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Privacy Policy

Last updated: April 9, 2026

1. Who We Are

GenuFly ("we", "us", "our") is a travel planning and concierge service operated at genufly.com. We act as the data controller for personal information collected through our platform. Contact us at: concierge@genufly.com

2. What Data We Collect

We collect the following categories of personal data: - Identity data: name, email address, phone number - Account data: membership tier, preferences, saved destinations - Transaction data: booking history, payment records (we do not store card numbers) - Usage data: pages visited, searches performed, items saved - Communications: inquiry details, messages sent to our concierge team - Technical data: IP address, browser type, device information, cookies

3. How We Use Your Data

We use your data to: - Provide and personalise our travel concierge service - Process your membership subscription - Send transactional emails (booking confirmations, inquiry updates) - Send marketing communications (with your explicit consent) - Improve our platform and services - Comply with legal obligations - Detect and prevent fraud Legal basis for processing: contract performance, legitimate interests, legal obligation, and consent where indicated.

4. Cookies and Tracking

We use cookies and similar technologies to: - Keep you logged in (essential session cookies) - Remember your preferences (functional cookies) - Analyse site usage (analytics cookies — only with your consent) - Track affiliate referrals (marketing cookies — only with your consent) You can manage your cookie preferences at any time using our Cookie Settings link in the footer. Withdrawing consent will not affect the lawfulness of processing before withdrawal.

5. Data Sharing

We share your data only with: - Travel partners and suppliers necessary to fulfil your booking - Payment processors (Stripe, PayPal) who process payments on our behalf - Email service providers who send communications on our behalf - Analytics providers (with your consent) We do not sell your personal data to third parties.

6. Data Retention

We retain your data for: - Account data: for the duration of your account plus 2 years - Transaction records: 7 years for tax and legal compliance - Marketing data: until you withdraw consent or request deletion - Inquiry notes: 3 years after inquiry closure You may request deletion of your account and personal data at any time (see Your Rights below).

7. Your Rights Under GDPR

If you are in the European Economic Area or United Kingdom, you have the right to: - Access: request a copy of the personal data we hold about you - Rectification: correct inaccurate or incomplete data - Erasure: request deletion of your personal data ("right to be forgotten") - Portability: receive your data in a structured, machine-readable format - Restriction: request we limit processing of your data - Objection: object to processing based on legitimate interests or for marketing - Withdraw consent: at any time where processing is based on consent To exercise any of these rights, email us at: concierge@genufly.com We will respond within 30 days. You also have the right to lodge a complaint with your local data protection authority.

8. California Privacy Rights (CCPA)

California residents have the right to: - Know what personal information we collect, use, disclose, and sell - Delete personal information we have collected - Opt-out of the sale of personal information (we do not sell personal information) - Non-discrimination for exercising your privacy rights To submit a request, email: concierge@genufly.com

9. International Transfers

Your data may be processed in countries outside your own, including the United States. Where we transfer data outside the EEA, we ensure appropriate safeguards are in place including Standard Contractual Clauses approved by the European Commission.

10. Security

We implement appropriate technical and organisational measures to protect your personal data including encryption in transit (TLS), encrypted storage, access controls, and regular security assessments. No system is completely secure and we cannot guarantee absolute security.

11. Children

Our service is not directed to children under 16. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a child, please contact us immediately.

12. Changes to This Policy

We may update this policy periodically. We will notify you of material changes by email or prominent notice on our website. Continued use of our service after changes constitutes acceptance of the updated policy.

13. Contact Us

For privacy questions, requests, or complaints: Email: concierge@genufly.com Website: genufly.com/contact Data Controller: GenuFly Travel Email: concierge@genufly.com

Exercise Your Rights

To access, correct, delete or export your data:

Submit a Data Request