Privacy Policy

In our mission to make travel better for everyone, Wander collects and uses information about our users, customers using Wander Products and Services to power your business, guests and other customers and third-parties using or facilitating the use of Wander Services and Products including our Website and Apps, partners who develop apps and other Services, and visitors to websites hosted by Wander and anyone contacting the Wander Concierge or Wander Support.

This Privacy Policy for Wander, Inc. (“Company”, “we”, “us” “our”) describes how we collect, use and disclose information about Users of the Company’s website (www.wander.com), Wander hosted sites, WanderOS, any Wander-related applications, any and all Products and Services, tools and features (collectively, the “Services”), and customers, guests, and other third-parties related to the provision of any Products and Services. For the purposes of this Privacy Policy, “you” and “your” means you as the User of the Services, any persons or entities that may become Users of the Services and Products because they were introduced or referred by you, and any company or other entity that you may act for when using or purchasing any Wander products and Services.

By creating an account or purchasing or using Wander Products and Services directly or indirectly, you agree that Wander may contact you using automated technology, including but not limited to SMS, prerecorded or artificial voice messages, and auto-dialing or power-dialing systems, for service-related and marketing purposes. Consent is not a condition of purchase. Message and data rates may apply. You may opt out at any time by replying STOP or contacting us.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY USING, ACCESSING, OR DOWNLOADING ANY OF THE SERVICES, YOU AGREE TO THE USE OF YOUR INFORMATION IT DESCRIBES AND TO THE OTHER TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT ACCESS AND USE THE SERVICES.

Please familiarize yourself with the Privacy Policy below as well as the Terms of Service (and related policies and agreements incorporated therein), including the Booking Rules, and Good Neighbor Policy.

1. Updating This Privacy Policy

We may modify this Privacy Policy from time to time in which case we will update the “Last Revised” date at the top of this Privacy Policy. If we make changes that are material, we will use reasonable efforts to notify you (e.g. by email sent to the email address specified in your account) and obtain your consent and take additional steps as required by applicable law. Notice may be by email to you at the last email address you provided us, by posting notice of such changes on the Services, or by other means, consistent with applicable law.

IF YOU DO NOT AGREE TO ANY UPDATES TO THIS PRIVACY POLICY PLEASE DO NOT ACCESS OR CONTINUE TO USE THE SERVICES.

2. Company’s Collection and Use of Information

In order to provide you with particular services, we may ask you to provide us with certain details or information or otherwise collect certain information about you. Information that you submit through our Services include:

• Basic contact details, as follows: first and last name, email address, mailing address, and phone number. We collect basic contact details to communicate with you, customize your experience, provide you with products and services, to improve our products and services, and to market to you.
• Account information, as follows: username, password and security questions. We collect account information to maintain and secure your account with us. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. We highly recommend that you do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, please contact us immediately.
• Payment information, as follows: bank account and routing number, credit or debit card information, and billing address. We collect payment information to process your payment, process security deposit and any incidental damage charges, and to provide you with products or services you have requested.
• Demographic information, as follows: age, gender, and marital status. We collect demographic information to customize your experience, improve our products and services and to market to you.
• Identification information, as follows: driver’s license, passport information, and government visa information. We collect identification information to facilitate our products and services and comply with applicable laws and regulations.
• Insurance information to comply with applicable laws and regulations.
• Any other information you choose to include in communications with us, for example, when sending a message through the Contact Us web form. Some features of the Services may require you to enter certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features.

We also automatically collect certain information about your interaction with the Services (“Usage Data”). To do this, we may use cookies, web beacons/clear gifs, other geolocation tracking technologies, etc. (“Tracking Technologies”). Usage Data may include:

• Unique device identifier
• Device type, such as your phone, computer, or tablet
• IP address
• Browser type
• Date and time stamps, such as the date and time you first accessed the Services
• Operating system
• Log data
• Precise location
• Other information regarding your interaction with the Services, such as clickstream data and ad impressions

We use the information we collect automatically to tailor features and content to you, market to you, provide you with offers or promotions, run analytics, and better understand user interaction with the Services.

We may obtain information about you from outside sources. Such information may include information from third parties that you choose to share with us, for example:

• When you choose to link any social media platforms to your account, such as Instagram, Facebook or Twitter. This information is used to maintain your account and login information. Any information we receive from outside sources will be treated in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. See Section 6 below for more information.

3. How the Company Shares Your Information

In certain circumstances, the Company may share your information with third parties. Such circumstances may include:

• With vendors or other service providers, such as:
  • Payment processors
  • Data analytics vendors
  • Cloud storage providers
  • IT service management vendors
  • Email marketing services vendors
  • Security vendors
• With third parties for marketing purposes
• To comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries
• In connection with an asset sale, merger, bankruptcy, or other business transaction
• To enforce any applicable terms of service
• To ensure the safety and security of the Company and/or its users
• When you request us to share certain information with third parties, such as through your use of social media widgets or login integrations
• With professional advisors, such as auditors, law firms, or accounting firms

You acknowledge that such sharing of information may occur in all of the aforementioned circumstances and is permitted by and subject to this Privacy Policy.

We generally process your information when we need to do so to fulfill a contractual obligation (for example, to process your subscription payments to use the Wander platform or to provide other Wander Products and Services), or where we or someone we work with needs to use your personal information for a reason related to their business (for example, to provide you with a service). Laws in the European Economic Area (“EEA”) and in the United Kingdom (“UK”) call these reasons “legitimate interests.” These “legitimate interests” include:

• preventing risk and fraud
• answering questions or providing other types of support
• helping merchants find and use apps through our app store
• providing and improving our products and services
• providing reporting and analytics
• testing out features or additional services
• assisting with marketing, advertising, or other communications

We only process personal information for these “legitimate interests” after considering the potential risks to your privacy and balancing any risks with certain measures—for example, by providing clear transparency into our privacy practices, offering you control over your personal information where appropriate, limiting the information we keep, limiting what we do with your information, who we send your information to, how long we keep your information, or the technical measures we use to protect your information.

We may also process your personal information where you have provided your consent. In particular, where we cannot rely on an alternative legal basis for processing, where you direct us to transfer information to a third party, where we receive your data from a third party is sourced and it already comes with consent or where we are required by law to ask for your consent (including in the context of some of our sales and marketing activities). At any time, you have a right to withdraw your consent by changing your communication choices, opting out from our communications or by contacting us.

Depending on whether you are a guest or other customer, partner, user or visitor, please refer to our supplemental privacy policies, as relevant, to understand our purposes for processing, categories of recipients and legal basis for processing for each type of personal data.

We believe you should be able to access and control your personal information no matter where you live. Depending on how you use Wander, you may have the right to request access to, correct, amend, delete, port to another service provider, restrict, or object to certain uses of your personal information. We will not charge you more or provide you with a different level of service if you exercise any of these rights. Please note that a number of these rights apply only in certain circumstances, and all of these rights may be limited by law.

Where Wander acts as processor or service provider of your personal data on behalf of Wander customers purchasing or using Wander products and Services, you need to directly contact the Wander customer or vendor you interacted with.

If you are a guest, customer, partner, website visitor or other individual that Wander has a direct relationship with or for whom Wander processes your Personal Data as a Data Controller, please submit your data subject request to [email protected]. We may require you to provide additional documentation to verify your identity and may use third parties to assist us with this process. Further information about rights available to US residents can be found below under the header “United States Regional Privacy Notice”. If you are not happy with our response to a request, you can contact us to resolve the issue. If you are located in the EEA or UK, you also have the right to lodge a complaint with your local data protection or privacy authority at any time.

To operate our business, we may send your personal information outside of your state, province, or country, including from or to the United States. This data may be subject to the laws of the countries where we send it. We take steps to protect your information when we send your information across borders.

We will retain your personal data only for as long as necessary to fulfill the purposes for which we have collected it. To determine the appropriate retention period, we consider the amount, nature and sensitivity of your personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements. We will also retain and use your personal information to the extent necessary to comply with our legal obligations, resolve disputes and enforce our policies. If you stop using our services or if you delete your account with us, we will delete your information or store your information in an aggregated and anonymized format.

One of the ways in which we are able to help guests and other customers using Wander and its Products and Services is by using techniques like “machine learning” (some laws, including certain EEA and UK laws, may refer to this as “automated decision-making”) to help us improve our Services. When we use machine learning, we either: (1) still have a human being involved in the process (and so are not fully automated); or (2) use machine learning in ways that don’t have legal or similarly significant effects.

4. Cookies and Other Tracking Technologies

We use cookies and similar tracking technologies on our Website and Apps and in connection with other Products and Services.

What are cookies?

A cookie is a small amount of information that’s downloaded to your computer or device when you visit certain websites. We use a number of different cookies, including strictly necessary, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it’s their first time visiting or if they are a frequent visitor.

What cookies do we use and why?

Some cookies are necessary to allow you to browse our website, use its features, and access secure areas. The use of these cookies is essential for the website to work. For example, we use user-input cookies for the duration of a session to keep track of their input when filling in forms that span several pages.

We also use functional cookies to remember choices you’ve made or information you’ve provided, such as your username, language, or the region you are in. This allows us to tailor your website experience specifically to your preferences. For example, authentication cookies are functional cookies that are used for the duration of a session (or persistent, if you agree to the “remember me” function) to allow users to authenticate themselves on subsequent visits or to gain access to authorized content across pages. The functional cookies we use include:

• User-centric security cookies to detect authentication abuses for a limited persistent duration, like repeated failed login attempts. These cookies are set for the specific task of increasing the security of the service.
• Multimedia content player session cookies (flash cookies) are used for the duration of a session to store technical data needed to play back video or audio content (e.g. image quality, network link speed, and buffering parameters).
• Load balancing session cookies are used for the duration of the session to identify the same server in the pool in order for the load balancer to redirect requests appropriately.
• User interface customization persistent cookies are used to store a user’s preference regarding a service across web pages.

Wander is dedicated to optimizing User experience and we use many tools to help us improve our Website, App, other commerce platforms, and other Products and Services. To this end, we use reporting and analytics cookies to collect information about how you use our website or our merchants’ storefronts, and how often. The performance cookies we use or may use include:

• First party analytics cookies - we use these cookies to estimate the number of unique visitors, to improve our websites and our merchants’ websites, and to detect the most searched for words in search engines that lead to a webpage. We use these cookies to learn how our websites and our merchants’ websites are performing and make relevant improvements to improve your browsing experience.
• Third party analytics cookies - we also use Google Analytics and other third-party analytics providers some of which are listed below to help measure how users interact with our website content. These cookies “remember” what our users have done on previous pages and how they’ve interacted with the website. For more information on Google Analytics, visit Google’s information page. For instructions on how to opt out of Google Analytics, see below.
• Advertising cookies may be used on our website to tailor marketing to you and your interests and provide you with a more personalized service in the future. These cookies remember that you visited our website and we may share this information with third-parties, such as advertisers. Although these cookies can track your device’s visits to our website and other sites, they typically cannot personally identify you. Without these cookies, the advertisements that you see may be less relevant and interesting to you.
• Social media and content cookies are placed by many social media plugins (for example the Facebook ‘like’ button), and other tools meant to provide or improve the content on a website (for example services that allow the playing of video files, or that create comments sections). We integrate these modules into our platform to improve the experience of browsing and interacting with our websites. Please note that some of these third party services place cookies that are also used for things like behavioural advertising, analytics, and/or market research.

Do Not Track Signals

Your browser settings may also allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, our website is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, you can visit http://www.allaboutdnt.com

Managing Cookies and Other Tracking Technologies

You may control the way in which your devices permit the use of Tracking Technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Services, including any portal features and general functionality, to work incorrectly.

Most browsers accept cookies automatically. However, you may be able to configure your browser settings to use the Services without some cookie functionality. You can delete cookies manually or set your browser to automatically delete cookies on a pre-determined schedule. For example, in the Internet Explorer menu bar, select: Tools > Internet Options > Browsing History > Delete to view manual and automatic options.

To opt out of tracking by Google Analytics, click here.

When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email or home address. We (or service providers on our behalf) may then send communications and marketing to these email or home addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout.

If you have questions regarding the specific information about you that we process or retain, as well as your choices regarding our collection and use practices, please contact us using the information listed below.

5. Social Features

Certain features of the Services permit you to initiate interactions between the Services and third-party services or platforms, such as social networks (“Social Features”). Social Features include features that allow you to click and access the Company’s pages on certain third-party platforms, such as Instagram and Twitter, and from there to “like” or “share” our content on those platforms. Use of Social Features may entail a third party’s collection and/or use of your data. If you use Social Features or similar third-party services, information you post or otherwise make accessible may be publicly displayed by the third-party service you are using. Both the Company and the third party may have access to information about you and your use of both the Services and the third-party service. For more information on third-party websites and platforms, see Section 6.

6. Third Party Websites and Links

We may provide links third-party 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 the privacy or security of these sites, including the accuracy, completeness, or reliability of their information. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms (such as Facebook or Twitter) may also be viewable by other users of the Services and/or users of those third-party online platforms without limitation as to its use by us or by a 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. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of personal information by third parties. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy.

7. Children’s Privacy

Children under the age of 13 are not permitted to use the Services, and we do not seek or knowingly collect any personal information about children under 13 years of age. If we become aware that we have unknowingly collected information about a child under 13 years of age, we will make commercially reasonable efforts to delete such information from our database.

If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the below information to request that it be deleted.

8. Data Security

Please note that any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure when it is transmitted to us. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” Any information you transmit to us you do at your own risk.

9. California Privacy Rights

Sharing for Direct Marketing Purposes

We do not share personal information as defined by California Civil Code Section 1798.83 (“Shine The Light Law”) with third parties for their direct marketing purposes.

10. Data Deletion Instructions

By applicable laws and regulations, we will delete or anonymize personal information once it is no longer needed for its intended purpose or upon request from the individual whose data is being stored. To delete your account and associated personal data, please access your profile within the Mobile App and select the “Delete your account” option; if you experience any problems, contact us at [email protected].

Please note that some data may need to be retained for legal or regulatory purposes, and in such cases, we will ensure that it is kept secure and confidential. By using our services, you agree to our data deletion instructions and acknowledge that we will do our best to comply with all applicable data protection regulations.

United States Regional Privacy Notice

This United States Regional Privacy Notice (“US Notice”) supplements our Privacy Policy.

This US Notice is for individuals residing in certain US states and is designed to help you better understand how we collect, use, and disclose your personal information and, depending on how you use Wander and where you reside, how to exercise available rights under various applicable privacy laws in the US, such as the California Consumer Privacy Act, the Colorado Privacy Act, the Connecticut Act Concerning Personal Data Privacy and Online Monitoring, the Utah Consumer Privacy Act, and the Virginia Consumer Data Protection Act (collectively, the “US Privacy Laws”).

What information we collect and share about you

To provide our apps and services to you, we must process information about you, including personal information.

We do not “sell” your personal information as that term is defined under US Privacy Laws.

Here is a summary of the categories of personal information we may have collected about you over the past 12 months and with whom we may have disclosed that information to, depending on how you use Wander.

To make commerce better for everyone using Wander and its Products and Services, we collect and use personal information provided by:

• You: We collect the information you provide when you use our platform, including when you sign up for Wander as a Guest, or other Customer or User, visit a Wander-powered website, fill in booking or other order information, visit one of Wander’s Websites or Apps, contact Wander support or the Wander Concierge. We collect account and payment information you provide to us (including information about your business if you are a business customer), Wander stores or items you save to favorites, purchases you make, reviews you post, and how you otherwise interact or communicate or interact with Wander and/or its Websites, Apps, or through its Products and Services. We also collect information about how you browse through our apps and sites, including search terms you may enter.
• Your device(s): We collect information from and about the devices you use, including computers, phones, and other web-connected devices you use to access our apps or services, and we combine this information across different devices you use.
• Third parties: We receive information from partners who help us provide you with our services including the following:
  • Email providers: If you use the Website or App or other Products and Services and you connect your third party inboxes, such as Gmail or Outlook (according to their terms and policies and as permitted by applicable law), we receive information to identify Wander-related emails about specific orders you have made, Services you have engaged with in the past, and other related information.
  • Service Providers: We receive information from our service providers, who help us provide services, like reviewing accounts for fraud or other concerns.
  • Marketplaces: If you use the Website or App, or similar Wander Services we may receive information from other marketplaces or platforms that you choose to connect. This information helps us to provide and improve our Services, to personalize your experience using our apps and services, and to determine if you are eligible for specific offers.
  • Subprocessors: We may work with third party subprocessors for cloud hosting, content delivery, data analysis, internal logging, fulfillment services and email transmission, among others, to provide you with our services.
  • Analytics and cookie providers: We may also receive information through our use of cookies, social plugins (such as the Facebook “like” button), pixels and tags for business purposes, such as providing information to help measure how users interact with our website content.

How long we keep your information

Because we need your personal information to provide Wander services, we generally keep your personal information, including sensitive personal information, while you use Wander products or services or until you tell us to delete your information. We may also keep personal information to comply with legal obligations or protect our or other’s interests.

Your rights over your information

Depending on where you live, how you use Wander, and subject to certain exceptions, you may have some or all of the following rights:

• Right to Know: The right to request that we disclose to you the personal information we collect, use, or disclose about you, and information about our data practices.
• Right to Request Correction: The right to request that we correct inaccurate personal information that we maintain about you.
• Right to Request Deletion: The right to request that we delete personal information that we have collected about you.
• Right to Object to Processing: You can exercise your right to object to certain types of processing activities here, subject to applicable law.

To exercise your rights, including the “right to know” and “right to delete,” please submit a request to [email protected].

Please note that to protect your information and the integrity of our products and services, we may need to verify your identity before processing your request. In some cases we may need to collect additional information to verify your identity, such as your email address or a government issued ID.

Under US Privacy Laws, you may also designate an authorized agent to make these requests on your behalf. If you use an authorized agent to submit a request, we may need to collect additional information, such as a government issued ID, to verify your identity before processing your request to protect your information.

For information on the CCPA requests we have received, please send an email to [email protected]. In certain states, you may have the right to appeal our decision regarding a request related to these rights. If you wish to appeal a decision, please contact [email protected].

We will not discriminate against you for exercising any of these rights.

European Data Subjects

This section supplements our Privacy Policy and applies if the processing of your Personal Data is subject to the data protection laws of the European Economic Area, the UK, or Switzerland.

Our legal basis for processing your Personal Data

Our legal basis for processing your Personal Data to show you targeted advertisements is your consent.

Your rights in relation to your Personal Data

In addition to the rights noted above, you can exercise the following rights:

• Objection to Processing and Restriction of Processing: Right to object to the processing of your Personal Data for certain purposes and to request the restriction of the processing of your Personal Data;
• Withdrawal of Consent: Right to withdraw consent where processing of your Personal Data is based on consent. If you withdraw your consent, this will not affect the lawfulness of any processing based on your consent before its withdrawal.

11. How to Contact Us

Should you have any questions about our privacy practices or this Privacy Policy, please email us at [email protected].