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This Privacy Policy was last updated on October 10, 2019

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1. Introduction


This General Jupiter HMS Privacy Policy (also referred to as the ‘Privacy Policy’) provides information on the collection, use, sharing and processing of personal information by Jupiter HMS and its affiliates (“Jupiter”, “we” or “us”) in connection with your use of Jupiter websites, mobile applications, and social media pages that link to this Privacy Policy, your interactions with Jupiter during in-person meetings or at Jupiter events, and in the context of other off-line sales and marketing activities. This Privacy Policy also explains the choices you have in relation to these processing activities.


We at Jupiter HMS, are committed to protecting and respecting your privacy. Please read this policy as it contains important information about how we use the personal data that we collect from you or that you provide to us.


By accessing the website or providing information, you agree to our privacy practices as set out in this privacy statement. We may change this policy from time to time. You should check this policy frequently to ensure you are aware of the most recent version.


If you have any questions regarding this policy or about our privacy practices, please contact us at the relevant address set out below in the ‘Contact Us’ section.

2. Know who are we?


When we say ‘we’ or ‘us’ in this policy, we are generally referring to the separate legal entities that make up the TechHighway group. These include: TechHighway Systems Inc, a company registered in Ontario, Canada with our registered office at TBDC, Suite 300, 325 Front St W, Suite 300 Toronto, ON, M5V 2Y1


It also includes any other businesses we add to this group in the future. If you would like more information about which TechHighway Group company you are dealing with, check the terms and conditions of your contract with us.

3. Information we collect from you?


Personal data is information that can be used to uniquely identify or contact a single person. We will collect and process information about users of our website and customers’ property guests, to provide our services. Therefore, we may process any information, including personal data, which our customer’s guests provide to the property or any online travel agency relating to the property guests’ arrangements.


Personal data processed by us may include but is not limited to: name, address, e-mail address, phone number, and credit card information, date of birth, records of our interactions and travel information.


We will hold your data on our systems for as long as is necessary for the relevant activity, or if is set out in any relevant contract you hold with us. We review our retention periods for personal data regularly. We are legally required to hold some types of information to fulfill our statutory obligations.

4. How do we collect your information?


Personal data is information that can be used to uniquely identify or contact a single person. We will collect and process information about users of our website and customers’ property guests, to provide our services. Therefore, we may process any information, including personal data, which our customer’s guests provide to the property or any online travel agency relating to the property guests’ arrangements.

  1. This is information about you that you give us directly through our website or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our website or services, when you report a problem with our website and when you provide us with details relating to the nature of any query or problem.

  2. Details you provide relating to your proposed travel arrangements, including relevant property bookings and related information.

  3. Information we collect about you.


When you visit our website, we will automatically collect:

  1. Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type, and its version, time zone setting, browser plug-in types and versions, and operating system and platform.

  2. Information about your visit, including the full Uniform Resource Locators (URL), click stream to, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers) and methods used to browse away from the page.

  3. Information we receive from other sources.

  4. This is information we receive about you if you use any of the other websites we operate or the other services we provide. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies).

  5. Personal information that is provided to us by travel agencies or online travel sites using The Jupiter product.

  6. Personal information that is provided to us by properties using The Jupiter product.

5. How do we collect your information?


We use information held about you to administer any contracts between you and us and for the legitimate interests of our business, for example, the processing of property guest data to register the property guest’s booking. Information you give to us. We will use this information:

  1. To communicate and provide you with the information, products or services that you request from us.

  2. To deliver functionality on our sites and for their technical and functional management.

  3. To administer subscriptions of Jupiter magazine and Profit magazine.

  4. To carry out our obligations under any contracts entered between you and us and to provide you with the information, products, and services that you request from us.

  5. To provide you with information about our products and services or related products and services, and to tailor our marketing and sales activities to your or your company’s interests. We offer that are like those that you have already purchased or enquired about.

  6. To engage in transactions with customers, suppliers and business partners and to process orders for Jupiter products and services.

  7. To analyze, develop, improve and optimize the use, function, and performance of our sites and products and services.

  8. To manage the security of our sites, networks, and systems.

  9. To comply with applicable laws and regulations and to operate our business.

  10. To provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail, Skype, SMS or any other communication medium) with information about products and services like those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. Our affiliates and we fully comply with national laws regarding SPAM. If you change your mind and decide that you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please use the unsubscribe option when we contact you. We agree that we will not sell, rent, or trade your email address to any unaffiliated third-party without your permission.

  11. To notify you about changes to our service.

  12. To ensure that content from our website is presented most effectively for you and your computer.


Information we collect about you. We will use this information:

  1. to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes

  2. to improve our website to ensure that content is presented most effectively for you and your computer or other devices.

  3. to allow you to participate in interactive features of our service when you choose to do so.

  4. as part of our efforts to keep our website safe and secure.

  5. to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.

  6. to make suggestions and recommendations to you and other users of our website about goods or services that may interest you or them.

  7. Information we receive from other sources. We will combine this information with the information you give to us and the information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive) and to facilitate the property booking and related services of property guests.5.3 We may aggregate your data into an anonymized form to help us provide more useful information to our customers and to understand which parts of the website are of most interest to visitors.


We may aggregate your data into an anonymized form to help us provide more useful information to our customers and to understand which parts of the website are of most interest to visitors.

6. Who we might share your information with?


We may from time-to-time make certain personal information available to strategic partners that work with Jupiter, such as the following:

  1. Various affiliates of Jupiter, which means our current subsidiaries and our ultimate holding company and its subsidiaries. It also includes such other affiliates as we may add in the future.

  2. Properties and online travel agencies through which you have arranged travel, but only the personal information that is needed for successful access to or processing of your travel arrangements.

  3. Service providers we use to support our business who provide services such as information processing, managing and enhancing customer data, providing customer service, assessing your interest in our products and services, and conducting customer research or satisfaction surveys, including service providers who offer applications which may be of interest to property customers through our Jupiter platform and

  4. In the event of a merger, acquisition, or any form of sale of some or all our assets, in which case personal data we hold about our customers will be among the assets transferred to the buyer.

  5. If we engage a third party to process an individual’s data on our behalf, that third party will be bound by our data privacy policies or have similar contractual obligations concerning the storage and processing of your personal information.

  6. We may also disclose your personal information to third parties to:

    1. Comply with any court order or other legal obligation or when data is requested by government or law enforcement authorities.

    2. Enforce or apply our terms of use and any other agreements.

    3. Protect the rights, property, or safety of us, our employees, customers, or others. This may include exchanging information with other companies and organizations for fraud protection and credit risk reduction.

    4. Credit reference agencies to assess your credit score where this is a condition of us entering into a contract with you.

7. International transfers of your data


From time to time, we may transfer your personal information to our group companies, suppliers or service providers based outside of the European Economic Area (EEA) for the purposes described in this policy. If we do this, your personal information will continue to be subject to one or more appropriate safeguards set out in the law. These might be the use of model contracts in a form approved by regulators or having our suppliers sign up to an independent privacy scheme approved by regulators (like the US ‘Privacy Shield’ scheme).


Our data is stored in the cloud using Amazon Web Services in India. If you are accessing any of our systems from outside India, you acknowledge that your personal information will be transferred to India, a jurisdiction which may have different privacy and data security protections from those of your jurisdiction, to be processed and stored.

8. Know your rights


You have the right to ask us not to process, or to stop processing, your data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us on the details set out below in the ‘Contact Us’ section.


Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

9. How you can access and update your information


You have the right to access the personal information that we hold about you in many circumstances. This is called a subject access request. If we agree that we are obliged to provide personal information to you (or someone else on your behalf), we will provide it to you or them free of charge except in exceptional circumstances.


Before providing personal information to you or another person on your behalf, we may ask for proof of identity and enough information about your interactions with us so that we can locate your personal information.


We strive to maintain accurate, complete, and relevant personal information for the purposes identified in this privacy statement. If any of the personal information we hold about you is inaccurate or out of date, you may ask us to correct it.


You have the right to object to us processing your personal information if we are not entitled to use it anymore or to have your information deleted or have its processing restricted in certain circumstances. You also have the right to port your data in certain circumstances.


If you would like to exercise any of these rights, please contact us using the details set out below in the ‘Contact Us’ section.


You also have the right to lodge a complaint with the supervisory data protection body that regulates us if you have concerns about how we use your personal information. For information on how to do this, please see the ‘Contact Us’ section.

10. Security precautions in place to protect against the loss, misuse or alteration of your information


We have implemented reasonable measures designed to secure your personal information from accidental loss and unauthorized access, use, alteration, and disclosure.

These includes –
  1. Physical security and access to all Jupiter premises.

  2. All access to computer hardware is password protected, with encryption and default security firewalls in place.

  3. Staff access to personal information is given on a need to know basis only. Tight controls, consistent with the Payment Card Industry standard (audited annually), are maintained concerning the use, storage, and processing of PII credit card data.

  4. Regular training of staff concerning storage and

  5. Otherwise following Jupiter’s Data Protection Policy.


The safety and security of your information also depend on you. Any content, including personal information, that you contribute to be shared, published or transmitted to other users of the website, is visible to other users and can be read, collected, or used by them. We urge you to be careful about giving out information in public areas of any of the websites. You understand and acknowledge that, even after removal, copies of your content, including personal information, that you contribute to be shared, published or displayed on a website, or transmitted to other users of a website, may remain viewable in cached and archived pages. Although we take efforts to protect your personal information, we cannot guarantee the security of your personal information transmitted to a website. Any transmission of personal information is at your own risk.

11. Cookies


The website may use “cookies” and other technologies such as pixel tags and web beacons. These technologies help us to improve and to deliver a better and more personalized service by enabling us to:

  1. Estimate our audience size and usage patterns.

  2. Store information about your preferences, allowing us to better customize the services according to your interests;

  3. Speed up your searches.

  4. Recognize you when you return to the website and

  5. Deliver targeted advertising based on products or content you have shown an interest in.


You may refuse to accept cookies by activating the appropriate settings on your browser. Check with your provider to find out how to disable cookies. Please note that certain features of the website may not be available if cookies are disabled.

12. Payments processors


We provide paid products and/or services on our website. In that case, we use third-party services for payment processing (e.g. payment processors).


We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council.

13. Updates to Our Privacy Policy


We reserve the right to modify this Privacy Policy at any time. If we make material changes to this policy, we may notify you on our Website, by a blog post, by email, or by any method we determine. The method we chose is at our sole discretion. We will also change the “Last Updated” date at the beginning of this Privacy Policy. Any changes we make to our Privacy Policy are effective as of this Last Updated date and replace any prior Privacy Policies.

14. Contact Us


If you have any questions regarding this policy or about our privacy practices, please e-mail us at