TRVL LABS PRIVACY POLICY

Last Updated: 22 June 2022

TRVL Holdings Ltd, a company incorporated in the British Virgin Islands the owner and operator of trvl.com/TRVL Labs (hereinafter referred to as “TRVL”, “we” or “us”) recognises the importance of privacy. In this privacy policy, we describe how we collect, use, and disclose information that we obtain about visitors to our website, www.trvl.com, and the services available through our website.

1. Information we collect

We collect personal information directly from you, from third parties, and automatically through your use of our website. We may combine information automatically collected with other information that we have collected about you.

Personal information is any information that is about you.

We are the Data Controller for data collected through our website.

If you are in the EU or the UK, the lawful basis when we process your personal information for the provision of our services is pursuant to a contract.

If you are in the EU or the UK, the lawful basis when we process your personal information for marketing is consent.

You may browse and use certain portions of our website without directly providing us with any personal information.

Certain features, however, may only be used by users that are registered or where you provide us with personal information.

Information we may collect from you (or someone acting for you):

• contact information, including your name, address, email address, telephone number and other contact details;
• billing or payment information, such as your credit card number, cardholder name, expiration date, authentication code and billing address;
• details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries; and
• information you provide to us through customer surveys or feedback.

Information about you we collect from third parties. If you apply to work with us, we collect information from you from:

• recruitment consultants;
• your previous employers; and
• other organisations that are authorised to give us information about you

to assist to decide whether we can work with you.

Information we collect automatically. We automatically collect information through your use of our website using cookies and other technologies. This information includes your

• domain name, operating system, settings and system configurations,
• IP address,
• the webpages you access within our website,
• the website that led you to our website,
• the website to which you go after leaving our website;
• the dates and times you access our website, and
• web log personal information.

2. How we use your information

We use your information for the following purposes:

• Providing our services. Provide any TRVL token related services on the website including selling TRVL tokens, staking TRVL tokens, to manage any account you may open with us, to communicate with you, including via email, about your use of our services, to respond to your inquiries, and for similar customer service purposes.
• Marketing. Where you consent, we will provide you with news, special offers, promotions, and information about products we think may interest you; and for other marketing, advertising, and promotional purposes provided that you have not opted-out of receiving such communications.
• Analysing Use of Our Services. To better understand how users access and use our website and services, on an aggregated basis; to respond to user desires and preferences; and for other research and analytical purposes.
• To Protect Rights and Interests. To protect our rights and interests as well as the rights and interests of our customers, users of our website or services, and any other person.

3. Marketing

TRVL would like to send you information about products and services of ours that we think you might like.

If you have agreed to receive marketing, you may always opt out at a later date.

You have the right at any time to stop us from contacting you for marketing purposes.

If you no longer wish to be contacted for marketing purposes, please click the ‘Unsubscribe’ button contained in the footer of each of our emails or contact us at [email protected].

4. How we store your personal information

We undertake a number of physical, administrative, personnel, and technical measures to protect your personal information and prevent it from misuse, interference and loss, as well as unauthorised access, modification or disclosure. Our data security measures include, but are not limited to: Secure Sockets Layer (SSL) encryption technology, pseudonymisation, internal data access restrictions, and strict physical access controls to buildings & files.

TRVL will keep your personal information for the duration that your account is active, and for the requisite period in accordance with applicable law following the deactivation of your account. Once this time period has expired, we will delete your personal information.

5. Security

We take reasonable steps to protect your personal information from misuse, loss, unauthorised access, modification or disclosure. For example, we take steps to destroy or permanently de-identify personal information if we no longer need it for any purpose. Please be aware that despite our efforts, no personal information security measures can guarantee 100% security.

If you have an account with us, you should take steps to protect against unauthorised access to your account by, among other things, choosing a robust password that nobody else knows or can easily guess and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorised password activity.

6. How we disclose your information

We may disclose your information, including personal information, with the following entities:

• Service Providers. We disclose your information to our vendors, service providers, or others who perform functions on our behalf. All service providers are required to keep your personal data safe, and process pursuant to a data processing agreement. If the service provider is located outside of the UK or the EU, we put in place measures to ensure that your information has the same level of protection.
• Cross Border Disclosure of Information. We may disclose your personal information to international third parties, including countries outside the European Economic Area (EEA) (collectively “Cross-border Disclosure”), generally to provide the services offered to you. Whenever we perform Cross-border Disclosures, we will do so in accordance with applicable law and ensure that a similar degree of protection is afforded to it by implementing appropriate safeguards. Cross-border Disclosures outside the EEA will only be made:

1. to a country recognised by the European Commission as providing an adequate level of protection; or
2. to a country which does not offer adequate protection, but whose transfer has been governed by the standard contractual clauses of the European Commission, or by implementing other appropriate cross-border transfer solutions to provide adequate protection.

We may also disclose your information, including personal information, in the following ways:

• Business Transfers. We may disclose your information to another entity if we are acquired by or merged with another company, if we sell or transfer a business unit or assets to another company, as part of a bankruptcy proceeding, or as part of a similar business transfer.
• Protecting Rights and Interests. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms and Conditions or this privacy policy, or as evidence in litigation in which we are involved.

7. Cookies and other tracking mechanisms

We and our service providers use cookies and other tracking mechanisms to track your use of our website or services. We use these in a range of ways including:

• Keeping you signed in;
• Understanding how you use our website;
• Functionality - TRVL uses tracking mechanisms so that we recognise you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party tracking mechanisms are used; and
• Advertising - TRVL uses these tracking mechanisms to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. TRVL shares some limited aspects of this personal information with third parties for advertising purposes. We also share personal information collected through tracking mechanisms with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

Types of tracking mechanism we use:

• Cookies. We or our service providers use cookies to track visitor activity on our website. A cookie is a text file that a website transfers to your computer's hard drive for record-keeping purposes. We or our service providers may use cookies to track user activities on our website, such as the pages visited and time spent on our website. Most browsers allow users to refuse cookies. The ‘Help’ portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Users who disable cookies may not be able to browse certain areas of the website; and
• Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies, which are embedded invisibly on web pages. We or our service providers may use clear GIFs (also known as web beacons, web bugs or pixel tags), in connection with our website to track the activities of visitors to our website, help us manage content, and compile statistics about usage of our website. We or our service providers also use clear GIFs in HTML emails to our users, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

8. Third-party analytics

We use service providers, such as Google Analytics demographics and interests reports as well as advertising reporting features, to evaluate the use of our website and our services. We or our service providers use automated devices and applications to evaluate use of our website and services. We or our service providers use these tools to help us improve our website, services, performance, and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or Flash LSO, to perform their services. To opt out of Google Analytics, go here. To opt out of Google Analytics for display advertising or customise Google display network ads, you can visit the Google Ads Settings page.

9. Interest-based advertising

We use third parties such as network advertisers to serve advertisements on our website and on third-party websites or other media (e.g., social networking platforms). This enables us and these third parties to target advertisements to you for products and services in which you might be interested.

Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance ("DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative ("NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.

Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies' delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our website. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA's website at www.aboutads.info or the NAI's website at www.networkadvertising.org.

10. User-generated content

Note that if you post information in a publicly accessible portion of our website or service, it may be viewed by other users and potentially be further disclosed by those users. Please exercise caution when deciding to disclose such information.

11. Your choices

We take steps to ensure the personal information that TRVL collects, uses or discloses is accurate, complete and up-to-date.

You may modify your personal information by updating your account on our website or by contacting us at [email protected]. On request, we will give you access to the personal information we hold about you. If any personal information we hold about you is out of date or inaccurate, we encourage you to let us know by contacting us using one of the methods listed above and ask us to correct it.

If you are a registered user, we may send periodic informational emails to you. You may opt out of such communications at any time by following the opt-out instructions contained in the email. Please note that it may take up to five business days for us to process opt-out requests.

If you opt out of receiving emails about recommendations or other information we think may interest you, we will still send you emails about your account or any services you have requested or received from us provided that you have not opted-out of receiving such emails.

12. Your Rights

The right to access – You have the right to request us for copies of your personal information. We may charge you a small fee for this service.

The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete the information you believe is incomplete.

The right to erasure – You have the right to request that we erase your personal information, under certain conditions.

The right to restrict processing – You have the right to request that we restrict the processing of your personal information, under certain conditions.

The right to object to processing – You have the right to object to our processing of your personal information, under certain conditions.

The right to personal information portability – You have the right to request that we transfer the personal information that we have collected to another organisation, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at [email protected].

13. Children

Our website is not targeted to children under 13 years of age and we do not knowingly collect personal information from children under 13 without parental consent.

If we discover that the personal information of a child under 13 of age is in the system without parental consent, we will promptly delete such personal information from our systems.

We encourage children of all ages to obtain their parent's or guardian's permission before sharing personal information with any website.

14. External links

This website contains links to other websites. We are not responsible for the information handling practices or content of these external websites. Please read the privacy policies of these third parties before using such websites.

15. Contact us

If you have any questions or concerns about the privacy aspects of our website or services or want to complain about an interference with your privacy by TRVL, please email us at [email protected]. We will do our best to resolve your complaint as quickly as possible.

You can also contact your local data protection authority to lodge a complaint.

If you are in the EU you can find your Data Protection Authority here.

If you are in the UK you can contact the Information Commissioner’s Office here.

16. Changes to this privacy policy

We may change this privacy policy from time to time, and new versions will be posted on this website, so please check back periodically for updates.

If you are registered with us, we will let you know when we update this privacy policy.