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DELFINA TRAVEL GROUP, INC. – PRIVACY POLICY
Last updated & effective: April 27, 2023
Delfina Travel Group, Inc. (“DELFINA”) respects your privacy. This Privacy Policy explains how DELFINA collects, uses and safeguards information on its subsidiary internet properties including, without limitation, www.govisitcostarica.com, mobile websites, microsites, mobile applications, DELFINA profiles on DELFINA social media sites and any other digital services and properties officially operated or used by DELFINA from time to time (the “Sites” or “Services”).
Information We Collect
1. Personally Identifiable Information: We may collect information that identifies you (“Personally Identifiable Information”) when you interact and provide such information on our Sites such as, but not limited to, registering for an DELFINA event or program, participation in a DELFINA sweepstakes or contest, purchasing DELFINA products or services. The types of Personally Identifiable Information collected on our Sites will vary based on the Services offered on the Sites, but may include, among other things, your name, address, phone number, birth date, billing and delivery information, e-mail address, credit card or other financial account information.
2. Non-Personal Data: As you interact on our Sites, we may also collect information that is not Personally Identifiable Information but may disclose other aspects of your browsing history or certain other information about you through the use of a variety of technologies, including, but not limited to, cookies, tags, beacons, Internet Protocol (IP) address tracking/URL tracking, and other tools. "Cookies" are pieces of code/text that gets placed on your computer when you browse our Sites. Cookies may be placed by us or third party advertisers contracted by us. “Tags” and web beacons refer to code scripts that are primarily used to track visitors’ activities on our Sites by web analytics software. The types of non-personal data collected on our Sites through the use of these, and other tools as DELFINA may add from time to time, may include: the search terms you used, new or returning user, browser information, computer type, operating system, internet service providers, website usage, referring/exit pages, platform type, date/time stamp, number of clicks, ads viewed, etc. Additionally, cookies, tags and other tools placed by third parties may collect other information about you such as, but not limited to, your industry, company size, job function, seniority level, etc.)(collectively, all of the foregoing data the "Non-Personal Data").
How We Use and Share Personally Identifiable Information
Once collected, we may use your Personally Identifiable Information in a variety of ways including (but not limited to):
- Provide service communications such as bill reminders, order confirmations, program registrations, and customer service messages
- Answer your emails or online requests
- Sending out email newsletters
- Deliver and process surveys
- Personalize and improve the usability of the Sites
- Fulfill and/or deliver DELFINA products and services
- Sharing with our business partners to offer you products and services that may be of interest to you as described below
- Sharing with third parties as required by law or to protect DELFINA as described below
- Sharing your Email Address as permitted under DELFINA Email Policy as described below
Sharing your Personally Identifiable Information to Fulfill Service Requests
When fulfilling service requests initiated by you, we may share your Personally Identifiable Information with certain third parties to fulfill the requests.
Sharing your Personally Identifiable Information With Our Business Partners
DELFINA may share Personally Identifiable Information, other than email address and financial account information, with our business partners in order to provide them an opportunity to offer products or services that may be of interest to you, which helps contribute non-dues revenue to DELFINA. DELFINA also occasionally hires other companies to provide limited services on our behalf including, but not limited to, packaging, mailing and delivering promotional offers, sweepstakes or contests, answering customer questions about products or services, consulting services, data modeling, printing, sending postal mail and processing event registration. At this time we do not share this information with any business partners but reserve the right to do so in the future
Sharing Your Personally Identifiable Information When Legally Necessary or to Protect DELFINA’s interests.
DELFINA may disclose your Personally Identifiable Information if required to do so by law or in the good-faith belief that such action is necessary to: (a) conform to legal requirements or comply with legal process served on DELFINA; (b) protect and defend the rights or property of DELFINA; or (c) protect the personal safety of DELFINA personnel or members of the public in appropriate circumstances.
Sharing Your Email Address Pursuant to DELFINA Policy.
Your email address will only be used by DELFINA and its entities. We do not sell or rent email addresses to anyone outside DELFINA. DELFINA will also not offer email addresses to unrelated third-parties or affiliates except under circumstances described above.
How to Manage The Sharing Of Your Personally Identifiable Information
If you prefer to receive mailings only from DELFINA and have your name and address removed from the list provided to our business partners, please contact us. Again, at this time we do not share this information with any business partners but reserve the right to do so in the future. For California residents, please consult the “California Privacy Rights” section below for additional considerations.
How We May Use and Share Non-Personal Data
Through the use of various technological tools, we may collect Non-Personal Data to improve the usability of our Sites/Services and for other business reasons. We may share the Non-Personal Data we collect with third parties or permit third parties to place tools like cookies, tags, web beacons, to collect additional Non-Personal Data when you browse our Sites. We or other third party companies may then use the Non-Personal Data to provide advertisements and targeted advertisements to you (ads based on the Non-Personal Data). We do not share Personally Identifiable Information with third parties to whom we share your Non-Personal Data. Please note that you may be subject to the privacy policies of other non-DELFINA companies when you hit an advertising link or other link that takes you to sites not operated by DELFINA.
How You Can Manage The Collection of Non-Personal Data.
You can opt out of targeted advertisements by visiting the Opt Out From Online Behavioral Advertising website. By opting out of targeted advertisements you will no longer see advertisements on our Site from third-party partners that participate in the DAA; however, you may still continue to see other non-targeted advertisements on our Sites. You may also block or disable cookies on your computer which will restrict the collection of Non-Personal Data enabled through the use of cookies but doing so may prevent you from accessing certain functionalities on the Sites.
Collection of Data for Website Traffic Analysis
We use Google Analytics for aggregated, anonymized website traffic analysis. In order to track your session usage, Google drops a cookie (_ga) with a randomly-generated ClientID in your browser. This ID is anonymized and contains no identifiable information like email, phone number, name, etc. We also send Google your IP Address. We use Google Analytics to track aggregated website behavior, such as what pages you looked at, for how long, and so on. This information is important to us for improving the user experience and determining site effectiveness. If you would like to access what browsing information we have - or ask us to delete any Google Analytics data - please delete your _ga cookies, reach out to us via this form, and/or install the Google Analytics Opt-Out Browser Add-On.
California Privacy Rights
In addition to the rights as explained in this Privacy Policy, under California’s "Shine the Light" law, California residents who provide personal information (as defined in the statute) in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the personal information we shared, if any, with other businesses for marketing uses. If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which we shared such personal information for the immediately prior calendar year (e.g. requests made in 2013 will receive information about 2012). To obtain this information please write to us at: Delfina Travel Group, Inc., 4151 Mission Blvd Suite 212, San Diego, CA 92109, USA, Attn: DELFINA Privacy Officer -- California Privacy Law. Please include your full name and address.
Our Use of Cookies
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
We use cookies for the following purposes:
- Authentication - We use cookies to identify you when you visit our website and as you navigate our website.
- Status - We use cookies to help us to determine if you are logged into our website.
- Security - We use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally.
- Advertising - We use cookies to help us to display advertisements that will be relevant to you.
- Analysis - We use cookies to help us to analyze the use and performance of our website and services.
We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
- Chrome - https://support.google.com/chrome/answer/95647?hl=en
- Firefox - https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
- Opera - http://www.opera.com/help/tutorials/security/cookies/
- Internet Explorer - https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
- Safari - https://support.apple.com/en-gb/guide/safari/sfri11471/mac
- Edge - https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
Please note that blocking cookies may have a negative impact on the functions of many websites, including our Site. Some features of the Site may cease to be available to you.
Mediavine Programmatic Advertising (Ver 1.1)
The Website works with Mediavine to manage third-party interest-based advertising appearing on the Website. Mediavine serves content and advertisements when you visit the Website, which may use first and third-party cookies. A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Website.
First party cookies are created by the website that you are visiting. A third-party cookie is frequently used in behavioral advertising and analytics and is created by a domain other than the website you are visiting. Third-party cookies, tags, pixels, beacons and other similar technologies (collectively, “Tags”) may be placed on the Website to monitor interaction with advertising content and to target and optimize advertising. Each internet browser has functionality so that you can block both first and third-party cookies and clear your browser’s cache. The "help" feature of the menu bar on most browsers will tell you how to stop accepting new cookies, how to receive notification of new cookies, how to disable existing cookies and how to clear your browser’s cache. For more information about cookies and how to disable them, you can consult the information at All About Cookies.
Without cookies you may not be able to take full advantage of the Website content and features. Please note that rejecting cookies does not mean that you will no longer see ads when you visit our Site. In the event you opt-out, you will still see non-personalized advertisements on the Website.
The Website collects the following data using a cookie when serving personalized ads:
- IP Address
- Operating System type
- Operating System version
- Device Type
- Language of the website
- Web browser type
- Email (in hashed form)
Mediavine Partners (companies listed below with whom Mediavine shares data) may also use this data to link to other end user information the partner has independently collected to deliver targeted advertisements. Mediavine Partners may also separately collect data about end users from other sources, such as advertising IDs or pixels, and link that data to data collected from Mediavine publishers in order to provide interest-based advertising across your online experience, including devices, browsers and apps. This data includes usage data, cookie information, device information, information about interactions between users and advertisements and websites, geolocation data, traffic data, and information about a visitor’s referral source to a particular website. Mediavine Partners may also create unique IDs to create audience segments, which are used to provide targeted advertising.
If you would like more information about this practice and to know your choices to opt-in or opt-out of this data collection, please visit National Advertising Initiative opt out page. You may also visit Digital Advertising Alliance website and Network Advertising Initiative website to learn more information about interest-based advertising. You may download the AppChoices app at Digital Advertising Alliance’s AppChoices app to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out.
For specific information about Mediavine Partners, the data each collects and their data collection and privacy policies, please visit Mediavine Partners.
Third-party Service Providers
We may use third-party service providers to service various aspects of the Website. We also participate in affiliate marketing. When you make a purchase using an affiliate link, the third-party from which you make the purchase may transfer information regarding the sale back to us. This will depend on the individual company's privacy policies as listed below.
Currently, we host affiliate links from the following providers:
Email Addresses
We may collect your email address, but only if you voluntarily provide it to us. This may occur, for example, if you sign up to receive an email newsletter, or enter a promotion. We will use your email address for the purposes for which you provided it to us, and also from time to time to send you emails regarding the Site or other products or services that we believe may be of interest to you. You may opt out of such email communications at any time by clicking the “unsubscribe” button in the email.
Your email address may also be shared with the technology provider we use in connection with the purposes for which you provided it, and that technology provider may also contact you from time to time.
If you are a resident of a country in the European Economic Area (EEA), please refer to the section below entitled "Additional Rights of EEA Residents."
Transactional Data
We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our Site ("Transactional Data"). The Transactional Data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. Payment processing on our Site is handled by our payment services provider, Paypal. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at https://www.paypal.com/us/webapps/mpp/ua/privacy-full.
Additional Rights of EEA (European Economic Area) Residents
If you are a resident of a country in the EEA, you have the rights, among others, to:
- access your personal data
- ensure the accuracy of your personal data
- the right to have us delete your personal data
- the right to restrict further processing of your personal data, and
- the right to complain to a supervisory authority in your country of residence in the event that data is misused
If you believe that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your residence, your place of work or the place of the alleged infringement.
You may exercise any of your rights in relation to your personal data by written notice to us addressed to the following:
Attn: EU Privacy Complaints; Delfina Travel Group, Inc., 4151 Mission Blvd Suite 212, San Diego, CA 92109, USA; 858-581-9209; euprivacy@govisitcostarica.com
Children
We do not knowingly solicit data online from or market online to children under the age of 18.
Information security
DELFINA implements commercially reasonable security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. We restrict access to personal information to DELFINA’s business partners who may need to know that information in order to operate, develop or improve our services. These individuals or partner organizations are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.
User ID and password
Certain areas of the Site may require the use of a user ID, email address or password as an additional security measure that helps protect your information. To help you protect your privacy, DELFINA Sites have clear tools to help you log in and log out.
Linking to other Internet sites
You should be aware that other Internet sites that are linked from the Sites or from an DELFINA email message may contain privacy provisions that differ from the provisions of this Privacy Policy. To ensure your privacy is protected, we recommend that you review the privacy statements of these other linked sites, applications or other digital properties.
How you can access and change information
If you are a registered user of the Sites, subscriber to DELFINA publications, or purchaser of DELFINA products and services, you may review and update/correct your information by contacting us.
No guarantee
Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. Accordingly, and despite our efforts, DELFINA cannot guarantee or warrant the security of any information you transmit to us, or to or from our online products or services. If you have questions about this Privacy Policy, please contact us.
Sale of Business or Assets
In the event that the Site or substantially all of its assets is sold or disposed of as a going concern, whether by merger, sale of assets or otherwise, or in the event of an insolvency, bankruptcy or receivership, the information we have collected about you may be one of the assets sold or merged in connection with that transaction.
Changes to the Privacy Policy
We may change this Privacy Policy from time to time. The most recent version of the Privacy Policy will always be posted on the Site, with the "Effective Date" posted at the top of the Policy. We may revise and update this Privacy Policy if our practices change, as technology changes, or as we add new services or change existing ones. If we make any material changes to our Privacy Policy or how we handle your personal information, or we are going to use any personal information in a manner that is materially different from that stated in our Privacy Policy at the time we collected such information, we will give you a reasonable opportunity to consent to the change. If you do not consent, your personal information will be used as agreed to under the terms of the privacy policy in effect at the time we obtained that information. By using our Site or services after the Effective Date, you are deemed to consent to our then-current privacy policy. We will use information previously obtained in accordance with the Privacy Policy in effect when the information was obtained from you.
Contacting Us
If you have any questions about this Privacy Policy, or the practices of this Site, please contact us. You can also write to us at: Delfina Travel Group, Inc., 4151 Mission Blvd Suite 212, San Diego, CA 92109, USA.
