PRIVACY STATEMENT

Effective June 8, 2020

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This Privacy Statement applies to the websites and services (collectively, the “Services”) provided by Coho.Res, LLC. and its affiliates (“Coho”) to you, unless there is a separately posted privacy statement or description for such Services.

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This Privacy Statement explains generally how we receive personal information about you, and what we do with that personal information once we have it. This Privacy Statement does not apply to information which does not permit identification of an individual. This Privacy Statement applies regardless of the type of device you use to access our Services. You may choose not to provide certain information to us but doing so may restrict your ability to use our Services.

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How do you learn information about me?

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We learn information about you when you or other businesses interact with us and use our services, including when:

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• you give it to us directly (e.g., when you choose to contact us, or make a request for information);

• we collect it automatically through our products and Services (e.g., through your use of the Services); or

• someone else provides us information about you (e.g., when our client or a third party (such as an employer, travel agency, global distribution system, travel supplier, etc.) provides us your information in order for us to perform Services for them.

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What do you do with the information you gather?

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Generally, we use your information to help us operate our business, and to provide and improve our products and Services for you and our clients with which you have a business or employment relationship. Sometimes we try to understand more about you based on information you’ve given to us (e.g., when we use your IP address, browser navigator language, or other techniques to customize languages for some of our Services). When permitted by law or elected by you, we may also use the information to provide you information on additional or new Services and features offered by Coho or its strategic partners, or important information regarding Coho.

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If you have provided information to our client or a third party who shares your information with us or instructs us to collect or process your information, their privacy statement may also apply. You may also have access to other sites through the Coho websites. These sites may have different privacy practices, and you should read any privacy notices provided on those sites.

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Whose information may be processed in connection with the Services?

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In connection with the Services, we process information about different types of individuals. As discussed further below, the information that we process about an individual may depend on how he or she interacts with the Services. These different types of individuals include:

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Travelers and Those Acting on Their Behalf. Individual consumers and business travelers (“Travelers”) who make reservations, or use other travel-related products or services offered by Coho Subscribers or Travel Suppliers using the Services. Subscribers and Travel Suppliers may collect and send Coho information about Travelers. Subscribers and Travel Suppliers may have collected such information directly from the Traveler, or from another individual who acts on the Traveler’s behalf. Coho also may receive information about assistants, or other representatives who book travel-related products or services on behalf of other individuals.

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Subscriber and Travel Supplier Staff.  Coho may collect information about employees and other individuals associated with Coho Subscribers and Travel Suppliers.  “Subscribers” are travel agents, individuals at travel management companies, corporate travel departments, online travel websites, hoteliers, and others who subscribe to our Services to search, price, book, and manage travel services provided by a variety of participating travel suppliers, such as hotels, tour operators, and others (“Travel Suppliers”). For example, if a certain travel agency subscribes to our Services, Coho might process information about individual travel agents at that agency to help agencies evaluate efficiency.

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Other individuals who use our Services or contact us, and certain other individuals (such as sales leads).

 

When do you share my information with others?

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• When we have asked and received your permission to share it.

• When we’re required to provide it to our client or a third party from whom we received your information, or with whom you have a business or employment relationship. (One such example is when we receive your information from a travel agent with whom you do business, and we provide your information on their behalf to a Travel Supplier, such as a hotel.)

• For processing or providing products and Services to Coho or to you.

• When we provide information to our business partners to enhance the products and Services we offer.

• We may use and share the information we gather to comply with law (including cooperation with regulators or officials), legal process or legal advice.

• We may share your information when permitted by law if we believe it is reasonably necessary to protect the rights, property or safety of you, our other users, Coho or the public.

• If our organizational structure or status changes (e.g., if we undergo a restructuring, are acquired, or go bankrupt), we may transfer your information to a successor or affiliate.

• We may share information we gather to third parties that our clients have a relationship with such as loyalty providers, hotel property management systems, and other designated businesses that are affiliated with our client, in order to provide Services.

• We may share information we gather to otherwise operate our business, including to provide travel marketplace and travel management services. For example, information we gather may be shared with travel agents, travel management companies, corporate travel departments, online travel websites, and others, and with Travel Suppliers, such as airlines, hotels, cruise lines, car rental companies, rail providers, tour operators, and others.

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How do you store and protect information about me?

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We implement physical, administrative and technical security measures designed to protect your personal information. Coho is not responsible for unauthorized access to such information by hackers or others that obtain access through illegal measures.

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The safety and security of your information also depends on you.  Any content, including information, that you contribute to be shared, published, or displayed on the Services, or transmitted to other users of the Services, either via the Services or via social networking or other third party sites available through the Services, is visible to other users and can be read, collected, or used by them.  We urge you to be careful about giving out information in public areas of the Services.  You understand and acknowledge that, even after removal, copies of your content, including information, that you contribute to be shared, published, or displayed on the Services, or transmitted to other users of the Service, may remain viewable in cached and archived pages, or might have been copied or stored by other users.

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How do you use cookies and similar website technology?

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Coho uses cookies or other similar tracking technologies to provide you with better Services. We may collect information about your activities on our Services through the use of cookies, clear GIFs or web beacons, local shared objects or Flash cookies, or through other similar identifiers and technologies (“Cookies”). Cookies are pieces of information a website transfers to your computer’s hard disk for record-keeping purposes. We use both session and persistent Cookies. Cookies can either be persistent (i.e., they remain on your computer or device until you delete them) or temporary (i.e., they last only until you close your browser). We use first-party and third-party Cookies. First-party Cookies are used and controlled by us. Third-party Cookies are controlled by third parties, mostly for the purpose of analytics.

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Cookies can make the Web more useful by storing information about your preferences for a particular site. The use of Cookies is an industry standard, and many major websites use them to provide useful features for their customers. By using our websites, you consent to our use of Cookies and our processing of information collected through such Cookies, in accordance with this Privacy Statement. You can withdraw your consent at any time by deleting placed Cookies and disabling Cookies in your browser (consult your browser ‘help’ files or visit www.aboutcookies.org or www.allaboutcookies.org to learn more about Cookies and their management). However, if you refuse to accept Cookies, you may not be able to take full advantage of the functionality of the websites or Services. We currently do not respond to “do not track” browser headers with respect to the Services.

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You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality. By using our Services you consent to the cookies you permit.

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Besides Cookies, we may use other technologies, such as web logs, scripts, or other applications that recognize your computer and gather information, such as your internet protocol address and type of browser, the type of operating system you are using, the domain name of your Internet service provider, the web pages you have visited, and the type of mobile device and provider used to utilize the Service. We may use this information to manage our websites and online services, including to provide you appropriate and better service. We and others may collect personal information about your online activities over time and across different Web sites.

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What if you change this Privacy Statement?

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We may need to change this Statement and our notices. The updates will be posted online. If the changes are material to the way we process your personal information, we will announce the update through Coho’s websites by including a “NEWLY UPDATED” label with the Privacy Statement link on our websites for 30 days after material changes are made. Your continued use of the Services after the effective date of such changes constitutes your acceptance of such changes. To make your review more convenient, we will post an effective date at the top of the page containing the Privacy Statement.

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How may I control information about me?

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You may access and control the information provided to us in a number of ways.

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If you maintain an account with us directly, you may update certain information provided to us in your online account (such as contact details) by logging in to your account and editing that information. To the extent that an employer, travel agency or other entity maintains or manages information on your behalf in an online account with us, you may not be able to update such information yourself but may be able to request that such entity do so for you.

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You may accept Cookies or change your Cookies settings by activating the appropriate settings on your browser. Check your browser help to find out how to adjust these settings. Please note that certain features of the Service may not be available once cookies are disabled.

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If you have another request regarding your personal information, or if you have any questions or comments about this privacy statement and our privacy practices, please direct such inquiries or requests to support@cohores.com or CohoRes, LLC., 7200 NE 41st Street, Suite 100, Vancouver, WA 98662

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If you are dissatisfied, we ask that you contact us first to see if we can resolve the issue.  However, if you are an individual in Europe or certain other jurisdictions, you may have the right to lodge a complaint with the supervisory authority in the country in which you live, in which you work, or in the place of the alleged infringement of your privacy rights.

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EU-Specific Notice

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These terms apply to personal information collected by Coho through the Services if you are an EU resident. Where Coho collects information directly from you through its Services, such personal information is controlled by CohoRes, LLC., 7200 NE 41st Street, Suite 100, Vancouver, WA 98662.

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The legal basis for processing of your data includes the purposes set forth above in this Privacy Statement. In some cases, we may additionally process your information based on your consent.

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Your personal information will not be stored for longer than necessary for the purposes for which they were collected, or in accordance with applicable law.

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Subject to applicable law, you have (i) the right to access and request personal information controlled by Coho, (ii) the right to request the transmission of the personal information you have provided to us to you or another company, (iii) the right to object to uses or disclosures of your personal information, (iv) the right to withdraw your consent in relation to our processing of your personal information based on your consent (however, such withdrawal of consent will not affect the lawfulness of processing based on consent before such withdrawal), (v) the right to request deletion of your personal information and (vi) the right to request that we restrict processing of your personal information.

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You may exercise these rights free of charge unless the request is unfounded, excessive, or otherwise unreasonable, for instance, because it is repetitive. In some situations, we may refuse to act or may impose limitations on your rights, as permitted by law. Before Coho is able to provide you with any information or correct any inaccuracies, we may ask you to verify your identity and/or provide other details to help us respond to your request. For the exercise of your rights, please contact Coho’s Representative at the location below.

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If you are dissatisfied, we ask that you contact us first to see if we can resolve the issue.  However, if you are an individual in in Europe or certain other jurisdictions, you may have the right to lodge a complaint with an appropriate supervisory authority.

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Your California Privacy Rights

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California law permits users of our Services 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, California residents should send an e-mail to support@cohores.com or CohoRes, LLC., 7200 NE 41st Street, Suite 100, Vancouver, WA 98662

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Coho is a service provider to employers, travel agencies, global distribution systems and travel suppliers who provide information about you in order for Coho to provide the Services.  If you are a California consumer, please direct any questions regarding your California Consumer Privacy Act privacy rights to the business(es) who collected information about you.

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Coho does not and will not sell personal information of California residents to third parties, within the meaning of the California Consumer Privacy Act.

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International Transfers

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We’re headquartered in the United States, and our information systems are in several countries around the world. We also use service providers whose information systems may also be in various countries. This means your personal information might end up in one of those information systems in another country, and that country may have a different level of data protection regulation than yours. By giving us personal information, you expressly consent, or the company from whom we received your personal information consents to the processing of your personal information as described in this document.

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No matter what country your personal information is in, we comply with applicable law and will also abide by the commitments we make in this Privacy Statement.

With respect to sales leads created by Coho, and information received from individuals directly contacting us, Coho is typically a controller of such specific personal information.

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Children’s Information

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If you are a parent and believe your child who is under 16 has provided us with personal information without your express consent, please contact us at support@cohores.com to have your child’s information removed.

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GDPR COMPLIANCE

Effective March 2018

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GDPR Compliance

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As you may know, the General Data Protection Regulation (GDPR) is a data privacy law effective May 25, 2018, and will apply to any company, such as COHO Res, LLC through our use and resale of products owned by Sabre GLBL Inc., that processes data for European Union (EU) residents, regardless of the business location, in the context of the activities of the establishment.
 

As a valued customer, we want to ensure that your organization is aware of the GDPR and takes all necessary steps to evaluate whether it applies to you. If you believe you are subject to the requirements of the GDPR, please engage your COHO contact directly or send an email to info@cohores.com and we will provide the necessary contract amendment relating to Sabre’s services to you.

We are happy to share with you more information about our GDPR readiness efforts. However, as you can appreciate, we are not in a position to provide legal advice or to advise what actions are required on your part. We hope you understand the need for a deliberate approach given the upcoming compliance deadline, and we urge you to ensure that your organization reviews the applicability of the GDPR to its business and completes its GDPR compliance efforts by May 25, 2018. 

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Consumer Disclosure
 

From time to time, COHO Res, LLC (we, us or Company) may be required by law to provide to you certain written notices or disclosures. Described below are the terms and conditions for providing to you such notices and disclosures electronically through the DocuSign, Inc. (DocuSign) electronic signing system. Please read the information below carefully and thoroughly, and if you can access this information electronically to your satisfaction and agree to these terms and conditions, please confirm your agreement by clicking the ‘I agree’ button at the bottom of this document.

Getting paper copies
At any time, you may request from us a paper copy of any record provided or made available electronically to you by us. You will have the ability to download and print documents we send to you through the DocuSign system during and immediately after signing session and, if you elect to create a DocuSign signer account, you may access them for a limited period of time (usually 30 days) after such documents are first sent to you. After such time, if you wish for us to send you paper copies of any such documents from our office to you, you will be charged a $0.00 per-page fee. You may request delivery of such paper copies from us by following the procedure described below.

Withdrawing your consent
If you decide to receive notices and disclosures from us electronically, you may at any time change your mind and tell us that thereafter you want to receive required notices and disclosures only in paper format. How you must inform us of your decision to receive future notices and disclosure in paper format and withdraw your consent to receive notices and disclosures electronically is described below.
 

Consequences of changing your mind
If you elect to receive required notices and disclosures only in paper format, it will slow the speed at which we can complete certain steps in transactions with you and delivering services to you because we will need first to send the required notices or disclosures to you in paper format, and then wait until we receive back from you your acknowledgment of your receipt of such paper notices or disclosures. To indicate to us that you are changing your mind, you must withdraw your consent using the DocuSign ‘Withdraw Consent’ form on the signing page of a DocuSign envelope instead of signing it. This will indicate to us that you have withdrawn your consent to receive required notices and disclosures electronically from us and you will no longer be able to use the DocuSign system to receive required notices and consents electronically from us or to sign electronically documents from us.

All notices and disclosures will be sent to you electronically
Unless you tell us otherwise in accordance with the procedures described herein, we will provide electronically to you through the DocuSign system all required notices, disclosures, authorizations, acknowledgements, and other documents that are required to be provided or made available to you during the course of our relationship with you. To reduce the chance of you inadvertently not receiving any notice or disclosure, we prefer to provide all of the required notices and disclosures to you by the same method and to the same address that you have given us. Thus, you can receive all the disclosures and notices electronically or in paper format through the paper mail delivery system. If you do not agree with this process, please let us know as described below. Please also see the paragraph immediately above that describes the consequences of your electing not to receive delivery of the notices and disclosures electronically from us.
 

How to contact COHO Res, LLC.:
You may contact us to let us know of your changes as to how we may contact you electronically, to request paper copies of certain information from us, and to withdraw your prior consent to receive notices and disclosures electronically as follows: To contact us by email send messages to: maili.morrison@cohores.com. 

 

To advise COHO Res, LLC. of your new e-mail address To let us know of a change in your e-mail address where we should send notices and disclosures electronically to you, you must send an email message to us at maili.morrison@cohores.com and in the body of such request you must state: your previous e-mail address, your new e-mail address. We do not require any other information from you to change your email address.

In addition, you must notify DocuSign, Inc. to arrange for your new email address to be reflected in your DocuSign account by following the process for changing e-mail in the DocuSign system.

 

To request paper copies from COHO Res, LLC..

To request delivery from us of paper copies of the notices and disclosures previously provided by us to you electronically, you must send us an e-mail to maili.morrison@cohores.com and in the body of such request you must state your e-mail address, full name, US Postal address, and telephone number. We will bill you for any fees at that time, if any.

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To withdraw your consent with COHO Res, LLC.

To inform us that you no longer want to receive future notices and disclosures in electronic format you may:
 

• decline to sign a document from within your DocuSign session, and on the subsequent page, select the check-box indicating you wish to withdraw your consent, or you may;

 

• send us an e-mail to maili.morrison@cohores.com and in the body of such request you must state your e-mail, full name, US Postal Address, and telephone number. We do not need any other information from you to withdraw consent.. The consequences of your withdrawing consent for online documents will be that transactions may take a longer
   time to process.

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