California Privacy Policy

(in compliance with the California Consumer Privacy Act)

Effective Date:  April 2, 2026

Last Updated on: April 2, 2026

This California Privacy Policy describes how Havynn Group d/b/a Havynn World (“Company”, “we”, or “us”) collects and processes personal information about our Subscribers who reside in California. The California Consumer Privacy Act (“CCPA”) requires us to provide our California consumers with a privacy policy that contains a comprehensive description of our online and offline practices regarding our collection, use, sale, haring, and retention of their personal information, along with a description of the rights they have regarding their personal information. This California Privacy Policy provides the information the CCPA requires, together with other useful information regarding our collection and use of personal information. Any terms defined in the CCPA have the same meaning when used in this policy.

This California Privacy Policy does not apply to our collection and use of personal information in an employment capacity. Employees, job applicants, contractors, interns, or other workers seeking more information on our employment-related personal information policies and practices should see our employee privacy policy available upon request from legal@havynnworld.com.   

This California Privacy Policy does not apply to our collection and use of personal information from residents outside of California. Consumers residing in other locations should see our general Privacy Policy at: https://havynnworld.com/privacy-policy/

Personal Information Collected

We collect and use information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information“). Personal information does not include:

• Publicly available information, including from government records, through widely distributed media, or that the consumer made publicly available without restricting it to a specific audience.
• Lawfully obtained, truthful information that is a matter of public concern.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act.

Personal Information Categories Chart

The chart below identifies the categories of personal information we collected from our consumers within the last 12 months and the expected retention period.

Sensitive Personal Information Categories Chart

Sensitive personal information is a subtype of personal information consisting of the specific information categories listed in the chart below. Importantly, the CCPA only treats this information as sensitive personal information when we collect or use it to infer characteristics about a consumer.

The chart below identifies which sensitive personal information categories, if any, we have collected from consumers to infer characteristics about them in the last 12 months.

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you, such as from the forms or other information you provide to the Company.
• Indirectly from you, such as from your interactions with the Company’s websites, mobile applications, social media platforms, or customer service interactions.
• From our third-party suppliers or third-party providers, such as our travel and lifestyle partners from whom you purchase travel or lifestyle products, customer service support providers, data analytics providers.
• Government databases.
• Other customers, such as from referral programs.
• Inferences generated by the Company’s or our service providers’ computer systems.

How We Use Personal Information

Personal Information Collection, Use, and Disclosure Purposes

We may use and disclose the personal information, including sensitive personal information, we collect to advance the Company’s business and commercial purposes, specifically to:

• Develop, offer, and provide you with access to third-party suppliers and providers and their travel and lifestyle products.
• Meet our obligations and enforce our rights arising from any contracts with you, including for billing or collections, or to comply with legal requirements.
• Fulfil the purposes for which you provided your personal information or that were described to you at collection and as the CCPA otherwise permits.
• Improve our products or services, marketing, or customer relationships and experiences.
• Notify you about changes to our products or services.
• Administer our systems and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.
• Enable your participation in our websites’ or mobile apps’ interactive, social media, or other similar features.
• Protect our Company, employees, or operations.
• Measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
• Make suggestions and recommendations to you and other consumers about the travel and lifestyle products provided by our third-party suppliers and providers that may interest you or them, including developing profiles.
• Manage your consumer relationship with us, including for:
  • online account creation, maintenance, and security;
  • reaching you, when needed, about your account;
  • billing and collections;
  • facilitating your interactions with our third-party suppliers and third-party providers of travel and lifestyle products.
• Perform data analytics and benchmarking.
• Administer and maintain the Company’s systems and operations, including for safety purposes.
• Engage in corporate transactions requiring review of consumer records, such as for evaluating potential Company mergers and acquisitions.
• Comply with all applicable laws and regulations.
• Exercise or defend the legal rights of the Company and its employees, and affiliates, customers, contractors, and agents.
• Respond to law enforcement requests and as required by applicable law or court order.

Sensitive Personal Information Use and Disclosure Purposes

We may use or disclose sensitive personal information for the following statutorily approved reasons (Permitted SPI Purposes):

• Performing actions that are necessary for our consumer relationship and that an average consumer in a relationship with us would reasonably expect.
• Preventing, detecting, and investigating security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information.
• Defending against and prosecuting those responsible for malicious, deceptive, fraudulent, or illegal actions directed at the Company.
• Ensuring physical safety.
• Short-term, transient use, such as non-personalized advertising shown as part of your current interactions with us, where we do not:
  • disclose the sensitive personal information to another third party; or
  • use it to build a profile about you or otherwise alter your experience outside your current interaction with the Company.
• Services performed for the Company, including maintaining or servicing accounts, processing or fulfilling transactions, verifying consumer information, processing payments, or providing financing, analytic services, storage, or similar services for the Company.
• Activities required to:
  • verify or maintain the quality or safety of a product, service, or device that we own, manufacture, had manufactured, or control; or
  • improve, upgrade, or enhance the service or device that we own, manufacture, had manufactured, or controlled.
• Collecting or processing sensitive personal information that we do not use for the purpose of inferring characteristics about a consumer.

We do not]use or disclose sensitive personal information for purposes other than the Permitted SPI Purposes. Subject to your limitation rights, the additional sensitive personal information use purposes include all of the purposes described in the Personal Information Collection, Use, and Disclosure Purposes section above.  For more on your right to limit these additional sensitive personal information use purposes, see Your Rights and Choices.

Additional Categories or Other Purposes

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. If required by law, we will also seek your consent before using your personal information for a new or unrelated purpose.

We may collect, process, and disclose aggregated or deidentified consumer information for any purpose, without restriction. When we collect, process, or disclose aggregated or deidentified consumer information, we will maintain and use it in deidentified form and will not to attempt to reidentify the information, except to determine whether our deidentification processes satisfies any applicable legal requirements.

Disclosing, Selling, or Sharing Personal Information

Business Purpose Disclosures

We may disclose the personal information we collect, including sensitive personal information,] to service providers and contractors for the business purposes described in the Personal Information Collection, Use, and Disclosure Purposes section and in the table below, such as to support our business functions. For example, we may disclose information from your visits to the Company’s website to a cybersecurity consultant to help secure the website.  For further example, we may disclose your address to our third-party suppliers and third-party providers with whom you interact through our Website.

We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, prohibit using the disclosed information for any purpose except performing the contract, and meet the CCPA’s other contract requirements for engaging service providers or contractors.

The chart below identifies the personal information categories we disclosed to service providers or contractors for a business purpose over the preceding 12 months and the specific business or commercial purpose for disclosing that information/categories of entities to whom we have disclosed our consumers’ personal information for a business purpose over the preceding 12 months, along with the personal information categories disclosed and the disclosure’s business purposes.

Business Purposes Disclosure Recipient Category, Personal Information Category, and Purposes Chart

Selling or Sharing Personal Information

We do not sell your personal information, including sensitive personal information, to third parties and have not sold it in the preceding 12 months. We do not share your personal information with third parties for cross-context behavioral advertising purposes and have not shared your personal information in the preceding 12 months.

Our personal information sharing does not include information about consumers we know are under age 16.

Your Rights and Choices

If you are a California resident, the CCPA grants you the following rights regarding your personal information:

Right to Know and Data Portability Requests

You have the right to request that we disclose certain information to you about our collection and use of your personal information (the “right to know“), including the specific pieces of personal information we have collected about you (a “data portability request“). Our response will cover the 12-month period preceding the request, although we will honor requests to cover longer periods that do not extend past April 6, 2026, unless doing so would be impossible or involves disproportionate effort. You may exercise your right to know twice in any 12-month period. Once we receive your request and confirm your identity (see How to Exercise Your Rights), we will disclose to you:

• The categories of:
  • personal information we collected about you; and
  • sources from which we collected your personal information.
• The business or commercial purpose for collecting your personal information and, if applicable, selling or sharing your personal information.
• If applicable, the categories of persons, including third parties, to whom we disclosed your personal information, including separate disclosures identifying the categories of your personal information that we:
  • disclosed for a business purpose to each category of persons; and
  • sold or shared to each category of third parties.
• When your right to know submission includes a data portability request, a copy of your personal information, subject to any permitted redactions.

For more on exercising this right, see Exercising the Rights to Know, Delete or Correct.

Right to Delete and Right to Correct

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions and limitations (the “right to delete“). Once we receive your request and confirm your identity, we will delete your personal information from our systems unless an exception allows us to retain it. We will also notify our service providers, contractors, and other recipients to take appropriate action.  You must submit any request to delete your personal information to third-party suppliers and third-party providers with whom you interacted through our Website.  We do not exercise authority or control with regard to the third-party providers and third-party suppliers.

You also have the right to request correction of personal information we maintain about you that you believe is inaccurate (the “right to correct“). We may require you to provide documentation, if needed, to confirm your identity and support your claim that the information is inaccurate. Unless an exception applies, we will correct personal information that our review determines is inaccurate and notify our service providers, contractors, and other recipients to take appropriate action.

For more on exercising these rights, see Exercising the Rights to Know, Delete or Correct.

Right to Limit Sensitive Personal Information Use and Disclosure to Permitted SPI Purposes

You have a right to ask businesses that use or disclose your sensitive personal information to limit those actions to just the CCPA’s Permitted SPI Purposes (the “right to limit“). As we do not use or disclose sensitive personal information beyond the CCPA’s Permitted SPI Purposes, we do not currently provide this consumer right. 

For more on the Permitted SPI Purposes and our additional use purposes, if any, see Sensitive Personal Information Use and Disclosure Purposes.

Personal Information Sales or Sharing Opt-Out and Opt-In Rights

You have the right to request that businesses stop selling or sharing your personal information at any time (the “right to opt-out“), including through a user-enabled opt-out preference signal. Similarly, the CCPA prohibits businesses from selling or sharing the personal information of consumers it actually knows are under 16 years old without first obtaining consent from consumers who are between 13 and 15 years old or the consumer’s parent or guardian for consumers under age 13 (the “right to opt-in“).

We cannot share your personal information after we receive your request to opt-out unless you later consent to the sharing of your personal information. For more on exercising your opt-out rights, see Exercising the Right to Limit or Opt-Out.

ADMT Rights

When a business uses automated decision-making technology (ADMT) to make significant decisions about you, you may have rights to:

• Obtain certain information about how the business uses ADMT, that is specific to you (the “ADMT access right“).
• Opt-out of the ADMT use (the “ADMT opt-out right“) unless the business provides you with a method to appeal the decision to a human reviewer with the authority to overturn the decision (the “ADMT appeal right“) or another exception applies.

ADMTs are technologies that process personal information and use computation to execute a decision and either replace or substantially replace human decision-making, resulting in decisions made without human involvement. Decisions are significant when they result in the provision or denial of financial or lending services, housing, education enrollment or opportunities, employment or independent contracting opportunities or compensation, or healthcare services. Advertising is not a significant decision.

We do not currently use ADMT to make significant decisions about consumers, so we do not provide ADMT access, opt-out, or appeal rights.

Right to Non-Discrimination

You have the right not to be discriminated or retaliated against for exercising any of your privacy rights under the CCPA.

How to Exercise Your Rights

Exercising the Rights to Know, Delete, Correct

To exercise the right to know (including data portability), delete, or correct described above, please submit a verifiable request to us by either:

• Emailing us at customerservice@havynnworld.com.

Please describe your request with sufficient detail so we can properly understand, evaluate, and respond to it. You or your authorized agent may only submit a request to know, including for data portability, twice in a 12-month period.

Exercising the Right to Limit or Opt-Out

You can submit your request to limit or opt-out through:

• Emailing customerservice@havynnworld.com.

You can also submit your request to opt-out of personal information sales and sharing through an opt-out preference signal.

Verification Process and Authorized Agents

Only you may make a request to know, delete, or correct related to your personal information. If your minor child is our consumer, you may also make a verifiable request on their behalf. We may request specific identifying information from you or your authorized representative to confirm your or their identity before we can process your right to know, delete, or correct your personal information. 

We cannot respond to your request to know, delete, or correct if we cannot verify your identity or authority to make the request and confirm the personal information relating to you. We will only use personal information provided in the request to verify the requestor’s identity or authority to make the request.

We consider requests made through your password-protected account with our company sufficiently verified when the request relates to personal information associated with that specific account. 

For requests to limit or opt-out, we ask for the information necessary to complete the request, which may include, for example, the consumer’s name, email address, or account username.

Responding to Your Requests to Know, Delete, or Correct

We will confirm receipt of your request within ten business days. If you do not receive confirmation within the ten-day timeframe, please legal@havynnworld.com. 

We endeavor to substantively respond to a verifiable request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. We will deliver our written response to your verified email address or through your Subscriber account. Our substantive response will tell you whether or not we have complied with your request. If we cannot comply with your request in whole or in part, we will explain the reason, subject to any legal or regulatory restrictions. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, deleted, or made your personal information anonymous in compliance with our record retention policies and obligations.

Any disclosures we provide will cover information for the 12-month period preceding the request’s receipt date. We will consider requests to provide longer disclosure periods that do not extend past April 6, 2026, unless providing the longer timeframe would be impossible or involves disproportionate effort.

For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Response and Timing on Rights to Limit or Opt-Out

In response to your request to limit or opt-out, we will process your request, as soon as feasibly possible, but no later than 15 business days from the date we receive the request. We will only use personal information provided from your request to comply with the request.

We will also notify our service providers, contractors, and certain other downstream recipients of your request to limit or opt-out and instruct them to both:

• Comply with your request.
• Forward the request to their own downstream recipients, if applicable.

We may deny opt-out requests if we have a good-faith, reasonable, and documented belief that the request is fraudulent and will clearly explain our denial decision to the requestor.

How We Protect Your Personal Data

We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Services. In particular, email, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us through these communications channels. Any transmission of personal data is at your own risk.

The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.

Privacy Policy Changes

We reserve the right to update this California Privacy Policy at any time, as we continue to develop our compliance program in response to legal developments of the CCPA. If we make any material changes to this California Privacy Policy, we will update the policy’s effective date and post the updated policy on our Website.  We encourage you to check our Website to review the current Privacy Policy in effect.  Continued use of our Website constitutes your consent to our California Privacy Policy and general Privacy Policy, as amended or revised at the time of use.

Contact Information

If you have any questions or comments about this policy, the ways in which we collect and use your information described here, or your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Email: customerservice@havynnworld.com 

Postal Address:

2757396 ALBERTA INC. d/b/a Havynn Group d/b/a HavynnWorld

Suite 500, 940-6^th Avenue SW

Calgary, Alberta, T2P 3T1, Canada

If you need to access this California Privacy Policy in an alternative format due to a disability, please contact customerservice@havynnworld.com.