Effective 1/28/2021

Introduction
S & D Vacations LLC (dba Tourissimo) is committed to respecting your privacy. This Privacy Policy (“Privacy Policy”) describes how we collect, process, and share your Personal Data (defined below). We also describe your rights and choices with respect to your Personal Data and other important information. Please read this Privacy Policy carefully and contact us if in doubt.

Scope 
This Privacy Policy applies to Personal Data collected through our “Services”, which include:
• Our “Tour Programs”- Services you use when you travel with companies operated by S & D Vacations;
• Our “Digital Services” – Our websites and other online services, including data collected when you interact with or reference our products/services or advertisements online.
Note that certain third parties may be able to identify you across sites and services using the information they process, however, any such processing not done at the direction of S & D Vacations is outside the scope of this Privacy Policy.

Who we are
S & D Vacations LLC is a company registered and based in Massachusetts (USA), 184 Park Ave, Bridgewater 02324.  Tourissimo is the commercial brand of the company.  

How to Contact Us

If you have any comments or questions about this Privacy Policy or privacy practices, please contact our office at:
S & D Vacations LLC
Attn: Heather Dowd
184 Park Ave
Bridgewater, MA - 02324

General Inquiries and Data Updates: info@tourissimo.travel
Marketing Choices: If you would like to make changes to your communications preferences, click the link in any email from us, or send us an email at info@tourissimo.travel.

Categories and Sources of Personal Data

The following describes how we process data relating to identified or identifiable individuals and households (“Personal Data”), including the categories of Personal Data, its sources, and the purposes for which we process that data.

The categories of Personal Data we process
The categories of Personal Data we collect and use include (these are examples may be subject to change):

Identity Data
Information such as your name; address; email address; telephone number; gender; date of birth, age and/or age range; account login details, including your user name and password, or other account-related information; information you provide in connection with your application to be a vendor, volunteer, employee, or otherwise join or support our team; your identity, public profile, and similar information from social networks such as Facebook. 

Contact Data
Identity Data that relates to information about how we can communicate with you, such as email, phone numbers, physical addresses, social media handles, and information you provide to us when you contact us by email or when you communicate with us via social media.

Device/Network Data
Browsing history, search history, and information regarding your interaction with our web site, application, or advertisement (e.g. IP Address, MAC Address, SSIDs or other device identifiers or persistent identifiers), online user ID, device characteristics (such as browser/OS version), web server logs, application logs, browsing data, first party cookies, third party cookies, web beacons, clear gifs and pixel tags.

Commercial Data
Information about the Services we provide to you and about reservations and transactions you make S & D Vacations or other companies operating through us or on our behalf (including travel agents), information relating to events and services at our properties and locations you attend/use, information about purchases, what has been provided to you, when and where and, if applicable, how much you paid, and similar information.

Inference Data
Personal Data used to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes, market segments, likes, favorites and other data or analytics provided about you or your account by social media companies or data aggregators, including household data such as income, number of children, occupation, social grade, home ownership status, the products and services you use or intend to use or purchase, and your interests.

Audio/Visual Data
Recordings and images collected during a Tour Program you've joined, as well as audio files and records, such as voice mails, call recordings, and the like.

Health Data
Information about your health so that we can provide or adjust certain services or make recommendations on suitable Tour Programs. 

User Content
Unstructured/free-form data that may include any category of Personal Data, e.g. data that you give us in free text fields such as comment boxes, answers you provide when you participate in sweepstakes, contests, votes and surveys, including any other Personal Data which you may provide through or in connection with our Services.

Sources of Personal Data
We collect Personal Data from various sources, which vary depending on the context in which we process that Personal Data:
Data you provide us
We will receive your Personal Data when you provide them to us, when you purchase our products or services, or complete a transaction via our Services, or when you otherwise use our Services.

Data we collect automatically
We collect Personal Data about or generated by any device you have used to access our Services, the websites of subsidiary companies the websites of any service provider used to purchase accommodations at properties or travel with companies operated by S & D Vacations. 

Data we receive from service providers & Agents
We receive Personal Data from travel agents who transfer Personal Data to us when you purchase services from them in connection with Services that we provide, and other service providers performing services on our behalf.

Data we receive from aggregators and advertisers
We receive Personal Data from ad networks, behavioral advertising vendors, market research, and social media companies or similar companies that provide us with additional Personal Data such as Inference Data.

Data we receive from social media companies
We receive Personal Data from Facebook and other social media companies who may transfer Personal Data to us when you register for one of our Services or interact with that social media company on or in connection with our services, properties or locations.

Data we create and infer
We, certain partners, social media companies, and third parties operating on our behalf create and infer Personal Data such as Inference Data or Aggregate Data based on our observations or analysis of other Personal Data processed under this Policy, and we may correlate this data with other data we process about you. We may combine any Personal Data about you that we receive from you, from other companies within our family of companies, and from third parties.

How We Process Personal Data

When you use our Services, we process your Personal Data in specific contexts and for certain specified purposes, as well as for our general business purposes and, in some cases, for commercial purposes.

How we Collect and Use Personal Data
We collect and process Personal Data in several contexts when you use our Services, including:
• When you make a purchase or other transaction through our Service
• When you purchase and join a Tour Program
• When you access or use our Digital Services
• Cookies and other tracking technologies
• When you enter a contest or other promotion
• When you contact us or submit information to us
• Feedback and Surveys
• Applications for employment or to provide services

See below for more information regarding the context in which we process Personal Data.

When you make a purchase or other transaction through our Service
We generally process Identity Data, Financial Data, Commercial Data and Contact Data when you engage in a purchase and sale transaction, whether through our Digital Services or in person. We process this Personal Data as necessary to perform or initiate a contract with you, process your order and payment, and carry out fulfillment and delivery. In addition, we may also collect or create Device/Network Data and Inference Data. This data, together with other data we collect in this context is used as necessary in connection with certain legitimate business interests, such as:
• ensuring the security of our Services and to prevent fraud;
• providing you with information about our Services, to contact you about administrative matters, to manage and respond to any queries or complaints you make or any correspondence you send us.

We may also use this Identity Data, Commercial Data, Contact Data, and Device/Network Data collected in this context for our Commercial Purposes.

When you join a Tour Program or travel with S & D Vacations
We generally process Identity Data, Commercial Data, Financial Data, and Contact Data when you interact with us Offline. In addition, we may process this data in combination with Inference Data and Location Data that we collect and/or create as necessary in connection with certain legitimate business interests in:
• verifying your identity for authentication and security purposes;
• helping us to ensure our customers are genuine and to prevent fraud; and
• to help us to return lost property to its rightful owner.

Note, in certain cases, we may collect Health Data. Health Data is generally used so that we can provide certain services to you such as to provide you with tailored services or in connection with our response to health-related incidents that may have taken place while traveling with S & D Vacations. In each case, where consent is required by law, we will process this information only with appropriate consent.

We may also use this Identity Data, Commercial Data, and Contact Data collected in this context for Commercial Purposes.

When you access or use our Digital Services
When you use our Digital Services, we automatically collect and process Device/Network Data. We use this data as necessary to initiate or fulfill your requests for certain features or functions through our Services, such as keeping you logged in, delivering pages, etc. In addition to Device/Network Data, we may also collect and process Contact Data, Identity Data and Inference Data that we collect, create, and/or receive (including through the use of cookies and similar technologies). We typically use this data as necessary in connection with certain legitimate business interests, such as:
• ensuring the security of our websites and other technology systems;
• analyzing the use of our Services, including navigation patterns, clicks, etc. to help understand and make improvements to the Services.

Some Digital Services may, with your consent, process Location Data. We use this data, together with Inference Data, and Device/Network Data in order to provide directions and contextual information to you, and other features that require the use of location. We may also use this information in connection with our legitimate business interests, such as, creating aggregate information about users’ location and patterns, which we use to help improve our Services. Note, Location Data may be required in order for you to use certain features of our Digital Services. We may also process Identity Data, Contact Data, and User Content if you interact with or identify us, relevant promoters, or other partners on social media platforms. Note, Personal Data processed when you submit information to us (such as when you make a reservation) may involve processing through Digital Services.
We may also use Identity Data, Device/Network Data, Location Data, Inference Data and Contact Data collected in this context for Commercial Purposes.

Cookies and other tracking technologies
We use cookies and similar technologies on our Digital Services. These technologies can be used to collect or create Identity Data, Device/Network Data, Contact Data, or Inference Data. Third parties may be allowed to view, edit, or set their own cookies or place web beacons on our websites. Cookies and web beacons allow us and third parties to distinguish you from other users of our websites, and some of these technologies can be used by us and/or our third party partners to identify you across platforms, devices, sites, and services. Third parties may engage in targeted advertising using this data.

We and authorized third parties may use cookies and similar technologies for the following purposes:
• for “essential” or “functional” purposes, such as to enable certain features of our Digital Services (for example, to allow a customer to maintain a basket when they are shopping at an online store);
• for “analytics” purposes, such as to analyze the traffic to and on our Digital Services (for example, we can count how many people have looked at a specific page, or see how visitors move around the website when they use it, what website they visited prior to visiting our website, and use this information to understand user behaviors and improve the design and functionality of the website);
• for “retargeting” or similar advertising or commercial purposes, such as:
• for social media integration e.g. via third-party social media cookies, or when you share information using a social media sharing button or “like” button on our Services or you link your account or engage with our content on or through a social networking website such as Facebook or Twitter;
• to collect information about your preferences and demographics to help target advertisements which are more likely to be of interest to you using behavioral advertising; and
• to allow us to carry out retargeting (this includes, for example, when advertisements are presented to you for products or services which you have previously looked at on a website but have not purchased).

The use of these technologies by third parties may be subject to their own privacy policies and is not covered by this Privacy Policy, except as required by law.
We may also use your Identity Data, Device/Network Data, Inference Data and Contact Data collected in this context for Business Purposes and Commercial Purposes.

When you enter a contest or other promotion
We collect and process Identity Data, Contact Data, and User Content as necessary to process your request to enter the contest, or take part in a promotion, notify you if you have won or to process delivery of a prize or for other related purposes.

In addition, we may process this information in connection with our legitimate business interests, such as:
• verifying your identity for authentication and security purposes (in which case we may process Government ID Data to complete verification); and
• helping us to ensure our customers are genuine and to prevent fraud.

Note, if you win a contest/sweepstakes, we may publicly post some of your data on our website (for example acceptance of a prize may also require you to allow us to post publicly some of your Personal Data such as on a winners’ page). Where required by law, your information will not be posted without your consent. Unless prohibited by law, we may use this Identity Data, Contact Data, and User Content information for Commercial Purposes.

When you contact us or submit information to us
We collect and process Identity Data, Contact Data, and any Audio/Visual data or User Content you provide as necessary to address your request, fulfill the business purpose for which that information was provided, or for other related purposes. Additionally where you consent, if relevant to your request (such as an inquiry regarding a product, service, etc.) or if otherwise permitted by law, we may send you marketing communications as described further below, and use this information for Commercial Purposes.

Feedback and Surveys
We generally process Identity Data, Contact Data, Inference Data, and User Content collected in connection with guest surveys or questionnaires. We generally process this Personal Data as necessary to respond to guest requests/concerns, and create aggregate analytics regarding guest satisfaction. We may store and analyze feedback for our purposes, for example, to personalize the services, and help recommend relevant offers or services. We may also use the Identity Data, Contact Data, Inference Data, and User Content collected in this context for Business Purposes and Commercial Purposes.

Employment & Service Provider Applications
We may process Personal Data in connection with your application to be a vendor, employee, or otherwise join or support our team. We process this Personal Data primarily in connection with the personnel relationship. 

How we Process Personal Data for Business Purposes
We and our service providers process Personal Data we hold for numerous business purposes, depending on the context of collection, your rights and choices, and our legitimate business interests. For example, we generally process Personal Data:
• In connection with providing our services, and fulfilling our contractual obligations to you
• To maintain the quality and stability of, and generally improve, our Services
• To secure our properties and services, and prevent fraud
• To personalize the Services, and in connection with marketing and advertising, including behavioral advertising
• To compile aggregate statistics regarding the use of the services, and for research and market analysis
• To comply with the law, and for other purposes in the public interest

Service Provision and Contractual Obligations
We process any Personal Data as is necessary to provide our Service, to provide you with the products and services you purchase or request, to authenticate users and their rights to access the Service, or various data, features, or functionality, and as otherwise necessary to fulfill our contractual obligations to you, and provide you with the information, features, and services you request. Additionally, we use information to authenticate your right to access our properties and locations, deliver products and services, and for other related matters. Similarly, we may use Personal Data as necessary to audit compliance, and log or measure aspects of service delivery (e.g. to document ad impressions).

Internal Processing and Service Improvement
We may use any Personal Data we process through our Services as necessary in connection with our legitimate business interests in improving the design of our Service, understanding how are Services are used or function, for customer service purposes, in connection with logs and metadata relating to service use, and for debugging and similar purposes relating our identification of errors and improving the stability of the Service. Additionally, we may use Personal Data to understand what parts of our Service are most relevant to Users, how Users interact with various aspects of our Service, how our Service performs or fails to perform, etc., or we may analyze use of the Service to determine if there are specific activities that might indicate an information security risk to the Service or our Users.

Security and Incident Detection
Whether online or off, we work to ensure that our Services are secure. We may process any Personal Data we collect in connection with our legitimate business interest in ensuring that our Tour Programs and related processes and services are secure, identify and prevent crime, prevent fraud, and ensure the safety of our guests. Similarly, we process Personal Data on our Digital Services as necessary to detect security incidents, protect against, and respond to malicious, deceptive, fraudulent, or illegal activity. We may analyze network traffic, device patterns and characteristics, maintain and analyze logs and process similar Personal Data in connection with our information security activities.

Compliance, health, safety, public interest
We may also process any Personal Data as necessary to comply with our legal obligations, such as where you exercise your rights under data protection law and make requests, for the establishment and defense of legal claims, or where we must comply with our legal obligations, lawful requests from government or law enforcement officials, and as may be required to meet national security or law enforcement requirements or prevent illegal activity. We may also process data to protect the vital interests of individuals, or on certain public interest grounds, each to the extent allowed under applicable law. Please see the data sharing section for more information about how we disclose Personal Data in extraordinary circumstances.

Aggregated data
We process Personal Data about our customers and users in order to identify trends (to create aggregated and anonymized data about our customers/users, buying and spending habits, use of our Services, and other similar information (“Aggregated Data”). We may pass Aggregated Data to the third parties referred to in the section below to give them a better understanding of our business and to bring you a better service. Aggregated Data will not contain information from which you may be personally identified.

Personalization
We process certain Personal Data as necessary in connection with our legitimate business interest in personalizing our Digital Services. For example, aspects of the Digital Services may be customized to you so that it displays your name and other appearance or display preferences, to display content that you have interacted with in the past, or to display content that we think may be of interest to you based on your interactions with our Digital Services and other content. This processing may involve the creation and use of Inference Data relating to your preferences.

Other Business Purposes
If we process Personal Data in connection with our Service in a way not described in this Privacy Notice, this Privacy Notice will still apply generally (e.g. with respect to your rights and choices) unless otherwise stated at collection. We will process such information in accordance with the notice provided at the time of collection or in a manner that is necessary and proportionate to achieve the operational purpose for which the personal information was collected or processed or for another operational purpose that is compatible with the context in which the personal information was collected.

How we Process Personal Data for Commercial Purposes
We and certain third parties process Personal Data we hold for certain purposes, depending on the context of collection and your rights and choices:
• Marketing communications
• To create marketing profiles
• In connection with online advertising, including targeted advertising

S & D Vacations does not sell data. 

Personalization & Consumer Profiles
In order to understand our customers’ preferences, and better recommend products and services that are personalized to our prior customers, we may create a “Consumer Profile” by linking together and analyzing Personal Data collected in the following contexts:
• When you make a purchase or other transaction through our Service
• When you stay at properties or travel with companies owned or operated by S & D Vacations.
• When you access or use our Digital Services
• Cookies and other tracking technologies
• When you enter a contest or other promotion
• When you contact us or submit information to us
• Feedback and Surveys

We use Consumer Profiles for our legitimate interests in market research and statistical analysis in connection with the improvement of our Services. For example, we may analyze the Personal Data of people who have made a reservation for a particular itinerary in the past and compare them with other people in our database. If we identify people in the database who have similar Personal Data to the previous guests, we may then target marketing about a future event to the new people we have identified in our database, for example by sending marketing emails. We may conduct the profiling and send the direct marketing emails automatically. We may also use this information for other Commercial Purposes.

Marketing Communications
Consistent with our legitimate business interests, we (or if appropriate, our third-party partners) may send you marketing and promotional communications if you sign up for such communications or purchase products or services from us. Where allowed, we may also send you these communications if you register for our Services or for a promotion, or in connection with your communications with or submission of User Content to us. These communications may be personalized or customized based on your user profile.

Similarly, we may also collect Device/Network Data and contact data so that we can determine whether you have opened an email or otherwise interacted with our communications, and we may generate Inference Data based on these interactions. We may also process this Personal Data for targeted advertising. However, where consent to processing is required by law, we will link and process this information for targeted advertising with appropriate consent.

Targeted advertising
S & D Vacations, and certain third parties operating on or through our Services, may engage in targeted advertising. This form of advertising includes various parties and services providers, including third party data controllers, engaged in the processing of Personal Data in connection with advertising. These parties may be able to identify you across sites, devices, and over time.

The parties that control the processing of Personal Data for behavioral advertising purposes may create or leverage information derived from personalization and profiling. In some cases, these parties may also develop and assess aspects of a profile about you to determine whether you are a type of person a company wants to advertise to, and determine whether and how ads you see are effective. These third parties may augment your profile with demographic and other Inference Data derived from these observations, and may also track whether you view, interact with, or how often you have seen an ad, or whether you complete a purchase for a good or services you were shown in an advertisement.

We generally use targeted advertising for the purpose of marketing our Services and third-party goods and services, to send marketing communications, including by creating custom marketing audiences on third-party websites (such as Facebook).

Data Sales
S & D Vacations does not sell data.

How we Retain Your Personal Data

We retain Personal Data for so long as it, in our discretion, remains relevant to its purpose, and in any event, for so long as is required by law. We will review retention periods periodically and may sometimes pseudonymize or anonymize data held for longer periods, if appropriate.

Your Rights & Choices

You may have certain rights and choices regarding the Personal Data we process. Please note, these rights may vary based on the country or state where you reside, and our obligations under applicable law.

To the extent applicable law grants you the right to do so, and subject to any necessary verification, you may have the right to:
• request that we provide you with a copy of the Personal Data which we hold about you;
• request that we update any of your Personal Data which are inaccurate or incomplete;
• request that we delete any of your Personal Data which we are holding; or
• request that we provide your Personal Data to you or a third-party provider of services in a structured, commonly-used and machine-readable format.

To submit a request, you may contact our Data Privacy Team. Your request must include your name, email address and postal address and we may require proof of your identity.

Your Choices
Marketing Communications.
You can withdraw your consent to receive marketing communications by clicking on the unsubscribe link in an email. You can also withdraw your consent to receive marketing communications or any other consent you have previously provided to us by contacting us. To opt-out of the collection of information relating to email opens, configure your email so that it does not load images in our emails.

Withdrawing Your Consent/Opt-Out
Where we are processing your Personal Data based on your consent, you may change your mind and withdraw your consent at any time. The consequence of you withdrawing consent might be that we cannot perform certain services for you, such as location-based services, personalization or providing certain types of advertising, or other services conditioned on your consent or choice not to opt-out.

Location Preferences
You may control or limit location data that we collect through our Services by changing your preferences in your device’s location services preferences menu, or through your choices regarding the use of Bluetooth, WiFi, and other network interfaces you may use to interact with our Services. Note, general location data may still be collected if you opt out of specific location services.

Do-not-Track
Our Services do not respond to your browser’s do-not-track request. If you do not want information collected through the use of cookies, you can manage/deny cookies (and certain technologies) using your browser’s settings menu. You must opt out of third party services directly via the third party. For example, to opt-out of Google’s analytic and marketing services, visit Google Analytics Terms of Use, the Google Privacy Policy, or Google Analytics Opt-out.

Advertising
You may opt out or withdraw your consent to behavioral advertising. In some cases, we may be able to process third party opt-out requests directly (e.g. when you click the “do not sell my personal information” link on our website), however in some cases, you must opt out of third party services directly via the third party. For example, to opt out of Google’s use of cookies, visit Google’s Ads Settings, here

How we protect your Personal Data

We use industry standard technical and organizational security measures to protect your Personal Data. We cannot guarantee the security of your Personal Data when you transmit it to us, and any such transmission is at your own risk.

Where we have given you (or where you have chosen) a password which enables you to access one of our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone (including us).

Third Party Websites and Mobile Applications
We are not responsible for the privacy policies, content or security of any linked third party websites or mobile applications. We recommend that you check the privacy and security policies of each and every website and mobile application that you visit.

Minors

Do not access or use the Services if you are not of the age of majority in your jurisdiction unless you have the consent of your parent or guardian.

Changes to our Privacy Policy

We reserve the right to change our Privacy Policy from time to time. Any such changes will be posted on this page so that we can keep you informed about how we process your Personal Data. We recommend that you consult this page frequently so that you are aware of our latest Privacy Policy and can update your preferences if necessary. Your continued use of our Services shall constitute your acceptance of any revised Privacy Policy.