inform you of program changes that are important to your participation or relate to additional security requirements; and
• We may obtain personal information about you from third-party sources, including social media platforms, identity verification services, and publicly available sources.

3. DEVICES AND USAGE DATA

We use common information-gathering tools, such as tools for collecting usage data, cookies, web beacons, pixels, and similar technologies to automatically collect information that may contain Personal Data as you navigate our websites, our services, or interact with emails we have sent to you. We also collect information such as your device type, unique device identification numbers, and your interactions with our website or app, to enhance your user experience. As is true of most websites, we gather certain information automatically when individual users visit our websites. This information may include identifiers, commercial information, and internet activity information such as IP address (or proxy server information), device and application information, identification numbers and features, location, browser type, plug-ins, integrations, Internet service provider, mobile carrier, the pages and files viewed, searches, referring website, app or ad, operating system, system configuration information, advertising and language preferences, date and time stamps associated with your usage, and frequency of visits to the websites. This information is used to analyze overall trends, help us provide and improve our websites, offer a tailored experience for website users, and secure and maintain our websites. In addition, we may gather certain information automatically as part of your use of our cloud products and services, and through our live chat function. This information may include identifiers, commercial information, and internet activity information such as IP address (or proxy server), mobile device number, device and application identification numbers, location, browser type, Internet service provider or mobile carrier, the pages and files viewed, website and webpage interactions including searches and other actions you take, operating system and system configuration information and date and time stamps associated with your usage. This information is used to maintain the security of the services, to provide necessary functionality, to improve performance of the services, to assess and improve customer and user experience of the services, to review compliance with applicable usage terms, to identify future opportunities for development of the services, to assess capacity requirements, to identify customer opportunities, and for the security of Crewfare® generally. Information Collected by Cookies and Other Tracking Technologies We use technologies such as web beacons, pixels, tags, and JavaScript, alone or in conjunction with cookies, to gather information about the use of our websites and how people interact with our emails. When you visit our websites, we, or an authorized third party, may place a cookie on your device that collects information, including Personal Data, about your online activities over time and across different sites. Cookies allow us to track use, infer browsing preferences, and improve and customize your browsing experience. Our use of cookies and tracking technologies includes but is not limited to understanding user preferences, improving site performance, tailoring advertising, and ensuring data protection. We use both session-based and persistent cookies on our websites. Session-based cookies exist only during a single session and disappear from your device when you close your browser or turn off the device. Persistent cookies remain on your device after you close your browser or turn your device off. To change your cookie settings and preferences for one of our websites, click the Cookie Preferences link in the footer of the page. You can also control the use of cookies on your device, but choosing to disable cookies on your device may limit your ability to use some features on our websites and services. We also use web beacons and pixels on our websites and in emails. For example, we may place a pixel in marketing emails that notify us when you click on a link in the email. We use these technologies to operate and improve our websites and marketing emails. For instructions on how to unsubscribe from our marketing emails, please see below. reCAPTCHA This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. Advertising and Analytics Services Provided by Others We may allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used to, among other things, analyze and track data, deliver advertising and content targeted to your interests with our Services, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices. You can also change your browser settings to block cookies, although doing so may disable some features of our website and Services. Internet-based ads Cookies are also used to collect information about your interests and preferences for the purposes of interest-based advertising. You may turn off these cookies; however, you may still receive advertisements, with the difference that these will not be specifically tailored to you. To understand and responsibly manage cookies that enable interest-based ads, we recommend visiting the website of the Digital Advertising Alliance (DAA) or the Network Advertising Initiative (NAI). To learn more, please visit https://youradchoices.com/. Many of our third-party service providers that serve interest-based advertisements to you across our services are members of the NAI, or they follow the DAA’s Self-Regulatory Principles for Online Behavioral Advertising. You can choose to opt out directly from these third parties by visiting their opt-out pages on the NAI website and DAA website. Opt-out from the setting of cookies on your individual browser Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser or device to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. While some internet browsers offer a “do not track” or “DNT” option that lets you tell websites that you do not want to have your online activities tracked, these features are not yet uniform and there is no common standard adopted by industry groups, technology companies, or regulators. Therefore, we do not currently commit to responding to browsers’ DNT signals with respect to our websites. Crewfare® takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard. Once you block cookies on your browser, parts of the website may become unavailable to you or may otherwise not function properly. Social Media Features Our websites may use social media features, such as sharing widgets (“Social Media Features”). Social Media Features may allow you to post information about your activities on our website to outside platforms and social networks. Social Media Features may also allow you to like or highlight information we have posted on our website or our branded social media pages. Social Media Features are either hosted by each respective platform or hosted directly on our website. To the extent the Social Media Features are hosted by the platforms themselves, and you click through to these from our websites, the platform may receive information showing that you have visited our websites. If you are logged in to your social media account, it is possible that the respective social media network can link your visit to our websites with your social media profile. Your interactions with Social Media Features are governed by the privacy policies of the companies providing them. Telephony log information If you use certain features of our services on a mobile device, we may also collect telephony log information (like phone numbers, time and date of calls, duration of calls, SMS routing information and types of calls), device event information (such as crashes, system activity, hardware settings, browser language), and location information (through IP address, GPS, and other sensors that may, for example, provide us with information on nearby devices, Wi-Fi access points and cell towers).

C. PURPOSES FOR WHICH WE PROCESS PERSONAL DATA AND THE LEGAL BASES ON WHICH WE RELY

We collect and process your Personal Data for the following purposes. Where required by law, we obtain your consent. Otherwise, we rely on another authorized legal basis, including performance of a contract or legitimate interest.

• Providing our websites and Services (including necessary functionality for both): We process your Personal Data to perform our services with you and to fulfill our obligations under the applicable terms of use and service; if we have not entered into a contract with you, we base the processing on our legitimate interest to operate and administer our websites and to provide you with content you access and request;
• Arranging, managing, and fulfilling accommodation reservations: We process reservation and rooming list data to arrange, manage, and fulfill accommodation reservations, including transmitting that information to the applicable accommodation provider and recording confirmation numbers, changes, and cancellations returned by that provider;
• Promoting the security of our websites and services: We process your Personal Data by tracking use of our websites and services, creating aggregated non-personal data, verifying accounts and activity, investigating suspicious activity, and enforcing our terms and policies, in our legitimate interest in promoting safety and security;
• Handling contact and user support requests: If you request support or contact us by other means, we process your Personal Data to perform our services and in our legitimate interest in fulfilling your requests;
• Managing event registrations and attendance;
• Managing contests or promotions;
• Managing payments: If you have provided financial information to us, we process your Personal Data to verify that information and to collect payments to the extent necessary to complete a transaction and perform our services;
• Developing and improving our websites and services;
• Assessing and improving user experience;
• Reviewing compliance with applicable usage terms;
• Assessing capacity requirements;
• Identifying customer opportunities;
• Displaying personalized advertisements and content;
• Sending marketing communications; and
• Complying with legal obligations.

If we need to collect and process Personal Data by law, or under a contract we have entered into with you or related to the provision of services, and you fail to provide the required Personal Data when requested, we may not be able to perform our contract with you or to provide such services.

D. SHARING OF INFORMATION

We may share information about you as follows or as otherwise described in this Privacy Policy:

• Accommodation Providers: To fulfill and service reservations, we disclose Personal Data to the hotels, resorts, and other accommodation providers at which reservations are made (“Accommodation Providers”). This includes guest names, the names of additional guests and roommates, arrival and departure dates, room type and preferences, special requests, guest contact information, and, where a reservation is to be paid at the property, payment card information. This disclosure may be made on our own behalf, on behalf of a customer that has submitted a rooming list or reservation record to us, or on behalf of a third party authorized by that customer. Accommodation Providers act as independent controllers with respect to information they receive and process for their own purposes, including guest servicing, loyalty program administration, and their own legal and tax compliance. Their handling of your information is governed by their own privacy policies. Accommodation Providers may in turn transmit confirmation numbers, reservation changes, and cancellations back to us, which we use to update the applicable reservation record and to notify the applicable customer or guest.
• International transfers to Accommodation Providers: Where an Accommodation Provider is located outside your jurisdiction, disclosure of your Personal Data to that provider involves an international transfer. Such transfers are necessary for the performance of your reservation contract or the contract between us and the customer that arranged your reservation, and are made on that basis under applicable data protection law.
• Service Providers: With our contracted service providers, who provide services such as IT and system administration and hosting, payment processing and payment card vaulting, research and analytics, marketing, customer support and data enrichment, for the purposes and pursuant to the legal bases described above;
• Customers With Whom You Are Affiliated: If you use our services as an authorized user, we may share your Personal Data with your affiliated customer responsible for your access to the services to the extent this is necessary for verifying accounts and activity, investigating suspicious activity, or enforcing our terms and policies;
• Event Partners: If you opt in to receive marketing communications as part of booking travel to an event, we may share your Personal Data (including your name, email address, phone number, and booking details) with the event partner(s) associated with that event. Such event partners may use your Personal Data for their own marketing purposes. Each event partner’s use of your Personal Data will be governed by that event partner’s own privacy policy;
• Third party networks and websites: With third-party social media networks, advertising networks and websites, so that Crewfare can market and advertise on third party platforms and websites;
• Third Parties Involved in a Corporate Transaction: If we are involved in a merger, reorganization, dissolution or other fundamental corporate change, or sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by a third party. In accordance with applicable laws, we will use reasonable efforts to notify you of any transfer of Personal Data to an unaffiliated third party;
• In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;
• When we believe in good faith that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to comply with the law or legal processes or respond to lawful requests, claims or legal authorities;
• If we believe your actions are inconsistent with the spirit or language of our policies, or to protect the rights, property, and safety of our staff or others;
• For any other purpose disclosed by us when you provide your Personal Information; or
• With your consent or at your direction.

We may also share anonymous or de-identified usage data with Crewfare’s service providers for the purpose of helping Crewfare in such analysis and improvements. Additionally, Crewfare® may share such anonymous or de-identified usage data on an aggregate basis in the normal course of operating our business. Our service providers are strictly prohibited from using your Personal Data for any purpose other than to perform the contracted services. They are also not allowed to use your Personal Data for their own marketing purposes or share it for marketing purposes. For more information on the recipients of your Personal Data, please contact us at privacy@crewfare.com.

E. DATA RETENTION

We store the information we collect on you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory or other compliance obligations. We determine the appropriate retention period for Personal Data on the basis of the amount, nature, and sensitivity of the Personal Data being processed, the potential risk of harm from unauthorized use or disclosure, whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements. We retain your Personal Data only as long as necessary for the purposes for which it was collected, to resolve disputes, or as required by law. After the expiration of the applicable retention periods, your Personal Data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of such data. Reservation records, including rooming list data, are retained for the period necessary to fulfill and service the reservation, resolve disputes, and meet our legal, tax, and accounting obligations, and are thereafter deleted or de-identified. Payment card information is purged from our vault thirty (30) days following the later of guest checkout or the applicable event end date, or upon termination of the applicable customer agreement, whichever is earlier.

F. TRANSFER OF INFORMATION TO THE U.S.

We are based in the United States and process and store information in the United States. It is possible that non-U.S. residents may access and use the Services. If you are located outside the United States, we and our service providers may transfer your information to, or store or access your information in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. For transfers of Personal Data from the European Economic Area and the United Kingdom, we rely on the European Commission’s Standard Contractual Clauses, as set out in our Data Processing Addendum at https://crewfare.com/dpa, together with supplementary technical and organizational measures. Crewfare is not currently self-certified to the EU-US Data Privacy Framework. Where we disclose your Personal Data to an Accommodation Provider located outside the EEA or the United Kingdom in order to fulfill your reservation, that transfer is necessary for the performance of your reservation contract, or of a contract concluded in your interest between us and the organization that arranged your reservation. If we collect Personal Data from European Union or United Kingdom residents, we strive to do so in compliance with the GDPR and UK GDPR. Please see our full GDPR Statement at https://crewfare.com/gdpr, which also contains the details of our EU and UK Representatives appointed under Article 27.

G. YOUR RIGHTS RELATING TO YOUR PERSONAL DATA

1. YOUR RIGHTS

You may have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws these rights may include the right to:

• Access your Personal Data held by us;
• Know more about how we processed your Personal Data;
• Rectify inaccurate Personal Data and, taking into account the purpose of processing, ensure it is complete;
• Erase or delete your Personal Data, to the extent permitted by applicable data protection laws;
• Restrict our processing of your Personal Data, to the extent permitted by law;
• Transfer your Personal Data to another controller, to the extent possible (right to data portability);
• Object to any processing of your Personal Data. Where we process your Personal Data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time without having to provide any specific reason;
• Opt out of certain disclosures of your Personal Data to third parties;
• If you are under the age of 16, opt in to certain disclosures of your Personal Data to third parties;
• Not be discriminated against for exercising your rights described above;
• Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects (“Automated Decision-Making”). Automated Decision-Making that produces legal effects concerning you or similarly significantly affects you does not currently take place on our websites or in our services; and
• Withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal.

You have the right to opt out of marketing communications, control cookie settings, and make choices about how your data is used and shared. You may exercise your rights by contacting us at privacy@crewfare.com. We will respond to your request as soon as possible.

2. YOUR RIGHTS RELATING TO CUSTOMER DATA

You may update and correct certain information you provide to us by emailing us at privacy@crewfare.com. If you wish to delete information we have collected from you, please email us at privacy@crewfare.com, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for as long as necessary for our business purposes. As described above, we may also process Personal Data submitted by or for a customer to our cloud products and services. To this end, if not stated otherwise in this Privacy Policy or in a separate disclosure, we process such Personal Data as a processor on behalf of our customer (and its affiliates) who is the controller of the Personal Data. We are not responsible for and have no control over the privacy and data security practices of our customers, which may differ from those explained in this Privacy Policy. If your data has been submitted to us by or on behalf of a Crewfare® customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with them directly. Because we may only access a customer’s data upon their instructions, if you wish to make your request directly to us, please provide us the name of the Crewfare® customer who submitted your data to us. We will refer your request to that customer, and will support them as needed in responding to your request within a reasonable timeframe. Where your Personal Data was submitted to us by a customer or by a third party acting on that customer’s behalf — for example, by an event organizer, production company, or agency arranging accommodation on your behalf — and you contact us directly, we will refer your request to that customer and support them in responding within a reasonable timeframe. Where an Accommodation Provider has separately processed your data for its own purposes, you may also need to contact that provider directly.

3. HOW TO EXERCISE YOUR RIGHTS

To exercise your rights, please contact us at privacy@crewfare.com. Your Personal Data may be processed in responding to these rights. We try to respond to all legitimate requests within one month unless otherwise required by law, and will contact you if we need additional information from you in order to honor your request or verify your identity. Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive. If you are an employee of a Crewfare® customer, we recommend you contact your employer’s system administrator for assistance in correcting or updating your information. Some registered users may update their user settings, profiles, organization settings and event registrations by logging into their accounts and editing their settings or profiles. To update your billing information, or request return or deletion of your Personal Data and other information associated with your account, please contact us at privacy@crewfare.com.

H. YOUR CALIFORNIA PRIVACY RIGHTS

Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (“CCPA”), and Cal. Civil Code § 1798.83, California residents have certain rights to know what information we collect, how we use that information, and rights and choices concerning that information. This Section applies solely to visitors, users, and others who reside in the State of California.

1. INFORMATION WE COLLECT

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). We have collected the following categories (as listed in Cal. Civ. Code § 1798.140) of personal information from consumers within the last twelve (12) months: A. Identifiers (e.g., email addresses); B. Personal information categories in Cal. Civ. Code § 1798.80(e) (e.g., names, credit card information, addresses); D. Commercial information (e.g., records and consuming histories); F. Internet information (e.g., information regarding a consumer’s interaction with a website); G. Geolocation data; I. Professional or employment-related information; and K. Inferences drawn from other personal information. Personal information does not include publicly available information from government records, de-identified or aggregated consumer information, and information excluded from the CCPA’s scope. Please see Section C above for more information on how the information is used.

2. SHARING PERSONAL INFORMATION

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose to the following categories of third parties:

Category of personal information disclosed	Categories of third parties
A. Identifiers (name, email, phone, address)	Accommodation Providers; service providers (hosting, payment processing, payment card vaulting, customer support, email delivery, analytics); event partners (opt-in only); professional advisors
B. Cal. Civ. Code § 1798.80(e) information (name, payment card information, address)	Accommodation Providers; payment processors and payment card vault providers; service providers
D. Commercial information (reservation and booking records)	Accommodation Providers; the customer that submitted the reservation; service providers; event partners (opt-in only)
F. Internet activity information	Analytics and advertising service providers
G. Geolocation data	Analytics service providers
I. Professional or employment-related information	Service providers; the customer through which you access our services
K. Inferences	Analytics and marketing service providers

In the preceding twelve (12) months, we have not sold any personal information of anyone (including California residents) to any third parties. Even though we do not sell personal information, if you are a California resident, you may still submit a verified request to opt out of the sale and/or sharing of your personal information and we will record your instructions and incorporate them in the future if our policy changes. If you are a California resident and would like to opt out of the sale or sharing of your personal information, please contact us at privacy@crewfare.com. In connection with event-related bookings, we may disclose identifiers (e.g., name, email address, phone number) and commercial information (e.g., reservation details) to event partners for their marketing purposes, where you have opted in to receive marketing communications.

3. YOUR RIGHTS AND CHOICES

Right to Know. 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 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you: the categories of personal information we collected about you; the categories of sources; our business or commercial purpose for collecting that personal information; the categories of third parties with whom we share that personal information; and the specific pieces of personal information we collected about you. Deletion Request Rights. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain restrictions. We may deny your deletion request if retaining the information is necessary for us or our service providers to: detect security incidents or protect against malicious, deceptive, fraudulent, or illegal activity; debug products to identify and repair errors; comply with the California Electronic Communications Privacy Act; comply with a legal obligation; or make other internal and lawful uses of that information. Right to Correct. You have the right to request that we correct inaccurate personal information we maintain about you. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, and describe your request with sufficient detail. Response Timing and Format. We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the request’s receipt.

4. CALIFORNIA NOTICE OF FINANCIAL INCENTIVE

We may provide programs such as sweepstakes, contests, or other similar promotional campaigns (“Programs”). When you sign up for one of our Programs, we typically ask you to provide your name and contact information. Because our Programs involve the collection of personal information, they might be interpreted as a “financial incentive” program under California law. The value of your personal information to us is related to the value of the free or discounted products or services, or other benefits that you obtain as part of the applicable Program, less the expense related to offering those products, services, and benefits to Program participants. You may withdraw from participating in any of our Programs at any time by contacting us at privacy@crewfare.com.

5. ADDITIONAL INFORMATION

We will not discriminate against you for exercising any of your CCPA rights. We reserve the right to amend this section at our discretion and at any time. When we make changes to this privacy notice, we will notify you through a notice on our website homepage.

I. YOUR NEVADA PRIVACY RIGHTS

This Section applies solely to Nevada residents. Under Nevada law (NRS § 603A.300), Nevada residents can opt out of the sale of certain types of personal information. If you are a Nevada resident, you may submit a verified request to opt out of sales and we will record your instructions and incorporate them in the future. Opt-out requests may be sent to privacy@crewfare.com.

J. CHILDREN

Our website and Services are not directed at children and we do not knowingly collect personal information directly from children (including information concerning a child or that child’s parents or guardians, any screen or user name that functions as online contact information for a child, any photograph, video, or audio file containing a child’s image or voice) directly from users under the age of thirteen (13) or from other websites or services directed at children. Consistent with the Federal Children’s Online Privacy Protection Act (“COPPA”), we will not knowingly request or collect personal information from any child under the age of thirteen (13) in the United States without obtaining the required consent from the appropriate parent or guardian. Children may access and browse our website and Services without disclosing any personal information. If you have any concerns about your child’s access to our website and Services or how information that your child provides is used by us, please contact us at privacy@crewfare.com. California consumers: We will not sell or share the information of California consumers who are 16 years old or younger unless we have prior parental authorization. If a California consumer is under the age of 13, a parent or guardian must consent. If the California consumer is between the ages of 13 and 16 years old, the minor may consent on an opt-in basis. EU and UK residents: We do not collect or process personal information of data subjects in the EU or UK under the age of 16 without explicit consent from a parent or guardian.

K. GDPR STATEMENT AND SUBPROCESSORS

Our full GDPR Statement, including our EU and UK Article 27 Representatives, our lawful bases of processing, our international transfer mechanisms, and our current list of subprocessors, is available at https://crewfare.com/gdpr. We maintain that page as the canonical, dated list of subprocessors who process Personal Data on our behalf. We will notify customers in advance of any intended addition or replacement of a subprocessor, in accordance with our Data Processing Addendum at https://crewfare.com/dpa.

L. CONTACT US

If you have any questions or comments about our Privacy Policy, the ways in which we collect and use your Personal Data, your choices and rights regarding such use, or wish to exercise your rights regarding your Personal Data, or to submit a verifiable consumer request, please contact us by:

• Emailing us at privacy@crewfare.com;
• Calling us at 786-400-2739; or
• Writing to us at Crewfare, Inc., 2678 Edgewater Court, Weston, Florida 33332, USA.