1.         Scope of Privacy Policy

This policy addresses how AdeoTours (“Adeo”) treats personally identifiable information (“PII”) that Adeo collects and receives from you as a Customer, including information related to your past use of Adeo products and services.  “PII” is information about you that is personally identifiable, such as your name, physical address, e-mail address, telephone number, social security number, or other information that is not otherwise available from public sources such as telephone directories or government records.

2.         Information Collection, Use, Sharing and Disclosure

General Collection and Use:

·           Adeo collects PII when you:  (1) purchase Adeo products and services; (2) visit the Adeo web site (www.adeotours.com), or the web sites or web pages or certain Adeo contractors and suppliers; (3) communicate directly with Adeo, including e-mails and telephone calls received by our Customer Service and Privacy departments; and (4) enter any promotions or sweepstakes that Adeo may offer (although additional terms and conditions will apply to such promotions or sweepstakes).  Adeo may choose to combine your PII with information ARC obtains from its business partners or other affiliated companies for internal surveying or marketing purposes.
 
·           When you purchase products and services from Adeo you will be asked for information such as name, address, telephone number, zip code, and for payment information, such as a bank account or credit card number.
 
·           Adeo collects PII and other information about Customer transactions with Adeo and with certain affiliated business partners, agents, contractors and suppliers who assist in providing support for Adeo internal operations and services.

·           Adeo automatically receives and records information on Adeo web server logs from Customer web browsers, including Customer IP addresses, Adeo cookie information and the particular web pages a Customer requests.

·           Adeo uses Customer PII and other information Customer information collected for the following purposes:  (1) to verify the identity of individual Adeo Customers; (2) to fulfill Customer requests for Adeo products and services; (3) to enforce transactions with Customers; (4) to improve Adeo services, including the content, customization and/ or layout of the Adeo web site; (6) to conduct Customer use surveys and related research.

·           Adeo may, from time to time, provide anonymous reporting of aggregate data to affiliated parties and to unaffiliated external clients; however, such reporting will be done on an anonymous basis using aggregated data that is not displayed in such a manner that it constitutes PII for individual Adeo Customers.
 
Adeo Web Site Cookies:

·          Adeo may utilize and access Adeo cookies on Customer computers.  Adeo cookies are intended to improve and enhance Customer visits to the Adeo web site.  Adeo may use cookies for any or all of the following activities: to store Customers’ preferences; record web site session information (such as items that Customers add to their shopping cart); record Customer-specific information regarding what web pages Customers access or visit; alert Customers to new areas that Adeo believes may be of interest to them when they return to the Adeo web site; record previous Customer activities at the Adeo web site in order to provide better service when Customers return to the site; ensure that Customers or other web site visitors are not repeatedly sent the same banner ads; and customize web page content based on a Customer or visitor’s browser type or other information.

·           Although Adeo currently utilizes cookies only, Adeo reserves the right to use other methods of online Customer session tracking, including but not limited to such technologies as logging or web beacons, any time in the future.

Confidentiality and Security:

·           Adeo has internal policies and procedures designed to keep Customer PII safe. These include:

• Allowing access to Customer PII only to authorized employees, agents, contractors or suppliers who need that information to perform specific job responsibilities;

• Maintaining physical, electronic and procedural safeguards that comply with federal regulations to guard Customer PII, including appropriate security measures in place in Adeo’s physical facilities to protect against the loss, misuse or alteration of collected PII, and requiring Adeo subcontractors to employ the same safeguards;

• Training Adeo employees on privacy and implementing disciplinary procedures for any employees who violate Adeo procedures, and requiring that all Adeo subcontractors train their employees regarding Adeo privacy policies and procedures.

·           In certain areas within the Adeo web site, including the purchasing area, Adeo uses industry-standard Secure Socket Layer (“SSL”) technology and encryption to protect data transmissions.

Information Sharing and Disclosure:

·          Adeo does not rent, sell, or share PII about Adeo Customers with unaffiliated individuals or companies except to:  (1) provide Adeo Products and Services a Customer requests; and (2) under the following conditions:

• When Adeo provides PII and other information to contractors and affiliated companies who work either on behalf of or with Adeo under agreements that provide for confidentiality of PII, such affiliated contractors and companies may use Customer PII to assist Adeo in communicating with Customers; however such confidentiality provisions prevent Adeo-affiliated companies from sharing or selling PII to any third parties not under any contractual obligations to Adeo; and

• When Adeo is responding to subpoenas, court orders, or other legal process or procedure, including the requests of governmental authorities in conjunction with an investigation.

Certain Third-Party Affiliates:

·          The Adeo web site may contain links to other web sites, as well as advertisements, that are not related to contractors or suppliers affiliated with Adeo.  Adeo is not liable for the use of any web monitoring technologies employed by these other, unaffiliated web sites, and Adeo strongly advises you to familiarize yourself with such sites individual privacy policies should you decide to visit or enter PII on such sites.

3.         Children’s Online Privacy Protection Act (“COPPA”) Applicability

Adeo takes the protection of children very seriously.  Adeo has made commercially reasonable efforts to prevent children under the age of 13 from purchasing Adeo products and services.  Adeo does not direct its Web Site or portions of its Web Site to children under the age of 13, and will not contact children under the age of 13 about special offers or for marketing purposes.  Because Adeo does not target any of its products or services or its web site to children under the age of 13, and because children under the age of 13 will not be allowed to order or register for Adeo products or services, the Children’s Online Privacy Protection Act (“COPPA”) is not applicable to Adeo’s web site or online activities.

4.         Customer Requests for Information

Upon written request, Adeo will provide Customers with access to the following information that Adeo maintains: financial information (e.g. credit card account information); unique identifier information (e.g. Customer number or password); specific transaction information (e.g. dates on which Customers made purchases or ordered services, including information about the amount and types of purchases or services); communications that the Customer has directed to the Adeo Customer Service site (e.g. e-mails and Customer inquiries); contact information (e.g. name, physical address, phone number, e-mail address); and a general description of the information Adeo maintains about the Customer.  Customers can access their Customer information by sending an e-mail to Adeo Customer Service at privacy@adeotours.com, by calling 1-512-699-3467or by writing to Adeo Privacy Department, AdeoTours, 4501 Placid Place, Austin, Texas  78701.

5.         Changes To This Privacy Policy

From time to time, Adeo may use customer PII for new, unanticipated uses not previously disclosed in the current version of this Privacy Policy.  In the event this occurs, Adeo will notify you about the significant changes in the Adeo Privacy Policies, including any changes in the methods by which PII is handled, by posting prominent notice of Privacy Policy changes on the Adeo web site.  The new Privacy Policy will contain an effective date, and only the PII collected after such effective date will be used for any new purposes.  If you are concerned about how your PII is used, you should check the Adeo web site periodically.

Customers may prevent their PII from being used for purposes other than those for which it was originally collected by e-mailing ARC Customer Service at privacy@adeotours.com.

6.         Questions, Suggestions and Reports of Privacy Policy Non-Compliance

If you believe that the Adeo web site is not following its stated Privacy Policies, you may contact us at the above address, e-mail address or telephone number.