PRIVACY AND SECURITY POLICY

Adestinn, LLC (“Adestinn”) respects the privacy of visitors to our website (the “Site”) and of our Adestinn Vacation Savings Match Program members (“Members”) as well as the security of any information that our Members enter on the Site. This Privacy and Security Policy discloses how Adestinn collects and uses information about you, the choices that you can make about the way your information is collected and used and how Adestinn secures the data it collects.

1. INFORMATION COLLECTION AND USE

Some portions of the Site collect information from you, including personally identifiable information. Also, if you have contacted Adestinn other than through the Site, Adestinn may have collected any information that you provided. Adestinn may use this information for a number of purposes, including, without limitation: for proper operation and security mechanisms of the Site, to contact you with opportunities to receive information from Adestinn including information relating to products or services offered on the Site by Adestinn, or to contact Members with information relating to products or services offered on the Site by others which may be of interest to our Members. You may opt out of receiving such information under the procedures described in Section 2 below. Adestinn will never sell, use or share any personal information with any third-party other than as outlined above.
In addition, portions of the Site request that Members provide personal financial information in order for you to use the full functionality of the Site. Adestinn will never sell, use or share any personal financial information with any third-party other than to properly process a financial transaction that you initiate and with our banking partner who maintains your FDIC insured Adestinn Vacations Savings Account.

Cookies/IP Addresses

Adestinn may use persistent cookies to personalize your visit and allow us to deliver unique products and services developed specifically for your interests. Persistent cookies are small files stored on your computer by your web browser. In addition, we use temporary session cookies to enhance your experience on the Site. Session cookies are not saved on your computer, but are only stored in your computer’s memory temporarily while you are using the Site. While your browser may allow you to "reject" cookies, the Site requires that you accept all cookies in order for all of the features and security mechanisms to function fully.
Adestinn may collect and use Site users’ Internet Protocol or “IP” addresses and other Site usage data to gather broad demographic information and for the basic operation of the Site and security mechanisms of the Site. This data helps Adestinn serve you by allowing Adestinn to understand how visitors use the Site. Adestinn generally does not use IP addresses to identify a user. Adestinn, however, may use IP addresses to identify a user when Adestinn feels it is necessary to protect our services, the Site, our customers or others, or in response to requests or subpoenas by law-enforcement authorities.
Adestinn may use third-party service providers to help us analyze certain online activities. For example, these service providers may help us measure the performance of our online campaigns or analyze activity on the Site. We may permit these service providers to use cookies and other technologies to perform these services for Adestinn. We do not share any personal information about our members with these third-party service providers, and these service providers do not collect such information on our behalf. Our third-party service providers are required to comply fully with this Privacy and Security Policy.

Links to External Sites

At times, we may provide links to sites outside the control of Adestinn to provide you with additional information about our destinations or to advise you about additional travel products and services offered by third parties. Provided links are meant to supplement Adestinn’s products and services or provide other information we believe may be of interest to you. Although we will only provide links to sites we believe are reputable, we do not make any representations concerning the linked sites' contents, availability or security. Please note that linked sites may have different privacy and information security policies than Adestinn, and you should carefully review each linked site's privacy and information security policies carefully before you enter personal or financial information onto the linked site. Adestinn may present links in a format that enables us to keep track of whether these links have been followed and whether any action has been taken on a third-party Web site.

Contests, Giveaways and Surveys

From time to time, Adestinn may offer you the opportunity to participate in contests, giveaways and other promotions. Any information submitted in connection with such activities will be treated in accordance with this Privacy and Security Policy, except as specifically set forth in the rules for those contests, giveaways or promotions.
From time to time, Adestinn may also invite you to participate in surveys designed to help improve the Site. Any personal information provided in connection with any survey will be used only in relation to that survey and as elsewhere set forth in this Policy.

Your data may be transferred upon change of control but only in accordance with this

Policy

Personal information may be transferred to a third-party as a result of a sale, acquisition, merger, reorganization or other change of control. If we sell, merge or transfer any part of our business, part of the sale may include your personal information.

Disclosure of your information to protect our rights or if required by law

Notwithstanding the foregoing, Adestinn reserves the right (and you authorize Adestinn) to share or disclose your personal information when Adestinn determines, in its sole discretion, that the disclosure of such information is necessary or appropriate:

To enforce our rights against you or in connection with a breach by you of this Privacy and Security Policy or the Adestinn.com Terms of Use;

To prevent prohibited or illegal activities; or

When required by any applicable law, rule regulation, subpoena or other legal process.

2. CONSENT TO PRIVACY STATEMENT/OPT-OUT

By providing the information requested by the Site (or by otherwise providing information to Adestinn) or by continuing to use the Site after having an opportunity to review this Privacy Policy, you have consented to the terms of the Privacy Policy, and Adestinn’s use of the information it collects as described in this Privacy Policy. If you do not agree to the Privacy Policy, you may not use the Site.
The Site provides users who have requested information from Adestinn the opportunity to opt- out of receiving future communications on special promotions from us. If you do not wish to receive these future special promotion communications from us, please send your request to either of the addresses (e-mail or physical) set forth below.

3. ACCESS/CORRECTION/REMOVAL OF YOUR INFORMATION

Often, Adestinn will not retain personal data it has collected. Most data that Adestinn collects and stores about you is accessible and editable by you through the Site. However, certain data items can only be corrected by Adestinn and you may request that the information be corrected by sending a request to the address set forth below. In order to protect your privacy and security, Adestinn will need to take reasonable steps to verify your identity before making changes to your information.
Nevertheless, you may request access to any data about you that Adestinn has collected and stored by sending a request to the address set forth below. If you believe that an error has been made in the accuracy of the data collected from you, you may request that the information be corrected by sending a request to the address set forth below. Adestinn will correct the error upon adequate verification of the error and the identity of the person seeking the correction. You may also request that we cancel your account by sending a request to the address set forth below. When you request us to delete your account, all sensitive information will be securely removed Adestinn’s primary production servers. However, your data may remain on a backup server or media. In order to protect your privacy and security, Adestinn will need to take reasonable steps to verify your identity before granting access, making corrections or deleting your information.

4. SECURITY OF THE DATA COLLECTED

We are committed to protecting the confidentiality of your sensitive information. Our security measures include protecting your data physically, technically, and administratively with locked buildings, network firewalls, and secure backups. For our online sessions, we use Secure Sockets Layer (SSL) encryption – the highest industry standard for online security – to secure your online sessions.

Every secure page on our Web site has been certified and noted with a digital certificate. This is shown as a “site certificate” resident on all secure pages.

You are responsible for maintaining the confidentiality of your Login ID and Password

The most important aspect of securing your Member data, however, is for you to select a Password for the Member’s only portion of the Site that is difficult to guess (your password must be a combination of upper and lower case letters and at least one non-alpha character such as a number, and should preferably be something not related to your job or personal life) and then guard it carefully. If your Password is breached, no other security we can employ will protect your data against someone who knows the Password. If you have reason to believe your Password may have been discovered, immediately change your Password. Under no circumstances will an Adestinn employee ever ask for your password. Adestinn will never initiate a request for personal information from you via email (i.e., Social Security Number, Personal ID, Password, PIN or account number). If you receive an email that requests this type of sensitive information, you should be suspicious of it.

Your data is securely stored in the cloud using Microsoft’s Azure cloud security

To summarize, the company applies security mechanisms at different layers of the cloud infrastructure to implement a defense-in-depth approach. These layered mechanisms include:

Physical security of the data centers (locks, cameras, biometric devices, card readers, alarms)

Firewalls, application gateways and IDS to protect the network

Access Control Lists (ACLs) applied to virtual local area networks (VLANs) and applications

Authentication and authorization of persons or processes that request access to data

Hardening of the servers and operating system instances

Redundant internal and external DNS infrastructure with restricted write access

Securing of virtual machine objects

Securing of static and dynamic storage containers

Assets are categorized as to the level of security required, based on the potential for damage. Highly sensitive assets are protected by more stringent mechanisms, such as multi-factor authentication (smart cards, biometrics, hardware tokens). The principle of least privilege is followed, whereby persons and processes are given the lowest level of access that is required for them to do their jobs and no more.
Microsoft's online services teams apply the Security Development Lifecycle (SDL) principles (security by design, security by default, and security in deployment + communications) to the online services. To read more about the SDL and SD3+C principles, follow this link.

No Warranty or Liability

No technology, however, can guarantee that information you transmit will be 100% safe from interception or misappropriation. Therefore, Adestinn cannot ensure or warrant the security of any information collected by us and/or our third-party providers, transmitted over the Internet, or maintained in your user profile. You agree that any data transmission you make or receive through the Site is at your own risk.

5. DISCLAIMER OF LIABILITY

Section 5 of the Website Terms of Use is incorporated herein by reference.

6. ENFORCEMENT/REDRESS

If you believe that Adestinn has not adhered to the Privacy Policy, please notify us at the address set forth below. Adestinn will endeavor to respond to your concerns and, when appropriate, take steps to correct a problem.

7. CHANGES TO THIS AGREEMENT

Adestinn may change this Privacy Policy at any time without your affirmative consent by providing you with written notice that the policy has changed. The means of providing this notice includes, without limitation, (i) Adestinn providing, on the Site’s home page and/or the Site’s Member login page, a prominent and conspicuous notice of the change and a hyperlink to the web page displaying the new Privacy Policy, or (ii) Adestinn e-mailing you notice of the change and including a link to this web page displaying the new Privacy Policy. If you elect to become a Member of the Site, Membership will include that you agree to receive e-mails notifying you of changes to this Privacy Policy and/or other Adestinn agreements and policies (such as the Website Terms of Use).
Notwithstanding any provision of this Privacy Policy to the contrary, Adestinn may make changes to this Privacy Policy without notice to comply with applicable laws and such changes shall be binding on you and Adestinn.

8. CONTACT INFORMATION

If you have any questions about this Privacy Policy, the practices of this Site, or your dealings with this Site, you may contact us by sending an e-mail request to membersupport@adestinn.com.

DATE OF LAST MODIFICATION: May 2, 2022