Privacy Notice

This Privacy Notice describes the data that Hopper Inc. and its affiliates, as identified in the Section 8 (HTS Group) of this Privacy Notice (collectively, "HTS"), collect about you when you use the HTS websites, websites hosted for HTS partners and HTS services (the "Services"), and how HTS uses and discloses that data.  This Notice also explains your rights, including your rights to request information about HTS’s data processing, and/or deletion of your data.

First, we want you to know that HTS is committed to protecting your privacy and your personal data and information. HTS uses and discloses your data only to provide the Services to you, for example to book your next trip or notify you when we see a deal that you won’t want to miss, as explained in this Notice. If you have any questions about your data, you can always reach our Privacy team by emailing us at privacy@hopper.com.

1. The Information HTS Collects.

A. Information You Provide. When you create a HTS account, you may be required to provide and verify your mobile phone number. To make travel bookings using the HTS Services or to communicate to HTS for other purposes, you may be required to provide additional personal information including, for example, your name, address, email, government identification or third-party rewards numbers, date of birth, gender, and payment information. You may also be required to provide this personal information for any individual(s) on whose behalf you make travel booking(s).

B. Your Device. When you use or access HTS Services, HTS receives information about the computers, phones, or other web-connected devices and browsers that you use. The device information HTS receives includes attributes such as the device or browser type, operating system, hardware and software versions, display settings, language, region, location, currency, and time zone settings, mobile carrier, your IP address, and any device, operating system or advertising identifiers. HTS may also collect device and browser signals (for example, browser and device attributes, geolocation data, network characteristics, and usage patterns) from third-party providers to generate a unique device identifier solely to detect and prevent fraudulent or abusive activity on our Services.

C. Your Usage and Transactions. HTS collects information about how you use the Services, such as the flights or hotels you watch and the content you view or engage with. HTS also retains records of the travel bookings or other product/service purchases that you make using the Services, and any interactions with HTS’s support team.

D. Geolocation Data. HTS receives geolocation data from your device solely for the purpose of populating search fields, such as the “origin airport” field within the flight search section of the website, or to allow you to search for nearby pickup locations within the cars search section of the website. HTS does not retain your geolocation data. You can decline to provide geolocation data using your browser settings.

E. Cookie Data: When you visit HTS websites, HTS uses “cookies” and/or similar identifying technology on your device(s) to collect data, including cookie IDs, settings, and usage data. Please refer to HTS’s Cookie Statement, as part of HTS’s Supplemental Privacy Notice attached to this Notice, for more information.

2. How HTS Uses Your Information.

A. To Provide, Improve and Personalize the Services. HTS stores and uses the data it collects for the following purposes:

(i) to provide and support the Services for you, including by making bookings, supporting your bookings, and notifying you about deals;

(ii) to personalize the Services for you, such as by watching or suggesting trips or other products, deciding which products to offer, and administering HTS rewards programs, discounts, and offers;

(iii) to analyze and improve the Services and products, such as by marketing to you and measuring the effectiveness of our marketing;

(iv) to improve products and develop new products (based on usage trends);

(v) to ensure the security of the Services and prevent fraud or other illegal activity, such as by verifying the validity of an attempted booking or payment, including using unique device identifiers, which may also include the use of automated decision-making, for example, in relation to assessing fraudulent transactions or suspicious activity;

(vi) to comply with applicable accounting, legal and regulatory requirements; and

(vii) as otherwise explained to you at the time of the collection of data.

B. To Communicate with You. HTS also uses the data you provide to communicate with you about your travel bookings, about deals on travel that you are watching or may be interested in, and/or about other HTS products and services that we think you may be interested in. HTS may communicate with you via email, phone, SMS, or other messaging means based on contact information that you provide. You will have the opportunity to decline to receive any marketing communications from HTS unrelated to any booking, purchase, or support request that you make.

C. Data Retention. We will retain your personal information in accordance with all applicable laws, for as long as it may be relevant to fulfill the purposes set forth in this Privacy Notice, unless a longer retention period is required or permitted by law. We may retain anonymized data for analytical purposes over longer periods of time.

3. When HTS Shares Your Information.

A. To Make Travel Bookings. When you request to make a travel booking, HTS may share your data to third-party travel service suppliers (such as airlines, hotels, rental car providers, or insurance providers) and their data-processing partners, and/or to HTS’s third-party travel booking partners (such as a Global Distribution System provider) only as necessary to complete your booking. HTS’s third-party travel-booking partners (other than travel service providers) are required by HTS to use and disclose your data only as necessary to complete your HTS travel booking. Third-party travel service suppliers (such as airlines, hotels, rental car providers) that you select are not controlled by HTS, and any data disclosed to them will be subject to that supplier’s privacy policy and security practices. Therefore, we encourage you to review the privacy policies of any travel supplier whose products you purchase through HTS.

B. To Vendors that Help HTS Provide the Services. HTS works with a number of third-party data processing partners who help us provide and improve the Services. These partners include cloud-hosting services, data analytics and processing services, communication management (support) services, technology integration partners, survey partners, and payment and fraud-prevention service providers (including third-party device fingerprinting services). These third-party processing partners have access to your data only as necessary to perform their functions for HTS, and they are not permitted to share or use your data for any other purpose. They are also required to follow the same data security practices that HTS employs.

C. As Required by Law. HTS may share information with law enforcement and governmental entities, or in response to legal requests, only when necessary as required by law, or in the good-faith belief that such action is required by law, such as in response to a facially valid judicial, or other governmental entity, order, subpoena or warrant. HTS may also share information with law enforcement if we have a good-faith belief that such disclosure is necessary to detect, prevent and address fraud, unauthorized use of the Services, violations of our terms or policies, or other harmful or illegal activity.

D. For Marketing and Analytics Purposes. When you use the HTS Services, HTS may share your device advertising identifier or cookie information, and information about actions you take on the website, if you have enabled these features in your device settings, with third parties for the purpose of analyzing the effectiveness of HTS marketing activities and/or future marketing activities. You can disable, opt-out, and prevent the sharing of this information in your device or browser settings without impacting your ability to use the Services. HTS will accept your decision to disable sharing of your device advertising identifier as your signal of an election to opt-out of sharing and limit the use and processing of your personal data, and will abide by that decision in a frictionless manner. If you permit the sharing of such information, HTS’s third-party partners may combine information they receive from HTS with information about you obtained from other sources.

4. Your Rights to Your Personal Information, to Opt-Out of Sharing and to Limit Processing.

HTS provides all Users, regardless of your country of residency, with rights to rectify, object to the processing, or withdraw consent, to future sharing or processing of your data by HTS. You may make any such requests to HTS by emailing us at privacy@hopper.com and subsequently verifying your identity as requested by HTS. Absent exceptional circumstances, there is no fee for such requests and HTS will respond within thirty (30) days, or otherwise as required by law. Please note that certain Services that require data processing may no longer be available to you following a request for data deletion or cessation of processing, and a withdrawal of consent to processing will not prevent HTS from continuing to process data where HTS relies on a legal basis other than consent. If you are a resident of Canada, California (United States), the United Kingdom or the European Union, you may have additional rights under the Personal Information Protection and Electronic Documents Act (PIPEDA), California Consumer Privacy Act of 2018 (CCPA), the UK General Data Protection Regulation (UK GDPR), Swiss Federal Act on Data Protection (FADP) and the EU General Data Protection Regulation (EU GDPR), respectively. These rights are explained in our Supplemental Privacy Notice following this notice.

5. International Data Transfer.

HTS shares information globally within the HTS companies, including its global subsidiaries, and to the external processing partners and third-party suppliers mentioned above. Your information may, for example, be transferred or transmitted to, or stored and processed by, HTS group entities and/or third-party data processors located in the United States, Canada, or other countries outside of where you live, as necessary for the purposes as described in this Notice and to provide the Services to you. The laws in the countries in which your data is processed may differ from the laws in your home country. In order to protect your data during processing in any country, HTS may utilize standard contract clauses, rely on the European Commission’s adequacy decisions about certain countries, as applicable, or obtain your consent for these data transfers. When transferring certain information to the United States, we may rely on the European Commission Adequacy Decision for the EU-US Data Privacy Framework (including the UK extension to the EU-US Data Privacy Framework) and the Swiss-US Data Privacy Framework. Please refer to the Data Privacy Frameworks Disclosure for Hopper (USA) Inc. following this notice for more information about this data transfer mechanism and privacy practices of Hopper (USA) Inc.

6. Information About Minors.

The HTS Services are not intended for or directed to persons under the age of 16, and we do not knowingly collect personal information from persons under the age of 16 without obtaining parental consent. An adult making a booking on behalf of a person under the age of 16 consents to the collection and use of data about such person. If we learn that personal information has been collected on the Services from persons under 16 years of age and without verifiable consent, then we will take the appropriate steps to delete this information.

7. How HTS Protects Your Information.

HTS employs industry standard procedures and other accepted best practices to protect the information that we collect, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. HTS therefore cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. If you believe your personal information has been compromised, please contact us as set forth in the “Contact Us” section below.

8. HTS Group.

HTS website is provided by Hopper Inc. 5795 Avenue de Gaspe, Montreal, Quebec, H2S 2X3, Canada. Hopper Inc. controls any information collected from you. Where you use HTS to book travel, your information may be processed by the HTS group entities in each of the following jurisdictions:

9. Non-Covered Privacy Practices.

Please note that this Notice does not cover the privacy practices relating to the personal information of job applicants, employees and other HTS personnel. Please refer to those separate websites for applicable privacy policies.

10. Changes to this Notice.

Before we make changes to the way we collect, use, and disclose your information, we will make available a revised version of this Notice via the Services. If possible, or where required by law, we will notify you of the change and give you the opportunity to review the revised Notice before you choose to continue using the Services. By continuing to use the Services following publication of any update, you consent to the updated Notice.

11. Contact Us.

If you have any questions or comments about this Notice or your personal data, or to make an access, deletion, or correction request, or to exercise any other applicable rights, you can email us at privacy@hopper.com, or by mail to: Hopper, Inc., 5795 Avenue de Gaspe, Montreal, Quebec, H2S 2X3, Canada.

Supplemental Privacy Notice for Residents of Canada, California(U.S.), India, United Kingdom, Switzerland and the European Union

This Supplemental Privacy Notice (“Notice”) supplements HTS’s Privacy Notice and explains: (1) how HTS collects and uses Personal Information with specific reference to the requirements of the Personal Information Protection and Electronic Documents Act (PIPEDA), California Consumer Privacy Act of 2018 (CCPA), India Digital Personal Data Protection Act (DPDPA), UK General Data Protection Regulation (UK GDPR), Swiss Federal Act on Data Protection (FADP) and EU General Data Protection Regulation (EU GDPR); and (2) your rights under each of these laws and regulations.

1. Definition of “Personal Information”

HTS uses the Personal Information that it collects from you in accordance with our Privacy Notice, and otherwise in accordance with PIPEDA, CCPA, DPDPA, UK GDPR, FADP and EU GDPR. HTS does not sell your Personal Information. The term “Personal Information,” for purposes of each of the above-referenced Laws, means:

2. Data Controllers

HTS website is provided by Hopper Inc. 5795 Avenue de Gaspe, Montreal, Quebec, H2S 2X3, Canada. Hopper Inc. is a Controller of any information collected from you. Where you use HTS to book travel, the following HTS group entities act as the Controller for data collected from you in each of the following jurisdictions:

Where your personal data is processed by Hopper Inc. and Hopper Travel (Ireland) Ltd. as joint controllers, Hopper Inc. and Hopper Travel (Ireland) Ltd. will jointly determine the purposes and means of processing your personal data in accordance with this Privacy Notice. In relation to any travel bookings you make, both of the controllers are responsible for the collection and processing of your personal data in accordance with this Privacy Notice, informing you about how your personal data will be processed, and assisting you with exercising your privacy rights. Hopper Inc. is responsible for providing communications to you relating to your booking, including ancillary services, and providing you with customer support. Where you have consented to your personal data being used to receive updates, news and travel information, Hopper Inc. will be responsible for the processing of your personal data in this way.

Hopper Travel (Ireland) Ltd. has nominated a data protection officer. You can contact our data protection officer for Hopper Travel (Ireland) Ltd. at privacy@hopper.com or via mail: Hopper Travel (Ireland) Ltd, Mespil Business Centre, Mespil House, Sussex Road, Dublin 4, Ireland.

Depending on the country where your payment instrument has been issued, your personal data may be processed by the following entities within HTS group for purposes related to the facilitation of the payment transaction as separate data controllers: Hopper (USA), Inc., 265 Franklin St., Suite 1702, Boston, MA 02110, United States; Hopper Australia PTY LTD 6/189 Ashmore Road, Benowa QLD 4217, Australia; Hopper Brazil Servicos de Viagens Ltda Av Brig Faria Lima, 2369 Andar 11 Sala 1102, Jardim Paulistano, Sao Paulo, Brazil; Hopper India Private Limited Unit No 203, 2nd Floor Suite No.305, SBR CV Towers, Sector-I, Sy No 64, HUDA Techno Enclave, Madhapur, Hyderabad - 500081, India; SINAIR Travel Agency (Private) Limited 22 Cross Street Cross Street Exchange, Singapore 048421; Hopper App Travel Mexico, S.A. de R.L. Insurgentes Sur 64, A-1515, Colonia Juárez, C.P. 06600, Alcaldía Cuauhtémoc, Ciudad de México, Mexico; Hopper Colombia SAS Carrera 9 #115 06 Tierra Firme Piso17, Bogotá Colombia; Hopper Travel Ireland, Ltd., Mespil Business Centre, Mespil House, Sussex Road, Dublin 4, Ireland; Hopper Netherlands B.V. Herengracht 449A, 1017 BR Amsterdam, Netherlands; Hopper UK Inc., Ltd., 58-60 Kensington Church St., Kensington, London W8 4DB, United Kingdom; Hopper Inc. 5795 Avenue de Gaspe, Montreal, Quebec, H2S 2X3, Canada; Hopper (Canada), Inc., 2020 10060 Jasper Ave Tower 1, Edmonton, AB T5J 3R8, Canada; and Hopper Money (USA) Inc., 265 Franklin St Ste. 1702, Boston, MA 02110.

3. Categories of Information Collected, Used, Shared

The table below summarizes the categories of Personal Information HTS may have collected about you over the past 12 months, depending on how you use our Services, as well as how we use it and with whom we may have shared it:

4. Sources of Information

HTS receives Personal Information from you, including information that you provide or from your usage of the Services, and from your device(s). This collection of data is explained in our Privacy Notice. The categories of sources from which we’ve collected or received Personal Information include:

5. Lawful Bases for Processing

HTS collects, uses, processes and discloses personal information based on: (i) the need to process data to carry out HTS’s contractual obligations to you and/or HTS’s legal obligations; (ii) your consent, for the uses and purposes set forth in HTS’s Privacy Notice and/or as explained at the time of the data collection; (iii) contractual necessity; and/or (iv) based on HTS’s legitimate interest in optimizing, improving, and providing the Services, consistent with the purposes for which you provided the data to HTS, where such interest is not overridden by your rights. HTS will store personal information for an indefinite period of time as necessary to continue to provide the Services to you.

If HTS collects and uses your personal information in reliance on its legitimate interests (or the legitimate interests of any third-party), this interest will typically be to operate or improve the HTS platform and communicate with you as necessary to provide services to you, for security verification purposes when you contact HTS, to respond to your queries, undertaking marketing, or for the purposes of potentially detecting or preventing illegal activities.

HTS may in some cases use automated decision-making, for example, in relation to assessing fraudulent transactions or suspicious activity on the HTS website. As part of this processing, automated decisions may be made by putting your personal information into a system and the decision is calculated using automatic processes. If you pose a fraud risk, this may affect your ability to book on HTS. You may have rights in relation to automated decision making, including the ability to request a manual decision-making process instead or contest a decision based solely on automated processing. If you want to know more about your data protection rights, please contact HTS by emailing privacy@hopper.com.

6. Consumer Rights – California Residents

If you are a California Resident, you have the following rights under the CCPA:

• Right to Access: You have the right to request that HTS disclose to you the Personal Information that we collect, use, or disclose, and information about our data practices;

• Right to Request Deletion: You have the right to request that HTS delete your Personal Information that we have collected from you; and

• Right to Non-Discrimination: HTS will not discriminate against you for exercising any of these rights by either: (a) denying goods or services; (b) charging different prices or rates for goods or services, including through discounts; or (c) providing a different level or quality of goods or services. Please note that deletion of data necessary to the Services (such as bookings and transactions) will make these Services unavailable to you.

• Right to Opt-Out of Data Sharing. 

• Right to Opt-Out of Data Sharing. HTS’s collection and use of data for some marketing purposes, as described in the Privacy Notice and this Supplement, may be considered by the California Attorney General and/or California Privacy Protection Agency to be the “sharing” or “sale” of data, as those terms are used in the CCPA, CPRA, and implementing regulations. You have the right to opt-out of such use of data by HTS by: (i) disabling your device advertising identifier, which HTS will accept and implement in a frictionless manner as a signal of your intent to opt-out; (ii) by emailing HTS at privacy@hopper.com.

7. Consumer Rights – United Kingdom, Switzerland, European Union, India and Canada Residents

If you are a resident of the United Kingdom, Switzerland, European Union, India or Canada, you have the following rights under applicable data protection laws:

• Right to Access: You have the right to request that HTS disclose to you the Personal Information that we collect, use, or disclose, and information about our data practices;

• Right to Request Deletion: You have the right to request that HTS delete your Personal Information that we have collected from you;

• Right to Rectify: You have the right to request that HTS correct any of your Personal Information used or stored by HTS;

• Right to Data Portability – You have the right to request the export of electronic data in a reasonable usable form;

• Right to Withdraw Consent, and/or Object to or Restrict Processing – You have the right to request that HTS cease or restrict its processing of your personal information, in certain circumstances, including where HTS’s processing is based on its legitimate interests rather than your consent.

You also have the right to lodge a complaint about HTS’s data practices with a supervisory authority. For more information, you can visit the European Commission’s page on Data Protection, Information Commissioner’s Office website, Federal Data Protection and Information Commissioner’s website or Office of the Privacy Commissioner of Canada website.

Residents of Québec additionally have the right to:

• request a cessation of dissemination of personal data; and

• de-indexation or re-indexation of personal data.

In accordance with Bill 64, an Act to modernize legislative provisions as regards the protection of personal information, HTS appointed Matilda Korian as a data protection officer responsible for overseeing the protection of personal information in Québec. You can contact our data protection officer by emailing us at privacy@hopper.com.

If you are a resident of India, you also have the right to nominate another person to exercise your rights in case of death or incapacity.

8. Exercising Consumer Rights

You may exercise your rights and make requests for information or deletion by emailing us at privacy@hopper.com. Please note that to protect your information and the integrity of our Products, we may need to verify your identity before processing your request. In some cases we may need to collect additional information to verify your identity, such as a government issued ID.

9. Cookie Statement

“Cookies” are small pieces of text sent as files to your computer or mobile device when you visit most websites. When you use the Services, cookies may be delivered by HTS (“first-party” cookies) or delivered by a third-party provider (“third-party” cookies). Cookies are either session cookies or persistent cookies. Session cookies enable HTS to recognize and link the actions you take during a single browsing session. Persistent cookies enable HTS to recognize you as an existing user, and these cookies are stored on your system or device until they expire, or until you delete them. HTS also may use other technologies similar to Cookies, including (and all are referred to as “Cookies”):

• Pixels are small objects embedded into a web page that are not visible to the user. We use pixels to deliver cookies to your computer, facilitate the log-in process, monitor the activity on our sites, and deliver online advertising.

• Tags are small pieces of HTML code that tell your browser to request certain content generated by an ad server. We use tags to show you relevant advertising and promotions.

• Scripts are pieces of JavaScript code that launch automatically when certain webpages load, to determine whether users view associated advertisements.

• Local Storage Objects, such as HTML 5, are used to store content and preferences. Third-parties with whom we partner to provide certain features on our site to display advertising based upon your web browsing activity use Local Storage Objects to collect and store information.

Types of Information Collected Using Cookies. As explained in HTS’s Privacy Notice, the types of information that we collect through cookies include: IP address; Device ID; Viewed pages; Browser type; Browsing information; Operating system; Internet Service Provider; Whether you have responded to, or interacted with, an advertisement; Referring or referred links or URLs; and Features used and activities engaged in on our sites .

How we use Data Collected Using Cookies. HTS uses Cookies on the HTS website for a number of reasons, including to:

(i) Help us improve your experience when visiting our sites;

(ii) Fulfill transactions and ensure our sites perform as intended;

(iii) Remember your preferences, such as language, region, or currency;

(iv) Provide you with relevant advertising and analyze performance of the ads;

(v) Enable you to return to previous travel searches;

(vi) Identify errors on our sites;

(vii) Help with data protection and potentially detect and investigate malicious or fraudulent activity;

(viii) Help us understand traffic to our site, including time and date of the visit, time and date of the last visit, and other information; and

(ix) Analyze how well our sites are performing.

Types and Functions of Cookies.

Essential Cookies. Certain cookies are required or “essential” for our sites to function as intended. Essential cookies are necessary for you to navigate our site and use certain features like logging in to your account and managing your bookings. These cookies are also used to remember security settings that allow access to particular content. Lastly, we use essential cookies to collect information on which web pages visitors go to most, so we can improve our online services. You are not able to opt out of essential cookies.

Functional Cookies. We want to make sure when you visit our site, your preferences (such as your preferred language), settings, and previous searches are remembered. Functional cookies enhance your experience on any HTS site.

Analytics Cookies. We use analytics cookies to understand our site’s performance and how it is used, including the number of visitors, how long you stay on the site, and which parts of the site you visit. We can see details about how visitors interact with the sites, like the number of clicks visitors made on a given page, their mouse movements and scrolling activity, the search words visitors used, and the text visitors enter into various fields. We also use Analytics Cookies to test different designs and features for our site, determine effectiveness of our advertising, and to improve our services, including your experience on our site. For analytics, our third-party service providers may use cookies to perform their services and may combine the information that they collect about you on our sites with other information that they have collected. This Cookie Statement does not cover such third-parties’ use of your information.

Advertising Cookies. HTS and our third-party advertising partners may use advertising cookies to show you advertisements both on and off our sites that are based on your interests. We may allow third-parties to collect information about your online activities through cookies to perform their services and may combine the information that they collect about you on our sites with other information that they have collected. These third-parties include business partners who collect information when you view or interact with one of (1) their advertisements on our sites or (2) our advertising or booking information on their sites and advertising networks, which collect information about your interests when you view or interact with one of the advertisements or tracking mechanisms they place on many different sites on the Internet. Our partners may make assumptions about your interests, characteristics, or preferences and add you to groups based on those assumptions in order to show you tailored advertisements. HTS does not have access to the cookies these third-parties may use to collect information about your interests, and the information practices of these third-parties are not covered by this Cookie Statement or our above Privacy Notice.

Manage your Cookies. You can set or amend your web browser controls to accept or refuse cookies whenever you like, but please remember if you do choose to reject cookies, your access to some of the functionality and areas of our site may be restricted.

Do-Not-Track Signals and Similar Mechanisms. Some web browsers may transmit “do-not-track” or Global Privacy Control (GPC) signals to sites with which the browser communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether web users intend for these signals to be transmitted, or whether users are even aware of them. HTS is evaluating the use of opt out signals received by its website. HTS currently does take action to such signals on the HTS website by recognizing a user’s decision to block the sharing of a device IDFA (iOS) and/or AdID (Android) as a signal of the user’s intent to opt-out of the sharing of data for certain marketing purposes and to limit the processing of data as set forth above in this Privacy Notice.

Data Privacy Frameworks Disclosures for Hopper (USA) Inc.

Hopper (USA) Inc. has certified its participation in the EU-US Data Privacy Framework, including UK Extension to the EU-US Data Privacy Framework and Swiss-US Data Privacy Framework (collectively, the “DPF”) with the US Department of Commerce. This certification sets forth the privacy principles that Hopper (USA) Inc. followed when processing personal information received from the European Economic Area (“EEA”), United Kingdom (and Gibraltar) and Switzerland under the DPF in connection with our certification. Hopper (USA) Inc. adheres to the principles set out in the DPF.

To learn more about the DPF, and to view HTS’s certification, please visit the DPF website.

For purposes of these Data Privacy Frameworks Disclosures for Hopper (USA) Inc., personal data means data about an identified or identifiable individual that is received by Hopper (USA) Inc. in the United States from the EEA, the United Kingdom (and Gibraltar), or Switzerland and recorded in any form, and is within the scope of the GDPR, the UK GDPR and FADP, respectively.

In compliance with the DPF, HTS commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.

Processing Activities and Security

Please refer to Section 3 “When HTS Shares Your Information” of the Supplemental Privacy Notice for Residents of Canada, California (U.S.), United Kingdom, Switzerland and the European Union attached to this Privacy Notice for details about:

• the types of personal information processed;

• the purposes for which personal information is processed;

• the types of third parties to which personal information is disclosed and the purpose of the disclosures.

For more information about our security standards, please see Section 7 “How HTS Protects Your Information” of the Privacy Notice.

Data Subject Rights

To learn more about your rights, please refer to Section 7 “Consumer Rights – United Kingdom, European Union and Canada Residents” and Section 8 “Exercising Consumer Rights” of the Supplemental Privacy Notice for Residents of Canada, California (U.S.), United Kingdom, Switzerland and the European Union attached to this Privacy Notice.

Please note that Hopper (USA) Inc. offers the choices and means for limiting the use and disclosure of their personal data. At any point you have the right to opt-out of marketing use of data by HTS, as set out in Section 4 “Your Rights to Your Personal Information, to Opt-Out of Sharing and to Limit Processing” of this Privacy Notice.

Onward transfer

Hopper (USA) Inc. may disclose personal data to subcontractors and third-party agents in line with Section 3 “When HTS Shares Your Information” of the Privacy Notice and Section 3 “Categories of Information Collected, Used, Shared” of the Supplemental Privacy Notice for Residents of Canada, California (U.S.), United Kingdom, Switzerland and the European Union attached to this Privacy Notice.

HTS remains responsible for any of your personal information that is shared under the onward transfer principle with third parties for external processing on our behalf, as described in this Privacy Notice.

Regulatory Authority and Disclosures

Hopper (USA) Inc. is subject to investigatory and enforcement powers of the Department of Transportation in the United States in connection with its Data Privacy Framework program. Hopper (USA) Inc. might also be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements as set out in this Privacy Notice.

Questions and disputes

Please email us at privacy@hopper.com with any questions or concerns about our DPF certification. You may also refer a complaint to your local data protection authority and we will work with them to resolve your concern. In some situations, the DPF framework gives you the right to invoke binding arbitration. You can do this to resolve complaints not resolved by other means, as described in Annex I to the DPF.

Effective Date of this Notice: Version 1.2 – July 28, 2026