Privacy Policy

Last Updated: June 13th, 2022

This Privacy Policy explains how information about you is collected, used, and disclosed by EIN Plus LLC DBA GoTravel™. GoTravel™ is a registered trademark of EIN Plus LLC. (“GoTravel™,” “we,” “we,” or “our”). This Privacy Policy applies to information we collect when you use our website, mobile applications, online products, and services (collectively, the “Services”), or when you otherwise interact with us.

In compiling this Policy, we have taken steps to incorporate the standards and principles outlined in data collection and privacy frameworks, including the European Union’s General Data Protection Regulation (“GDPR”). This Policy describes:

  1. The types of information we may collect from you or that you may provide when you visit our website (the “Website” or “Site”) as well as any websites and blogs directly owned by GoTravel™ (“our websites” or “our sites”), and
  2. Our practices for collecting, using, maintaining, protecting, and disclosing that information.

GoTravel™ has certified to the US Department of Commerce that it adheres to the US Privacy Shield Principles. Per Article 45 of the GDPR, the European Commission recognizes that certifying under the EU-U.S.-Privacy Shield ensures an adequate data protection level. The data transfer to the USA does not require any specific authorization. (See also § 10, “Compliance and Cooperation with Regulatory Authorities.”)

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the beginning of the policy and posting the revised policy to our Services, and, in some cases, we may provide you with additional notice such as by adding a statement to the homepage of our Services or by sending you a notification. We encourage you to review the Privacy Policy whenever you access the Services to stay informed about our information practices and the ways you can help protect your privacy

1. Collection of Information

We collect information about you in three different ways.

Information You Provide to Us

  1. We collect information you provide directly to us. For example, when you sign up, apply for our government services or fill out forms, or use any of our services, we collect all information needed for that application, including your name, address, phone number, social security number, alien registration number, tax identification number, citizenship or visa status, family member, structure or type of your business or organization, business address, reasons for application, employee information, and other information you choose to provide. We also collect information when you create an account, fill out any other form or application, request customer support, or otherwise communicate with us.

Information We Collect Automatically When You Use the Services

  1. When you access or use our Services, we automatically collect information about your use of the Services, the movements of your mouse, and your keystrokes to help understand what our users are looking for and how they interact with our Services.

We also automatically collect the following types of information:

  1. Usage Information: We log information about your use of the Services, such as features and applications you visit and use.
  2. Log Information: We log information about your use of our websites, including your browser type and language, access times, pages viewed, your IP address, operating system and version, and the website you visited before navigating to our websites.
  3. Information Collected by Cookies and Other Tracking Technologies: We and our service providers use various technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that helps us to improve our Services and your experience, see which areas and features of our Services are popular and count visits. Web beacons are electronic images that may be used on our website or in our emails that help deliver cookies, count visits, and understand usage. For more information about cookies, and how to disable them, please see “Your Choices” below.

2. Use of Information

We use the information we collect primarily to determine your eligibility for government applications, benefits or services, and to help you apply for such services. We may use information about you for various other purposes, including but not limited to: Provide and deliver the services you request, process forms, and send you related information, including post-submission summaries, confirmations, and receipts; Maintain and improve our Services; Send you technical notices, updates, security alerts and support, and administrative messages; Respond to your comments, questions and requests, and provide customer service; Communicate with you about services and events offered by GoTravel™, our affiliates, partners or subsidiaries, and provide news and information we think will be of interest to you; Administer surveys and events, such as focus groups; Monitor and analyze trends, usage and activities in connection with our Services; Personalize and improve the Services and provide content, or features that match aggregate user behavior; Detect, investigate, and prevent fraudulent and other illegal activities, and protect the rights and property of GoTravel™ and others; and Carry out any other purpose for which the information was collected. Additionally, We may send you related offers with other services we offer. At your request we will send notifications of address updates to vendors you select only if and when you select this service.

GoTravel™ is based in the United States and the information we collect is governed by U.S. law. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries, where you may not have the same rights as you do under local law. Where this is the case, we will take appropriate measures to protect information about you in accordance with this Privacy Policy.

3. Sharing of Information

The purpose of our service is to enable sharing of the information you provide with various government agencies and other entities at your direction. For example, we may share information with the Internal Revenue Service, and other entities to help obtain government services. Accordingly, we share information with applicable government agencies or vendors at your request. By using the Services, you consent to these uses of your personal information.

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

  1. With our corporate affiliates;
  2. With vendors, consultants and other service providers who need access to such information to carry out work on our behalf, including analyzing data trends within our Services;
  3. In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation, or legal process, or as otherwise required by any applicable law, rule, or regulation;
  4. If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of GoTravel™ or others, including employers that use our Services;
  5. To process payments you make in connection with the Services;
  6. With our partners or third parties when providing a new or integrated feature;
  7. If you ask us to introduce you to one of our partners;
  8. With your consent or at your direction, including but not limited to if we notify you through our Services that the information you provide will be shared in a particular manner and you provide such information; and
  9. In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company.

We may also share aggregated or anonymized information, which cannot reasonably be used to identify you.

We do not share information about you with third parties for their own marketing or business purposes without your consent.

4. Third-Party Analytics Services

We may allow others to provide analytics services on our behalf. These entities may use cookies, web beacons and other technologies to collect information about your use of the Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked. This information may be used by GoTravel™ and others to, among other things, analyze and track data, determine the popularity of certain content, deliver content targeted to your interests on our Services, and better understand your online activity..

5. Security

GoTravel™ takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction.

6. Your Choices

  1. Application Information. It is your responsibility for maintaining the accuracy of your application. You may update, correct, or delete information about you at any time by contacting us. You may also delete your application by emailing customer service. Any changes you make to your Application will impact the scope and type of services we can provide to you. Note that we may retain certain information as required by law or for legitimate business purposes for a reasonable period of time. We may also retain cached or archived copies of information about you.
  2. Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.
  3. Promotional Communications. You may opt out of receiving promotional emails from GoTravel™ by following the instructions in those emails. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business related relations.
  4. Governing Law; Arbitration. This Privacy Policy is governed by Terms of use, and is subject to change, which can be found by clicking the link Terms & Conditions on our home page.

7. Protecting Children

The products and services at GoTravel™ are not marketed or offered to, and not intended for, and should not be used by, any children under the age of 13. 

GoTravel™ will not knowingly collect any information from individuals under the age of thirteen. Using our Services, you represent that you are over the age of 13 and old enough to consent to the processing of your personal data in your country or that your parent or guardian gives consent on your behalf. If information is inadvertently collected for children under the age of 13, we will delete such information if we are notified or otherwise aware of it. The Children’s Online Privacy Protection Act (COPPA) protects children under the age of 13 from the online collection of personal information. Learn more about COPPA on the Federal Trade Commission’s website at https://www.ftc.gov/business-guidance/privacy-security/childrens-privacy

8. Linking and Framing to Other Websites

Our website and other electronic communications from GoTravel™ may display links and frames to other sites. Once you enter a third party website, or a portion of a third party site is framed within our website, you agree that GoTravel™ is not responsible for these other sites’ privacy practices. GoTravel™ encourages you to look for and review the privacy statements of each website that you visit.

GoTravel™ does not represent, warrant, or endorse expressly or impliedly as to any information, services, products, or messages on any third party websites which may be accessed through the GoTravel™ website or that is sent by email. In particular, these links and frames are for your convenience only. They are not an endorsement by GoTravel™ of the organization or individual operating the website or a warranty or endorsement of any type regarding the website or the information, services, products, or messages posted on or available from such website.

9. Compliance and Cooperation With Regulatory Authorities

GoTravel™ complies with the EU–US Privacy Shield Framework and the Swiss–US Privacy Shield Framework set forth by the US Department of Commerce regarding collecting, using, and retaining Personal Information transferred from the European Union and Switzerland to the United States, respectively. 

GoTravel™ has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program and to view our certification, please visit https://www.privacyshield.gov.

10. E-Communications from GoTravel™

GoTravel™ and its parent company and subsidiaries may send you emails or other electronic communications regarding us or our services. These electronic communications will be sent to the email address that you provide to us. Should you wish to cease receiving these electronic communications, you can opt-out via the instructions located at the bottom of each electronic communication. GoTravel™ will never send you an email requesting your password, credit card number, or social security number. If you receive a message that looks like it is from usbut asks you for these, it is a fraudulent email or “phish.” We recommend you report it to the proper authorities and notify us immediately.

11. Dispute Resolution.

If you have any complaints regarding our compliance with this Policy or a Privacy Shield related or general privacy related complaint, you should first contact us. We will investigate and attempt to resolve complaints and disputes regarding the use and disclosure of Personal Information per this Policy and the Terms and Conditions.

Concerning human resources data, GoTravel™ will cooperate and comply with the EU Data Protection Authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and the advice given by such authorities for human resources data transferred from the EU and Switzerland. If you do not receive timely acknowledgment of your complaint from GoTravel™, or if we have not addressed your complaint to your satisfaction, you may contact the EU DPA for more information or to file a complaint. The services of the EU DPAs are provided at no cost to you.

12. For Website Visitors in the European Union (“EU”)

Under the GDPR, our EU visitors are provided additional rights concerning their Personal Information, or “personal data” as defined under the GDPR. For this Policy and any personal data processed for Website visitors or individuals in the EU, GoTravel™ operates as a data controller unless otherwise determined by agreement or law. Any personal data we collect from you is processed in the United States and under the terms of this Policy in our business’s legitimate interest and providing our services to you as the lawful means for such processing. 

You may always withdraw your consent to our use of your personal data, as described below. We will only retain your personal data for the time necessary to provide you the information and marketing services to which you have consented, and per your rights below and in this Policy.

You can exercise any of the following rights by notifying us as described below:

  1. Access. You may email us to request a copy of the personal data our website currently contains.
  2. Correction or Rectification. You can correct what personal data our Website currently contains by signing into your account and clicking the Account Settings tab or emailing us to request that we correct or rectify any personal data you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
  3. Restrict Processing. When applicable, you may restrict the processing of your personal data by requesting via email. In your email, please explain how you wish GoTravel™ to restrict the processing of your personal data. When such restrictions are not possible, GoTravel™ will advise you accordingly. You can then choose to exercise any other rights under this Policy, including withdrawing your consent to the processing of your personal data.
  4. Object to Processing. When applicable, you have the right to object to the processing of your personal data by requesting via email. When such objections are not possible, GoTravel™ will advise you accordingly. You can then choose to exercise any other rights under this Policy, including withdrawing your consent to the processing of your personal data.
  5. Portability. Upon request and when possible, GoTravel™ can provide you with copies of your personal data. You may submit a request via email. When such a request cannot be honored, GoTravel™ will advise you accordingly. You can then choose to exercise any other rights under this Policy, including withdrawing your consent. Where applicable, GoTravel™ will ensure such changes are shared with any trusted third parties.
  6. Withdraw Consent. At any time, you may withdraw your consent to GoTravel™ processing of your personal data through this website by notifying us via email. Using the same email address for your website account, simply type the words “Withdraw Consent” in your email’s subject line. Upon receiving such a withdrawal of consent, GoTravel™ will confirm receipt and proceed to stop processing your personal data. Where applicable, GoTravel™ will ensure such changes are shared with trusted third parties.
  7. Erasure. If you wish to cease using our website and have your personal data deleted from our website, you may submit a request by emailing us. Upon receiving such an erasure request, GoTravel™ will confirm receipt and confirm once your personal data has been deleted.
  8. Submit Complaints or Questions. If you wish to raise a complaint on how we have handled your personal data, you can contact us as described below. If you reside in a European Union Member State, you may also complain to your country’s supervisory authority.

13. Privacy Notice for California Residents

This Privacy Notice for California Residents supplements the information contained in GoTravel™’s Privacy Policy. It applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA), and any terms defined in the CCPA have the same meaning when used in this notice.

A. Information We Collect

The GoTravel™ website (the “Website”) collects information that identifies, relates to, describes, references can be for, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, the site has collected the following categories of personal information from its consumers within the last 12 months:

  1. Identifiers
  2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  3. Protected classification characteristics under California or federal law
  4. Commercial information
  5. Internet or other similar network activity
  6. Geolocation data
  7. Professional or employment-related information
  8. Non-public education information (per the Family Educational Rights and Privacy Act (20 USC § 1232(g), 34 CFR § 99))
  9. Inferences drawn from other personal information

Personal information does not include:

  1. Publicly available information from government records
  2. Deidentified or aggregated consumer information
  3. Information excluded from the CCPA’s scope, such as:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
  • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994

GoTravel™ obtains the categories of personal information listed above:

  1. Directly from you, for example, from forms you complete or products and services you purchase;
  2. Indirectly from you, for example, from observing your actions on our site; and
  3. Indirectly from your employer, for example, information for you to complete a survey or assessment.

B. Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  1. To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to aid new product orders 
  2. To provide, support, personalize, and develop our site, products, and services.
  3. To create, maintain, customize, and secure your account with us.
  4. To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  5. To support you and respond to your inquiries, including investigating and addressing your concerns and monitoring and improving our responses.
  6. To personalize your site experience.
  7. For surveying, research, analysis, and product development, including to develop and improve our site, products, and services.
  8. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  9. As described to you when collecting your personal information or as otherwise outlined in the CCPA.

GoTravel™ will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without notifying you.

C. Sharing Personal Information

GoTravel™ may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

  1. Subsidiaries and affiliates
  2. Contractors and service providers
  3. Data aggregators
  4. Third parties with whom we partner to offer products and services to you

D. Disclosures of Personal Information for a Business Purpose

In the preceding 12 months, GoTravel™ has not disclosed the following categories of personal information for a business purpose to one or more of the parties identified above:

  1. Category A: Identifiers
  2. Category B: California Customer Records personal information categories
  3. Category C: Protected classification characteristics under California or federal law
  4. Category D: Commercial information
  5. Category E: Internet or other similar network activity
  6. Category F: Geolocation data

E. Sales of Personal Information

In the preceding 12 months, GoTravel™ has not sold personal information.

F. Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

G. Access to Specific Information and Data Portability Rights

You have the right to request that GoTravel™ disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

  1. The categories of personal information we collected about you.
  2. The categories of sources for the personal information we collected about you.
  3. Our business or commercial purpose for collecting or selling that personal information.
  4. The categories of third parties with whom we share that personal information.
  5. The specific pieces of personal information we collected about you (also called a data portability request).
  6. If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • Sales, identifying the personal information categories that each category of recipient purchased
  • Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained

H. Deletion Request Rights

You have the right to request that GoTravel™ delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records unless an exception 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 information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, 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 and ensure another consumer’s right to exercise their free speech rights or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement if you previously provided informed consent.
  7. Enable solely internal uses reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information compatible with the context in which you provided it.

I. Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by contacting us. Only you, or a person registered with the California Secretary of State whom you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice in 12 months. 

The verifiable consumer request must

  1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
  2. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

J. Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of receipt. If we need more time (up to 90 days), we will inform you of the reason and extension in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12 months preceding the verifiable consumer request’s receipt. The response we provide will also explain why we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and allow you to easily transmit the information from one entity to another.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

K. Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us not to sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we know are less than 16 years of age unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age or the parent or guardian of a consumer who is between 13 and 16 years of age.  

Consumers who opt into personal information sales may opt out of future sales at any time.

L. Nondiscrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  1. Deny your goods or services;
  2. Charge you different prices or rates for goods or services, including granting discounts or other benefits or imposing penalties;
  3. Provide you a different level or quality of goods or services; or
  4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

M. Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our site who 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.

14. Contact

If you have any questions about this Privacy Policy, please contact us.‍