Introduction

Spirit Empire, LLC ("Spirit Empire", "we," "us," or "our") takes data privacy seriously. This Privacy Policy describes how we collect, use, share, and protect personal information when you access our website, make tour bookings, purchases, or otherwise use our services (collectively "Services"). Please review carefully.

By accessing or using any Services, you expressly agree to the collection, use, and disclosure of your personal information as outlined in this Privacy Policy. If you do not consent, please immediately discontinue all use of the Services.

What Information We Collect

We collect the information you submit during tour reservations, account registration, shopping, emails, calls with our representatives, website activity, and other transactions. This may include:

• Identity data: Full name, address, date of birth, phone number, email address, usernames and passwords

• Billing details: Payment card number, expiration date, CVC code, and billing address

• Commercial data: Information about reservations, tour history, wishlists, shopping cart contents

• Device/Usage data: IP addresses, browsing history, device characteristics, operating systems, clickstream data

Additionally, we may obtain supplementary personal information about you from third-party sources, including marketing partners and tourism platforms that help provide or enhance our Services.

How We Use Your Information

We use your personal information only as disclosed in this policy, including to:

• Provide, analyze, administer, and improve our Services

• Process payments, fulfill orders, maintain accounts

• Create reservation confirmations, send pre-tour communications

• Personalize your experience by recommending tours, remembering your preferences

• Respond to inquiries, review and address complaints

• Send tour-related announcements, updates, offers and promotions

• Protect security, investigate suspicious activity, and prevent fraud

• Comply with legal obligations and enforce our Terms of Service

• Share with trusted third-party service providers acting at our instruction (payment processors, website hosts, etc.)

• Advertise Spirit Empire tours on other platforms based on your inferred interests

Cookies and Tracking Technologies

We use tracking technologies like cookies to collect device and behavioral data. This allows understanding how you interact with our website and personalizing the Services to your preferences. You can control cookie collection in your browser or device settings, but disabling them may degrade your user experience.

How Information is Disclosed

We disclose your information only as reasonably necessary to provide Services and conduct our tour operations, including to:

• With vendors or other third parties who perform services on our behalf (e.g., IT management, payment processing, data analytics, customer support, cloud storage, fulfillment, and shipping).

• With business and marketing partners to provide services and advertise to you.

• Our business and marketing partners will use your information in their privacy notices.

• Select tour partners and tourism platforms to expand marketing and availability of tours

• When you direct, request us, or otherwise consent to our disclosure of certain information to third parties, such as to ship your products or through your use of social media widgets or login integrations, with your consent.

• With our affiliates or otherwise within our corporate group, in our legitimate interests to run a successful business.

• In connection with a business transaction such as a merger or bankruptcy, to comply with any applicable legal obligations (including responding to subpoenas, search warrants, and similar requests), to enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

Rights & Choices

Depending on where you live, you may have some or all of the rights listed below in your personal information. However, these rights are not absolute and may apply only in certain circumstances, and, in some instances, we may decline your request as permitted by law.

• Right to Access / Know. You may have a right to request access to personal information that we hold about you, including details relating to how we use and share your information.

• Right to Delete. You may have a right to request that we delete the personal information we maintain about you.

• Right to Correct. You may have a right to request that we correct the inaccurate personal information we maintain about you.

• Right of Portability. You may have a right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party in certain circumstances and with certain exceptions.

• Right to Opt out of Sale or Sharing or Targeted Advertising. You may have a right to direct us not to "sell" or "share" your personal information or to opt out of the processing of your personal data for purposes considered to be "targeted advertising," as defined in applicable privacy laws. Please note that if you visit our Site with the Global Privacy Control opt-out preference signal enabled, depending on where you are, we will automatically treat this as a request to opt out of the "sale" or "sharing" of information for the device and browser that you use to visit the Site.

• Right to Limit and/or Opt out of Use and Disclosure of Sensitive Personal Information. You may have a right to direct us to limit our use and/or disclosure of sensitive personal information to only what is necessary to perform the Services or provide the goods reasonably expected by an average individual.

• Restriction of Processing: You may have the right to ask us to stop or restrict our processing of personal information.

• Withdrawal of Consent: Where we rely on consent to process your personal information, you may have the right to withdraw this consent.

• Appeal: You may have a right to appeal our decision if we decline to process your request. You can do so by replying directly to our denial.

• Managing Communication Preferences: We may send you promotional emails, and you may opt out of receiving these at any time by using the unsubscribe option displayed in our emails to you. If you opt out, we may still send you non-promotional emails, such as those about your account or orders that you have made.

You may exercise any of these rights where indicated on our Site or by contacting us using the contact details provided below.

We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address or account information, before providing a substantive response to the request. In accordance with applicable laws, You may designate an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. We will respond to your request promptly as required under applicable law.

Data Security & Retention

While we aim to protect your data, we cannot guarantee perfect security. We retain personal information only as long as legally required or relevant for our legitimate operational purposes and managing the customer relationship.

USER-GENERATED CONTENT

The Services may enable you to post product reviews and other user-generated content. If you submit user-generated content to any public area of the Services, this content will be shared and accessible to anyone.

We do not control who will have access to the information you choose to make available to others and cannot ensure that parties with access to such information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available or for the accuracy, use, or misuse of any information that you disclose or receive from third parties.

THIRD-PARTY WEBSITES AND LINKS

Our Site may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of such sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms, may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use by us or by third-party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services.

CHILDREN'S DATA

The Services are not intended to be used by children, and we do not knowingly collect any personal information about children. If you are the parent or guardian of a child who has provided us with their personal information, you may contact us using the contact details below to request that it be deleted.

As of the Effective Date of this Privacy Policy, we do not have actual knowledge that we "share" or "sell" (as those terms are defined in applicable law) personal information of individuals under 17 years of age.

International Data Transfers

We may transfer your personal data internationally, including to the United States. All transfers out of jurisdictions with data protection laws will have appropriate safeguards as required by regulations.

Changes to this Policy

We may occasionally update this Privacy Policy to reflect changes in data practices or operational needs. We will post an updated version on our website along with a revised "Last updated" date. Continued use of Services after changes signifies acceptance.

COMPLAINTS

If you have complaints about how we process your personal information, please get in touch with us using the contact details provided below. If you are not satisfied with our response to your complaint, depending on where you live, you may have the right to appeal our decision by contacting us using the contact details set out below or lodge your complaint with your local data protection authority.

INTERNATIONAL USERS

Please note that we may transfer, store, and process your personal information outside your country, including the United States. Staff and third-party service providers and partners in these countries also process your personal information.

If we transfer your personal information out of Europe, we will rely on recognized transfer mechanisms like the European Commission's Standard Contractual Clauses or any equivalent contracts issued by the relevant competent authority of the UK, as appropriate, unless the data transfer is to a country that has been determined to provide an adequate level of protection.

contact our Data Protection Team

For privacy inquiries, requests, or complaints, please email our Data Protection Team at privacy@spiritempire.com.