1. Introduction
JustKeeps Travel, LLC ("JustKeepsTravel," "we," "us," "our") respects your privacy. This Privacy Policy explains what personal informationwe collect, how we use and share it, and the rights you have over it.
This Policy applies to our website and anyrelated pages or booking portals we operate (the "Site"), to our booking and travel planning services, and to our communications with you byemail, phone, and messaging platforms.
Because we arrange international travel, thisPolicy is written to address the requirements of United States privacy laws,the EU and UK General Data Protection Regulation ("GDPR"), andother applicable privacy laws.
Ourcommitment to discretion
We understand that many of our clients valueprivacy as much as the travel itself. We treat your itineraries, destinations, travel dates, travel companions, and personal information as confidential, andwe disclose them only as necessary to arrange and service your travel or whererequired by law.
We will never sell or rent your clientinformation, travel history, or itinerary details to advertisers, data brokers,or marketing companies. Whereyou travel, when, and with whom is not information we monetize.
Please read this Policy together with ourTerms of Service.
2. Who We Are
Data Controller:
- JustKeeps Travel, LLC (a Florida limitedliability company)
- Telephone: 561-300-3540
- Email: Hello@justkeepstravel.com
For privacy questions or to exercise yourrights, contact us at Hello@justkeepstravel.com.
3. Information We Collect
3.1 Information You Provide Directly
Identity and contact information
Full legal name as shown on travel documents,preferred name, date of birth, gender, postal address, email address, andtelephone number.
Travel documentation
Passport number, passport issuing country,passport issue and expiry dates, visa details, nationality, citizenship,redress or Known Traveler numbers, and TSA PreCheck or Global Entryinformation.
How we protect these documents: Travel documents are stored securely, accessis limited to the personnel and service providers who need them to arrange yourtravel, and passport details are shared only with the Suppliers and authoritiesthat require them for your specific booking. We redact or delete them once theyare no longer needed to service your travel, unless the law requires us to keepthem.
Booking and preference information
Destinations, travel dates, party composition, seat and room preferences, loyalty program numbers, and past booking history.
Payment information
Billing name and address, and the last four digits and expiry of payment cards. We do not store full payment card numbers or security codes. Card payments are processed by PCI-DSS compliant third-party payment processors.
Sensitive personal information
Where you provide it so we can arrange your travel appropriately, we may collect dietary requirements, allergies, accessibility and mobility needs, medical conditions relevant to travel, and vaccination status. Under GDPR this is "special category" data and we process it only with your explicit consent or where otherwise permitted by law. You are never required to provide it, but withholding it may limit our ability to arrange suitable travel.
Information about others
When you book on behalf of companions, family members, or guests, you provide their information to us. You confirm that you are authorized to do so and that you have made them aware of this Policy.
Communications
The content of emails, WhatsApp and SMS messages, call notes, forms, and any reviews or testimonials you submit.
3.2 Information Collected Automatically
When you visit the Site, we and our service providers may collect: IP address, browser type and version, device type and operating system, referring URL, pages viewed, time spent, and general location inferred from IP address. This is collected through cookies and similar technologies described in Section 8.
3.3 Information From Third Parties
We may receive information from travel Suppliers (airlines, hotels, villa managers, tour operators, cruise lines), host agencies or consortia we work with, payment processors, and publicly available sources or social media platforms where you interact with us.
4. How We Use Your Information
We collect only what we need to plan, book,and look after your travel. Specifically, we use personal information to:
- Prepare quotes, proposals, and itineraries
- Book, confirm, modify, and service travel arrangements with Suppliers
- Process payments, issue invoices, and manage credits and refunds
- Communicate with you about your bookings, including confirmations, changes, and travel alerts
- Provide customer support before, during, and after travel
- Comply with legal, regulatory, and tax obligations
- Detect, prevent, and investigate fraud, chargebacks, and misuse
- Establish, exercise, or defend legal claims
- Maintain business records
- Improve the Site and our services
- Send marketing communications where you have consented or where otherwise permitted, subject to your right to opt out at any time
We do not use your personal information to train artificial intelligence or machine learning models, and we do not permit our service providers to do so.
Automated decision-making. We do not make decisions about you basedsolely on automated processing that produce legal or similarly significant effects.
We do not sell your personal information. SeeSection 10.
5. Legal Bases for Processing (GDPR)
Where GDPR applies, we rely on the followinglegal bases:
Arranging and servicing your travel
Payment processing and invoicing
Tax, accounting, and regulatory compliance
Fraud prevention, security, and defending claims
Service improvement and analytics
Marketing communications
Dietary, medical, and accessibility information
Performance of a contract with you
Performance of a contract; legal obligation
Legal obligation
Legitimate interests
Legitimate interests; consent for non-essentialcookies
Consent, or legitimate interests where permitted
Explicit consent (Article 9)
Where we rely on legitimate interests, we have assessed that our interests are not overridden by your rights and freedoms. You may object to such processing; see Section 11.
6. How We Share Your Information
We share personal information only asdescribed below. We do not sell it.
Travel Suppliers. Airlines, hotels, villa owners and managers, cruise lines, tour operators, transfer companies, activity providers, and event vendors receive the information necessary to fulfill your booking. This necessarily includes names, dates of birth, passport details where required, and any accessibility or dietary needs you have asked us to convey. Suppliers act as independent controllers of that information and handle it under their own privacy policies.
Service providers. Booking and CRM platforms, email and messaging providers, payment processors, accounting and bookkeeping providers, IT and hosting providers, and marketing platforms. These parties act as processors on our instructions and are contractually restricted from using your information for their own purposes.
Host agencies, consortia, and independent agents. Where a booking is placed through a host agency or consortium, or serviced by one of our independent travel advisors, they receive the information necessary to place and service the booking.
Insurers. Where you elect to purchase travel insurance through a referral, the insurer receives the information necessary to quote and issue the policy.
Professional advisors. Attorneys, accountants, and auditors, subject to confidentiality obligations.
Legal and regulatory disclosure. Government authorities, courts, law enforcement, border and immigration authorities, and regulators, where required by law, subpoena, or legal process, or to establish or defend legal claims. Certain destinations legally require advance passenger information to be transmitted before travel.
Business transfers. In connection with a merger, acquisition, financing, or sale of all or part of our business, subject to this Policy continuing to apply.
Payment disputes. In a chargeback or payment dispute, we may submit booking confirmations, itineraries, and your electronic communications to the payment processor, card network, or issuing bank as evidence of authorization and delivery.
7. International Data Transfers
Travel is inherently international. To arrange your travel, we transfer personal information to Suppliers and service providers located outside your country of residence, including outside the European Economic Area and the United Kingdom. These countries may not offer the same level of data protection as your home jurisdiction.
Where we transfer personal information from the EEA or UK, we rely on appropriate safeguards, including:
- Standard Contractual Clauses approved by the European Commission, and the UK International Data Transfer Addendum where applicable;
- Adequacy decisions, where the destination country has been recognized as providing adequate protection; or
- Article 49 derogations, including transfers necessary for the performance of a contract with you or for the conclusion of a contract in your interest, which commonly applies when booking travel with a Supplier in a third country.
You may request further information about the safeguards applied by contacting us at Hello@justkeepstravel.com.
8. Cookies and Tracking Technologies
The Site uses cookies and similar technologies.
Strictly necessary cookies enable core functionality such as security, form submission, and session management. These cannot be disabled.
Analytics cookies help us understand how visitors find and use the Site so we can improve it. These may be provided by third-party analytics services, which receive usage data in accordance with their own privacy policies.
Advertising and social media cookies may be set by third-party advertising and social media platforms to measure campaign performance, understand which content is effective, and show you relevant content on other sites. By engaging with the Site without disabling these cookies where a choice is offered, you consent to their use as described in this Section.
You may request a current list of the specific analytics and advertising providers we use by writing to Hello@justkeepstravel.com.
You can control cookies through your browser settings and, where offered, through our cookie banner. Blocking cookies may affect Site functionality. Where required by law, we obtain consent before setting non-essential cookies.
We honor Global Privacy Control (GPC) and comparable opt-out preference signals where applicable law requires us to do so, and we treat such a signal as a request to opt out of any sale or sharing of personal information. Browser Do Not Track signals are not yet supported by a common standard, and we do not currently respond to them separately.
9. Data Retention
We keep personal information only as long asnecessary for the purposes described in this Policy:
- Booking and travel records: for the duration of the client relationship and for such further period as is necessary for our accounting and tax obligations and to resolve any question that may arise about a booking
- Passport and visa details: deleted or redacted once no longer needed to service the booking, unless retention is required by law
- Payment records: for the period required by applicable tax and financial recordkeeping obligations
- Marketing contact details: until you unsubscribe or request deletion
- Records relevant to a dispute or legal claim: until the matter is fully resolved and any limitation period has expired
Retention periods vary by record type and by the legal obligations that apply to it. When information is no longer needed for the purpose it was collected for, and no legal obligation requires us to keep it, we securely delete or anonymize it.
10. Sale and Sharing of Personal Information
We do not sell your personal information, and we do not share it for cross-context behavioral advertising, as those terms are defined under the California Consumer Privacy Act as amended by the CPRA. We have not sold or shared personal information in the preceding twelve (12) months.
We do not knowingly sell or share the personal information of anyone under 16.
To be explicit about what this means for travel: we do not sell, rent, trade, or otherwise make available our client lists, your travel history, your destinations, or your itinerary information to advertisers, marketing companies, data brokers, or any other third party for their own commercial purposes. The Suppliers and service providers described in Section 6 receive only what is necessary to fulfill your booking.
11. Your Privacy Rights
11.1 Rights Under GDPR (EEA and UK Residents)
You have the right to:
- Access the personal information we hold about you
- Rectify inaccurate or incomplete information
- Erase your information ("right to be forgotten"), subject to our legal retention obligations
- Restrict processing in certain circumstances
- Data portability receive your information in a structured, commonly used, machine-readable format
- Object to processing based on legitimate interests, and to direct marketing at any time
- Withdraw consent where processing is based on consent, without affecting the lawfulness of prior processing
- Lodge a complaint with your local data protection supervisory authority, as EU and UK law provides
11.2 Rights Under California Law (CCPA/CPRA)
California residents have the right to:
- Know what personal information we collect, use, disclose, and the categories of sources and recipients
- Access a copy of the specific pieces of personal information we hold
- Delete personal information, subject to legal exceptions
- Correct inaccurate personal information
- Opt out of sale or sharing (we do not sell or share; see Section 10)
- Limit the use of sensitive personal information
- Non-discrimination we will not deny service, charge different prices, or provide a lesser quality of service because you exercised a privacy right
11.3 California "Shine the Light"
California residents may request information about personal information we disclosed to third parties for their direct marketing purposes in the preceding calendar year. We do not disclose personal information for third-party direct marketing purposes.
11.4 Rights Under Other U.S. State Laws
Residents of other states with comprehensive privacy laws, including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and Florida, have comparable rights of access, correction, deletion, portability, and opt-out. We honor these rights on the same basis described above.
11.5 How to Exercise Your Rights
Email Hello@justkeepstravel.com with the subject line "Privacy Request." Tell us what right you wish to exercise and provide enough information for us to locate your records.
We will verify your identity before acting on a request, typically by confirming details already in our records. We do not require you to create an account.
We respond within thirty (30) days for GDPR requests and forty-five (45) days for U.S. state law requests, and may extend where permitted by law with notice to you.
An authorized agent may submit a request on your behalf with written authorization, and we may ask you to confirm the agent's authority directly.
12. Marketing Communications
Where you have opted in, or where otherwise permitted by law, we may send travel offers, destination content, and newsletters.
You can unsubscribe at any time using the link in any marketing email, or by emailing us. Opting out of marketing does not stop transactional messages about your bookings, confirmations, itinerary changes, payment reminders, and travel alerts, which are necessary to service your travel.
Where we contact you by SMS or WhatsApp for marketing, we do so only with your consent, and you may opt out by replying STOP or by contacting us.
13. Data Security
Protecting your information is something we take seriously, and we back that up with real controls: encrypted transmission of data, access limited to the people who genuinely need it, secure storage of travel documents, and written security obligations on every service provider who handles your information on our behalf.
That said, no system is completely secure and we cannot promise absolute security. Please don't send passport numbers or payment card details by ordinary email or text message. Just ask us and we will provide a secure way to send them.
If a breach occurs that is likely to result in a risk to your rights, we will notify you and the relevant authorities as required by applicable law.
14. Children's Privacy
Our services are directed to adults. We do not knowingly collect personal information directly from children under 13 (or under 16 in the EEA and UK) without parental consent.
We do collect information about minors when a parent or guardian books family travel and provides it. That information is used only to arrange the travel and is treated with the same protections described in this Policy.
If you believe a child has provided us information directly without parental consent, contact us at Hello@justkeepstravel.com and we will delete it.
15. Third-Party Websites and Suppliers
The Site may contain links to Supplier websites, booking engines, insurance providers, and social media platforms. We are not responsible for their content or privacy practices. Once your information is transferred to a Supplier, that Supplier's privacy policy governs its handling. We encourage you to read the privacy policies of any Supplier you book with.
16. Changes to This Policy
We may update this Policy from time to time. The Last Updated date at the top reflects the most recent revision. Where changes are material, we will provide prominent notice on the Site and, where required, obtain your consent. Continued use of the Site or our services after changes take effect constitutes acceptance of the revised Policy.
17. Contact Us
Questions, requests, or complaints about thisPolicy or our handling of your personal information:
A postal address for correspondence will beprovided on written request to the email address above.
We aim to resolve any concern directly and encourage you to contact us first. EU and UK law also provides a right to lodge a complaint with your local data protection supervisory authority.