Privacy Policy

Last Updated: May 7, 2018

ETMA, Inc. (“PlacePass,” “we,” “our,” and/or “us”) operates a travel platform that helps people discover, review, and book unique experiences and activities around the world. This privacy policy (the “Privacy Policy”) explains how we collect, use, and share your Personal Information. “Personal Information” means any information relating to an identified or identifiable individual. We operate our own website at www.placepass.com and mobile application, and we also operate websites on behalf of third parties we partner with in the travel industry (our “Partners”). This Privacy Policy applies to our website, app, and any Partner website that we operate, including moments.marriott.com, or any online service where this Privacy Policy is posted (our “Services”). Beyond the Privacy Policy, your use of our Services is also subject to our Terms and Conditions moments.marriott.com/terms.

Personal Information We Collect

We may collect Personal Information about you from various sources described below. Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our Services, if that information is necessary to provide you with the Services or if we are legally required to collect it.

A. Personal Information You Provide to Us

Registration Information. When you sign up for an account, you give us your name, and email address. If you decide to sign up for an account using a third-party account such as your Marriott Rewards account, Starwood Preferred Guest account, Google account or your Facebook account, we will also get basic Personal Information from the profile associated with your account. If you sign up with your Google account, we will receive your name and the email address associated with the account. If you sign up with your Facebook account, we will receive your name, and you can optionally give us permission to access additional Personal Information such as birth date, hometown, and your friends list. If you already have an account (such as a travel rewards loyalty member account) with one of our Partners, you may be able to create an account for or log into the Services using those account credentials. You can choose not to provide Personal Information to us, but in order to receive relevant offerings from PlacePass and our Partners, and to enjoy other benefits of being a registered member, some Personal Information about you is required.

Booking Information. When you book an experience or activity through our Services, we receive information about the booking you make and all of the information you provide us in connection with the booking, such as your name, address, phone number, date of birth, and travel rewards program numbers. We also receive any other Personal Information you may provide such as your passport details, hotel arrangements, information about the people traveling with you, or other information needed to book your particular activity (e.g., your weight for a helicopter tour).

Payment Information. When you use your credit card or other payment method to book an activity or experience through the Services, a third party that handles payments for us will receive your card information. We do not store your payment information on our servers.

Communications. If you contact us directly, we may receive additional information about you. For example, when you contact our customer support team, we may receive your name, phone number, email address, the contents of a message or attachments that you may send to us, and other information you choose to provide.

Information about others. In some cases, you may provide information about other people through our Services. For example, if you book an activity or experience through the Services for someone else, you will need to submit that individual’s Personal Information. You may need to obtain consent of other individuals and inform them prior to providing us with their Personal Information, as may be necessary under applicable laws.

Content contributions. You may be able to contribute to our Services in a variety of ways, for example filling out your profile, writing reviews, sharing photos, etc. You are responsible for the information you include in your content. We may store these contributions and use them in different ways, including for promotional purposes and for display on the website.

Other. In some cases we may contact you to ask for other demographic information, such as gender, age, travel habits, country of residence, etc.

B. Personal Information We Collect When You Use the Services

Location Information. If you permit us to access location information from your device through the permission system used by your mobile platform, we will collect your location information when you use the Services in order to provide you with relevant, personalized experiences and activities based on your location. If you sign up for an account or book an experience through one of our Partner websites, or you log into our website or mobile app using an account affiliated with one of our Partners, we will share your location information with the relevant Partner.

Address Book Contacts. If you permit us to access the address book on your device through the permission system used by your mobile platform, we will access and store names and contact information from your mobile phone address book to facilitate sharing your bookings on the Services and for other purposes described in this Privacy Policy.

Device Information. We receive information from your device, including IP address, web browser type, mobile operating system version, phone carrier and manufacturer, application installations, device identifiers, mobile advertising identifiers, and, depending on whether you register with your Google or Facebook account, your Android ID or Facebook identifier.

Usage Information. To help us understand how you use the Services and to help us improve them, we automatically receive information about your interactions with the Services, like the pages or other content you view, your actions on the websites and online services, and the dates and times of your visits.

Information from Cookies and Similar Technologies. We collect information through the use of “cookies,” tracking pixels, and similar technologies to understand how you navigate through Services, to learn what content is popular, and to help us improve our algorithms and the offerings on the Services. Cookies are small text files that web servers place on your device; they are designed to store basic information and to help websites and apps recognize your browser. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be accessed every time you use the Services. We also use analytics providers such as Google Analytics cookies for these purposes, and you can find more information on how Google uses data from these cookies at google.com/policies/privacy/partners/. These analytics providers may collect or have access to information about you which they may collect over time and across different websites. You should consult your web browser(s) to modify your cookie settings. Please note that if you delete or choose not to accept cookies from us, you may be missing out on certain features of the Services.

C. Other Information We Collect from Third Parties

Our Partners. If you sign up for an account or book an experience through one of our Partner websites, or you log into our website or mobile app using an account affiliated with one of our Partners, such as your Marriott Rewards account our Starwood Preferred Guest account, we may receive additional Personal Information about you, such as loyalty points balance, demographic data and/or the location, dates, and nature of your upcoming travel, from our Partners and combine it with other information that we have about you. We use this information to personalize your experience and make relevant recommendations to you on the Services.

Suppliers. Sometimes the activity or experience you book through our Services may be supplied by a third party that is an aggregator of travel experiences and activities (“third party supplier” or “supplier”), and you will be directed to that supplier’s website to complete your booking. When you book through a supplier, the supplier may provide us with your name and email address, and the fact that you made a booking. Please note that the Personal Information you provide directly to our third party suppliers is not governed by this Privacy Policy, and you should consult the supplier’s privacy policies to learn more about how they handle your Personal Information.

How We Use the Information We Collect

We use the Personal Information we collect from users to:

  • Provide you with the Services to allow you to discover, review, and book unique experiences and activities around the world;
  • Improve, expand, and promote the Services;
  • Analyze how users interact with the Services;
  • Communicate with you, either directly or through one of our Partners, including for tailored marketing and promotional purposes and to send you text messages;
  • Analyze how users interact with the Services in order to enhance user experience;
  • Customize our offerings for you;
  • Facilitate transactions and payments;
  • Provide you with customer support; and
  • Address legal issues that may arise, comply with our legal obligations and potential requests from authorities.

If you are located in the European Economic Area, we only process your Personal Information based on a valid legal ground, including when:

  • You have consented to the processing of your Personal Information. For example, we may seek to obtain your consent to send you marketing communications.
  • We need your Personal Information to provide you with services and products requested by you, or to respond to your inquiries.
  • We have a legal obligation to process your Personal Information.
  • We or a third party, have a legitimate interest in using your Personal Information, such as to ensure and improve the safety, security, and performance of our Services.

How We Share the Information We Collect

Our Affiliates. We may share Personal Information we collect about you with our affiliates and other entities of the ETMA group of companies.

Sharing on Social Platforms. Users can choose to share the experiences and activities they have booked on the Services through social media channels such as Facebook and Twitter and via email.

Third Parties Involved in Booking Your Experiences and Activities. When you book an activity or experience through the Services, you may provide information directly to third parties that facilitate or provide the activity or experience you’ve signed up for, or we may share your Personal Information with them. For example:

  • Some experiences and activities will be booked with our third party suppliers (as described above);
  • We may share your booking information with aggregators, companies, or distributors who help facilitate or provide the experience or activity (e.g., Ticketmaster); and
  • We may share your booking information with the operator of the activity or experience (e.g., the kayaking outfitter that runs your kayaking trip).

Third Party Partners. If you sign up for an account or book an experience through one of our Partner websites, or you log into our website or mobile app using an account affiliated with one of our Partners, we will share all Personal Information that we receive from or about you with that Partner so that they can provide you with customized services and experiences that may be of interest to you.

Service Providers. We work with third party service providers to perform services on our behalf, such as to process your payment information, and we may share your Personal Information with such service providers to help us provide the Services, including to do all of the things described in Section titled “How We Use the Information We Collect.”

Third Party Advertisers. When you visit our Services, third party advertisers may set and access their own cookies, pixel tags, and similar technologies on the Services and they may otherwise collect or have access to Personal Information about you that they collect over time and across different websites. We and third party advertisers may target advertisements for products and services in which you might be interested based on your use of the Service. If you prefer to not receive targeted advertising, you can opt-out of some network advertising programs that use your Personal Information. To learn more about your choices, please visit the Digital Advertising Alliance (DAA) Opt-Out Page: http://www.aboutads.info/choices, or the Network Advertising Initiative (NAI) Opt-Out Page: http://optout.networkadvertising.org/choices. European users may opt out of receiving some targeted advertising through members of the European Digital Advertising Alliance on https://www.youronlinechoices.eu/. Please note that even if you choose to opt out, you will still see advertisements.

Other Sharing. We may share your Personal Information with other third parties in the following cases:

  • While negotiating or in relation to a change of corporate control such as a restructuring, merger or sale of our assets;
  • If a government authority requests information and we think disclosure is required or appropriate in order to comply with laws, regulations, or a legal process;
  • With law enforcement officials, government authorities, or third parties if we think doing so is necessary to protect the rights, property, or safety of PlacePass, the Services, or our users;
  • To comply with a legal requirement or process; and
  • Whenever you consent to the sharing or as otherwise permitted or required under applicable law.

Your Choices

Email Subscriptions. You can always unsubscribe from our promotional emails but we will still send you transactional emails about your bookings through the Services.

Location and Address Book Information. You can use the settings on your mobile operating system to prevent your device from sharing location information or your address book contacts with us, but please note that all features of the Services may not be available to you if you choose to turn off this sharing.

Information from Third Party Applications. If you sign up or log in to the Services using a third-party account through which we receive your contacts or friends, you can access your settings for those accounts to learn how you can control the sharing of your contacts and friends.

Editing and Accessing Your Information. You can review and edit certain account information by logging in to your account settings. If would like to close your account, please contact us at support@placepass.com or marriott-moments@placepass.com with your request. Please note that in some cases we may retain certain Personal Information about you as required by law, or for legitimate business purposes to the extent permitted by law. We may also de-identify your data and retain the de-identified data for analytics purposes.

European Users. In some countries and, in particular, if you are located in the European Economic Area, you may also have the right to request access to and receive information about the Personal Information we maintain about you, to update and correct inaccuracies in your Personal Information, to restrict or to object to the processing of your Personal Information, to have the information anonymized or deleted, as appropriate, or to exercise your right to data portability to easily transfer your Personal Information to another company.

In addition, you can withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.

You may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.

Those rights may be limited in some circumstances. You may exercise your rights by contacting us at support@placepass.com or marriott-moments@placepass.com or as indicated below.

Do Not Track. At this time we do not respond to Do Not Track signals.

Other

Data Security. We are committed to protecting your Personal Information. Even though we take reasonable precautions to protect your data, no security measures can be 100% secure, and we cannot guarantee the security of your data.

Data Retention. We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep it for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.

Data Transfers. The Services are hosted in the United States. If you are accessing the Services from the European Union or other region with laws or regulations governing Personal Information collection, use, and disclosure that differ from United States laws, please note that we may transfer your Personal Information to countries other than the country where you are located, including to the United States, for storage and processing. By providing your information you consent to any transfer and processing in accordance with this Privacy Policy.

California Privacy Rights. California Civil Code Section 1798.83 permits users who are California residents to request and obtain from us once a year, free of charge, information about certain personal information we disclose to third parties for their direct marketing purposes in the preceding calendar year. This information includes a list of the categories of personal information that we shared and the names and addresses of all third parties with which we shared the information. If you are a California resident and would like to make such a request, please submit your request in writing to: Attn: PlacePass. 77 Summer Street, 10th Floor, Boston, MA 02111.

Children’s Privacy. The Services are not directed to children, and we don’t knowingly collect Personal Information from children under 16. If we find out that a child under 13 has given us Personal Information, we will take steps to delete that information. If you believe that a child under the age of 16 has given us personal information, please contact us at Attn: PlacePass. 77 Summer Street, 10th Floor, Boston, MA 02111.

Changes to Our Privacy Policy. We may make changes to this Privacy Policy from time to time. If we make any material changes, we will let you know through the Services, by email, or other communication. We encourage you to read this Privacy Policy periodically to stay up-to-date about our privacy practices. As long as you use the Services, you are agreeing to this Privacy Policy and any updates we make to it.

Contact Information. ETMA Inc., d/b/a PlacePass are responsible for the processing of your Personal Information described in this Privacy Policy. Feel free to contact us at any time with any questions or comments about this Privacy Policy, your Personal Information, our use and sharing practices, or your consent choices or other rights by contacting us at support@placepass.com or marriott-moments@placepass.com or Attn: PlacePass. 77 Summer Street, 10th Floor, Boston, MA 02111, USA.

ETMA Inc. operates moments.marriott.com on behalf of Marriott International, Inc. located at 10400 Fernwood Road, Bethesda, MD 20817, USA.  For information on Marriott’s privacy practices, please consult Marriott’s privacy policy.