Indie Campers EU-GDPR Personvernerklæring

Sist oppdatert: 18. januar 2022

Indie Campers Group anerkjenner viktigheten av å beskytte personopplysningene til alle de som besøker nettstedet https://indiecampers.no eller samhandler på annen måte med en enhet i gruppen. Indie Campers Group overholder gjeldende lovgivning i denne saken, nemlig forordningen (EU/EEA) nr. 2016/679 General Data Protection Regulation ("GDPR").

1. INFORMATION WE COLLECT

During a User’s access or use of the Company Website or any other Services, the Company may, either directly or by other sources (such as Our service providers), gather, collect, record, hold, distribute, share, disclose or otherwise use personal information or data about You which You provide to Us, as described in Section 1.1 below, or which is automatically collected, as described in Section 1.2 below (hereinafter collectively referred to as the User’s “Personal Information”).

INFORMATION YOU PROVIDE TO US. We collect Personal Information that You provide to Us ( either directly or to Our other sources, such as to Our service providers or to Our Affiliates/Parent/Subsidiaries, as such term is defined in Section 3 herein), including without limitation any Personal Information You provide during Your use of the Company Website or any other Services. For example, we may collect Personal Information from You in the following circumstances: You provide Us with your Personal Information in any stage of the customer/user registration process, including without limitation when You register for an account, create or modify your profile, set preferences, sign-up for Services, fill in booking information, or otherwise make bookings through the Services. You speak with Our customer service personnel; You request, seek, or procure any of the Services; You request any customer support; You request any refund or return of any Services; You request any information from or about the Company or its affiliates, such as a newsletter, e-alert, or any other information about Our products/ services, events or business partners; You communicate with any other representative of the Company; or You otherwise communicate with Us in any other way. In these instances, the following are the types of Personal Information that may be collected from You: Your name; Mailing address and/or billing address; Phone (or mobile) number; E-mail address; Date of birth or age; Driver’s License; Passport or other citizen identification information; Your profile photo (if You use one with Your profile with Your account with Us); Certain payment and billing information (including without limitation credit or debit card information) when You make a booking or inquiry or to otherwise charge You once the booking is confirmed. You might also provide payment information, such as payment card details, which We may collect via certain payment processing services. Any other information You provide when You request, seek, or procure any of the Company’s goods/services, including product/service parameters or preferences You provided when making such request; or Information You provide involved in the return or refund of goods or services about the transaction, product details, purchase price, and the date of the transaction.

1.2 INFORMATION AUTOMATICALLY COLLECTED. When a User navigates or otherwise use the Company Website or any other Services, We may automatically collect certain Personal Information about You, including: Automatically Generated Information. We (or our service providers) may collect information about, or as a result of Your use of Your computer, tablet, phone or other device that You use to navigate or otherwise use the Company Website our any other Services, including without data identifying the Internet Protocol (IP address), type of device (including without limitation any hardware models, and operating system and version thereof), Your browser and its version, Your login and account information (including without limitation any user name, preferences regarding marketing, payment or credit card information) or data derived from observing the SSL protocol Cookies and other Web-based Tracking Technologies: We (or our service providers) may use different technologies such as cookies, web beacons, or other types of small temporary files or web-based tracking technologies to gather certain information. A cookie is a small data file stored by Your web browser on Your computer or mobile device (hard drive) that helps Us to improve the way We deliver our Company Website or other Services to You, helps Us improve Your overall experience using Our Company Website or other Services, and/or helps Us analyze the areas and features of our Services that are most popular or to detect fraud. Web beacons are electronic images that may be used in Our Services or emails and help deliver cookies, count visits, and understand usage. Like many other websites, cookies and these other web-based tracking technologies may be used by Us (or our service providers) during Your visit to the Company Website or other Services in order to improve Your individual experience as a User of the Company Website or other Services or to generally improve or enhance the overall functionality of the Company Website or other Services. While most websites automatically accept cookies for these purposes, You may be able to instruct Your browser to stop accepting cookies or prompt You before accepting a cookie from the sites You visit, including the Company Website. SEE SECTION 5.5 OF THIS PRIVACY POLICY WHICH PROVIDES FURTHER NOTICE ABOUT HOW THESE COOKIES ARE USED AND PROVIDES INSTRUCTIONS IF YOU WANT TO DISABLE ANY OF THESE COOKIES. Geo-location Data: Subject to any of Your device permissions, We (or our service providers) may be able to collect information about the precise location of your device or may gather other general location data based on GPS data, mailing address, and/or billing address (hereinafter collectively referred to as “Geo-location Data”).

1.3 EXCLUSIONS FROM PERSONAL INFORMATION SUBJECT TO THIS PRIVACY POLICY “Personal Information” for purposes of this Privacy Policy does not include any of the following types of information: (i) publicly available information from government records; and (ii) de-identified or aggregated consumer information.

2. HOW WE USE YOUR INFORMATION

2.1 PRIMARY WAYS WE USE YOUR INFORMATION. User’s Personal Information may be gathered, collected, recorded, held, or otherwise used by or on behalf of the Company( including by Our service providers) to provide, maintain, and improve our Services to You, including for the following purposes: As part our managing or administering Our contractual or business relationship with You, including without limitation the following: Pre-contractual procedures; Reservation; Signing of the vehicle rental contract without driver; Rental monitoring; Invoice management; Management of fee payments Management of potential complaints; Management of compensation for potential damage to the vehicle and insurance management; Post-rental communications; Invoice management Management of payment of your fees; Management of fines, in particular in relation to communications with competent authorities; - Management of potential complaints; Management of compensation for potential damage to the vehicle; and To send any other support and administrative messages, and to respond to any of Your other comments, questions, or customer service requests; We may use Personal Information for the purposes of sending You information and news about certain events, campaigns, special offers, products, campaign, offers, promotions or other marketing information, and We may do this using various communication channels. If you prefer not to receive promotional communications from Us, you may “Opt Out” at any time by following the “Opt Out” instructions in Section 5.1 herein; To allow You to sign up and participate in any other communication resources that We offer or support, including without limitation any newsletters or blogs. If you prefer not to continue to receive these other communications, , you may “Opt Out” at any time by following the “Opt Out” instructions in Section 5.1 herein; We may use Your Personal Information to better personalize Your experience and the advertisements and content You see when You use the Company Website or any other Services based on Your preferences, interests, and browsing and purchasing behavior; We may use Personal Information by sharing it with our Insurance providers which allows You to take out insurance for a specific rental. The insurers may need to have access to certain Personal Information about the policyholder and the insured object in order to issue and administer the requested insurance. This Personal Information is normally only passed on to the insurer if You apply for the insurance. Complete information about the insurers' processing of any such Personal Information can be found on their own websites. We may use Personal Information for compliance purposes as may be required by applicable laws or regulations or as requested by any judicial process or governmental agency (including without limitation tax reporting) or as may be requested under any subpoena; We may use Personal Information to facilitate Your use of various social media sharing features or other integrated tools (including, for example only, certain Facebook features, such as a Facebook “Like” button) which You may use as part of social media pages; or We may use Personal Information to carry out any other purpose described to You at the time the Personal Information is collected.

2.2 OTHER WAYS WE MAY USE YOUR INFORMATION. In addition to the above, Your Personal Information may be gathered, collected, recorded, held or otherwise used for the following additional purposes: To use with, or otherwise distribute, share or disclose to, any of the Company’s professional advisors such as attorneys or accountants (“Outside Professionals”) in order to facilitate the professional advice from those Outside Professionals; or To use with, or otherwise distribute, share or disclose to, any government agencies or third parties in order to comply with, or otherwise pursuant to, any subpoena, court order, or other governmental order, law or regulation (including without limitation tax reporting).

2.3 OTHER TERMS REGARDING THE USE OF YOUR INFORMATION. 2.3.1 We typically only intend to use or share Your Personal Information only for the purposes as described in this Section 2 and in Section 3 herein, unless We reasonably determine We need to use it for another reason and that reason is compatible with the original purpose(s) described herein. For example, We consider de-identification, aggregation, and other forms of anonymization of Personal Information to be compatible with the purposes listed herein and in Your interest because the anonymization of such information reduces the likelihood of improper disclosure of that information. If We need to use Your Personal Information for an unrelated purpose, We will notify You and We will explain the legal basis which allows us to do so.

2.3.2 PLEASE NOTE THAT WE MAY PROCESS YOUR PERSONAL INFORMATION WITHOUT YOUR KNOWLEDGE OR ADDITIONAL CONSENT IN COMPLIANCE WITH THIS PRIVACY POLICY AND WHERE DOING SO IS REQUIRED OR PERMITTED BY LAW INCLUDING WITHOUT LIMITATION ANY SUBPOENA OR OTHER TYPES OF COURT ORDERS.

3. SHARING OF INFORMATION

We may distribute, share or disclose Personal Information about You as follows or as otherwise described herein: Our Affiliates, Parent or Subsidiaries. We may disclose Your Personal Information with, and allow Your Personal Information to be used by, any of the Company’s affiliates, parent entity, or subsidiaries for any and all of the purposes described in this Privacy Policy, including without limitation any one of the following entities which are part of the broader Indie Campers Group: Indie Campers SA, WCC LDA, Indie Campers Spain, S.L. , Indie Campers France S.A.R.L , Indie Campers Italy S.R.L. , Indie Campers Germany GmbH , Indie Campers Belgium SPRL , Indie Campers Adriatic D.O.O. , Indie Campers UK LTD , Indie Campers Iceland, ehf. , Indie Campers Ireland Limited, Indie Campers Central Services, Unipessoal Lda, Indie Campers Netherlands, B.V. , Indie Campers Sweden AB , Indie Campers AV GmbH, INDIE CAMPERS POLAND SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, Indie Campers Finland Oy, and/or INDIE CAMPERS NORWAY AS (all of the foregoing hereinafter collectively referred to as “Our Affiliates/Parent/Subsidiaries”). Our Partners and Resellers. We work with a global network of partners (“Global Partners/Resellers”) who help us market and promote our products (for example, by providing consulting and sales services), who generate leads for Us, help Us improve Our Services and resell our Services. We may share Your information with these partners in connection with these Services, such as to assist with marketing and promotions, or as part of our agreement with them. We may also share information about You with third parties (including Our partners and resellers) when You give Us consent to do so. For example, we often display personal testimonials of satisfied customers on our public websites. With your consent, we may post your name alongside the testimonial. Advertising/Marketing Partners. We may work with third party advertising or marketing companies (collectively, “Advertising Partners”) in order to provide You with advertisements, marketing or other information that We think may interest You. These Advertising partners may set or access their own cookies, pixel tags or similar technologies as part of Our Services or they may otherwise collect or have access to data about You which they may collect over time and across different online services. These Advertising partners may also provide Us with their own independent data about potential customers and such data could include data about You previously collected by the Advertising Partner. Service Providers. We may share or disclose Your Personal Information with Our service provides or other third party vendors that We retain in connection with the provision of the Services to You, including without limitation the following types of service providers that we may engage: Email, internet or other telecommunication service providers; Cloud, other data storage, or other hosting service providers; Third party payment service providers, including without limitation third party credit card processors (see Third Party Application Providers below); Analytics companies who assist Us with various types of data analytics (see Third Party Analytics Tools or Services below); Third parties delivery or shipping service providers; or Other third party contractors we engage to assist Us in providing Our goods and Services. Third Party Application Providers. If a third-party application is used to support the Services provided to You, We may share or disclose Your Personal Information to such third party application providers, including without limitation third party credit card processors, other third party payment service providers, or intermediary services that assist in processing your payments. Third Party Analytics Tools or Services. We may use analytics tools or services provided by a third party analytics service provider or by using one of their tools, such as but not limited to Google Analytics, to collect and process certain analytics data (“Third Party Analytics Tools or Services”). These Third Party Analytics Tools or Services may also collect data about Your use of other websites, apps, and online resources. SEE SECTION 5.5 OF THIS PRIVACY POLICY WHICH PROVIDES FURTHER NOTICE ABOUT HOW SOME OF THESE THIRD PARTY ANALYTICS TOOLS OR SERVICES MAY USE COOKIES AND PROVIDES INSTRUCTIONS IF YOU WANT TO DISABLE ANY OF THESE COOKIES. Social Media Features. The Services provided to You may, now or in the future, offer social media features, including certain sharing tools or other integrated tools (such as the Facebook “Like” button), which let You share actions that You take on Our social media pages. Your use of such features enables the sharing of Personal Information with the public, depending on the settings You establish with the entity that provides the social sharing feature. Merger, Sale, or Other Asset Transfers. We may share or disclose or otherwise transfer Your Personal Information to the Company’s Outside Professionals (as defined in Section 2.2 herein), other advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which We are acquired by or merged with another company or We sell, liquidate, or transfer all or a portion of Our assets. The use of Your Personal information following any of these events will be governed by this Privacy Policy. As Required By Law, Subpoena or Similar Government Order. We may access, preserve, share, or disclose Your Personal Information if We believe doing so is required or appropriate to: (i) comply with all laws or regulations, including any tax reporting requirements of the Company; (ii) comply with any other law enforcement requests or legal process, such as a court order or subpoena; (iii) respond to Your requests; or (iv) protect Your, Our, or others’ rights, property, or safety. FOR THE AVOIDANCE OF DOUBT, WE MAY BE REQUIRED TO DISCLOSURE YOUR PERSONAL INFORMATION TO: (I) TAXING AUTHORITIES AS PART OF OUR TAX REPORTING REQUIREMENTS; OR (II) LAW ENFORCEMENT AUTHORITIES OR OTHER GOVERNMENTAL AGENCIES OR VIA SUBPOENA ARISING OUT OF YOUR USE OF ANY UNLAWFUL OR INFRINGING CONTENT WHILE USING ANY OF THE SERVICES. Company’s Outside Professionals. We may share or disclose Your Personal Information with any of the Company’s Outside Professionals (as defined in Section 2.2 herein) in order to facilitate the professional advice such Outside Professionals provide to the Company. Aggregated Form. We may make certain automatically-collected, aggregated, or otherwise de-identified Personal Information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our Users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Services. Consent. We may also share or disclose Your Personal Information with your permission.

4. ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS REGARDING ADDITIONAL RIGHTS GIVEN TO CALIFORNIA RESIDENTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

In addition to the other notices and disclosures that We have provided in this Privacy Policy to residents of the State of California (“California Residents”) pursuant to the California Consumer Privacy Act (CCPA), We hereby provide the following notices to all California Residents regarding their rights under the CCPA:

4.1 ACCESS TO SPECIFIC INFORMATION AND DATA PORTABILITY RIGHTS Each California Resident has the right to request that the Company disclose certain information to such California resident about the Company’s collection and use of such California Resident’s Personal Information over the past 12 months. Once the Company receives and confirms a California Resident’s verifiable consumer request (see Section 4.4: Exercising Your Access, Data Portability, and Deletion Rights), the Company will disclose to such California Resident(per Your request): The categories of Personal Information We collected about such California resident. The categories of sources for the Personal Information We collected about such California resident. Our business or commercial purpose for collecting or selling that Personal Information. The categories of third parties with whom We share that Personal Information. The specific pieces of Personal Information We collected about such California resident (also called a data portability request). If We sold or disclosed Personal Information for a business purpose; two separate lists disclosing: “Sales” (if any), identifying the Personal Information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

4.2 DELETION REQUEST RIGHTS Each California Resident has the right to request that We delete any of such California Resident’s Personal Information that the Company collected from such California Resident and retained, subject to certain exceptions. Once the Company receives and confirms a California Resident’s verifiable consumer request (see Section 4.4: Exercising Your Access, Data Portability, and Deletion Rights), the Company will delete (and direct our service providers to delete) such California Resident’s Personal Information from our records, unless an exception applies. However, the Company may deny such California Resident’s deletion request if retaining the information is necessary for the Company or its service provider(s) to: Complete the transaction for which We collected the Personal Information, provide a good or service that such California Resident requested, take actions reasonably anticipated within the context of Our ongoing business relationship with such California Resident, or otherwise perform Our contract with such California Resident; Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; Debug products to identify and repair errors that impair existing intended functionality; Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.); Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if such California resident previously provided informed consent; Enable solely internal uses that are reasonably aligned with consumer expectations based on such California Resident’s relationship with Us; or Comply with a legal obligation; or Make other internal or lawful uses of that information that are compatible with the context in which such California Resident provided it.

4.3 NOTIFICATION REGARDING “SALE” (IF ANY) OF PERSONAL INFORMATION UNDER THE CCPA In view of the definition of “sale” under the CCPA, We may, either now or in the future, exchange, share, and/or “sell” (as defined under the CCPA) certain Personal Information to certain third parties. Access https://dev-website-add-usa-regions-to-search.goindie.online/privacy for the Company’s “DO NOT SELL MY PERSONAL INFORMATION” notice to California Residents about their right to stop any such “sales”, if any such “sales” exist: https://dev-website-add-usa-regions-to-search.goindie.online/privacy

4.4 EXERCISING A CALIFORNIA RESIDENT’S ACCESS, DATA PORTABILITY, AND DELETION RIGHTS To exercise the access, data portability, deletion rights, and other rights described in this Section 4, a California Resident must submit a verifiable consumer request to the Company by either: Calling the Company at +1 855-661-3485 or Emailing the Company at: reservations@indiecampers.com. Only a California Resident, or a person registered with the California Secretary of State that a California Resident authorizes to act on the California Resident’s behalf, may make a verifiable consumer request to the US Company related to the California Resident’s Personal Information. A California Resident may also make a verifiable consumer request on behalf of such California Resident’s minor child who is a California Resident. A California Resident may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: Provide sufficient information that allows the Company to reasonably verify that California resident are the person about whom We collected Personal Information or an authorized representative. Describe California resident request with sufficient detail that allows the Company to properly understand, evaluate, and respond to it. The Company cannot respond to a California Resident’s request or provide a California Resident with Personal Information if the Company cannot verify the California Resident’s identity or authority to make the request and confirm the Personal Information relates to such California Resident. Making a verifiable consumer request does not require a California Resident to create an account with us. The Company will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

4.5 RESPONSE TIMING AND FORMAT If a California Resident sends a verifiable consumer request as set forth in Section 4.4 above, the Company will endeavor to respond to such verifiable consumer request within forty-five (45) days of its receipt. If the Company requires more time (up to a total aggregate of 90 days), the US Company will inform such California Resident of the reason and extension period in writing. If such California Resident has an account with Us, We will deliver our written response to that account. If such California Resident do not have an account with Us, We will deliver Our written response by mail or electronically. Any disclosures We provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response We provide will also explain the reasons We cannot comply with a request, if applicable. For data portability requests, We will select a format to provide the California Resident’s Personal Information that is readily useable and should allow such California Resident to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to a California Resident’s verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If We determine that the request warrants a fee, We will tell such California Resident why We made that decision and provide such California Resident with a cost estimate before completing such California Resident’s request.

4.6 NON-DISCRIMINATION NOTICE The Company will not discriminate against any California Resident for exercising any of such California Resident’s rights under the CCPA. Unless permitted by the CCPA, We will not: Deny such California Resident any goods or services; Charge such California Resident different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; Provide such California Resident a different level or quality of goods or services; or Suggest that such California resident may receive a different price or rate for goods or services or a different level or quality of goods or services.

4.7 SPECIAL NOTICE ABOUT EXCLUSION OF CERTAIN INFORMATION FROM GOVERNANCE OF THE CCPA IN ACCORDANCE WITH THE CCPA, THE COLLECTION AND USE OF THE FOLLOWING INFORMATION IS NOT SUBJECT TO OR GOVERNED BY THE CCPA AND, THUS, IS EXCLUDED FROM THE TERMS AND CONDITIONS OF SECTION 4 OF THIS PRIVACY POLICY ANY HEALTH OR MEDICAL INFORMATION COVERED BY COVERED BY OR OTHERWISE SUBJECT TO: (A) THE U.S. FEDERAL HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT OF 1996 (HIPAA) AND ITS RELATED REGULATIONS; OR (B) THE CALIFORNIA CONFIDENTIALITY OF MEDICAL INFORMATION ACT (CMIA) AND ITS RELATED REGULATIONS); OR ANY INFORMATION COVERED BY CERTAIN OTHER INDUSTRY SECTOR-SPECIFIC PRIVACY LAWS, INCLUDING THE FAIR CREDIT REPORTING ACT (FRCA), THE GRAMM-LEACH-BLILEY ACT (GLBA), THE CALIFORNIA FINANCIAL INFORMATION PRIVACY ACT (FIPA), AND THE DRIVER'S PRIVACY PROTECTION ACT OF 1994.

5. CERTAIN ADDITIONAL CHOICES YOU MAY HAVE ABOUT YOUR INFORMATION

5.1 OPT-OUT FROM RECEIVING INFORMATION FROM THE COMPANY. 5.1.1 YOU CAN OPT-OUT FROM RECEIVING INFORMATION FROM THE COMPANY. In the event a User has provided the Company with Personal Information such as that discussed above, and thereafter a User does not want to continue to directly receive further notices, or information from the Company such as emails about the Company’s products or services, the User must send an email message to reservations@indiecampers.com stating that the User no longer wants to receive these communications directly from the Company (“Opt Out”). Once the Company has received the User’s request to Opt Out, the US Company will use commercially reasonable efforts, in a commercially reasonable time period, to try to carry out such User’s request to Opt Out; provided, however, the Company will not have any obligation to retrieve, and cannot prevent the further use by others of, such User’s Personal Information which may have been shared up to that time with other parties as permitted by the provisions of this Privacy Policy. 5.1.2 EFFECT OF OPT-OUT FROM RECEIVING INFORMATION FROM THE COMPANY. If a User elects to Opt Out, and provided such User has properly delivered its Opt Out request to the Company in accordance with Section 5.1.1 herein, such User will no longer receive emails directly from the Company after a commercially reasonable time from the date such User sent its Opt Out notice to the Company. However, the Company does not have any obligations under, or liability arising out of, this Privacy Policy with regard to a User’s decision to share its Personal Information with, Our use of, any other internet websites, forums, or programs that the User may have linked to via the Company Website which are not under the Company’s direct control or ownership. Accordingly, after sending Your Opt Out to the Company, You may need to contact these other entities directly regarding their use of Your Personal Information.

5.2. GEO-LOCATION DATA. You may be able to prevent your device from sharing precise location information, including without limitation some or all of the Geo-Location Data described in Section 1.2 above, at any time through your device’s operating system settings

5.3. DO NOT TRACK: SPECIAL ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS. Some browsers have a “DO NOT TRACK” feature that lets website users inform websites or other applications that they do not want to have their online activities tracked. These “do not track” features may also give website users other choices regarding the collection of their personal identifiable information. However, these “do not track” features and “do not track’ signals are not yet uniform. ACCORDINGLY, EACH USER OF THE COMPANY WEBSITE OR ANY OTHER SERVICES IS HEREBY NOTIFIED THAT THE COMPANY WEBSITE AND THE OTHER SERVICES ARE NOT CURRENTLY SET UP TO RESPOND TO ANY OF THE USER’S “DO NOT TRACK” FEATURES OR “DO NOT TRACK” SIGNALS.

5.4. CHILDREN / MINORS; NOTICE UNDER U.S. FEDERAL CHILDREN'S ONLINE PRIVACY PROTECTION ACT ("COPPA"). This Company Website and the other Services are not directed to children under the age of 13. We adhere to the U.S. federal Children's Online Privacy Protection Act ("COPPA") and will not knowingly register or otherwise collect any Personal Information from any child under the age of 13. We ask that minors under the age of 13 not submit any Personal Information to the Company. If You have reason to believe a child under the age of 13 has provided the Company with any Personal Information, please contact the US Company at reservations@indiecampers.com and request that such information be deleted from Our records.

5.5 U.S. COOKIES POLICY; HOW YOU CAN DISABLE COOKIES. 5.5.1 What Are Cookies. As is common practice with almost all professional websites, the Company Website (and possibly other Services) uses cookies, which are tiny files that are downloaded to your computer, to improve your experience. This section describes what information they gather, how We use it and why We sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored however this may downgrade or ‘break’ certain elements of a website’s functionality. 5.5.2 How We Use Cookies. WE USE COOKIES FOR A VARIETY OF REASONS AS DESCRIBED ABOVE IN SECTION 1 AND SECTION 3 OF THIS POLICY AND BELOW IN THIS SECTION 5.5. Unfortunately, in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that You leave on all cookies if You are not sure whether You need them or not in case they are used to provide a service that You use. 5.5.3 Disabling Cookies. You can prevent the setting of cookies by adjusting the settings on Your browser (see Your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that You visit. Disabling cookies will usually result in also disabling certain functionality and features of the Company Website or any other Services. Therefore, it is recommended that You do not disable cookies. 5.5.4 The Cookies We May Set. In addition to the disclosures We have provided in Section 1.2 of this Policy regarding cookies or other web-based tracking technologies, the following section details certain ways that We may set or use cookies or other web-based tracking technologies on the Company Website or any other Services: Email newsletters related cookies: The Company Website or other Services may offer newsletters or other types of email subscription services and cookies may be used to remember if You are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users. Orders processing related cookies: The Company Website or other Services may offer e-commerce or payment facilities and some cookies are essential to ensure that Your order is remembered between pages so that We can process it properly. Contact or comment related cookies: When You submit any other data through the Company Website or other Services, certain contact or comment-related cookies may be set to remember Your user details for future correspondence or transactions. 5.5.5 Third Party Cookies. In certain instances, cookies provided by third parties may also be sued. In addition to the disclosures We have provided in Section 1.2 of this Policy regarding use of cookies or other web-based tracking technologies by third parties, the following section details certain third party cookies you might encounter through the Company Website or any other Services: As noted in Section 3, the Company Website or other Services, may use Third Party Analytics Tools or Services (including without limitation Google Analytics) which provides Us with widely-used analytics tools or services to help Us better understand how You and other Users are utilizing the Company Website or other Services, in order to allow Us to improve Your experience. These cookies may track things such as how long You spend on the Company Website or other Services and the pages that You visit so we can continue to produce engaging content. Third Party Analytics Tools or Services are also used to track and measure usage of this Company Website or other Services so that We can continue to produce engaging content, help Us to understand how We can improve the Company Website or other Services site for You and and/or to give Us a better understanding of broader industry trends From time to time, We test new features and make subtle changes to the way that the Company Website or other Services are delivered. When We are still testing new features these cookies may be used to ensure that You receive a consistent experience while on the Company Website or other Services while ensuring We understand which optimizations the Users appreciate the most. As We promote our products or services, it’s important for Us to better understand statistics about how many of the users to the Company Website or other Services actually make a purchase or which US Company products or services the users viewed the most and, thus, this is additional types of data that these cookies will track. We consider this to be important to You as it means that We can accurately make business predictions that allow Us to monitor our advertising and product /service costs to ensure the best possible services to all of the Users. Certain of Our Advertising Partners or Global Partners/Resellers (as defined in Section 3 of this Policy) may advertise on Our behalf and affiliate tracking cookies allow Us to see if Our customers have come to the Company Website or other Services through one of these Advertising Partner sites or sources. As noted in Section 3, We may also use social media buttons and/or plugins on the Company Website or other Services that allow You to connect with Your social network in various ways. For these to work, many social media sites (such as, but not limited to, Facebook, Instagram or LinkedIn) may set cookies through Our Company Website or other Services and such cookies may be used to enhance Your profile on their social media site or to contribute to the data they hold for various purposes outlined in their respective privacy policies.

6. ADDITIONAL NOTICE TO NEVADA RESIDENTS UNDER NEVADA PRIVACY LAW

In addition to the other notices and disclosures that We have provided in this Privacy Policy to residents of the State of Nevada (“Nevada Residents”), We hereby provide the following additional notices to all Nevada Residents regarding their rights under Nevada law: UNDER NEVADA REVISED STATUTES CHAPTER 603A (THE “NEVADA PRIVACY ACT”), NEVADA RESIDENTS (AS DEFINED ABOVE) WHO HAVE PURCHASED GOODS OR SERVICES FROM US MAY NOTIFY US TO NOT SELL (AS CONTEMPLATED UNDER THE NEVADA PRIVACY ACT) SUCH PERSON’S COVERED PERSONAL INFORMATION AS CONTEMPLATED BY THE NEVADA PRIVACY ACT. COVERED PERSONAL INFORMATION INCLUDES FIRST AND LAST NAME, ADDRESS, EMAIL ADDRESS, PHONE NUMBER, OR AN IDENTIFIER THAT ALLOWS A SPECIFIC PERSON TO BE CONTACTED. IF YOU ARE A NEVADA RESIDENT, YOU MAY SUBMIT A REQUEST TO US TO NOT “SELL” YOUR COVERED PERSONAL INFORMATION BY SENDING AN EMAIL MESSAGE TO THE US COMPANY AT RESERVATIONS@INDIECAMPERS.COM

7. ENFORCEMENT OF THIS PRIVACY POLICY BY COMPANY.

Each User confirms and agrees that by the User’s act of using any of the Services, including without limitation uploading any of the User’s Personal Information or any other content via any Services, the User: (a) unconditionally agrees to all of the terms and conditions of this Privacy Policy; and (b) further agrees that no provision of this Privacy Policy shall limit, condition, alter, or amend, in any way whatsoever, any rights that User may have separately granted to the USA Company pursuant to any other agreement that the User may have separately entered into with the Company.

8. USER RESPONSIBLE FOR UPDATING USER’S OWN PERSONAL INFORMATION.

Users are solely responsible for correcting, updating, or modifying any and all of the User’s Personal Information as it appears in, and as otherwise stored or contained in, any Services. Without in any way limiting the foregoing, User acknowledges and agrees that the US Company does not have an independent obligation to maintain the accuracy or completeness of any of Personal Information provided by the User to the Company, including such Personal Information once it is stored, described or otherwise contained in the Company Website or in any other Services.

9. LINKS TO, AND USE OF, THIRD PARTY SITES OR SERVICES.

The Company Website or other Services may now or in the future provide links or other access to Internet websites, forums or other Services which are not under the US Company’s sole control and not solely owned by the US Company (collectively referred to as “Third Party Sites”). If a User clicks on a link to, or otherwise gains access to, any such Third Party Site, the User will be transported to one of these Third Party Sites. THIS PRIVACY POLICY ONLY APPLIES TO THE COMPANY WEBSITE AND THE OTHER SERVICES DIRECTLY OWNED BY THE COMPANY. THEREFORE, THIS PRIVACY POLICY: (A) DOES NOT DESCRIBE THE PRIVACY POLICIES OF ANY OF THESE THIRD PARTY SITES; AND (B) DOES NOT GOVERN THE COLLECTION OR USE OF YOUR PERSONAL INFORMATION BY THE THIRD PARTY SITES. THE US COMPANY IS NOT RESPONSIBLE FOR THE PRIVACY PRACTICES OF ANY OF THESE THIRD PARTY SITES. IF A USER CLICKS ON A LINK TO, OR IS SENT TO A LINK OF, OR OTHERWISE GAINS ACCESS TO, A THIRD PARTY SITE, THE USER SHOULD REVIEW THE PRIVACY STATEMENTS OR POLICIES OF SUCH THIRD PARTY SITES (IF ANY) TO DETERMINE THAT PARTICULAR THIRD PARTY SITES’ PRACTICES WITH REGARD TO THE COLLECTION AND USE OF PERSONALLY IDENTIFIABLE INFORMATION. WITHOUT LIMITING THE GENERALITY OF THE FOREGOING, EACH USER AGREES THAT IF THE USER USES ANY THIRD PARTY SITES IN ANY WAY, THE USER IS AWARE THAT ANY OF THE USER’S PERSONAL INFORMATION THAT THE USER PROVIDES TO THAT THIRD PARTY SITE MIGHT BE READ, COLLECTED, SHARED, DISTRIBUTED, OR OTHERWISE USED BY OTHER USERS OF THAT THIRD PARTY SITE OR BY ANY OTHER THIRD PARTIES, AND COULD BE USED TO SEND THE USER UNSOLICITED MESSAGES. THE COMPANY IS NOT RESPONSIBLE FOR ANY PERSONAL INFORMATION THAT THE USER ELECTS TO SUBMIT IN, OR OTHERWISE MAKE AVAILABLE TO, THESE THIRD PARTY SITES. Any link to any Third Party Site from the Company Website or any other Services does not imply any endorsement of the privacy practices of such Third Party Site by the Company, and no such Third Party Site is authorized to make any representation or warranty on our behalf.

10. This privacy policy might change

This Privacy Policy may be changed from time to time and at any time by the Company (a “Change”). The Company reserves the right to change it without notice to a particular User. YOU HEREBY AGREE THAT YOU ARE BOUND BY THE VERSION OF THIS PRIVACY POLICY THAT IS IN EFFECT AT THE TIME YOU FIRST USE THE COMPANY WEBSITE OR ANY OTHER COMPANY SERVICE. THE TERMS OF THIS PRIVACY POLICY MAY BE DIFFERENT THE NEXT TIME YOU USE THE COMPANY WEBSITE OR ANY OTHER COMPANY SERVICE. ANY USE OF THE COMPANY WEBSITE OR ANY OTHER COMPANY SERVICE BY YOU AFTER SUCH CHANGES SHALL BE DEEMED TO CONSTITUTE ACCEPTANCE BY THE USER OF THE CHANGES FOR USE OF ALL COMPANY SERVICES. EACH USER SHOULD REGULARLY REVIEW AND PRINT THIS PRIVACY POLICY FOR THE USER’S RECORDS.

11. COMMUNICATING WITH COMPANY.

If a User believes that the US Company is not complying with the policies outlined in this Privacy Policy, or if the User has any questions relating to this Privacy Policy, then the User should contact the Company at reservations@indiecampers.com.

DO NOT SELL MY INFORMATION NOTICE TO CALIFORNIA RESIDENTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA) BY INDIE CAMPERS USA, INC.

IN ACCORDANCE WITH THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA), ALL RESIDENTS OF THE STATE OF CALIFORNIA (“CALIFORNIA RESIDENTS”) ARE ENTITLED TO RECEIVE THIS “DO NOT SELL MY INFORMATION” NOTICE IN THE EVENT INDIE CAMPERS, USA, INC. (“COMPANY”) USES ANY PERSONAL INFORMATION OF A CALIFORNIA RESIDENT IN A WAY THAT MAY CONSTITUTE A “SALE” OF SUCH PERSONAL INFORMATION (AS THE TERM “SALE” IS DEFINED IN THE CCPA). ACCORDINGLY, THE COMPANY HEREBY GIVES CALIFORNIA RESIDENTS THE FOLLOWING “DO NOT SELL MY INFORMATION” NOTICE UNDER THE CCPA:

1. NOTICE REGARDING ANY “SALE” OF CERTAIN PERSONAL INFORMATION UNDER THE CCPA

Based on the definition of “sale” pursuant to the CCPA, the following uses of a California Resident’s Personal Information by the Company may constitute a “sale” of such Personal Information pursuant to the CCPA: The Company’s sharing of the following types of Personal Information to certain third party marketing companies or third party analytics companies that are engaged by the Company (“Third Party Marketing Companies”) and which may use these types of Personal Information: (a) identifiers; (b) Internet network activity information; (iii) commercial information; and/or (iv) inferences drawn from the categories described above. This Personal Information may be used by the Third Party Marketing Companies to assist our Company in creating marketing profiles, to deliver targeted advertisements or to otherwise promote the business of the Company. The Company’s use of certain web-based analytics tools and/or advertising technology tools (collectively “Web-based Analytics Tool”) that the Company’s website or other programs may use to gather Personal Information to assist our Company in creating marketing profiles, to deliver targeted advertisements or to otherwise promote the business of the Company. Our Company, however, does not knowingly “sell” any of the above described Personal Information of minors under the age of 13.

2. SPECIFIC STEPS CALIFORNIA RESIDENTS SHOULD TAKE TO TELL THE COMPANY TO “STOP SELLING” THE ABOVE DESCRIBED PERSONAL INFORMATION

In order for a California Resident to submit a DO NOT SELL MY INFORMATION notice to the Company under the CCPA in order to instruct the Company to stop the “sale” (as defined under the CCPA) of any Personal information to the above described Third Party Marketing Companies or as used by the above-described Web-based Analytics Tools, such California Resident must contact the Company by either emailing or calling the Company using the contact information provided in Section 3 of this Notice.

3. Contacting the Company

If any California Resident wants to send the Company this DO NOT SELL MY INFORMATION notice under the CCPA, such California Resident should contact Indie Campers USA, Inc. by either: Emailing Indie Campers USA, Inc. at: reservations@indiecampers.com; or Calling Indie Campers, USA, Inc. at +1 855-661-3485