TRU Privacy Policy

Effective date: August 17th, 2022

 Last updated: July 14, 2024

This Privacy Policy describes our policies and procedures on the collection, use and disclosure of Your information when You use the Services and Website and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions.

The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
• Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Aetheral, LLC.
• Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• Account means a unique account created for You to access our Service or parts of our Service.
• Website refers to Travel Reward University or Our Family Passport or Lets Travel Talk, accessible from https://travelrewarduniversity.com, ourfamilypassport.com, or letstraveltalk.com.  
• Service refers to the Website.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
• Personal Data is any information that relates to an identified or identifiable individual.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Notice 

We collect several types of information from and about users of our Website, including:

(a) Information by which you or your household may be personally identified, directly or indirectly, such as name, postal address, e-mail address, or telephone number;

(b) Personal Data that has been voluntarily made public by you;

(c) Personal Data that has either been de-identified or is aggregated in such a manner as to not be linked to you personally;

(d) Lawfully obtained truthful information that is of public concern;

(e) Information that is about you individually but does not identify you; and/or

(f) Information about your internet connection, the equipment you use to access our Website, and usage details.

We collect this information directly from you when you provide it to us, and automatically as you navigate through the Website.

Information You Provide To Us

The information we collect on or through our Website may include:

(a) Information that you provide to us directly, which may involve filling in forms on our Website, including:

1. Your name/alias
2. Your email
3. Your mailing or physical address
4. Your job title or employment information
5. Payment information

(b) Information when you report a problem with our Website.

(c) Records and copies of your correspondence (including email addresses) if you contact us.

(d) Information you provide us when entering into a contest, promotion, or sweepstakes sponsored by us.

(e) Information you provide us when completing a voluntary survey.

(f) Details of your transactions made through our Website, as well as details relating to the fulfillment of the transactions. This may include your financial information.

(g) The search queries that you make on our website’s integrated search feature.

(h) You also may provide information 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 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.

Our legal basis for collecting this data includes:

(a) By voluntarily providing us this information you have consented to our processing of your information;

(b) Processing is necessary for when we are required to process your personal data to comply with applicable laws and regulations, such as retaining records for tax purposes or providing information to a public authority.

We process your personal data based on our legitimate interests as a business. We carefully assess and balance our legitimate interests against your rights and freedoms to ensure that your privacy is protected.

Examples of processing activities based on our legitimate interests include:

(a) To present our Website and its contents to you.

(b) For marketing and/or promotional activities, such as, sending you marketing communications related to our products and services, provided that it does not conflict with your communication preferences.

(c) Conducting and fulfilling contests, sweepstakes, or promotions.

(d) Conducting and utilizing surveys completed by you.

(e) To provide or process information, products, or services that you request from us.

(f) To enforce our Terms and Conditions.

(g) Protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for such activities to ensure the safety of our customers’ information.

(h) For any other purpose that you consent to. If we cannot collect and use this information, our use of your data and information as described above will not be possible. We may not be able to provide our services to you, and you may not be able to access our Website.

Information We Collect Automatically

There is certain information that we will collect automatically as you navigate through and interact with our Website; this includes:

(a) Details of your visits to our Website, including:

1. Log data
2. Traffic data
3. Unique personal identifiers
4. The date and time of access, and
5. The resources that you access and use on our Website
6. Payment data

(b) Information about your computer, internet connection, or electronic network activity, including your geolocation data.

(c) Usage Data

(d) The technologies that we use to track and collect this data include:

Cookies

Cookies are small files of text delivered to your browser by a website you visit. They help that website identify your computer and remember information about your visit, making it easier to revisit the site and making the site more useful to you. There are other types of tracking technologies, such as pixels and beacons. Below is a description of how various cookies and other automatic tracking technologies may be used, a disclosure as to whether we use them, and your ability to control these technologies.

Essential Cookies

Essential cookies or strictly necessary cookies are cookies that are essential for a website to function correctly. These cookies are necessary to provide an online service on a website or used solely to carry out or facilitate the transmission of communications over a network.

We collect essential cookies that are strictly necessary for our Website to operate properly.

Analytics Cookies

Cookies and other technologies used for analytics help collect data that allows websites and services to understand how users interact with a particular website or service. This will enable companies to improve their services and content and build better features to enhance your experience. We collect analytics cookies on our Website. You can opt out of the use of third-party analytics cookies by following our opt-out procedures outlined in the “Your Rights” section of our Privacy Policy.

Advertising Cookies

Advertising cookies are used to (1) deliver advertisements more relevant to you and your interests; (2) limit the number of times you see an advertisement; (3) help measure the effectiveness of the advertising campaign; (4) retarget you to a Website, and (5) understand people’s behavior after they view an advertisement. They are usually placed on behalf of advertising networks with the site operator’s permission. They remember that you have visited a site, and often they will be linked to site functionality provided by the other organization. This may impact the content and messages you see on other websites you visit.

Managing Cookies

Most browsers allow you to manage how cookies are set and used as you are browsing and allow you to clear cookies and browsing data. Also, your browser may have settings letting you manage cookies on a site-by-site basis.

Business Justification

The information we collect automatically may include Personal Data. Our legal basis for collecting this data automatically is:

(a) To present our Website and its contents to you.

(b) For business intelligence and analytics, such as, analyzing aggregated and anonymized data to identify trends, measure performance, and inform business decisions.

(c) To provide or process information, products, or services that you request from us

(d) For any other purpose that you consent to.

If we are not able to collect and use this information, our use of your data and information as described above will not be possible. We may not be able to provide our complete services to you, and you may not be able to access our Website.

Third Parties

Any aggregated data or any information which does not identify any individual may be disclosed to third parties by us without any restrictions. We are not obligated to first receive consent before disclosing any such data or information. Any information that you have made public before we collect it may also be shared without restriction.

We may use your information and data for direct marketing. This may include using your information to contact you about our own or third parties’ goods or services that they or we think may be of interest to you. If you would like to unsubscribe from our email marketing, each email should contain an unsubscribe link allowing you to opt out of our direct marketing. If an email does not contain an unsubscribe link, follow the instructions provided in the “User Rights” section to opt-out. We will not disclose your personal information for advertising purposes without first getting your consent. You can opt out at any time by following the instructions provided in the “User Rights” section.

Third Party Tracking

Some cookies, web beacons and other tracking and storage technologies that we use are from third party companies (third party cookies) to provide us with web analytics and intelligence about our Website. These companies use programming code to collect information about your interaction with our Website, such as the pages you visit, the links you click on and how long you are on our Website. This code is only active while you are on our Website. For more information on how these companies collect and use the information on our behalf, please refer to the Google Analytics and Jetpack privacy policy. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions, you should contact the responsible provider directly.

Third-Party Disclosures

We may disclose Usage Data and Personal Data that we collect or that you provide as described in this privacy policy:

1. To our subsidiaries and Affiliates;

2. To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them;

3. 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 Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Company about our Website users is among the assets transferred;

4. For any other purpose disclosed by us when you provide the information;

5. For any purpose that you consent to;

6. To data analytics providers and email marketing vendors.

We may also disclose your Personal Data:

1. To comply with any court order, law, or legal process, including responding to any government or regulatory request.

2. For other agreements, including for billing and collection purposes.

3. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others.

Other:

We will only share your information or data if it is absolutely necessary to accomplish the purposes we collect it, which include, managing our interactions with you.

All of your data that we share with Service Providers, which is necessary for our Website’s business purpose, is disclosed in this Privacy Policy.

Our Service contains links to other sites over which we have no control, and we assume no responsibility for the content, privacy policies, or practices of other third-party sites to which you choose to visit from the links hosted on our Service, and such sites are not governed by this Privacy Policy. We encourage you to review the privacy policies of those other sites so you can understand how they collect, use, and share your Personal Data.

User Rights

Because you are the owner of your Personal Data, you are afforded certain choices concerning the information you provide to us and that we retain. We maintain the following options for you to control your information:

(a) Tracking Technologies and Advertising
We do not control third parties’ collection or use of your information or how it may be used. If you have any questions about a third party’s use or an advertisement or other targeted content, you should contact the responsible provider directly, as they may provide you with ways to choose not to have your information collected or used in this way. You may be able set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website may then be inaccessible or not function properly.

(b) Right to Know and Be Informed
You have the right to ask us about what kind of data we process, why it is necessary for us to collect, with whom we intend to share your information, your rights relating to your data, and the inferences we draw from your data. We designed this Privacy Policy to proactively answer all of those questions that you may have, but you have the option to contact us with any questions at [email protected] 

(c) Right to Access
You have the right to access your personal data that we process. This means that you may request your personal data file that we maintain, which may include the categories and sources of information and specific pieces of information we have collected from you. Upon your request, we will also share any information of yours that we have shared or sold, as well as the parties with whom we have shared your information. This allows you to become aware of the data that we are processing from you and describes our handling of such data so that you can verify the lawfulness of our data processing. We may require verification of your identity before we disclose any of the information that you may request from us.

(d) Right to Opt-Out
You have the right to opt-out of our selling or sharing of your Personal Data with third parties in your account preferences, or by making a request to [email protected]. Consumers who opt-in to Personal Data sales may opt-out of future sales at any time. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize the sharing or selling of Personal Data. However, you may change your mind and opt back in to Personal Data sharing or sales at any time. You can find all categories of third parties with whom we share Personal Data in this Privacy Policy. Please also review our Cookie Policy section to see how third parties interact with data on our Website. You may also be able to opt out of tracking by employing privacy-focused browsers, browser extensions, disabling JavaScript, using VPNs, adjusting cookie settings, and utilizing ad industry opt-out tools. However, no method guarantees a complete shield from tracking.

(e) Right to Deletion (Applies to US users only)
You have the right to request that we delete any of your Personal Data that we collect from you and retain, subject to certain exceptions. Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the Personal Data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3. Debug products to identify and repair errors that impair existing intended functionality.

4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us or that are compatible with the context that you provided it.

6. Comply with a legal obligation. We will delete or de-identify Personal Data not subject to one of these exceptions from our records and will direct our service providers to take similar action.

(f) Right to No Discrimination
We will not discriminate against you if you exercise any of your rights. However, we may charge different prices or provide different levels of services to you if the difference is reasonably related to the value provided to us by your data. Further, we retain the right to provide financial incentives for the ability to collect, sell, share, or retain Personal Data (if consented to).

(g) Right to Correct Inaccurate Data (Rectification)
You have the right to direct us to change or modify the data we have collected from you if you believe that the data is inaccurate or out-of-date. You can modify your information at any time in your User Account. If necessary, you may direct us to modify your information in writing.

(h) Right to Data Portability
You have the right to move, copy, or transfer your personal data in our possession to another controller if we are processing your data after receiving your consent or if the processing is being carried out by automated means. We will deliver your data in a structured, commonly used, and machine-readable format.

(i) Do Not Track Disclosures
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

(j) Direct Marketing
To opt-out of direct marketing, please uncheck the relevant box located on the form on which we collect your data. This could be the Website or service registration form or an order form (if applicable). You may also adjust your user preferences in your account profile or contact us directly.

(k) Children Under the Age of 13
Our Website is not intended for children under 13 years of age. No one under the age of 13 may provide any information to or on the Website. We do not knowingly collect Personal Data from children under 13. If you are under 13, do not use or provide any information on this Website or Service 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 Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at: [email protected].

(l) Exercising your Rights
To exercise any of the rights provided in this Privacy Policy or to withdraw your consent to any of our collection or processing of your Personal Data, please submit a request to:welcome@travelrewarduniversity.com.  Only you, or someone legally authorized to act on your behalf, may make a request to exercise your rights. You may only request to exercise your rights twice in one 12-month period.

Your request must:

1. Provide sufficient information to allow us to reasonably verify that you are the person about whom we collected Personal Data or an authorized representative.

2. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

3. We may ask that you provide us with further information that may help us verify your identity. We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm that the Personal Data relates to you. We will only use the Personal Data provided in the request to verify the requestor’s identity or authority to make it. At a minimum, your name and email address will be needed in your request. You do not need to create an account with us to submit a request.

United States Users: We will confirm receipt of your request within 10 days of receiving it. We will then work to deliver you the requested information within 45 days of receiving the request.

Security

(a) How We Are Protecting Your Data
We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers.

The safety and security of your information also depends on you. We urge you to be careful about giving out information in any public areas of our Website. The information you share in public areas may be viewed by any user of our Website. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on our Website.

(b) Location of Data Processing
All data processing activities occur in The United States of America.

(c) Length of Retention and When Destroyed
We will only retain your information for as long as it is necessary for the purposes that it was processed. We may decide to keep your data in perpetuity if it can no longer identify you individually.

Redress

(a) Changes to Our Privacy Policy
It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ Personal Data, we will notify you through a notice on the Website home page.

The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.

(b) How To Enforce Our Policy
To ask questions or comment about this privacy policy and our privacy practices, or to exercise any of your rights described herein, contact us at:welcome@travelrewarduniversity.com