1. Information We Collect

We collect personal information to deliver bespoke travel planning and support. This includes:

Information You Provide: When you inquire about a trip, complete a form, join our mailing list, request a quote, or otherwise interact with us, we may collect:

• Full name, email address, phone number, mailing address

• Travel preferences, destination interests, budget, passport or health info where necessary

• Payment information (processed securely via third-party services)

• Social media handles (if you engage with us through those channels)

• Any other information you choose to provide

Information We Collect Automatically: Our website may collect basic technical data such as:

• IP address, browser type, device and operating system

• Referring URL or pages visited

• Cookie and session data to enhance user experience

You can adjust your browser settings to manage cookies.

Location Information: We may collect approximate location data through your IP address or mobile device to offer region-specific content or communications.

Information from Other Sources: We may combine data from partners, social media platforms, or publicly available sources to better understand your preferences and deliver a more personalized experience.

2. How We Use Your Information

We use the information we collect to:

• Plan, manage, and fulfill your travel experiences

• Communicate about your booking, preferences, updates, and offers

• Customize our Services based on your interests

• Process payments and issue confirmations

• Improve our Services through analytics and customer feedback

• Comply with applicable laws and professional obligations

• Prevent fraud or misuse of our Services

With your consent, we may also use your information to deliver marketing or travel inspiration tailored to you. You can opt out of promotional communications at any time.

3. Sharing and Disclosure

We do not sell your personal data. We may share it with:

• Trusted suppliers (e.g., hotels, guides, insurance providers) solely to fulfill your travel arrangements

• Service providers who assist with communications, website hosting, or payment processing

• Legal authorities, if required by law or to protect our rights or your safety

4. Data Retention and Security

We retain your information only as long as necessary to fulfill the purposes outlined above. We use appropriate safeguards to protect your data, including secure third-party processors and encryption protocols.

5. Your Rights and Choices

You may:

• Request access or correction to your information

• Opt out of marketing communications

• Withdraw consent for data processing, where applicable

To exercise these rights, please contact us at info@upperfallstravel.com

6. Updates to This Policy

We may revise this Privacy Policy periodically. The most current version will always be available on our website and will include the effective date at the top.4. How We Share Your Information

We respect your privacy and never sell your personal data. We may share what we collect only in the following limited circumstances:

• With our affiliates and service providers – Third-party partners who help us deliver your travel arrangements, run our website, process payments, analyze data, or send you communications.

• With travel suppliers – Hotels, carriers, guides, insurers or other vendors strictly to fulfill your itinerary.

• To comply with legal obligations – In response to subpoenas, court orders, regulatory requests or other legal process.

• To protect rights and safety – To prevent fraud, defend or assert our legal rights, or safeguard the safety of our guests, employees or property.

• In connection with a business transfer – Should Upper Falls Travel merge with or be acquired by another entity, we may transfer your data to the successor organization, subject to this Policy.

7. Security of Your Information

We maintain administrative, technical, and physical safeguards—such as encrypted communications, access controls, and secure data centers—to protect your information. However, no internet or data transmission can be 100% secure; you share information with us at your own risk.

8. Data Retention

We retain your personal data only as long as necessary to:

• Provide and improve our Services

• Comply with contractual, legal or regulatory obligations

• Resolve disputes and enforce our agreements

When information is no longer needed, we securely delete or anonymize it.

9. Analytics & Advertising

Cookies & Tracking: We and our analytics partners (e.g., Google Analytics) use cookies, pixels, and similar technologies to understand how you use our Services, improve performance, and deliver relevant content.

Interest-Based Advertising: With your consent, we may use tracking technologies to serve tailored travel inspiration and ads on other sites (e.g., via Facebook Custom Audiences or Google Ads).

Your Choices: • You can manage or block cookies in your browser settings. • To opt out of personalized ads, visit:   – Network Advertising Initiative: http://optout.networkadvertising.org   – Your device’s settings (Android or iOS privacy controls)   – Browser-based tools (e.g., Google Analytics opt-out extension)

For more on your rights and how to control cookies, see Sections 2 and 5 above.8. Your Rights and Choices

Marketing Communications We may send you emails or other messages about our travel services, special offers, or partner promotions. You can opt out at any time by:

• Clicking the “unsubscribe” link in any marketing email; or

• Emailing us at info@upperfallstravel.com.

Please note that even if you opt out of marketing, we will still send you transactional or administrative messages—like booking confirmations or policy updates—that are necessary to deliver our Services and comply with legal requirements.

Tracking Technology Choices Most web browsers accept cookies by default. You can disable or delete non-essential cookies via your browser’s settings (Chrome, Firefox, Safari, etc.). If you block cookies, some parts of our website may not function properly.

Upper Falls Travel does not respond to “Do Not Track” signals, as there is not yet an industry standard for handling them. For more on Do Not Track, see http://www.allaboutdnt.com..

Analytics & Targeted Advertising

• To opt out of Google Analytics data collection, install Google’s opt-out browser add-on: https://tools.google.com/dlpage/gaoptout..

• To opt out of interest-based ads from participants in the Digital Advertising Alliance (DAA) or Network Advertising Initiative (NAI):

  • DAA Opt-Out: http://www.aboutads.info/choices

  • NAI Opt-Out: https://www.networkadvertising.org/choices/

Your opt-out settings apply only to the browser and device where you set them. Deleting cookies may reset your preferences.

Data Deletion You may request deletion of your personal data at any time. To do so, email privacy@upperfallstravel.com and specify which information you’d like removed. We’ll honor your request unless retaining the data is necessary to complete your booking, comply with legal obligations, or protect our legitimate interests.

10. Supplemental Notice for EEA & UK Residents

If you live in the European Economic Area (EEA) or the United Kingdom, Upper Falls Travel, LLC is the data controller for your Personal Data under the GDPR and UK Data Protection Act.

Legal Basis for Processing We process your Personal Data only when we have a lawful basis, such as:

1. Your consent;

2. Performance of our travel-planning agreement;

3. Compliance with a legal obligation;

4. Protection of vital interests; or

5. Our legitimate business interest (e.g., fraud prevention, service improvement).

Additional Rights In addition to the rights in Section 8, you may request:

• Data portability (transfer your data in a structured, machine-readable format)

• Restriction of processing (pause use of your data)

• Withdrawal of consent (where processing is consent-based)

You also have the right to lodge a complaint with your local data protection authority. We ask that you contact us first to seek resolution.

11. International Visitors

Our Services are hosted in the United States. If you reside outside the U.S., please know that any information you provide will be transferred to, stored, and processed in the U.S. or other designated locations. By using our Services, you consent to this transfer.

In limited circumstances, we may be required to disclose your information in response to lawful requests by public authorities (e.g., for national security or law enforcement).

12. Third-Party Links & Content

Our website and communications may include links to third-party sites, apps, or services. Upper Falls Travel is not responsible for their privacy practices. Please review their privacy policies before sharing any personal information.

13. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices, technology, or legal requirements. Each version will display a “Last Updated” date. Your continued use of our Services after such changes confirms your acceptance of the new terms.

14. Information from Children under Age 13

Upper Falls Travel does not knowingly collect personal information from children under 13. If we learn that we’ve inadvertently received personal data from a child under 13 without parental consent, we will delete it promptly. We may collect information about a client’s minor children only when provided by that client for travel-planning purposes.

15. Contact Information

If you have questions, concerns or requests regarding this Privacy Policy, please contact us:

Upper Falls Travel, LLC

1174 Boylston Street
Newton, MA 02464

T: (617) 865-5246

E: info@upperfallstravel.com