IMPERIAL CAPITALS FROM PANAMA

Zetta Travel, along with its affiliates and subsidiaries (hereinafter, "the Company," "We," or "Our"), respects your privacy and is committed to protecting it by adhering to this policy. This policy explains the types of information we may collect from you or that you provide to us when you visit our website (the "Website") or our social media platforms under our control, as well as our practices regarding the collection, use, storage, protection, and disclosure of such information.

This policy applies to the information we collect:

• Through this Website.
• By phone, email, text messages, and other electronic communication methods between you and us.
• Through mobile and desktop applications that you download from this Website, which provide a dedicated interaction outside of the browser between you and our Website.
• When you interact with our advertising and applications on third-party websites and services, provided that such applications or advertisements include links to this Website.

Please read this policy carefully to understand our practices regarding your information and how we handle it. If you do not agree with our policies and practices, we suggest that you do not use our Website. By accessing or using our Website, you agree to the terms of this privacy policy. Please note that this policy may be updated periodically (see the "Changes to Our Privacy Policy" section). Your continued use of the Website after such changes are posted constitutes your acceptance of those changes, so we encourage you to review the policy regularly to stay informed about updates.

We collect various types of information from and about users of our Website, including the following categories:

• Purchase Information: Data related to your transactions in our stores, on the Website, or through our mobile apps, such as the products you purchase, purchase frequency, and any rewards or promotions associated with those purchases.
• Personal Information: Any information by which you may be personally identified, either through your account with us or otherwise, such as your name, mailing address, email address, phone number, or other identifiers that allow us to contact you both online and offline (hereinafter referred to as "Personal Data"). The collection of this information is essential for providing our services to you.
• Device and Usage Information: Data about your internet connection (ISP), IP address, device identifiers, mobile ad IDs, the website that referred you to our site, details of the ads you click or hover over, cookies, analytics, the device used to access our Website, and details about your usage. We use cookies, web beacons, and similar technologies to collect this information.
• Location Information: Information about the location of your device, such as GPS data, to enhance or facilitate our services. This includes enabling features on our websites or mobile apps that provide you with information about nearby offers, allow you to place orders and make payments remotely, or receive certain products through third-party providers. If you wish to opt out of location information collection, please see the "Options on How We Use and Disclose Your Information" section or contact us as indicated in the "Contact Information" section.
• Public Information: Some of the information we collect is publicly available. Additionally, we may obtain information about you from third parties and other companies.

This data collection allows us to provide you with a more personalized experience and improve our services. We collect the following information from various sources:

• Directly from you, when you provide it to us.
• Automatically, as you browse our Website. Some data, such as your internet connection, the device you use to access the Website, and usage details, are collected automatically. Automatically collected information may include usage details, IP addresses, location, and information collected through cookies and other tracking technologies.
• Through third-party providers and analytics products, such as Google Analytics, to obtain, compile, and analyze information about how users interact with our Website. These providers may set cookies in your browser or mobile device or read existing cookies. Google Analytics, in particular, may also receive information about you from apps associated with Google. The information obtained by Google Analytics is not combined with personally identifiable data. If you wish, you can control the information provided to Google and opt out of certain ads using the methods outlined at Google Privacy Partners.
• From third parties, such as our business partners, affiliates, and agents.

Information You Provide to Us

The information we collect on or through our Website may include:

• General Data and Personal Data (those that allow you to be identified, such as your name, postal address, phone number, email address, date of birth, nationality, and passport details), as well as transaction-related information, such as credit/debit card details when making a purchase.
• Information provided when filling out forms on the Website, such as when registering to use the site, subscribing to our services, posting content, or requesting additional services. We also collect information when you enter a contest or promotion sponsored by us or report issues with the site.
• Correspondence records, including email addresses, if you communicate with us.
• Responses to surveys that we may request for research purposes.
• Transaction details made through our Website, as well as information necessary to complete your purchases and trips. You may be required to provide financial information, such as credit or debit card details, to process an order.
• Search queries and preferences through the use of the Website, including the option to share your location information with us and our web applications.

This data collection allows us to provide you with a personalized experience, facilitate our operations, and improve the services we offer you.

You may also provide information, feedback, or photographs to be posted or displayed (hereinafter, "User Contributions") in public areas of our Website or transmitted to other users of the Website or to third parties (collectively, "User Contributions"). Please note that your User Contributions are posted and shared at your own risk. While we offer options to limit access to certain pages and privacy settings through your account profile, no security measure is completely foolproof. Additionally, we cannot control how other users of the Website interact with your User Contributions. Therefore, we cannot guarantee that your contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

While you browse and interact with our Website, we may use automated technologies to collect information about your device, browsing patterns, and activities, including:

• Details of your visits to the Website, such as traffic data, access logs, and other communication data, as well as resources you access and use on the Website.
• Information about your computer and internet connection, which may include your IP address, operating system, and browser type.

The information we collect automatically is generally statistical in nature and does not contain personally identifiable information. However, we may link this information with personal data we have collected from other sources or received from third parties. This process helps us improve the functionality of our Website and provide you with more efficient and personalized service, including:

• Estimating the size of our audience and website usage patterns.
• Storing information about your preferences, which allows us to customize the Website according to your interests.
• Speeding up your searches within the Website.
• Recognizing you when you return to the Website.

The technologies we use for automatic data collection include:

• Cookies: These are small files placed on your computer’s hard drive. You can opt to disable cookies by adjusting your browser settings. However, if you choose not to accept cookies, you may not be able to access certain parts of the Website. Unless you have configured your browser to reject cookies, our system will issue cookies when you access our Website.
• Flash Cookies: Some features of our Website may use locally stored objects (Flash cookies) to collect and store information about your preferences and activities on the Website. Unlike traditional cookies, Flash cookies are not managed through standard browser settings. To learn more about how to disable or delete Flash cookies, refer to the section "Options on How We Use and Disclose Your Information."
• Web Beacons: Pages on our Website and emails we send may contain small electronic files known as web beacons (also called transparent gifs, pixel tags, or single-pixel gifs). These beacons allow the Company, among other things, to count users who have visited those pages or opened an email and gather statistics related to Website usage (for example, measuring the popularity of certain content or verifying the integrity of the system and server).
• JavaScript: JavaScript scripts are code snippets embedded in various parts of websites and applications that facilitate various operations, such as speeding up the update of certain features or monitoring the use of various online components.
• Entity Tags (ETags): ETags are HTTP code mechanisms that allow parts of websites to be stored or "cached" within your browser and validate these "caches" when the site is opened, improving performance by preventing the server from sending a full response if the content has not changed.
• HTML5 Local Storage: HTML5 local storage allows data to be stored or "cached" within your browser, enabling information to be retrieved on HTML5 pages when you return to the Website.

These technologies allow us to enhance the functionality and user experience on our Website, making it better suited to your needs and preferences.

Third-Party Information Collection

Some content or applications, including advertisements, on the Website are provided by third parties, such as advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies, web beacons, or other tracking technologies, either independently or in combination, to collect information about you when you use our Website. The information they collect may be linked to your personal information or may collect data about your online activities over time and across different websites and online services.

These third parties may use this information to serve you interest-based (behavioral) advertising or other targeted content. We do not control these third-party tracking technologies or how they are used. If you have questions about targeted ads or other content, we recommend that you contact the provider responsible directly.

How We Use Your Information and Legal Bases for Processing

We process your information only when necessary for the following purposes:

• Our legitimate interests: To establish and manage our relationship with you, including administrative purposes, credit assessments, marketing, and improving our Website.
• To fulfill our contractual obligations: To you, our affiliates, partners, and clients, such as sending confirmations, invoices, and travel or purchase-related documentation.
• Compliance with applicable laws and regulations: And our legal obligations, such as those related to accounting and tax requirements.

In some cases, we may seek your explicit consent to process your personal data. When this occurs, you may withdraw your consent at any time by contacting us as outlined in the Contact Information section. Withdrawing consent will not affect the legality of the processing based on your prior consent.

For example, we may use your information to contact you about our own products and services, as well as those of third parties that may be of interest to you. Additionally, we may use the information we collect to target ads to specific audiences of our advertisers. While we do not disclose your personal information for these purposes without your consent, if you interact with an advertisement, the advertiser may assume you meet the targeting criteria.

If you wish to opt-out of interest-based advertising, please refer to the Options on How We Use and Disclose Your Information section or contact us as detailed in the Contact Information section.

Disclosure of Your Information

We may disclose aggregated information about our users or information that does not identify any individual without restriction. However, we may disclose your personal information to the following recipients:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business, who are obligated to maintain the confidentiality of your personal information and use it only for the purposes for which we provide it.
• In the event of a corporate transaction, such as a merger, divestiture, restructuring, or sale of assets, including personal information about the users we hold as one of the transferred assets.
• To third parties, including suppliers, third-party vendors, business partners, and corporate affiliates, for the legitimate purposes mentioned above.
• To fulfill the purpose for which it was provided. For example, if you provide us with your email address to use the "send to a friend" feature on our Website, we will transmit the content and your address to the recipients.
• For any other purpose we have disclosed to you when you provided us with your information, with your consent, where necessary.
• To comply with a court order, law, or legal process, including responding to any government or regulatory requests. In such cases, we will share the information only with the appropriate agency, and will try to prevent its public disclosure, although we cannot be responsible if the agency discloses the information publicly.
• To enforce our terms of use or agreements related to the Website, including billing and collections.
• To protect the rights, property, or safety of VVIP, our customers, or others, which may include sharing information with other organizations to protect against fraud or reduce credit risk.

The disclosure of information in some of these cases may be necessary for proper operation and to ensure security and compliance with the law.

Options on How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide. Below are some options for controlling how we collect, use, and disclose your information when visiting our Website:

Tracking Technologies and Advertising

• Browser Cookies: You can set your browser to refuse all or some browser cookies, or to alert you when cookies are sent. If you disable or refuse cookies, some parts of our Website may not function properly.
• Flash Cookies: If you want to manage Flash cookies, you can do so by following the instructions provided on the Flash player settings page on Adobe’s website.
• Google Analytics: You can opt out of providing information to Google by using the Google Analytics opt-out browser add-on here, or by following the methods outlined in Google’s privacy policy.

Other Tracking Technologies

• Persistent Cookies: These can be deleted by following the instructions in your web browser. Session cookies disappear after you close your browser.
• Web Beacons and Entity Tags: You can reject cookies in your browser to prevent web beacons from tracking your specific activity, although some features of the Website may not function properly without cookies.
• HTML5 Local Storage: You can manage how your web browser handles these technologies or reject them according to your preference.
• Tracking Pixels: If you don’t wish to receive tracking pixels through emails, you can disable HTML images in your email client. This may affect your ability to view images in other emails you receive.

Location-Related Options

• Disable Location Collection: You can adjust your device settings so that your location information is not shared by turning off location services in your device settings or denying permission for certain websites or mobile apps.
• Device Settings: Review the relevant preferences and permissions in your mobile device or browser settings to manage location collection, which may also be derived from WiFi connection, Bluetooth, and other device settings.

Interest-Based Advertising

We do not control the collection or use of your information by third parties serving targeted ads. However, many of these third parties offer ways to opt-out of receiving interest-based ads. You can opt out of receiving targeted ads from members of the Digital Advertising Alliance (DAA) or the Network Advertising Initiative (NAI) by visiting their websites:

• DAA
• NAI

Access and Correction Rights

• Access and Correction: You have the right to access and correct the personal information we hold about you. You can request this by calling 1-800-779-0660.
• Opting Out of Marketing: If you do not wish for us to process your personal data for marketing purposes, you have the right to request that we refrain from doing so.
• Data Deletion and Portability: Under certain circumstances, you may request the deletion of your personal data or its portability.
• Exercising Your Rights: To exercise your rights or unsubscribe, you can contact us at optout@gotravelcloud.com, send a letter to the Privacy Policy Manager, Zetta Travel Group, at 3135 SW 3rd Ave, Miami, FL 33129, or call us at 1-800-779-0660.

Data Retention

We will retain your personal information only for as long as necessary to provide the services you have requested or to fulfill the purposes set out in this policy, in accordance with applicable laws.

Marketing Consent

By providing us with your personally identifiable information (PII), such as your full name, email address, and contact number, you consent to receiving telemarketing calls, text messages, and emails from Zetta Travel Group. You understand that this consent is not a condition for purchasing products or services and that you may opt out of receiving these communications at any time. You may also incur message and data fees if you receive SMS communications.

Information Security

We have implemented security measures to protect your personal information from unauthorized access, alteration, and disclosure.

• Passwords and Access: If we have provided or you have chosen a password to access certain parts of our Website, it is your responsibility to keep it confidential. Avoid sharing it with others and be careful when providing information in public areas of the Website.
• Transmission Risks: While we take measures to protect your information, data transmissions over the Internet are not 100% secure. The transmission of your personal information is at your own risk, and we are not responsible for bypassing privacy settings or security measures.

Changes to the Privacy Policy

Any changes we make to our privacy policy will be posted on this page, with a pop-up notice indicating that the policy has been updated. The date of the last revision of the privacy policy will be identified at the top of the page. We recommend reviewing this policy periodically to stay informed about any updates.

Contact Information

For questions or comments about this privacy policy, or to request the deletion or modification of the information collected, you can contact us:

• Email: privacy@zettatravel.com
• Address: Privacy Policy Manager, Zetta Travel Group, 1110 Brickell Avenue, Ste. 400, Miami FL 33131
• Phone: 1-800-976-0977

The Privacy Policy Manager will act as the responsible party for addressing any complaints or discrepancies you may have about this policy.

This section of options provides you with tools to exercise meaningful control over your personal information, helping to ensure your preferences and rights are respected in accordance with applicable law.