Effective Date: [12 Sept 2025]

This Privacy Policy describes how WinkTravelDeals.com which is owned and operated by Holiay Breakz Group LLC and is located at 5380 North Valentine Ave, Apt – 102, Fresno, CA 93711, United States, (“WinkTravelDeals,” “we,” “our,” or “us”) collects, uses, shares and protects your personal information when you visit our website (www.winktraveldeals.com) or use any of our related services (collectively, the “Services”)

You agree to this Privacy Policy by accessing or using our Website or Services. Please stop using our Services immediately if you do not agree.

1. Personal Information We May Collect

“Personal Information” means information that identifies you as an individual or relates to an identifiable person. Depending on how you interact with WinkTravelDeals, we may collect:

• Full name
• Postal and billing addresses
• Telephone numbers
• Email address
• Credit/debit card number and related billing data
• Passport or government ID numbers which include TSA Known Traveler Number or similar
• Social media account IDs if you choose to connect them
• Travel details like points of departure/destination, dates, special requests, dietary or accessibility needs
• Demographic details you choose to share
• Analytics or advertising identifiers (linked to a device/user ID)
• Inferences drawn from the data listed above to personalize services

If you submit Personal Information about someone else like another traveler on your booking, you confirm you have authority to do so and to permit us to use it in line with this Privacy Policy.

2. How We Collect Personal Information

We and selected third parties collect Personal Information in several ways:

• Through the Services: When you make a booking, create an account, sign up for offers or submit special requests.
• Offline: For example, when you contact our customer support team.
• From other sources: Airlines, hotels, car rental partners, public databases, joint marketing partners or social media platforms, where allowed by law.

3. Analytics and Advertising Data

Like many online services, we and our partners automatically gather information about your device and how you use our site/apps (“Analytics/Advertising Data”) like:

• Browser, device type, operating system, screen resolution, IP address or geolocation data
• Pages visited, searches performed, links clicked, scrolling and keystroke activity, chat usage, videos viewed
• Data tied to ad views or clicks (cookie IDs, iOS IDFA, Google AAID), conversions or hashed emails/phone numbers

If we combine Analytics/Advertising Data with Personal Information, the combined data will be treated as Personal Information.

4. How We Collect Analytics/Advertising Data

• Browser/device data: Collected automatically when you access our Services.
• Website/App usage: We track date/time of visits, content viewed and files downloaded.
• Cookies and similar tools: These store or read data about your visit; see our Cookie Policy for details.
• Pixel tags & web beacons: Measure engagement with content or emails.
• Flash LSOs & similar tech: May store information about your preferences.
• IP address: Logged automatically and used to estimate location.
• Physical location: May be derived from GPS, Wi-Fi or cell signals only if you grant permission.
• Aggregated information: We may aggregate data so that it no longer identifies you.

5. How We Use Personal Information

We may use your Personal Information to:

• Complete and manage your bookings which include payment processing and customer support
• Respond to inquiries and send service updates
• Provide marketing communications or personalized offers subject to your choices
• Run promotions, contests or surveys
• Support social sharing features at your request
• Enable you to send information to another traveler or friend with their consent
• Improve our Services through analytics, research, debugging and fraud prevention
• Protect our rights, safety, property or comply with legal obligations
• Produce aggregated or de-identified data for lawful purposes
• Any other use disclosed at the time of collection or with your consent

6. How We Disclose Personal Information

We may share Personal Information with:

• Corporate affiliates under Holiay Breakz Group LLC
• Travel suppliers like airlines, hotels, car rental and insurance providers to complete your reservations
• Business partners whose services you choose or who referred you to us
• Third-party service providers (IT hosting, analytics, marketing, payment processors, customer support) under confidentiality agreements
• Promotion sponsors if you participate in sweepstakes, contests or surveys
• Social media platforms if you link your account or use sharing features (subject to your platform settings)
• Public areas (e.g., reviews, forums, blogs) where you post content — information shared here becomes public
• Corporate transactions: Your data may transfer to the new entity subject to similar protections in a merger, acquisition, financing, reorganization or sale of assets.
• Legal or security reasons: Where required by law, to protect rights, investigate fraud or enforce our Terms

7. Third-Party Services

This Privacy Policy does not cover and we are not responsible for the privacy or data handling or other practices of any third parties. This includes but is not limited to:

• Third-party suppliers or intermediaries that help fulfill your travel arrangements
• Operators of websites or services to which the Services may link
• Third parties that provide widgets, plug-ins or social sharing tools on our Services (for example, “Like,” “Share,” or similar buttons from Facebook, Instagram, X/Twitter or other platforms)

A link, feature or reference to another website or service on WinkTravelDeals.com does not imply our endorsement of that site, its content or its operators.

We are also not responsible for how other organizations like Facebook, Apple, Google, Microsoft, wireless carriers, device manufacturers or any other app or platform providers collect, use, disclose or secure information which also includes Personal Information you may choose to share with them through or in connection with the Services.

We recommend that you review the privacy policies of those third parties before providing them with your Personal Information.

8. More on Advertising

We, along with certain third-party advertising partners like ad servers, retargeting providers, measurement and attribution companies and social media platforms, may use information about you to deliver advertising that is more relevant to your interests, to the content where the ads appear or to audiences similar to you. We may also use this information to:

• Optimize and measure the effectiveness of advertising campaigns
• Provide reporting, market research or other analytics services related to advertising
• Better understand your interests and preferences

Information for these advertising-related practices is usually collected through tracking technologies like cookies, web beacons/pixels, SDKs and APIs and may be used to recognize you across different devices and services. We may share a common identifier in some cases like a hashed or encrypted email address with advertising partners to help deliver more tailored ads.

Your Choices

If you prefer not to receive interest-based advertising on web or mobile browsers, you may visit:

• networkadvertising.org/managing/opt_out.asp
• aboutads.info/choices

You can adjust your advertising preferences through the settings on those platforms if you do not wish to receive targeted ads on social media platforms.

Please note:

• The links above relate to self-regulatory programs and we may or may not work with companies that participate in those programs.
• We are not responsible for the effectiveness of or compliance with any third party’s opt-out mechanisms or the accuracy of their statements regarding those options.

9. Security

We take the protection of your Personal Information seriously and use reasonable organizational as well as technical and administrative measures to safeguard the information we collect and store. These measures are designed to prevent unauthorized access, disclosure, alteration or destruction of your Personal Information.

However, no data transmission or storage system can be guaranteed to be completely secure. While we strive to protect your information, we cannot guarantee the absolute security of any data transmitted through our Services or stored in our systems.

If you believe that your interaction with us is no longer secure like if you suspect unauthorized access to your account or a potential data breach, please contact us immediately using the details provided in the “Contacting Us” section of this Privacy Policy.

10. Opt-Out of Marketing Emails

You may opt out of receiving marketing-related emails from WinkTravelDeals.com on a going-forward basis by following the “unsubscribe” instructions included in each such email or by contacting us as described in the “Contacting Us” section below.
You may also disable push notifications from us at any time through your device settings.

We will make reasonable efforts to process your request promptly. Please note that even if you opt out of marketing communications, we may still send you important transactional or administrative messages like confirmations, security alerts or booking updates from which you cannot opt out.

11. Accessing, Correcting or Deleting Your Personal Information

If you would like to request access to, correction of or deletion of Personal Information that you have previously provided to us, you may contact us at privacy@winktraveldeals.com or by using the form or instructions provided in the “Contacting Us” section below.

We will only fulfill requests regarding Personal Information associated with the email address you use to make the request and we may require you to verify your identity before taking action for your protection. We will handle your request as soon as reasonably practicable.

Please note that we may need to retain certain information for legitimate business purposes, legal obligations or to complete any transactions that you initiated before submitting your request. Some residual data may remain in our backup systems and records even after deletion.

12. Retention Period

Unless a longer retention period is mandated or allowed by law, we will keep your personal information for as long as is reasonably necessary to fulfill the goals mentioned in this Privacy Policy.

This can entail keeping data for as long as necessary to fulfill legal requirements, settle conflicts, uphold agreements, preserve security or defend our rights and those of others.

We will take reasonable safety precautions to erase, anonymize or otherwise dispose of it, conforming with applicable law when Personal Information is no longer required for these purposes.

13. Use of the Services by Minors

Our Services are not directed to or intended for individuals under the age of 18. We do not knowingly collect Personal Information from anyone under this age.
Please do not use the Services or submit any Personal Information through them if you are under 18.

We will take reasonable steps to delete any personal information if we become aware that we have inadvertently collected it from a minor. Parents or guardians who believe that their child has provided us with Personal Information may contact us using the details provided in the Contacting Us section below.

14. Important Notice to All Non-U.S. Residents

Our servers and primary operations are located in the United States.
If you are accessing our Services from outside the US, please know that any information you provide to us including Personal Information, will be transferred to, stored in and processed in the United States. Data protection laws of the US may differ from those in your country of residence.

Your decision to provide such information or to allow us to collect it through the Services constitutes your consent to this transfer and to the processing of your information in accordance with this Privacy Policy. Except where data transfers are conditional upon specific legal requirements like under the General Data Protection Regulation (GDPR) for residents of the European Economic Area, United Kingdom and Switzerland.

15. GDPR Notice

Natural persons located in the European Economic Area (“EEA”), the United Kingdom or Switzerland should review our GDPR Privacy Notice for information about how we process personal data under the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the UK GDPR and related local laws.

Please refer to our GDPR Privacy Notice linked above for details about cross-border transfers under the EU–U.S. Data Privacy Framework and other applicable transfer mechanisms.

16. Your U.S. State Privacy Law Rights

U.S. State Privacy Laws
 Residents of California, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah or Virginia may have certain rights regarding your Personal Information under applicable state privacy laws.

Consumer Health Data Privacy
Residents of Washington State or Nevada may have rights under applicable Consumer Health Data Privacy laws.

California “Shine the Light” Law
 California residents may request information about the disclosure of their Personal Information to our affiliates and to third parties for their own direct marketing purposes as permitted by California’s “Shine the Light” law. Please contact us as described in the “Contacting Us” section below to submit such a request.

Do Not Track
 We do not currently respond to browser-initiated Do Not Track (DNT) signals or similar mechanisms except for honoring Global Privacy Control (GPC) signals as described in the U.S. State Privacy Law Notice.

17. Your Canadian Privacy Rights

Residents of Canada have specific rights regarding the collection and usage as well as disclosure of their Personal Information under Canada’s federal and provincial privacy laws including Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial legislation.

You may request information about how we collect, use and disclose your Personal Information and you may also request access to, correction of or deletion of your Personal Information in our possession, subject to applicable legal limitations.

You may also request details regarding your Personal Information’s disclosure to our affiliates and to third parties for their own direct marketing purposes. Please contact us as described in the “Contacting Us” section below to make such a request or to exercise any of your Canadian privacy rights.

We will respond to your request in accordance with applicable Canadian privacy laws.

18. Sensitive Information

We ask that you do not send or disclose any sensitive Personal Information to us on or through the Services or otherwise.

“Sensitive Personal Information” includes information like

• Social Security or other government-issued identification numbers
• Information revealing racial or ethnic origin
• Political opinions
• Religious or philosophical beliefs
• Trade union membership
• Health information
• Biometric or genetic data
• Criminal background information

If you choose to provide any such information to us, you consent to its processing and use in accordance with this Privacy Policy. We do not require this type of data for you to use our Services and we strongly recommend that you avoid sending such details unless necessary like in connection with specific travel requirements.

19. Updates to This Privacy Policy

We may update or modify this Privacy Policy including any of its constituent sections from time to time. The “Effective Date” at the top of this page shows the last revised date of this Privacy Policy.

Any changes will take effect once the updated Privacy Policy is posted on our Websites and Apps or other Services as applicable. Your continued use of these Services after we post changes means that you accept the revised Privacy Policy.

20. Contacting Us

Please contact us using one of the methods below if you have any questions or concerns or comments about this Privacy Policy or our data practices:

By Email:
 privacy@winktraveldeals.com

By Mail:
 WinkTravelDeals
c/o Holiay Breakz Group LLC
5380 North Valentine Ave, Apt 102
Fresno, CA 93711
United States

Important: Please do not include sensitive information like credit card numbers or passport details in your emails to us as email communications are not always secure.