Privacy Policy for Huffman Travel, LLC

Effective Date: January 1, 2026

At Huffman Travel, LLC, we recognize that privacy is important. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you visit our website, use our services, or interact with us in any way.

We may collect personal information from you in the course of our business, including through your use of our websites, when you contact or request information from us, when you engage our services or as a result of your relationship with one or more of our staff, suppliers, affiliated entities or clients and their travel organizers.

Information We Collect

We may process the following personal information:

• Contact Information: Name, email address, phone number, postal address

• Travel Itineraries and Booking Details: Passport information, travel preferences, itinerary, visa data, information about travel plans and past travel, interests, and other preferences, such as languages spoken, dietary and accessibility preferences

• Payment Information: Name, Credit/debit card details, including card number, expiration date and security code, billing address (processed securely via third-party providers)

• Cookies & Tracking Technologies: Our website uses only strictly necessary cookies that are essential for providing the services you request and for ensuring the site’s secure operation.

You can manage your cookie preferences through your browser settings. Disabling cookies may affect site functionality. Contact us to find out more about the cookies we use and how to manage and delete cookies.

International Data Transfers

We may transfer your personal information to countries outside your country of residence. These transfers are conducted in compliance with applicable data protection laws and safeguards.

How We Use Your Information

We implement industry-standard security measures to protect your data from unauthorized access, disclosure, or misuse. However, no system is 100% secure, and we encourage you to take precautions when sharing personal information online.

Sharing Your Information

We may share your information with:

• Travel partners (including but not limited to, airlines, hotels, cruise lines, transport providers, tour operators)

• Payment processors

• Third parties who perform services on our behalf, such as printers and postal and couriers companies, professional advisers such as lawyers and accountants

• Virtuoso, Ltd. and the Virtuoso network of independent luxury travel agencies and preferred suppliers

• Legal and government authorities (if required by law), for example for the purpose of or in connection with legal proceedings, or otherwise for the purpose of establishing, exercising or defending our legal rights, or when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity.

• Affiliated entities and potential acquirors. We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

• Our websites may contain links to other websites whose privacy practices and policies may differ from ours. Please consult the other site’s privacy policies as we do not have control over their practices.

• Please note this list is non-exhaustive and there may be other examples where we need to share with other parties in order to provide the services as effectively as we can.

Do Not Sell: We do not sell or share your personal information, except as disclosed in this Privacy Policy. These third parties are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.

Data Retention

We will retain relevant personal information for at least seven years from the date of our last interaction with you and in compliance with our obligations under the EU General Data Protection Regulation or similar legislation around the world, or for longer if we are required to do so according to our regulatory obligations or professional indemnity obligations.

If personal information is only useful for a short period, for example for specific marketing campaigns, we may delete it.

Your Rights

Depending on your location, you may have rights to:

• Access, correct, or delete your personal data

• Object to or restrict certain processing

• Withdraw consent at any time

• Lodge a complaint with a data protection authority

• Unsubscribe from newsletters or emails

You can exercise your data protection rights in various ways. For example, you can opt out of marketing by clicking the “unsubscribe” link in the emails, in your account as applicable, or contacting our customer service. If you have questions on how to exercise these rights, contact us info@huffmantravel.com.

Artificial Intelligence

We and our suppliers, partners and affiliates, including but not limited to Virtuoso (“we”, “us”, “our” in this section), may use artificial intelligence and machine learning to power our platform and services, relying on your personal data for purposes including:

• Enhancing your user experience and personalizing content, search results, and recommendations based on your profile, preferences, and real-time factors like weather or flight delays

• Interacting with you via chatbots or virtual travel assistants to help plan trips

• Optimizing pricing, alerts, and margin adjustments

• Screening uploaded content (e.g. property images) for quality and formatting, and identifying amenities

• Moderating reviews to protect privacy and assess satisfaction

• Summarizing property reviews and answering frequently asked questions

• Preventing fraud and enforcing our terms

• Generating new content (e.g. summaries, translations, suggestions)

• Improving operational efficiency

• Resolving claims, complaints, disputes, and payments

• Creating insights and analytics

• Transcribing interactions with us and for taking notes during meetings and events

Some decisions may be automated using your data. We rely on legitimate interests for safety, efficiency, administrative and for improving user experience. We do not make significant decisions solely through automated processing unless:

• You’ve given explicit consent

• It’s required for a contract

• It’s authorized by law

You may request manual review of automated decisions or contest them.

Updates to This Policy

We may update this Privacy Policy periodically. Changes will be posted on this page with an updated effective date. Continued use of our services after changes indicates your acceptance.

Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact:

Huffman Travel, LLC

2507 Far Hills Avenue Dayton, OH 45419

info@huffmantravel.com

Additional Information for California Consumers as defined in the California Consumer Privacy Act 2018, as amended from time to time (“CCPA”)

You have certain choices regarding our use and disclosure of your personal information, as described below.

Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.

Deletion: You have the right to request that we delete certain personal information we have collected from you.

Opt-Out of Sale: You have the right to opt-out of the sale of your personal information. Shine the Light Request: You also may have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties.

How to Submit a Request: To submit a rights request email us at info@huffmantravel.com.

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request access to or deletion of your personal information, we may require you to provide any of the following information: First Name, Last Name, Email Address, Physical Address. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf (1) we may require you to provide the authorized agent written permission to do so, and (2) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).

Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This notice is available in alternative formats upon request. Please contact info@huffmantravel.com to request this notice in an alternative format.

Additional Information for Residents of the EU, EEA, UK

You have the following rights in relation to the personal information we hold about you:

Your right of access: If you ask us, we'll confirm whether we're processing your personal information and, if necessary, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

Your right to rectification: If the personal information we hold about you is inaccurate or incomplete, you are entitled to request to have it rectified. If you are entitled to rectification and if we've shared your personal information with others, we'll let them know about the rectification where possible. If you ask us where possible and lawful to do so, we'll also tell you who we've shared your personal information with so that you can contact them directly.

Your right to erasure: You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we've shared your personal information with others, we'll let them know about the erasure where possible. If you ask us where it is possible and lawful for us to do so, we'll also tell you who we've shared your personal information with so that you can contact them directly.

Your right to restrict processing: You can ask us to 'block' or suppress the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to us. If you are entitled to restriction and if we've shared your personal information with others, we'll let them know about the restriction where it is possible for us to do so. If you ask us where it is possible and lawful for us to do so, we'll also tell you who we've shared your personal information with so that you can contact them directly.

Your right to data portability: You have the right, in certain circumstances, to obtain personal information you've provided us with (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

Your right to object: You can ask us to stop processing your personal information, and we will do so, if we are:

• relying on our own or someone else's legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or

• processing your personal information for direct marketing purposes.

Your right to withdraw consent: If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

Your right to lodge a complaint with the supervisory authority: If you have a concern about any aspect of our privacy practices, including the way we've handled your personal information, you can report it to the relevant Supervisory Authority.

Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process the data or where data may be exempt from disclosure due to reasons of legal professional privilege or professional secrecy obligations.

Additional Information on Cookies and Other Tracking Technologies

This Cookie Policy explains how we use cookies and similar technologies on our website to improve your experience, personalize content, and ensure the smooth functioning of our services.

1. What Are Cookies?

Cookies are small text files stored on your device when you visit a website or use an app. They help us remember your preferences, understand how you interact with our services, and deliver relevant content.

2. Why We Use Cookies

Our website uses only strictly necessary cookies that are essential for providing the services you request and for ensuring the site’s secure operation.

These cookies do not collect personal information for marketing or analytics purposes and cannot be disabled through this site. You may control cookies through your browser settings, but doing so may affect how the website functions.

3. Updates to This Policy

We may update this Cookie Policy from time to time. Changes will be posted on this page with the updated effective date.

4. Contact Us

If you have any questions about our use of cookies, feel free to contact us at: info@huffmantravel.com