privacy policy for california residents

[July 17, 2022]

Privacy Policy for California Residents

Effective Date: July 18, 2022

Last Updated on: July 18, 2022

This Privacy Policy for California Residents supplements the information contained in Fitness International Travel, LLC’s Website Privacy Policy www.fitnessinternationaltravel.com/privacy-policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). Fitness International Travel, LLC (“FIT” or “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 Policy.

Where noted in this Policy, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information”) from some of its requirements.

Information We Collect

Our Website collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:

·       Publicly available information from government records.

·       Deidentified or aggregated consumer information.

In particular, our Website has collected the following categories of personal information from consumers within the last twelve (12) months:

 Our Website obtains the categories of personal information listed above from the following categories of sources:

·       Directly from you. For example, from forms and information you provide.

·       Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons,] [and other tracking technologies.

Use of Personal Information

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

·       To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to sign up for our newsletter, we will use that personal information to send you our newsletter periodically. If you provide your personal information to book a reservation, we will use that information to process your payment and reservation. We may also save your information to facilitate new bookings or process refunds. We do not save your payment information for any reason.

·       To provide, support, personalize, and develop our Website, products, and services.

·       To process your requests, purchases, transactions, and payments and prevent transactional fraud.

·       To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

·       To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.

·       For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.

·       To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

·       As described to you when collecting your personal information or as otherwise set forth in the CCPA.

·       To link your contact details to our third-party vendors who provide the services as reserved in the FIT tour reservation program.

·       To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below; applicable only to clients fully booked & paid for reservations, not applicable to website visits.

We do not sell personal information. In the preceding twelve (12) months, we have not sold personal information. For more on your personal information sale rights, see Personal Information Sales Opt-Out and Opt-In Rights.

 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.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:

·       The categories of personal information we collected about you.

·       The categories of sources for the personal information we collected about you.

·       Our business or commercial purpose for collecting or selling that personal information.

·       The categories of third parties with whom we share that personal information.

·       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; and

·       disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

·       The specific pieces of personal information we collected about you (also called a data portability request).

 We do not provide a right to know or data portability disclosure for B2B personal information.

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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, ensure the right of another consumer 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 that are 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 that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

We do not provide these deletion rights for B2B personal information.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either:

·       Emailing us at privacy@fitnessinternationaltravel.com

·       Writing a letter to Fitness International Travel, 10 Middle Street, Beverly, MA 01915

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. Please email the appropriate designation documents to privacy@fitnessinternationaltravel.com or call 781.660.3453.

You may also make a request to know or delete on behalf of your child by emailing privacy@fitnessinternationaltravel.com.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

·       Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:

·       Must show government issued I.D. and/or passport. 

·       Must show government I.D. and/or passport as well as proof of guardianship.

·       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.

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, Kelly McLay at kelly@fitnessinternationaltravel.com.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons 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 useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically via mail or email. 

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.

Personal Information Sales Opt-Out and Opt-In Rights

If you are age 16 or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years old. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by emailing privacy@fitnessinternationaltravel.com.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by emailing privacy@fitnessinternationaltravel.com.

Please note – we do not currently sell any personal information. 

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

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

·       Deny you goods or services.

·       Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

·       Provide you a different level or quality of goods or services.

·       Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@fitnessinternationaltravel.com or write us at: Fitness International Travel, 10 Middle Street, Beverly, MA 01915.

Changes to Our Privacy Policy

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your information described here and in the Website Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Website: https://www.fitnessinternationaltravel.com/inquire

Email: privacy@fitnessinternationaltravel.com

Postal Address:

Fitness International Travel

Attn: CA Privacy Department

10 Middle Street, Beverly, MA 01915.

If you need to access this Policy in an alternative format due to having a disability, please contact privacy@fitnessinternationaltravel.com.