Introduction
Sogno Tours LLC d/b/a VacationVIP.com, its affiliates and
subsidiaries ("Company," "We," “Us,” and “Our”)
respects your privacy and are committed to protecting it through
our compliance with this policy. This policy describes the types
of information we may collect from you or that you may provide
when you visit the website (our "Website") or
social media sites we control and our practices for collecting,
using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
- On or through this Website.
-
Over the phone, email, text, and other electronic messages
between you and Us.
-
Through mobile and desktop applications you download from this
Website, which provide dedicated non-browser-based interaction
between you and this Website.
-
When you interact with our advertising and applications on
third-party websites and services, if those applications or
advertising include links to this Website.
INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
Please read this policy carefully to understand our policies and
practices regarding your information and how we will treat it.
If you do not agree with our policies and practices, your choice
is to not use our Website. By accessing or using this Website,
you agree to this privacy policy. This policy may change from
time to time (see Changes to Our Privacy Policy). Your continued
use of this Website after we make changes is deemed to be
acceptance of those changes, so please check the policy
periodically for updates.
We collect several types of information from and about users
of our Website, including the following categories of
information:
-
Purchasing Information. This is information
that we may collect about your transactions in our stores, on
our websites or via our mobile applications including what
products you purchase, how frequently you purchase them, any
rewards or promotions associated with a purchase.
-
Personal Information. This is information by
which you may be personally identified, through your account
with us or otherwise, such as name, postal address, e-mail
address, telephone number, address, or any other identifier by
which you may be contacted online or offline (“Personal
Data”). The collection of such personal information is
necessary for Us to provide you with our services.
-
Device and Usage Information. This is
information about your internet connection (ISP), IP address,
device and mobile ad identifiers, the website that referred
you to our website, the subject of the ads you click or scroll
over, Cookies, Analytics, the equipment you use to access our
Website and usage details. To collect this information, we use
automatic data collection cookies, web beacons and similar
technologies.
-
Location information. This is information
about the location of your device, including GPS location, for
purposes of enhancing or facilitating our services, such as
enabling the functionality of our websites or mobile
applications that provide you with information about offers
near you, enabling you to remotely order and pay for our
products and services, or have certain products delivered by a
third-party vendor. If you want to opt out of the collection
of this location information, please see the section below
titled Choices on How We Use and Disclose Your Information or
by contacting us as detailed under Contact Information.
-
Public information. Some information we
gather is publicly available. We may also gather information
about you from third-parties and other companies.
We collect this information:
- Directly from you when you provide it to us.
-
Some information such as your internet connection and
equipment you use to access our Website and usage details is
automatically collected as you navigate through the site.
Information collected automatically may include usage details,
IP addresses, location and information collected through
cookies and other tracking technologies.
-
We use third party analytics providers and products, such as
Google Analytics, to obtain, compile and analyze information
about how users are using and interacting with the Website. In
order to collect this information, such providers may set
cookies on your browser or mobile device or read cookies that
are already there. Google Analytics may also receive
information about you from apps you have downloaded, that
partner with Google. We do not combine the information
collected through the use of Google Analytics with personally
identifiable information. You can control the information
provided to Google and opt out of certain ads provided by
Google by using one of the of the methods set forth in
>https://www.google.com/policies/privacy/partners/
-
From third parties, for example, our business partners,
affiliates and agents.
Information You Provide to Us. The information
we collect on or through our Website may include:
-
Certain general data and Personal Data (“Personal Data”) that
identifies our customers, that you provide or give us in
another way. This may include your first and last name, postal
address, telephone number, email address, date of birth,
citizenship, and passport details, and if you make a purchase,
your credit/debit card details in order to make a payment and
confirm the purchase.
-
Information that you provide by filling in forms on our
Website. This includes information provided at the time of
registering to use our Website, subscribing to our service,
posting material, or requesting further services. We may also
ask you for information when you enter a contest or promotion
sponsored by us, and when you report a problem with our
Website.
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Records and copies of your correspondence including email
addresses, if you contact us.
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Your responses to surveys that we might ask you to complete
for research purposes.
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Details of transactions you carry out through our Website and
of the fulfillment of your travel and purchases. You may be
required to provide financial information including credit or
debit card information before placing an order through our
Website.
-
Your search queries or preferences through use of the Website,
including the election to share location information with us
and our website applications.
You also may provide information, or comments, or photographs to
be published or displayed (hereinafter,
"posted") on public areas of the Website or
transmitted to other users of the Website or third parties
(collectively, "User Contributions"). Your User
Contributions are posted on and transmitted to others at your
own risk. Although we limit access to certain pages/you may set
certain privacy settings for such information by logging into
your account profile, please be aware that no security measures
are perfect or impenetrable. Additionally, we cannot control the
actions of other users of the Website with whom you may choose
to share your User Contributions. Therefore, we cannot and do
not guarantee that your User Contributions will not be viewed by
unauthorized persons.
Information We Collect Through Automatic Data Collection
Technologies.
As you navigate through and interact with our Website, we may
use automatic data collection technologies to collect certain
information about your equipment, browsing actions, and
patterns, including:
-
Details of your visits to our Website, including traffic data,
logs, and other communication data and the resources that you
access and use on the Website.
-
Information about your computer and internet connection,
including your IP address, operating system, and browser type.
The information we collect automatically is statistical data and
does not include personal information, but we may maintain it or
associate it with personal information we collect in other ways
or receive from third parties. It helps us to improve our
Website and to deliver a better and more personalized service,
including by enabling us to:
- Estimate our audience size and usage patterns.
-
Store information about your preferences, allowing us to
customize our Website according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Website.
The technologies we use for this automatic data collection may
include:
-
Cookies (or browser cookies). A cookie is a
small file placed on the hard drive of your computer. You may
refuse to accept browser cookies by activating the appropriate
setting on your browser. However, if you select this setting
you may be unable to access certain parts of our Website.
Unless you have adjusted your browser setting so that it will
refuse cookies, our system will issue cookies when you direct
your browser to our Website.
-
Flash Cookies. Certain features of our
Website may use local stored objects (or Flash cookies) to
collect and store information about your preferences and
navigation to, from, and on our Website. Flash cookies are not
managed by the same browser settings as are used for browser
cookies. Information on how to disable or remove flash cookies
can be found below under the section titled Choices on How We
Use and Disclose Your Information.
-
Web Beacons. Pages of the Website and our
e-mails may contain small electronic files known as web
beacons (also referred to as clear gifs, pixel tags, and
single-pixel gifs) that permit the Company, for example, to
count users who have visited those pages or opened an email
and for other related website statistics (for example,
recording the popularity of certain website content and
verifying system and server integrity).
-
Java Scripts. Java scripts are code snippets
embedded in various parts of websites and applications that
facilitate a variety of operations including accelerating the
refresh speed of certain functionality or monitoring usage of
various online components.
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Entity Tags. Entity Tags are HTTP code
mechanisms that allow portions of websites to be stored or
“cached" within your browser and validates these caches when
the website is opened, accelerating website performance since
the web server does not need to send a full response if the
content has not changed.
-
HTML5 Local Storage. HTML5 local storage
allows data from websites to be stored or “cached" within your
browser to store and retrieve data in HTML5 pages when the
website is revisited.
We do not collect personal information automatically through the
above technologies, but we may tie this information gathered to
personal information about you that we collect from other
sources or you provide to us.
THIRD PARTY COOKIES AND OTHER TRACKING TECHNOLOGIES
Some content or applications, including advertisements, on the
Website are served by third-parties, including advertisers, ad
networks and servers, content providers, and application
providers. These third parties may use cookies alone or in
conjunction with web beacons or other tracking technologies to
collect information about you when you use our website. The
information they collect may be associated with your personal
information or they may collect information, including personal
information, about your online activities over time and across
different websites and other online services. They may use this
information to provide you with interest-based (behavioral)
advertising or other targeted content.
We do not control these third parties' tracking technologies or
how they may be used. If you have any questions about an
advertisement or other targeted content, you should contact the
responsible provider directly.
HOW WE USE YOUR INFORMATION AND LEGAL BASES FOR PROCESSING
We only process your information where it is necessary for:
-
Our legitimate interests to establish and manage our
relationship with you, for administrative purposes, and other
legitimate business interests such as credit assessment,
marketing, presenting and improving our website;
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Fulfilling our contractual obligations towards you (e.g.,
sending confirmations, invoices, and travel documentation to
you), our affiliated or related entities, associates,
partners, and the customers of such affiliated or related
entities, associates and partners; and
-
Compliance with applicable laws and regulations and our legal
obligations, such as accounting and tax requirements.
There may be occasions where we request your consent to process
your personal data. Where applicable, you may withdraw consent
subsequently at any time by contacting us as detailed under
Contact Information, below, without affecting
the lawfulness of processing based on consent before its
withdrawal. For example, we may use your information to contact
you about our own and third-parties' goods and services that may
be of interest to you. We may use the information we have
collected from you to enable us to display advertisements to our
advertisers' target audiences. Even though we do not disclose
your personal information for these purposes without your
consent, if you click on or otherwise interact with an
advertisement, the advertiser may assume that you meet its
target criteria. Information on how to opt-out of interest-based
advertising can be found under the section titled Choices on How
We Use and Disclose Your Information or by contacting us as
detailed under Contact Information.
DISCLOSURE OF YOUR INFORMATION
We may disclose aggregated information about our users, and
information that does not identify any individual, without
restriction. We may disclose personal information that we
collect or you provide as described above (How We Use Your
Information and Legal bases for Processing) to the following:
- To our subsidiaries and affiliates.
-
To contractors, service providers, and other third parties we
use to support our business and who are bound by contractual
obligations to keep personal information confidential and use
it only for the purposes for which we disclose it to them.
-
To a buyer or other successor in the event of a merger,
divestiture, restructuring, reorganization, dissolution, or
other sale or transfer of some or all of VVIP's stock or
assets, whether as a going concern or as part of bankruptcy,
liquidation, or similar proceeding, in which personal
information held by VVIP about our Website users is among the
assets transferred.
-
To third parties, including but not limited to suppliers,
third-party vendors, business partners, and corporate
affiliates for the same legitimate purposes as detailed above.
-
To fulfill the purpose for which you provide it. For example,
if you give us an email address to use the "email a friend"
feature of our Website, we will transmit the contents of that
email and your email address to the recipients.
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For any other purpose disclosed by us when you provide the
information, with your consent, as applicable.
-
To comply with any court order, law, or legal process,
including to respond to any government or regulatory request.
When the disclosure of such personal information is required
to be made to a governmental or regulatory agency, we will
ensure that such personal information will only be shared with
the relevant governmental or regulatory agency and not
released to the general public. However, you will hold Us
harmless if the personal information is disclosed by the
governmental or regulatory agency to any third party or the
public.
-
To enforce or apply our terms of use of or terms and
conditions posted on the Website and other agreements,
including for billing and collection purposes.
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If we believe disclosure is necessary or appropriate to
protect the rights, property, or safety of VVIP, our
customers, or others. This includes exchanging information
with other companies and organizations for the purposes of
fraud protection and credit risk reduction.
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the personal
information you provide to us. Below are some of the mechanisms
available to change control over your information automatically
provided when visiting the Website:
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Tracking Technologies and Advertising. You
can set your browser to refuse all or some browser cookies, or
to alert you when cookies are being sent. To learn how you can
manage your Flash cookie settings, visit the Flash player
settings page on Adobe's website. If you disable or refuse
cookies, please note that some parts of this site may then be
inaccessible or not function properly.
-
Google Analytics. You can control the
information provided to Google and opt out of certain ads
provided by Google by using one the of the methods set forth
in >https://www.google.com/policies/privacy/partners/ or use
the Google Analytics opt out browser add-on at
https://tools.google.com/dlpage/gaoptout?hl=en.
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Cookies; Web Beacons; Entity Tags; and HTML5 Local Storage;
and other similar technologies.
Persistent cookies can be removed by following your web
browser’s directions. A session cookie is temporary and
disappears after you close your browser. You can reset your
web browser to refuse all cookies or to indicate when a cookie
is being sent. However, some features of the Site may not
function properly if the ability to accept cookies is
disabled. Turning off the browser's cookies will prevent web
beacons from tracking your specific activity. The web beacon
may still record an anonymous visit from your IP address, but
unique information will not be recorded. If you do not want to
receive tracking pixels, you will need to disable HTML images
in your email client, and that may affect your ability to view
images in other emails that you receive. Each browser is
different, but many common browsers (Internet Explorer,
Chrome, Firefox, and Safari) have preferences or options that
may be adjusted to allow you to either accept or reject
cookies and certain other technologies before they are set or
installed or allow you to remove or reject the use or
installation of certain technologies altogether. To find out
how to see what cookies have been set and how to reject and
delete the cookies, please visit:
https://www.aboutcookies.org.
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Opting out of sharing location information.
You may be able to adjust the settings of your device so that
information about your physical location is not sent to us or
third parties by (a) disabling location services within the
device settings; or (b) denying certain websites or mobile
applications permission to access location information by
changing the relevant preferences and permissions in your
mobile device or browser settings. Please note that your
location may be derived from your WiFi, Bluetooth, and other
device settings. See your device settings for more information
We do not control third parties' collection or use of your
information to serve interest-based advertising. However, these
third parties may provide you with ways to choose not to have
your information collected or used in this way. You can opt out
of receiving targeted ads from members of the Digital
Advertising Alliance or the Network Advertising Initiative
("NAI") on the NAI's website or by visiting www.AboutAds.info.
INFORMATION SENT ABROAD
VVIP is a global organization and provides global services. In
certain circumstances, sharing data cross-border is essential to
the services you receive from Us.
I. Special Requirements under EU Data Protection Laws
(GDPR):
In order to complete your booking, complete analysis, or for
other legitimate purposes we transfer, process and store
information about you outside of the EEA on servers located in
the United States by Sogno Tours LLC d/b/a VacationVIP.com and
its affiliates located at 5900 Lake Ellenor Drive Suite 300,
Orlando, FL 32809. Therefore, your information may be
transferred to, stored, or processed in the United States. We
will ensure that in terms of Data Security Standards of our
systems in the US will have the same level of data protection
that is adhered to by Us. If we transfer your Personal Data to
agencies or third parties outside the EEA, we require similar,
binding EU Standard Contractual Clauses, and we monitor
compliance with such. Our affiliated or related entities,
associates and partners have also agreed to adopt equivalent
measures. Copies of these measures can be obtained by contacting
Us as detailed under Contact Information below. You may lodge a
complaint with the UK Information Commissioner’s Office if you
consider that our processing of your Personal Data infringes
applicable law.
II. Special Requirements under Mexican Data Protection
Laws
In accordance with the requirements of the Mexican Federal Law
on the Protection of Personal Data Held by Private Parties ( Ley
Federal de Protección de Datos Personales en Posesión de los
Particulares ) (the “Mexican DP Law”), We inform our users and
subscribers located in Mexico of Our compliance with this Law.
Under Mexican DP Law, we do not need to obtain your consent for
the processing of your personal data for the purposes that give
rise and are necessary for the fulfillment of our relationship
(e.g. personal information required in order for you to
subscribe to our vacation programs). In case you do not agree
with the processing of your personal information for such
purposes and as described in this policy, please abstain from
acquiring or using our services.
Our Website users and subscribers located in Mexico should note
that:
-
The personal data provided by you to Us through email, fax,
websites, online services, enrollment or subscription forms
and agreements, telephone calls or any other means, is
processed by Us for the purposes set forth in section How We
Use Your Information; in the understanding that, in order to
comply with the Mexican DP Law, below we have set forth those
purposes that are not required to fulfill the relationship
between us, commonly known as “additional or secondary
purposes”:
-
To provide you with updates about discounted availability,
special offers, new services and products which may be of
interest to you and other noteworthy news items.
- Send advertisements, promotions and brochures.
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To contact you about our and third parties’ goods and services
that may be of interest to you.
- To ask for ratings and reviews of services or products.
-
Should you not wish that your personal information be used for
the purposes listed immediately above, please send an email to
[email protected] with subject line “Request for
Restriction on the use of My Personal Information for
Secondary Purposes / Mexico”.
-
That this privacy policy applies to all your personal
information that We may have access to, including: name,
nationality, birthdate and birthplace, age, address, telephone
number, cell phone number, email, tax identification number,
handwritten signature, as well as personal information that
may be considered sensitive and related to recorded video or
photographs, health condition, economic and financial data,
including your bank account information and information of
your credit or debit cards, as well as other personal data
listed in the section Information We Collect About You and How
We Collect It.
-
As described above (see Information We Collect Through
Automatic Data Collection Technologies), We also collect
information using various technologies, such as cookies and
web beacons.
-
That your personal information will be solely treated in
accordance with the terms and conditions of this privacy
policy.
-
In order for you to: (i) exercise your rights to Access,
Rectify, Cancel, and Object to the use of your personal
information (known as “ARCO Rights”), and (ii) to limit the
use and disclosure or to revoke your consent to the use of
your personal information for the secondary purposes described
above, please send an email to [email protected] with
subject line “Exercise of ARCO Rights / Mexico”. The request
should include, as minimum:
-
Copy of your official ID and/or of your legal representative.
Such documents should be scanned and attached to the
corresponding email communication. For legal representative,
please also attach a copy of his/her power-of-attorney.
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Clear and precise description of the personal information
about which the ARCO Rights are to be exercised, as well as
the right or rights you wish to exercise. This description
could be included in the email cover letter or in a document
attached thereto, scanned and initialized in each of its
pages.
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Expressly state your agreement to receive our response through
an email communication, specifying the corresponding email
address.
-
Any other data that allows US to locate your personal data.
We will issue a response within the following 20 business days
after we receive your request. Once you receive our response,
you will have a 15 business day period to respond to our
communication. In case you do not reply to our response within
the mentioned period, we will understand in good faith that you
agree with our response. We may refuse the exercise of your ARCO
Rights in the cases permitted by applicable law, and shall
inform you about such decision. The refusal may be partial, in
which case We will carry out the access, rectification,
cancellation or objection in the corresponding part.
As mentioned below, you can also review and change your personal
information by logging into the Website and visiting your
account profile page.
See the section Disclosure of Your Information for information
regarding the manner in which we share your personal information
with third parties and data-processors. Please note that we
require your consent to transfer your personal data to third
parties to market their own products or services to you.
Should you not wish that your personal data be transferred to
third parties for their own marketing purposes please send an
email to [email protected] line “Request for Restriction on
the Transfer of Personal Data to Third Parties for their Own
Marketing Purposes / Mexico”.
This privacy policy may be modified as described in the section
“Changes to the Privacy Policy” set forth below.
YOUR RIGHTS TO ACCESSING AND CORRECTING YOUR INFORMATION
You can review and change your personal information by logging
into the Website and visiting your account profile page. You
have the right to ask VVIP not to process your Personal Data for
marketing purposes. You also have the right to access Personal
Data about you by VVIP and to correct inaccurate Personal Data.
Please ensure that we have an up-to-date active and deliverable
email address for you. In accordance with applicable law, you
may also have the right to object to or request restriction of
the processing of your Personal Data and to request erasure and
to port Personal Data about you.
Should you wish to exercise your rights, or to unsubscribe
please contact [email protected] or Attn: Privacy Policy
Manager, Sogno Tours LLC d/b/a VacationVIP.com at 5900 Lake
Ellenor Drive Suite 300, Orlando, FL 32809 or via our toll-free
number: 800-266-0602.
Access to your Personal Data will be granted in accordance with
the requirements of applicable national legislation. The
information will be forwarded to you within an appropriate
period of time in accordance with applicable law, and where any
discrepancies are discovered following your enquiry, we will
take immediate steps to validate and, where appropriate, correct
our records.
RETENTION OF DATA
We will retain your personal information during the term of the
provision of the services availed by You only for so long as
reasonably necessary for the purposes set out herein, in
accordance with applicable laws.
MARKETING CONSENT
Upon contacting Sogno Tours LLC d/b/a VacationVIP.com. (VVIP)
and providing PII such as your full name, e-mail address, and/or
contact number, You expressly authorize and consent to receive
autodialed and/or pre-recorded telemarketing calls, as well text
messages and emails, from or on behalf of Sogno Tours LLC d/b/a
VacationVIP.com at the telephone number(s) provided. You hereby
understand that your permission overrides your listing on any
state, federal or company do not call list. You also understand
that your consent is not a condition of purchasing any good or
service. You agree to waive your rights under TCPA. You agree to
receive communication via SMS, email and telephone on an ongoing
basis and understand that you can opt-out of these
communications at any time. You understand that this means both
marketing and informational communication. You understand that
message and data rates may apply to any communication via SMS.
CHILDREN UNDER THE AGE OF 16
Our Website is not intended for children under 16 years of age.
No one under age 16 may provide any personal information to
Company or on the Website. We do not knowingly collect personal
information from children under 16. If you are under 16, do not
use or provide any information on this Website or on or through
any of its features/register on the Website, make any purchases
through the Website, use any of the interactive or public
comment features of this Website or provide any information
about yourself to us, including your name, address, telephone
number, email address, or any screen name or user name you may
use. If we learn we have collected or received personal
information from a child under 16 without verification of
parental consent, we will delete that information. If you
believe we might have any information from or about a child
under 16, please contact us as detailed under Contact
Information, below.
DATA SECURITY AND RETENTION
We have implemented measures designed to secure your personal
information from accidental loss and from unauthorized access,
use, alteration, and disclosure. All information you provide to
us is stored on our secure servers behind firewalls. Any payment
transactions provided therewith will be encrypted.
The safety and security of your information also depends on you.
Where we have given you (or where you have chosen) a password
for access to certain parts of our Website, you are responsible
for keeping this password confidential. We ask you not to share
your password with anyone. We urge you to be careful about
giving out information in public areas of the Website like
message boards. The information you share in public areas may be
viewed by any user of the Website.
Unfortunately, the transmission of information via the internet
is not completely secure. Although we do our best to protect
your personal information, we cannot guarantee the security of
your personal information transmitted to our Website. Any
transmission of personal information is at your own risk. We are
not responsible for circumvention of any privacy settings or
security measures contained on the Website.
Your Personal Data will be retained only for so long as
reasonably necessary for the purposes set out above, in
accordance with applicable laws.
YOUR CALIFORNIA PRIVACY RIGHTS
California Civil Code Section § 1798.83 permits users of our
Website that are California residents to request certain
information regarding our disclosure of personal information to
third parties for their direct marketing purposes. To make such
a request, please contact us as detailed under Contact
Information.
https://www.vacationvip.com/privacy-policy-ca to see your rights
as a resident of California under the California Consumer
Privacy act (CCPA).
YOUR NEVADA PRIVACY RIGHTS
Notice to Nevada Residents: If you are a
resident of Nevada, under certain circumstances, Nevada Civil
Code Section NRS 603A.340 allows you to request operators of
websites not to sell your Personal Information. To make such a
request, please send an email to our Privacy Policy Manger at
[email protected] or send a letter to:
Vacation VIP, LLC
5900 Lake Ellenor Drive Suite 300,
Orlando, FL 32809
Attn: Privacy Policy Manager
CHANGES TO OUR PRIVACY POLICY
It is our policy to post any changes we make to our privacy
policy on this page with a pop-up notice that indicates the
privacy policy has been updated on the Website home page. The
date the privacy policy was last revised is identified at the
top of the page. Please visit our Website and this privacy
policy periodically to check for any changes.
CONTACT INFORMATION
To ask questions or comment about this privacy policy and our
privacy practices, or request that we remove or opt-out any
information gathered about you, that we actually control, please
email or write to us at: [email protected] or Attn: Privacy
Policy Manager, Sogno Tours LLC d/b/a VacationVIP.com 5900 Lake
Ellenor Drive Suite 300, Orlando, FL 32809 or via our toll-free
number: 800-266-0602. The Privacy Policy Manager would also act
as a designated grievance officer and shall address any
discrepancies and grievances that you may have with respect to
this Privacy Policy.
Effective as of: 4/20/2020
