1. INTRODUCTION, SCOPE, AND DEFINITIONS
1.1 Welcome
Welcome to Palmera.
Palmera is an international digital marketplace, concierge, and lifestyle platform designed to help users discover, organize, reserve, purchase, and enjoy high-quality experiences through a single platform.
Depending on the services available in a user’s location, Palmera may allow individuals and groups to discover and interact with restaurants, cafés, hotels, wellness providers, beach clubs, nightlife venues, transportation providers, tourism operators, entertainment providers, luxury experiences, events, concierge services, membership benefits, and other lifestyle experiences offered by independent third parties.
Palmera also provides technology services that may include personalized recommendations, AI-powered concierge assistance, itinerary planning, booking coordination, social features, loyalty programs, messaging tools, and other services designed to improve the user experience.
This Privacy Policy explains how Palmera collects, uses, shares, stores, transfers, protects, and otherwise processes personal information when individuals interact with our Platform.
By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy.
1.2 Who We Are
For purposes of this Privacy Policy:
“Palmera,” “we,” “our,” or “us” refers to Palmera Services LLC, a limited liability company organized under the laws of the United States.
Palmera currently conducts marketplace operations in partnership with local operating entities within Senegal and may expand operations into additional jurisdictions in the future.
Although certain operational services may be performed through local affiliates, representatives, payment partners, or operational entities, Palmera Services LLC remains responsible for operating the Platform and managing this Privacy Policy unless otherwise stated.
1.3 Scope
This Privacy Policy applies to information collected through:
the Palmera mobile application;
the Palmera website;
concierge services;
AI-powered services;
customer support communications;
messaging features;
booking and reservation services;
payment processing activities;
loyalty and membership programs;
promotional campaigns;
merchant onboarding;
business partnerships;
social features;
events organized through the Platform;
and any other services that reference this Privacy Policy.
This Privacy Policy applies regardless of whether you access Palmera through:
a mobile device;
tablet;
desktop computer;
mobile website;
web browser;
third-party integrations;
future technologies or devices through which Palmera is made available.
1.4 Geographic Scope
Palmera welcomes users from around the world.
At the time of publication, Palmera primarily operates in the United States and Senegal. Our users may reside in or access the Platform from:
the United States;
Senegal;
other African countries;
Member States of the European Economic Area (EEA);
the United Kingdom;
and other jurisdictions where the Platform becomes available.
Because our users may come from multiple jurisdictions, Palmera strives to design its privacy practices to comply with internationally recognized privacy principles and applicable laws, including, where applicable:
the European Union General Data Protection Regulation (GDPR);
the UK General Data Protection Regulation (UK GDPR);
applicable United States federal and state privacy laws, including the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA), where applicable;
Senegal’s Law No. 2008-12 on the Protection of Personal Data, together with any amendments or successor legislation;
and other applicable privacy and consumer protection laws.
Certain rights described in this Privacy Policy may apply only where required by applicable law.
1.5 Our Role
Palmera primarily operates as a technology platform and marketplace connecting users with independent businesses and service providers.
Unless expressly stated otherwise, Palmera is not the owner, operator, employer, or direct provider of restaurants, hotels, transportation services, wellness facilities, nightlife venues, tourism experiences, or other third-party services available through the Platform.
Independent Providers remain responsible for their own business operations, customer interactions, legal compliance, pricing, licenses, insurance, and service delivery.
Because of this marketplace structure, certain information may be shared with Providers when necessary to facilitate reservations, bookings, purchases, customer support, legal compliance, or service fulfillment.
Additional information regarding these disclosures appears later in this Privacy Policy.
1.6 Defined Terms
For purposes of this Privacy Policy:
Account means a registered Palmera user account.
AI Concierge means Palmera’s artificial intelligence-powered features used to assist with recommendations, itinerary planning, concierge services, customer support, search, personalization, and other automated features made available through the Platform.
Booking means any reservation, purchase, inquiry, request, or transaction initiated through the Platform.
Concierge Services means any planning, reservation assistance, recommendations, itinerary services, coordination services, customer support, or related assistance provided by Palmera through human representatives, automated systems, or AI Concierge.
Experience means any activity, reservation, event, service, hospitality offering, transportation service, wellness experience, dining reservation, membership benefit, or other offering available through the Platform.
Favorites means Palmera’s feature allowing users to save businesses, Experiences, locations, or other content for future reference.
Friend Connections means features allowing users to connect with other users for social, planning, messaging, or collaborative booking purposes.
Merchant or Provider means any independent business or individual offering goods or services through the Platform.
Palmera Gold means Palmera’s premium membership program, including any successor membership programs offered by Palmera.
Personal Information means any information that identifies, relates to, describes, can reasonably be associated with, or could reasonably be linked to an identifiable individual, as defined under applicable law.
Platform means the Palmera mobile applications, websites, software, APIs, concierge services, AI systems, messaging systems, and all related products and services operated by Palmera.
Stories means temporary or persistent user-generated social content shared through the Platform.
User, you, or your means any individual accessing or using the Platform.
2. INFORMATION WE COLLECT
Palmera collects information in order to operate the Platform, provide concierge services, facilitate bookings and payments, personalize user experiences, improve our products, maintain security, comply with legal obligations, and support future platform functionality.
The categories of information we collect depend on how you interact with the Platform, the features you use, your device settings, your privacy preferences, applicable law, and the permissions you grant.
We collect information directly from you, automatically through your use of the Platform, from third parties, from our business partners, and through technologies that support the operation and security of our services.
The following sections describe these categories in detail.
2.1 INFORMATION YOU PROVIDE DIRECTLY
Depending on how you interact with the Platform, Palmera may collect information that you voluntarily provide to us.
The categories of Personal Information described below may be collected when you create an Account, make a Booking, communicate with us, interact with Providers or other users, purchase memberships, participate in promotions, submit content, or otherwise use the Platform.
The information collected may include, but is not limited to, the following categories.
A. Account Registration Information
When you create a Palmera Account, we may collect information including:
full name;
username or display name;
email address;
password (stored using industry-standard encryption and security practices);
mobile telephone number;
country of residence;
preferred language;
date of birth where required;
profile photograph;
account preferences;
authentication credentials;
account verification information;
login methods (such as email, Apple Sign In, Google Sign In, telephone authentication, or other authentication methods that may become available).
If additional authentication methods are introduced in the future, your use of those methods may also result in the collection of authentication information necessary to provide secure access to your Account.
B. Profile Information
Users may choose to provide additional information to personalize their experience on the Platform.
This information may include:
biography or profile description;
preferred cities or destinations;
travel preferences;
dining preferences;
wellness preferences;
accessibility preferences;
favorite categories;
favorite Providers;
interests;
loyalty preferences;
social preferences;
profile photographs;
membership information;
other information voluntarily added to a user profile.
Users control much of the information they choose to include within their profiles.
C. Booking Information
When you make or request a Booking, reservation, purchase, inquiry, or other transaction through the Platform, we may collect information including:
reservation details;
selected Provider;
selected Experience;
date and time of reservation;
number of guests;
group booking information;
special requests;
accessibility requests;
dietary restrictions;
seating preferences;
transportation preferences;
accommodation preferences;
concierge notes;
itinerary information;
payment confirmation information;
booking history;
cancellation requests;
refund requests;
communications relating to your Booking.
D. Concierge Communications
When you interact with Palmera Concierge Services, whether through human representatives or AI-powered systems, we may collect information necessary to provide assistance.
This may include:
travel plans;
destination preferences;
reservation requests;
scheduling information;
celebration information (such as birthdays or anniversaries);
special accommodations;
communication preferences;
customer support inquiries;
itinerary requests;
recommendations requested;
messages exchanged with concierge personnel;
AI Concierge conversations;
follow-up communications.
Certain Concierge interactions may be reviewed by authorized personnel to improve service quality, investigate disputes, enhance AI systems, maintain safety, or comply with legal obligations.
E. Communications
Whenever you communicate with Palmera, we may collect information contained within those communications.
Examples include:
customer support requests;
emails;
SMS messages;
WhatsApp communications;
push notification interactions;
in-app messages;
survey responses;
feedback;
feature requests;
bug reports;
dispute submissions;
safety reports;
fraud reports.
F. Social Features
Palmera may offer social and collaborative features that allow users to interact with one another.
Information submitted through these features may include:
Stories;
comments;
reviews;
ratings;
reactions;
Favorites;
saved collections;
Friend Connections;
collaborative planning;
shared itineraries;
invitations;
activity feeds;
profile interactions;
future social features introduced by the Platform.
Users should understand that information voluntarily shared through social features may be visible to other users according to each feature’s intended functionality and applicable privacy settings.
G. User-Generated Content
Palmera may permit users to create, upload, submit, or share content through the Platform.
Such content may include:
photographs;
profile images;
review photographs;
captions;
comments;
recommendations;
written reviews;
Stories;
travel notes;
itinerary notes;
other content voluntarily submitted by users.
Users remain responsible for ensuring they have the necessary rights to submit content uploaded through the Platform.
H. Membership Programs
If you enroll in Palmera Gold or any future membership program, we may collect information relating to:
membership enrollment;
membership status;
subscription history;
loyalty points;
rewards earned;
promotional offers redeemed;
membership preferences;
renewal history;
billing information;
membership communications.
I. Promotions, Referrals, and Events
When participating in promotions, referral programs, contests, sweepstakes, waitlists, events, or marketing campaigns, we may collect information including:
referral information;
promotional entries;
event registrations;
invitation responses;
promotional eligibility;
reward redemptions;
contest submissions;
survey responses;
marketing preferences.
Participation in certain promotions may be subject to separate terms and conditions.
J. Merchant & Provider Information
Individuals or businesses applying to become Providers on the Platform may submit additional information necessary to evaluate, onboard, and manage their relationship with Palmera.
Depending on the nature of the business, this information may include:
legal business name;
trade name;
contact information;
business registration documents;
tax identification numbers;
banking information;
licensing information;
insurance information;
operating hours;
service offerings;
pricing information;
availability;
photographs;
branding materials;
menus;
inventory;
cancellation policies;
payment preferences;
compliance documentation;
identity verification materials;
communications with Palmera.
K. Identity Verification
For certain transactions, experiences, memberships, payment activities, fraud prevention measures, or legal compliance requirements, Palmera or its authorized service providers may request additional identity verification information.
Depending on applicable law and the nature of the transaction, this information may include:
government-issued identification;
photographs submitted for identity verification;
proof of age;
verification documents;
payment verification information;
fraud prevention information.
Identity verification is only requested where reasonably necessary to provide services, comply with applicable law, protect users, or prevent fraud.
L. Information You Choose to Provide
You may voluntarily provide additional Personal Information when interacting with the Platform.
Examples include:
survey responses;
accessibility requests;
customer preferences;
travel interests;
feedback;
feature suggestions;
communications with Providers;
communications with other users;
responses to questionnaires;
information shared with customer support;
other information voluntarily submitted through the Platform.
You are under no obligation to provide optional information. However, choosing not to provide certain information may limit your ability to use some features or services offered by Palmera.
2.2 INFORMATION WE COLLECT AUTOMATICALLY
When you access or use the Platform, certain information is collected automatically through your device, browser, operating system, application, network connection, cookies, software development kits (“SDKs”), analytics technologies, security tools, and similar technologies used to operate, secure, maintain, and improve the Platform.
The information collected automatically helps us:
provide and maintain our services;
authenticate users;
improve Platform performance;
personalize user experiences;
facilitate reservations and concierge services;
enhance security;
prevent fraud and abuse;
troubleshoot technical issues;
analyze Platform usage;
comply with legal obligations;
develop new features and services.
The categories of information we may collect automatically include, but are not limited to, the following.
2.2.1 Device Information
When you use the Platform, we may automatically collect information about the device you use to access our services.
This information may include:
device type;
device manufacturer;
device model;
operating system;
operating system version;
browser type;
browser version;
application version;
unique device identifiers;
advertising identifiers, where permitted by law and your device settings;
language settings;
regional settings;
time zone;
screen resolution;
mobile carrier;
network connection type;
device performance characteristics;
battery status (where necessary for application functionality);
device diagnostics.
This information assists us in ensuring compatibility across devices, improving application performance, identifying technical issues, and maintaining the security of the Platform.
2.2.2 Usage Information
We automatically collect information regarding how users interact with the Platform.
This information may include:
pages viewed;
screens visited;
features used;
search activity;
businesses viewed;
categories browsed;
booking activity;
reservation requests;
time spent within the Platform;
navigation patterns;
clicks;
taps;
scrolling activity;
interaction with Stories;
interaction with Favorites;
interaction with recommendations;
interaction with AI Concierge features;
interaction with membership features;
interaction with promotional content;
referral sources;
session duration;
frequency of use;
dates and times of access.
This information helps us understand how users interact with the Platform and allows us to improve usability, discoverability, and overall customer experience.
2.2.3 Log Information
Our servers automatically generate logs whenever users interact with the Platform.
These logs may include:
Internet Protocol (IP) address;
approximate geographic region;
timestamps;
request information;
browser requests;
operating system information;
application events;
error reports;
crash logs;
authentication attempts;
security events;
API requests;
diagnostic information;
server response information.
Log information is used for security, fraud prevention, system monitoring, troubleshooting, auditing, and maintaining the integrity of the Platform.
2.2.4 Location Information
Depending on your device settings and permissions, Palmera may collect location information to provide location-based services and improve your experience.
Location information may include:
approximate geographic location;
city;
region;
country;
time zone;
location derived from IP address;
device-based location information;
manually selected destinations or cities;
locations selected for searching Experiences.
If you choose to grant location permissions through your device, Palmera may access more precise location information where necessary to provide requested functionality.
You may generally control location permissions through your mobile device’s operating system settings.
Certain features may function differently or become unavailable if location permissions are disabled.
2.2.5 Cookies and Similar Technologies
Palmera uses cookies and similar technologies to operate, improve, personalize, and secure the Platform.
These technologies may include:
browser cookies;
mobile SDKs;
pixels;
local storage;
session identifiers;
software development kits;
APIs;
web beacons;
similar technologies.
These technologies help us:
remember user preferences;
authenticate users;
maintain secure sessions;
improve Platform functionality;
analyze traffic;
understand user behavior;
personalize recommendations;
measure marketing effectiveness;
support security and fraud prevention.
Additional information regarding our use of cookies and similar technologies is provided in our Cookie Policy.
2.2.6 Analytics Technologies
Palmera may use analytics providers to better understand how users interact with the Platform.
Depending on the services we utilize, analytics technologies may collect information regarding user activity, application performance, engagement metrics, conversion data, and technical diagnostics.
Analytics providers may include, without limitation:
Google Analytics;
Google Analytics 4 (GA4);
Firebase Analytics;
Firebase Performance Monitoring;
Firebase Crashlytics;
PostHog;
Meta technologies;
Google advertising technologies;
OneSignal;
Sentry;
and other analytics, measurement, attribution, performance monitoring, customer engagement, or diagnostic providers that Palmera may adopt over time.
These providers may receive certain technical information in accordance with their respective privacy policies and applicable law.
Where required by applicable law, Palmera will obtain appropriate consent before enabling certain analytics technologies.
2.2.7 Application Performance and Diagnostics
To maintain a reliable Platform, we may automatically collect diagnostic information including:
application crashes;
performance metrics;
loading times;
response times;
connectivity information;
feature failures;
software errors;
debugging information;
device compatibility information.
This information allows us to identify bugs, improve stability, optimize performance, and provide technical support.
2.2.8 Security and Fraud Detection Information
To protect users, Providers, and the Platform, we may automatically collect information used to detect and prevent:
unauthorized access;
fraudulent transactions;
suspicious account activity;
account compromise;
payment fraud;
abuse of promotional programs;
automated bots;
scraping;
spam;
denial-of-service attacks;
malicious software;
suspicious login attempts;
violations of our Terms of Service.
We may combine this information with information obtained from trusted fraud prevention partners where permitted by applicable law.
2.2.9 Communications and Notification Analytics
When Palmera sends emails, push notifications, SMS messages, WhatsApp messages, or other communications, we may collect information relating to those communications.
This may include:
delivery status;
open rates;
click-through rates;
interaction with notifications;
unsubscribe requests;
communication preferences;
notification settings.
This information helps us improve communication effectiveness, personalize messaging, troubleshoot delivery issues, and comply with applicable marketing laws.
2.2.10 Future Technologies
As Palmera continues to develop and expand, we may implement additional technologies designed to improve security, performance, personalization, accessibility, fraud prevention, analytics, customer support, artificial intelligence, payment processing, or other Platform functionality.
When such technologies involve the collection or processing of Personal Information, Palmera will update this Privacy Policy as required by applicable law and, where necessary, obtain any legally required consents before implementing those technologies.
2.2.11 Your Choices Regarding Automatic Data Collection
Depending on your device, browser, operating system, and jurisdiction, you may have the ability to:
manage cookie preferences;
disable certain analytics technologies;
limit advertising identifiers;
control location permissions;
modify push notification settings;
manage browser privacy settings;
reset advertising identifiers;
withdraw consent where applicable.
Please note that disabling certain technologies may affect the functionality, availability, performance, or personalization of some features of the Platform.
3. HOW WE USE YOUR INFORMATION
Palmera processes Personal Information only where there is a legitimate business purpose, legal obligation, contractual necessity, user consent, or another lawful basis under applicable law.
The ways in which we use Personal Information depend on how you interact with the Platform, the features you use, your privacy preferences, and the services you request.
The purposes described below are intended to provide a comprehensive overview of how Palmera may use Personal Information as our Platform evolves.
3.1 To Provide the Platform
We use Personal Information to provide, operate, maintain, and improve the Platform and its related services.
This includes using information to:
create and manage user Accounts;
authenticate users;
provide access to Platform features;
facilitate Bookings and reservations;
manage Concierge Services;
enable AI Concierge functionality;
provide customer support;
personalize the user experience;
manage Friend Connections;
display Favorites;
support Stories and social features;
provide membership services;
administer loyalty programs;
maintain Platform functionality.
Without certain Personal Information, many core Platform features cannot operate.
3.2 To Process Reservations, Purchases, and Payments
Palmera uses Personal Information to facilitate commercial transactions occurring through the Platform.
This may include:
processing reservation requests;
confirming Bookings;
coordinating group reservations;
facilitating split payments;
communicating with Providers;
processing payments;
verifying payment authorization;
issuing refunds where applicable;
preventing duplicate transactions;
managing cancellations;
resolving payment disputes;
maintaining transaction records.
Payment information may also be shared with authorized payment processors necessary to complete transactions.
3.3 To Provide Concierge Services
Personal Information may be used to provide personalized Concierge Services.
This may include:
making recommendations;
organizing itineraries;
coordinating reservations;
assisting with planning;
managing special requests;
arranging transportation;
facilitating celebrations;
responding to customer inquiries;
providing travel assistance;
improving future recommendations.
Concierge Services may be provided by Palmera personnel, authorized contractors, AI systems, or combinations thereof.
3.4 To Operate AI Features
Palmera may use Personal Information to operate AI-powered services designed to improve the Platform.
Depending on available functionality, AI systems may assist with:
itinerary generation;
personalized recommendations;
intelligent search;
customer support;
booking assistance;
concierge conversations;
personalization;
content summarization;
recommendation ranking;
trend analysis;
service optimization;
future AI-powered Platform features.
AI-generated outputs are intended to assist users and should not be interpreted as guarantees, professional advice, or definitive recommendations.
Certain AI interactions may be reviewed by authorized personnel to improve service quality, investigate reported issues, ensure system reliability, maintain safety, and improve future AI performance.
3.5 To Personalize the User Experience
Palmera seeks to provide each user with a personalized experience.
We may use Personal Information to:
recommend Experiences;
recommend Providers;
prioritize relevant content;
personalize search results;
suggest destinations;
recommend restaurants;
recommend wellness providers;
recommend accommodations;
recommend nightlife;
personalize promotional offers;
customize loyalty rewards;
personalize membership benefits;
improve recommendations over time.
Personalization may be based upon information including user preferences, prior activity, Favorites, reservation history, location, interactions with the Platform, and other information permitted under applicable law.
3.6 To Improve the Platform
Palmera continually evaluates user feedback and Platform performance.
Personal Information may be used to:
identify bugs;
improve usability;
optimize performance;
develop new features;
improve accessibility;
evaluate user satisfaction;
measure feature adoption;
improve booking flows;
improve recommendations;
improve search functionality;
improve Concierge Services;
improve AI systems;
improve Platform stability.
Where possible, Palmera may aggregate or de-identify information before using it for research and product improvement.
3.7 To Communicate With You
We use Personal Information to communicate with users regarding the Platform.
These communications may include:
reservation confirmations;
booking updates;
payment confirmations;
receipts;
account notifications;
password resets;
security alerts;
customer support responses;
Concierge communications;
AI Concierge follow-up messages;
product announcements;
Platform updates;
maintenance notifications;
promotional communications;
loyalty program communications;
membership communications;
surveys;
invitations;
event notifications.
Users may manage certain communication preferences through their Account settings or by following unsubscribe instructions where applicable.
3.8 To Operate Social Features
Palmera may use Personal Information to operate collaborative and social functionality.
This includes using information to:
display Stories;
facilitate Friend Connections;
enable messaging;
enable group chats;
facilitate collaborative planning;
display activity feeds;
display reviews;
display ratings;
display comments;
manage Favorites;
facilitate invitations;
support future community features.
Users remain responsible for the information they voluntarily share with other users through social features.
3.9 To Prevent Fraud and Protect the Platform
Protecting users is one of Palmera’s highest priorities.
We may use Personal Information to:
detect fraud;
investigate suspicious transactions;
identify unauthorized access;
prevent account compromise;
verify identity;
detect payment fraud;
detect abuse of promotional programs;
prevent spam;
prevent scraping;
investigate security incidents;
enforce our Terms of Service;
protect users, Providers, employees, contractors, and the Platform.
We may combine information obtained from users with information received from trusted fraud prevention partners where permitted by applicable law.
3.10 To Comply With Legal Obligations
Palmera may use Personal Information where necessary to:
comply with applicable laws;
comply with court orders;
respond to lawful government requests;
comply with tax obligations;
comply with accounting requirements;
comply with payment regulations;
comply with anti-money laundering obligations where applicable;
enforce contractual rights;
resolve disputes;
protect legal claims;
establish, exercise, or defend legal rights.
3.11 For Business Operations
Personal Information may also be used for internal business purposes, including:
financial reporting;
accounting;
auditing;
compliance;
insurance;
quality assurance;
vendor management;
operational planning;
workforce training;
internal investigations;
risk management;
business continuity;
disaster recovery;
strategic planning.
3.12 To Develop Future Features
As Palmera evolves, we may use Personal Information to research, develop, test, and launch new Platform functionality.
Future uses may include:
expanded Concierge Services;
additional social features;
new loyalty programs;
new membership offerings;
enhanced personalization;
additional AI-powered services;
expanded payment capabilities;
new travel planning tools;
international expansion;
future Platform features consistent with this Privacy Policy.
Where additional processing materially differs from the purposes described in this Privacy Policy or where required by applicable law, Palmera will provide additional notice and obtain consent where legally required.
4. LEGAL BASES FOR PROCESSING PERSONAL INFORMATION
Palmera processes Personal Information only where we have a lawful basis to do so under applicable law.
Because Palmera serves users from multiple jurisdictions, including the United States, Senegal, the European Economic Area (“EEA”), the United Kingdom, and other countries where our Platform may become available, the legal basis for processing Personal Information may vary depending on a user’s location and the applicable laws.
Where required by applicable law, Palmera relies on one or more of the lawful bases described below.
4.1 Performance of a Contract
Much of the Personal Information processed by Palmera is necessary to perform our contractual obligations to users or to take steps requested by users before entering into a contractual relationship.
This includes processing Personal Information necessary to:
create user Accounts;
authenticate users;
provide access to the Platform;
facilitate Bookings and reservations;
process payments;
coordinate Concierge Services;
provide AI Concierge functionality;
manage memberships;
administer loyalty programs;
communicate regarding reservations and transactions;
provide customer support;
fulfill other services requested by users.
Without this information, Palmera may be unable to provide certain services requested by users.
4.2 Legitimate Business Interests
Where permitted by applicable law, Palmera processes Personal Information when doing so is necessary for our legitimate business interests, provided that those interests are not overridden by the rights and freedoms of our users.
Our legitimate interests include, but are not limited to:
operating the Platform;
improving user experience;
developing new features;
improving search functionality;
improving Concierge Services;
improving AI systems;
personalizing recommendations;
maintaining Platform security;
detecting fraud;
preventing abuse;
enforcing our Terms of Service;
protecting users and Providers;
evaluating Platform performance;
analyzing usage trends;
measuring customer satisfaction;
maintaining business records;
conducting internal audits;
training personnel;
protecting legal rights;
planning future business operations.
Where required, Palmera carefully balances these legitimate interests against the privacy rights and expectations of users before relying upon this legal basis.
4.3 User Consent
In certain circumstances, Palmera processes Personal Information based upon a user’s freely given, specific, informed, and unambiguous consent.
Examples may include:
receiving promotional marketing communications where consent is required;
enabling certain analytics technologies;
allowing optional cookies;
accessing precise device location;
accessing device contacts;
accessing calendars;
accessing photo libraries;
enabling certain optional Platform features;
participating in surveys;
participating in promotional campaigns;
future features requiring affirmative consent.
Users may withdraw consent at any time where processing is based upon consent.
Withdrawal of consent does not affect the lawfulness of processing conducted before consent was withdrawn.
Certain Platform features may become unavailable after consent is withdrawn.
4.4 Compliance With Legal Obligations
Palmera may process Personal Information where necessary to comply with legal obligations imposed by applicable law.
Examples include processing necessary to:
comply with tax laws;
comply with accounting obligations;
comply with financial reporting obligations;
comply with anti-money laundering requirements where applicable;
respond to lawful requests from governmental authorities;
comply with court orders;
comply with regulatory investigations;
comply with consumer protection laws;
comply with payment regulations;
comply with sanctions laws where applicable;
satisfy record retention obligations;
comply with applicable privacy laws.
4.5 Protection of Vital Interests
In limited circumstances, Palmera may process Personal Information where necessary to protect the vital interests of an individual or another natural person.
Examples may include situations involving:
health emergencies;
immediate safety concerns;
emergency response coordination;
prevention of serious physical harm;
assistance requested by emergency responders where legally permitted.
Palmera expects to rely upon this legal basis only in exceptional circumstances.
4.6 Public Interest
Where permitted or required by applicable law, Palmera may process Personal Information when necessary for reasons of substantial public interest or other lawful public interest purposes recognized under applicable law.
This legal basis is expected to apply only in limited circumstances.
4.7 Additional Legal Bases
Certain jurisdictions may recognize additional lawful bases for processing Personal Information.
Where applicable, Palmera may rely upon any additional lawful basis available under the laws governing a particular user, provided such processing is conducted in accordance with applicable legal requirements.
4.8 Sensitive Personal Information
Certain features of the Platform may involve the processing of information that is considered sensitive under applicable law.
Depending on the circumstances, this may include information relating to:
accessibility needs;
dietary restrictions;
health-related accommodations voluntarily provided by users;
identity verification documents;
payment verification information;
precise location information where permission is granted;
other categories of sensitive information recognized under applicable law.
Palmera does not request sensitive Personal Information unless reasonably necessary to provide requested services, comply with legal obligations, protect users, prevent fraud, or satisfy another lawful basis for processing.
Where required by applicable law, Palmera will obtain explicit consent before processing sensitive Personal Information.
Users are encouraged not to provide sensitive Personal Information unless requested or reasonably necessary for the services they seek.
4.9 Automated Decision-Making and Profiling
Palmera may use automated technologies, including artificial intelligence and machine learning systems, to assist with certain aspects of the Platform.
These technologies may be used to:
personalize recommendations;
improve search results;
prioritize relevant Experiences;
generate itineraries;
assist Concierge Services;
recommend Providers;
improve customer support;
identify fraudulent activity;
improve Platform performance;
support future AI-powered functionality.
Palmera does not make decisions producing legal or similarly significant effects solely through automated processing except where permitted by applicable law or where users have provided appropriate consent.
Where applicable law provides users with rights relating to automated decision-making or profiling, Palmera will honor those rights in accordance with applicable legal requirements.
4.10 Data Minimization and Purpose Limitation
Palmera is committed to collecting and processing only the Personal Information reasonably necessary for the purposes described in this Privacy Policy.
We strive to ensure that Personal Information is:
collected lawfully;
processed fairly;
relevant to the purposes for which it is collected;
accurate where reasonably practicable;
kept up to date where appropriate;
retained no longer than reasonably necessary;
protected using appropriate technical and organizational safeguards.
Where reasonably possible, Palmera may aggregate, anonymize, or de-identify information before using it for research, analytics, product development, or business intelligence.
Information that has been anonymized so that it can no longer reasonably identify an individual is generally no longer considered Personal Information under many privacy laws.
4.11 Changes to Processing Purposes
If Palmera intends to process Personal Information for a purpose that is materially different from the purposes described in this Privacy Policy, we will provide additional notice as required by applicable law.
Where legally required, we will obtain appropriate consent before processing Personal Information for materially different purposes.
Nothing in this section limits Palmera’s ability to process Personal Information where otherwise permitted or required by applicable law.
5. HOW PALMERA SHARES PERSONAL INFORMATION
Palmera does not sell Personal Information for direct monetary compensation.
However, in order to operate the Platform, provide Concierge Services, facilitate Bookings, process payments, improve user experiences, comply with legal obligations, and support future Platform functionality, Palmera may share Personal Information with certain categories of recipients as described in this section.
Palmera shares only the information reasonably necessary for the applicable purpose and seeks to work with service providers and business partners that maintain appropriate privacy and security practices.
For additional information regarding the purposes for which Personal Information is processed, see Section 3 (How We Use Your Information).
For additional information regarding international transfers of Personal Information, see Section 10 (International Data Transfers).
5.1 Sharing With Independent Providers
As a marketplace platform, Palmera facilitates interactions between users and independent Providers.
When necessary to facilitate a Booking, reservation, purchase, concierge request, or other transaction, Palmera may share relevant Personal Information with the applicable Provider.
Depending on the nature of the Experience, this information may include:
your name;
reservation details;
number of guests;
booking date and time;
contact information where necessary;
special requests;
dietary preferences;
accessibility accommodations;
celebration information;
loyalty information where applicable;
reservation notes;
payment confirmation status;
communications relating to the Booking.
Providers are independent businesses responsible for their own privacy practices, legal compliance, and handling of Personal Information they receive.
Palmera encourages users to review any privacy notices made available by individual Providers before sharing additional information directly with them.
5.2 Payment Service Providers
Palmera works with authorized third-party payment processors to facilitate secure financial transactions.
Depending upon the payment method selected, information may be shared with payment providers in order to:
authorize payments;
process transactions;
verify identities;
prevent fraud;
issue refunds;
manage chargebacks;
comply with financial regulations;
complete settlement processes.
Payment service providers may include providers supporting:
credit cards;
debit cards;
digital wallets;
mobile money;
bank transfers;
future payment technologies adopted by Palmera.
Palmera generally does not store complete payment card numbers on its own systems.
Payment information is processed in accordance with the applicable payment provider’s privacy practices, contractual obligations, and security standards.
5.3 Concierge Operations
To provide Concierge Services, Personal Information may be shared internally among authorized Palmera personnel, contractors, operational representatives, and approved technology providers assisting with concierge operations.
Information shared for concierge purposes may include:
reservation requests;
itinerary details;
travel preferences;
communications;
special requests;
scheduling information;
customer support history;
AI Concierge interactions where necessary.
Access is limited to individuals who require the information to perform authorized business functions.
5.4 AI and Technology Providers
Palmera may utilize trusted technology providers to support Platform functionality, artificial intelligence features, cloud infrastructure, communications, analytics, security, customer support, and other operational services.
Depending upon the services utilized, these providers may process Personal Information on Palmera’s behalf.
Examples include providers supporting:
cloud hosting;
artificial intelligence;
analytics;
customer support;
messaging;
authentication;
application performance monitoring;
fraud detection;
search functionality;
infrastructure monitoring;
email delivery;
push notifications;
SMS communications;
data storage;
software development.
These providers are contractually or legally required to process Personal Information only for authorized purposes and to maintain appropriate safeguards.
5.5 Operational Affiliates and Representatives
Because Palmera operates internationally, certain operational functions may be carried out by affiliated entities, authorized representatives, contractors, or local operating partners.
For example, local operational entities may assist with:
reservation coordination;
customer support;
merchant onboarding;
payment settlement;
operational administration;
regulatory compliance;
localized Platform operations.
Information shared with such entities is limited to what is reasonably necessary to perform their authorized responsibilities.
5.6 Business Service Providers
Palmera works with various third-party service providers that assist in operating the Platform.
These providers may perform services relating to:
cloud computing;
data hosting;
cybersecurity;
customer relationship management;
accounting;
auditing;
legal services;
insurance;
communications;
marketing;
analytics;
payment processing;
software development;
business operations.
Such providers may process Personal Information solely as necessary to provide contracted services to Palmera.
5.7 Communications Providers
To communicate with users, Palmera may share limited Personal Information with providers supporting:
email delivery;
SMS messaging;
push notifications;
WhatsApp communications;
customer service platforms;
notification management;
future communication technologies.
Information shared is limited to what is reasonably necessary to deliver communications requested by users or required for operation of the Platform.
5.8 Analytics and Measurement Providers
Palmera may share certain technical and usage information with analytics and measurement providers to better understand Platform performance and user engagement.
Such providers may assist with:
application analytics;
crash reporting;
performance monitoring;
attribution;
engagement measurement;
conversion analysis;
product improvement;
advertising measurement where permitted by applicable law.
Additional information regarding analytics technologies appears in Section 2.2 (Information Collected Automatically).
5.9 Legal and Regulatory Disclosures
Palmera may disclose Personal Information where we reasonably believe disclosure is necessary to:
comply with applicable laws;
comply with court orders;
comply with subpoenas;
respond to lawful governmental requests;
protect users;
investigate fraud;
enforce our Terms of Service;
protect our legal rights;
prevent illegal activity;
respond to emergencies;
satisfy regulatory obligations.
Whenever reasonably appropriate and legally permissible, Palmera will seek to limit the scope of such disclosures.
5.10 Business Transactions
If Palmera undergoes a merger, acquisition, financing, restructuring, corporate reorganization, sale of assets, bankruptcy proceeding, or other business transaction, Personal Information may be transferred as part of that transaction, subject to applicable law.
Where legally required, users will be provided notice of such transfers.
5.11 With Your Direction
Palmera may share Personal Information where you instruct us to do so.
Examples include:
inviting friends;
sharing itineraries;
collaborative planning;
group reservations;
sharing Favorites;
connecting with other users;
using social features;
interacting with Providers;
using third-party integrations.
You remain responsible for information you voluntarily choose to share with other users or third parties.
5.12 Aggregated and De-Identified Information
Palmera may aggregate, anonymize, or de-identify information so that it can no longer reasonably identify an individual.
Such information may be used for:
research;
analytics;
product development;
trend analysis;
benchmarking;
business intelligence;
statistical reporting;
operational improvements.
Where information has been properly anonymized or de-identified under applicable law, it is generally no longer considered Personal Information.
5.13 We Do Not Sell Personal Information for Money
Palmera does not sell users’ Personal Information for direct monetary compensation.
Certain privacy laws may define terms such as “sale,” “sharing,” or “targeted advertising” differently.
Where applicable law grants users rights relating to these activities, Palmera will honor those rights in accordance with applicable legal requirements.
For additional information regarding your privacy rights, see Section 13 (Your Privacy Rights).
6. SECURITY OF PERSONAL INFORMATION
Protecting Personal Information is one of Palmera’s highest priorities.
Palmera maintains administrative, technical, physical, and organizational safeguards designed to protect Personal Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, misuse, and other unlawful forms of processing.
Our security program is designed to evolve alongside the Platform, applicable legal requirements, emerging threats, and industry best practices.
While no system can guarantee absolute security, Palmera continuously evaluates and improves its security measures to reduce risk and protect users.
6.1 Security Measures
Depending upon the nature of the information being processed, Palmera may implement safeguards including:
encryption of data in transit using industry-standard protocols;
encryption of sensitive information at rest where appropriate;
secure authentication mechanisms;
password hashing;
multi-factor authentication for internal administrative systems where appropriate;
role-based access controls;
least-privilege access principles;
network security protections;
firewalls;
infrastructure monitoring;
intrusion detection technologies;
security logging;
vulnerability management;
software updates;
access auditing;
security testing;
backup systems;
disaster recovery planning;
secure development practices;
employee security training;
vendor security reviews;
incident response procedures.
Security controls may evolve over time as technology and industry standards continue to develop.
6.2 Employee and Contractor Access
Access to Personal Information is restricted to authorized personnel who require such access to perform legitimate business responsibilities.
Individuals with access to Personal Information may include:
employees;
authorized contractors;
customer support personnel;
Concierge personnel;
engineering personnel;
operations personnel;
legal and compliance personnel;
security personnel;
other authorized representatives acting on behalf of Palmera.
Such individuals are expected to maintain the confidentiality of Personal Information and access information only as necessary to perform authorized responsibilities.
6.3 Vendor Security
Palmera works with carefully selected service providers that support Platform operations.
Where appropriate, Palmera seeks to work with providers that maintain commercially reasonable security practices designed to protect Personal Information.
Depending on the services provided, Palmera may evaluate vendors based upon factors including:
security practices;
reliability;
privacy commitments;
regulatory compliance;
contractual protections;
technical safeguards;
operational controls.
However, each independent service provider maintains responsibility for its own security practices.
6.4 User Responsibilities
Users also play an important role in protecting their Personal Information.
Users are encouraged to:
maintain strong passwords;
keep login credentials confidential;
avoid sharing authentication information;
enable security features available on their devices;
promptly notify Palmera of suspected unauthorized access;
keep software and operating systems updated;
exercise caution when communicating with unknown individuals through the Platform.
Palmera will never request your password through unsolicited communications.
6.5 Security Incidents
Despite reasonable safeguards, no method of electronic storage, transmission, or processing can be guaranteed to be completely secure.
If Palmera becomes aware of a security incident affecting Personal Information, we will investigate the matter promptly and take actions we consider appropriate under the circumstances.
Where required by applicable law, Palmera will notify affected individuals and relevant regulatory authorities within the timeframes required by law.
The nature and timing of any notification may depend upon:
applicable legal requirements;
the scope of the incident;
the categories of information involved;
the risk posed to affected individuals;
ongoing law enforcement investigations.
6.6 No Absolute Guarantee
Although Palmera maintains safeguards designed to protect Personal Information, no security system can guarantee complete protection against every possible threat.
Accordingly, users acknowledge that transmission of information over the Internet and through mobile networks always involves some degree of inherent risk.
Palmera encourages users to take reasonable precautions when using online services.
7. DATA RETENTION
Palmera retains Personal Information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, comply with applicable legal obligations, resolve disputes, enforce agreements, protect our legal rights, and operate the Platform.
Retention periods may vary depending upon:
the nature of the information;
the purpose for which it was collected;
applicable legal requirements;
contractual obligations;
operational needs;
security considerations.
For additional information regarding the purposes for which Personal Information is processed, see Section 3 (How We Use Your Information).
7.1 Categories of Retention
Different categories of information may be retained for different periods.
Examples include:
Account Information
Account information may be retained while an Account remains active and for a reasonable period thereafter to comply with legal obligations, resolve disputes, maintain records, prevent fraud, or protect the Platform.
Reservation and Transaction Information
Booking records, reservation history, payment confirmations, invoices, and transaction-related records may be retained as necessary for accounting, tax compliance, dispute resolution, fraud prevention, and legal compliance.
Concierge Communications
Communications with Concierge personnel or AI Concierge may be retained to:
improve service quality;
investigate disputes;
fulfill ongoing requests;
maintain operational records;
improve future Concierge functionality.
Customer Support Communications
Support requests, complaints, feedback, and related communications may be retained to improve customer service, investigate issues, train personnel, and comply with legal obligations.
Social Features
Information submitted through Stories, reviews, comments, Favorites, Friend Connections, and other social features may remain available for the period reasonably necessary to operate those features unless removed by the user, deleted pursuant to Platform policies, or otherwise required by law.
Certain content may remain in system backups for a limited period following deletion.
Analytics Information
Analytics information may be retained for varying periods depending upon the configuration of applicable analytics providers and Palmera’s operational requirements.
Whenever reasonably possible, Palmera seeks to aggregate or de-identify analytics information.
Security Logs
Security logs, authentication records, fraud detection information, and system diagnostics may be retained for as long as reasonably necessary to:
maintain Platform security;
investigate incidents;
detect fraud;
comply with legal obligations;
protect users and the Platform.
7.2 Account Closure
If you close your Account, Palmera will take reasonable steps to delete or anonymize Personal Information that is no longer required.
However, certain information may be retained where necessary to:
comply with legal obligations;
satisfy accounting or tax requirements;
resolve disputes;
investigate fraud;
enforce contractual rights;
comply with regulatory obligations;
protect the security and integrity of the Platform;
maintain business records required by law.
7.3 Anonymized Information
Palmera may anonymize or de-identify Personal Information so that it can no longer reasonably identify an individual.
Information that has been properly anonymized or de-identified may be retained indefinitely for purposes including:
research;
analytics;
product development;
statistical reporting;
business intelligence;
operational planning;
improving the Platform.
Where information has been anonymized in accordance with applicable law, it is generally no longer considered Personal Information.
7.4 Legal Holds
Notwithstanding any other provision of this Privacy Policy, Palmera may retain Personal Information for longer periods where necessary to:
comply with legal obligations;
respond to litigation;
preserve evidence;
comply with court orders;
satisfy regulatory requirements;
investigate fraud;
protect legal rights;
enforce contractual obligations.
8. INTERNATIONAL DATA TRANSFERS
Palmera is an international technology platform.
As a result, Personal Information may be collected, accessed, processed, stored, transferred, or otherwise handled in countries other than the country in which a user resides.
Because Palmera serves users from multiple jurisdictions, including the United States, Senegal, the European Economic Area (“EEA”), the United Kingdom, and other regions where the Platform becomes available, Personal Information may be transferred across international borders in connection with the operation of the Platform.
For additional information regarding the purposes for which Personal Information is processed, see Section 3 (How We Use Your Information).
For additional information regarding the categories of recipients with whom Personal Information may be shared, see Section 5 (How Palmera Shares Personal Information).
8.1 Where Personal Information May Be Processed
Depending upon how you use the Platform, your Personal Information may be processed in:
the United States;
Senegal;
countries within the European Economic Area;
the United Kingdom;
countries where our authorized service providers operate;
countries where our cloud infrastructure providers maintain data centers;
countries where our payment providers process transactions;
other jurisdictions where Palmera lawfully conducts business or provides services in the future.
The locations in which Personal Information is processed may change as Palmera expands internationally, adopts new technologies, or engages additional service providers.
8.2 Cross-Border Transfers
Because Palmera is operated by a United States company while conducting marketplace operations in Senegal and serving international users, certain Personal Information may be transferred between countries in order to:
operate the Platform;
provide Concierge Services;
facilitate Bookings;
process payments;
provide customer support;
operate AI-powered services;
maintain Platform security;
comply with legal obligations;
investigate fraud;
improve Platform functionality;
support international business operations.
These transfers may occur between Palmera, our authorized operational representatives, our affiliated entities, our service providers, payment processors, cloud infrastructure providers, and other recipients described in this Privacy Policy.
8.3 International Users
By accessing or using the Platform, you acknowledge that your Personal Information may be transferred to, processed in, or stored in countries whose data protection laws may differ from those of your country of residence.
Where required by applicable law, Palmera will implement appropriate safeguards designed to protect Personal Information during such transfers.
Nothing in this Privacy Policy is intended to reduce any privacy rights that users may have under applicable law.
8.4 Transfers from the European Economic Area and the United Kingdom
When Personal Information originating from the European Economic Area or the United Kingdom is transferred outside those jurisdictions, Palmera seeks to implement appropriate safeguards consistent with applicable law.
Depending upon the circumstances, these safeguards may include:
Standard Contractual Clauses approved by the European Commission or other competent authorities;
the UK International Data Transfer Agreement or other approved transfer mechanisms;
adequacy decisions issued by competent regulatory authorities;
contractual protections with service providers;
organizational safeguards;
technical safeguards;
encryption measures;
access controls;
other lawful transfer mechanisms recognized under applicable law.
Palmera continually evaluates its international transfer practices and may implement additional safeguards as legal requirements evolve.
8.5 Transfers Within Palmera’s Operations
Because Palmera may utilize local operational representatives, contractors, affiliates, and authorized service providers in multiple jurisdictions, Personal Information may be shared internally where reasonably necessary to:
facilitate reservations;
provide customer support;
coordinate Concierge Services;
onboard Providers;
settle transactions;
comply with regulatory obligations;
investigate fraud;
maintain Platform operations.
Such access is limited to authorized personnel with a legitimate business need.
8.6 Cloud Infrastructure
Palmera utilizes third-party cloud infrastructure and technology providers to operate the Platform.
As a result, Personal Information may be stored or processed on servers located in multiple jurisdictions depending upon:
system architecture;
redundancy requirements;
disaster recovery planning;
content delivery optimization;
infrastructure providers;
operational needs.
Palmera seeks to work with providers maintaining commercially reasonable security and privacy practices.
8.7 International Payment Processing
Because Palmera facilitates international commerce, payment-related information may be processed by payment service providers located in different jurisdictions.
Payment processors may transfer information internationally where necessary to:
authorize payments;
prevent fraud;
comply with financial regulations;
settle transactions;
investigate chargebacks;
satisfy anti-money laundering requirements where applicable.
Payment processing is governed by the privacy and security practices of the applicable payment provider in addition to this Privacy Policy.
8.8 Data Localization
Certain jurisdictions impose restrictions regarding where Personal Information may be stored or processed.
Where applicable law requires localization of specific categories of information, Palmera will take commercially reasonable steps to comply with such legal requirements.
Nothing in this Privacy Policy shall be interpreted as guaranteeing that all categories of Personal Information will remain exclusively within any particular country unless required by applicable law.
8.9 Future International Expansion
As Palmera expands into additional countries, we may establish additional operational entities, engage additional service providers, or implement new infrastructure supporting international operations.
Where such expansion materially affects the processing or international transfer of Personal Information, Palmera will update this Privacy Policy as required by applicable law.
Where legally required, Palmera will provide additional notice or obtain user consent before implementing material changes affecting international data transfers.
8.10 International Compliance Commitment
Palmera recognizes that privacy laws continue to evolve around the world.
Accordingly, Palmera is committed to reviewing and updating its privacy practices on an ongoing basis in an effort to remain aligned with applicable legal requirements, evolving regulatory guidance, recognized industry standards, and responsible data governance practices.
This commitment includes continued evaluation of:
international transfer mechanisms;
privacy regulations;
data security standards;
artificial intelligence governance;
consumer privacy rights;
payment security requirements;
cross-border operational practices;
emerging legal obligations affecting the Platform.
8.11 Questions Regarding International Transfers
Users with questions regarding international transfers of Personal Information or applicable transfer safeguards may contact Palmera using the contact information provided in Section 15 (Contact Information).
Where required by applicable law, Palmera will make additional information regarding applicable transfer safeguards available upon request, subject to confidentiality obligations and applicable legal limitations.
9. ARTIFICIAL INTELLIGENCE (“AI”), AUTOMATED PROCESSING, AND PERSONALIZATION
Artificial intelligence is an important component of the Palmera Platform.
Our goal is to use AI responsibly to improve the user experience while maintaining transparency, protecting user privacy, supporting human decision-making, and respecting applicable legal requirements.
This section explains how Palmera may use artificial intelligence, machine learning, automated systems, personalization technologies, and similar technologies now and as the Platform continues to evolve.
For additional information regarding our lawful basis for processing Personal Information, see Section 4 (Legal Bases for Processing Personal Information).
For additional information regarding your rights relating to automated processing, see Section 13 (Your Privacy Rights).
9.1 Our Philosophy
Palmera believes artificial intelligence should enhance—not replace—the human experience.
Our AI systems are designed to assist users in discovering Experiences, planning itineraries, organizing reservations, finding recommendations, communicating more efficiently, and navigating the Platform.
Artificial intelligence is intended to support users by providing useful information and recommendations. Final decisions regarding reservations, purchases, travel plans, payments, and participation in Experiences always remain with the user.
9.2 How Palmera May Use AI
Depending upon the features available at a given time, Palmera may use artificial intelligence and related technologies to:
recommend restaurants, hotels, wellness providers, transportation, nightlife, and other Experiences;
generate personalized itineraries;
answer Concierge questions;
assist customer support;
improve search functionality;
personalize Platform content;
rank recommendations;
organize travel plans;
summarize user requests;
identify relevant Providers;
recommend destinations;
assist with reservation planning;
improve accessibility;
optimize Platform functionality;
detect unusual Platform behavior;
identify potential fraud;
improve operational efficiency;
analyze aggregate Platform trends;
improve future Platform features;
support additional AI-powered services introduced in the future.
The specific AI features available may change as the Platform evolves.
9.3 Information Used by AI Systems
Depending upon the feature being used, AI systems may process information including:
search activity;
destination preferences;
Favorites;
reservation history;
itinerary requests;
Concierge conversations;
AI Concierge conversations;
user preferences;
travel interests;
wellness interests;
dining preferences;
interaction history;
language preferences;
approximate location;
account settings;
feedback;
voluntarily submitted information.
AI systems are designed to use only the information reasonably necessary to provide the requested functionality or improve Platform performance.
9.4 Personalization
Palmera seeks to provide each user with a personalized experience.
Personalization may include:
recommending Experiences based upon prior activity;
suggesting destinations;
recommending Providers;
prioritizing relevant search results;
recommending new businesses;
suggesting events;
tailoring Concierge recommendations;
customizing membership benefits;
presenting relevant promotional offers;
improving future recommendations.
Personalization does not guarantee that recommendations will always reflect a user’s preferences or expectations.
9.5 Human Involvement
Although Palmera may utilize AI-powered technologies, human personnel remain involved in many aspects of Platform operations.
Depending upon the circumstances, authorized Palmera personnel may review AI-generated information to:
improve service quality;
verify recommendations;
investigate reported issues;
improve AI performance;
respond to customer support requests;
detect abuse;
improve Concierge Services;
maintain Platform safety;
comply with legal obligations.
Human review helps improve the reliability, fairness, and effectiveness of our AI systems.
9.6 AI Limitations
Artificial intelligence remains an evolving technology.
Accordingly, AI-generated content may:
contain inaccuracies;
contain incomplete information;
become outdated;
misunderstand user requests;
omit relevant information;
produce unexpected results;
rely upon information provided by users or third parties;
recommend Experiences that ultimately become unavailable;
recommend Providers whose pricing or availability changes.
Users should independently verify important information before relying upon AI-generated recommendations.
9.7 No Professional Advice
AI-generated outputs provided through the Platform are intended solely for informational and convenience purposes.
AI-generated content does not constitute:
legal advice;
medical advice;
financial advice;
tax advice;
travel guarantees;
safety advice;
investment advice;
emergency guidance;
professional consulting services.
Users remain responsible for exercising their own judgment when making decisions based upon AI-generated information.
9.8 No Guarantee of Results
Use of AI features does not guarantee:
reservation availability;
Provider acceptance;
pricing accuracy;
itinerary accuracy;
business quality;
service quality;
user satisfaction;
travel outcomes;
event availability;
operational hours;
transportation schedules.
Recommendations generated through AI are intended to assist—not replace—user decision-making.
9.9 AI Learning and Improvement
Palmera may use information relating to AI interactions to improve our artificial intelligence systems.
This may include:
improving recommendation quality;
improving response accuracy;
improving itinerary generation;
improving Concierge functionality;
improving personalization;
identifying recurring issues;
improving Platform performance;
improving future AI features.
Where reasonably practicable, Palmera seeks to use aggregated, anonymized, or de-identified information for AI improvement activities.
9.10 Responsible AI Principles
Palmera is committed to developing and deploying AI responsibly.
As our AI capabilities evolve, we strive to design systems guided by principles including:
transparency;
privacy;
fairness;
accountability;
security;
human oversight;
user control;
continuous improvement;
legal compliance;
responsible innovation.
These principles may continue to evolve alongside technological developments and emerging regulatory guidance.
9.11 Automated Decision-Making
Palmera may use automated technologies to assist in making recommendations and improving Platform functionality.
However, Palmera does not intentionally make decisions producing solely automated legal or similarly significant effects on individuals except where permitted by applicable law or where appropriate legal safeguards have been implemented.
Where applicable law grants users rights relating to automated decision-making, profiling, or similar processing, Palmera will honor those rights in accordance with applicable legal requirements.
9.12 Future AI Features
Artificial intelligence technologies continue to evolve rapidly.
Accordingly, Palmera may introduce additional AI-powered functionality in the future, including features relating to:
enhanced Concierge Services;
multilingual assistance;
travel planning;
reservation optimization;
intelligent search;
predictive recommendations;
operational automation;
accessibility;
fraud prevention;
customer support;
content generation;
other Platform functionality.
Where additional AI features materially change how Personal Information is processed, Palmera will update this Privacy Policy as required by applicable law.
9.13 User Choice
Where reasonably practicable and appropriate, Palmera may provide users with choices regarding certain AI-powered features.
Depending upon the feature, users may have the ability to:
adjust personalization preferences;
manage marketing preferences;
modify notification settings;
control certain recommendation settings;
exercise privacy rights available under applicable law.
Certain core Platform functionality may require the use of automated technologies in order to operate effectively.
9.14 Our Commitment
Palmera recognizes that artificial intelligence should strengthen trust—not diminish it.
As AI technologies continue to evolve, Palmera is committed to regularly evaluating our systems, governance practices, security controls, privacy protections, and legal compliance to promote responsible innovation while delivering meaningful value to users, Providers, and partners.
We will continue to review this Privacy Policy and our AI practices to reflect material developments in technology, regulation, and industry standards.
10. COOKIES, TRACKING TECHNOLOGIES, AND SIMILAR TOOLS
Palmera uses cookies, software development kits (“SDKs”), pixels, application programming interfaces (“APIs”), local storage technologies, web beacons, device identifiers, and similar technologies (collectively, “Tracking Technologies”) to operate, secure, maintain, improve, and personalize the Platform.
These technologies allow Palmera to deliver a reliable user experience, improve Platform functionality, understand how the Platform is used, protect users against fraud, measure performance, and support communications and marketing activities where permitted by applicable law.
For additional information regarding information collected automatically, see Section 2.2 (Information We Collect Automatically).
A more detailed explanation of our use of cookies and Tracking Technologies is provided in the Palmera Cookie Policy, which forms part of Palmera’s overall privacy framework.
10.1 Types of Tracking Technologies
Depending on the Platform, device, browser, operating system, and available features, Palmera may use technologies including:
browser cookies;
mobile application SDKs;
web beacons;
pixels;
local storage;
session identifiers;
device identifiers;
advertising identifiers where permitted;
APIs;
server-side tracking technologies;
authentication tokens;
similar technologies developed in the future.
Not every Tracking Technology is used on every Platform or device.
10.2 Purposes of Tracking Technologies
Tracking Technologies may be used for purposes including:
Platform Operation
user authentication;
maintaining secure sessions;
remembering preferences;
preserving user settings;
account management;
Platform functionality.
Security
Tracking Technologies may help:
prevent fraud;
detect suspicious activity;
identify unauthorized access;
investigate security incidents;
protect user Accounts;
maintain Platform integrity.
Performance
Tracking Technologies may be used to:
improve loading speeds;
optimize application performance;
identify technical issues;
monitor system reliability;
improve user experience;
troubleshoot errors.
Analytics
Tracking Technologies may be used to better understand:
Platform usage;
feature adoption;
customer engagement;
navigation patterns;
booking flows;
search behavior;
conversion rates;
overall Platform performance.
Analytics information assists Palmera in improving existing features and developing future functionality.
Personalization
Tracking Technologies may be used to:
recommend Experiences;
personalize search results;
recommend Providers;
customize Concierge Services;
tailor membership experiences;
improve AI recommendations;
display relevant content;
remember user preferences.
Communications
Tracking Technologies may assist Palmera in:
delivering notifications;
measuring communication effectiveness;
improving email delivery;
managing messaging functionality;
improving customer engagement.
Marketing
Where permitted by applicable law, Tracking Technologies may assist Palmera in:
measuring advertising performance;
evaluating marketing campaigns;
understanding referral sources;
improving promotional communications;
measuring customer acquisition.
Where consent is required for marketing-related Tracking Technologies, Palmera will request such consent before enabling those technologies.
10.3 Third-Party Technologies
Certain Tracking Technologies may be provided by authorized third-party service providers supporting Platform operations.
Depending upon the services utilized, these providers may support:
analytics;
cloud infrastructure;
fraud prevention;
authentication;
customer communications;
artificial intelligence;
customer support;
application performance monitoring;
payment processing;
security;
infrastructure management;
future Platform functionality.
Palmera seeks to engage service providers that maintain commercially reasonable privacy and security practices.
10.4 User Controls
Depending upon your jurisdiction, browser, device, operating system, and applicable law, you may be able to:
manage cookie preferences;
withdraw consent;
modify browser settings;
disable certain cookies;
limit advertising identifiers;
reset device identifiers;
control location permissions;
manage notification preferences;
modify privacy settings.
Please note that disabling certain Tracking Technologies may affect the functionality, availability, security, or performance of portions of the Platform.
10.5 Consent
Certain jurisdictions require user consent before specific categories of Tracking Technologies may be activated.
Where required by applicable law, Palmera will:
request consent before enabling applicable technologies;
honor legally required consent preferences;
provide mechanisms for managing consent;
allow withdrawal of consent where required.
The withdrawal of consent does not affect processing conducted prior to such withdrawal.
10.6 Do Not Track Signals
Some web browsers provide “Do Not Track” (“DNT”) settings.
Because there is currently no universally accepted industry standard governing how DNT signals should be interpreted, Palmera does not currently respond to browser-based Do Not Track signals unless required by applicable law.
Where applicable law requires recognition of browser privacy preference signals or similar technologies, Palmera will comply with such legal requirements.
10.7 Future Technologies
Technology continues to evolve.
Palmera may adopt additional Tracking Technologies that improve security, Platform functionality, fraud prevention, personalization, analytics, accessibility, customer support, artificial intelligence, or other Platform capabilities.
Where the use of such technologies materially changes the processing of Personal Information, Palmera will update this Privacy Policy and, where required, obtain appropriate user consent before implementing such changes.
10.8 Our Commitment
Palmera believes Tracking Technologies should improve the user experience—not compromise user privacy.
Accordingly, we strive to:
minimize unnecessary data collection;
provide transparency regarding our practices;
implement appropriate user controls;
comply with applicable privacy laws;
regularly review technologies deployed on the Platform;
evaluate new technologies before implementation;
balance innovation with responsible privacy practices.
As technology and legal requirements continue to evolve, Palmera will periodically review and update its Tracking Technology practices to reflect responsible data governance and evolving industry standards.
11. YOUR PRIVACY RIGHTS
Palmera respects the privacy rights of all users and is committed to providing individuals with meaningful control over their Personal Information.
Because Palmera serves users from multiple jurisdictions, the rights available to a particular individual may vary depending on:
the user’s country or region of residence;
the laws applicable to the processing of Personal Information;
the nature of the information involved;
the legal basis upon which the information is processed.
Regardless of where you reside, Palmera strives to handle Personal Information responsibly, transparently, and in accordance with applicable law.
For information regarding how Palmera processes Personal Information, see Section 3 (How We Use Your Information).
For information regarding the legal basis for processing Personal Information, see Section 4 (Legal Bases for Processing Personal Information).
11.1 Rights Available to All Users
Subject to applicable law and appropriate verification of identity, users may request that Palmera:
provide access to certain Personal Information;
correct inaccurate or incomplete Personal Information;
update outdated information;
delete certain Personal Information;
restrict certain processing activities;
object to particular uses of Personal Information where permitted by law;
withdraw consent where processing is based upon consent;
receive certain Personal Information in a portable format where applicable;
review certain Account information;
manage communication preferences;
manage notification preferences;
close an Account.
The availability of these rights may depend upon applicable legal requirements and the circumstances of each request.
11.2 Additional Rights for Users in the European Economic Area and the United Kingdom
If you reside within the European Economic Area (“EEA”) or the United Kingdom, you may have additional rights under the General Data Protection Regulation (“GDPR”) or the UK GDPR.
These rights may include:
Right of Access
The right to request confirmation regarding whether Palmera processes your Personal Information and to receive a copy of certain Personal Information.
Right to Rectification
The right to request correction of inaccurate or incomplete Personal Information.
Right to Erasure
In certain circumstances, you may request deletion of Personal Information where continued processing is no longer legally justified.
This right is not absolute and may be limited where Palmera is legally required to retain information.
Right to Restrict Processing
You may request that Palmera temporarily restrict certain processing activities under circumstances recognized by applicable law.
Right to Object
You may object to certain processing conducted on the basis of legitimate interests or for direct marketing purposes where permitted by applicable law.
Right to Data Portability
Where applicable, you may request a copy of certain Personal Information in a structured, commonly used, and machine-readable format.
Where technically feasible, you may also request transmission of such information to another service provider.
Rights Relating to Automated Decision-Making
Where applicable law grants such rights, you may request information regarding certain automated decision-making or profiling activities and, where appropriate, request human review.
For additional information regarding AI and automated processing, see Section 9 (Artificial Intelligence, Automated Processing, and Personalization).
Right to Withdraw Consent
Where processing is based upon consent, you may withdraw that consent at any time.
Withdrawal of consent does not affect processing conducted before consent was withdrawn.
11.3 Additional Rights for United States Residents
Residents of certain U.S. states may have additional privacy rights under applicable state privacy laws.
Depending on your state of residence and applicable law, these rights may include:
the right to know what categories of Personal Information are collected;
the right to access certain Personal Information;
the right to correct inaccurate Personal Information;
the right to request deletion of Personal Information;
the right to obtain certain Personal Information in a portable format;
the right to opt out of certain targeted advertising activities where applicable;
the right to opt out of certain profiling activities where applicable;
the right to appeal certain privacy decisions where required by applicable law;
the right to limit certain processing of sensitive Personal Information where applicable.
Palmera will honor rights granted under applicable U.S. privacy laws, including, where applicable, laws enacted by states such as California and other jurisdictions adopting comprehensive consumer privacy legislation.
11.4 Additional Rights Under Senegalese Law
Users whose Personal Information is protected under Senegalese data protection law may have rights recognized under applicable legislation, including Law No. 2008-12 and any amendments or successor legislation.
Subject to applicable law, these rights may include:
access to Personal Information;
correction of inaccurate information;
objection to certain processing;
deletion where legally appropriate;
information regarding the processing of Personal Information;
submission of complaints to the competent supervisory authority.
Palmera is committed to cooperating with applicable Senegalese authorities where required by law.
11.5 Exercising Your Rights
Users wishing to exercise applicable privacy rights may submit a request using the contact information provided in Section 15 (Contact Information).
Privacy requests should, where possible, include:
your full name;
the email address associated with your Account;
sufficient information to identify the request;
the specific right being exercised;
any additional information reasonably necessary to process the request.
Palmera may request additional information where reasonably necessary to verify identity before responding.
11.6 Identity Verification
To protect the privacy and security of users, Palmera may take reasonable steps to verify the identity of individuals submitting privacy requests.
Verification procedures may vary depending upon:
the nature of the request;
the sensitivity of the information requested;
applicable legal requirements;
the potential risk of unauthorized disclosure.
Palmera reserves the right to decline requests that cannot be reasonably verified or where disclosure would violate applicable law or the rights of another individual.
11.7 Response Time
Palmera will acknowledge and respond to privacy requests within the timeframes required by applicable law.
The time required to complete a request may vary depending upon:
the complexity of the request;
the number of requests received;
applicable legal requirements;
the need to verify identity;
technical considerations.
Where permitted by law, Palmera may extend response deadlines when reasonably necessary and will notify the requesting individual where such extensions apply.
11.8 Appeals
Where applicable law grants users the right to appeal a privacy-related decision, users may submit an appeal using the contact information provided in Section 15 (Contact Information).
Palmera will review such appeals in accordance with applicable legal requirements.
If an appeal is denied, users may have additional rights to contact applicable regulatory authorities depending upon their jurisdiction.
11.9 Complaints to Supervisory Authorities
If you believe Palmera has processed your Personal Information in violation of applicable privacy law, you may have the right to submit a complaint to the appropriate supervisory authority or regulatory body in your jurisdiction.
Palmera encourages users to contact us first so that we may attempt to resolve privacy concerns promptly and collaboratively.
Nothing in this Privacy Policy limits any rights users may have to contact a competent regulatory authority directly.
11.10 No Discrimination
Palmera will not unlawfully discriminate against individuals for exercising privacy rights granted under applicable law.
However, certain Platform features may require the processing of specific categories of Personal Information in order to function.
Accordingly, the exercise of certain privacy rights may affect the availability or functionality of some Platform services where such processing is necessary to provide requested services or otherwise permitted by applicable law.
11.11 Our Commitment
Privacy rights continue to evolve around the world.
Palmera is committed to regularly reviewing its privacy practices, updating its policies, and honoring user rights in accordance with applicable legal requirements as new privacy laws and regulations emerge.
Our objective is not merely to comply with privacy laws, but to foster transparency, accountability, and trust with every individual who uses the Platform.
12. CHILDREN’S PRIVACY
Protecting the privacy of children and young people is important to Palmera.
The Platform is intended for individuals who are at least 13 years of age, or such higher minimum age as may be required by applicable law in the jurisdiction where the user resides.
Individuals who do not meet the applicable minimum age requirement should not create an Account, access the Platform independently, or otherwise provide Personal Information to Palmera without appropriate authorization where permitted by applicable law.
12.1 Minimum Age
Palmera does not knowingly collect Personal Information directly from children under the age of 13.
Where applicable law establishes a higher minimum age for digital consent or use of online services, Palmera intends to comply with those legal requirements within the relevant jurisdiction.
12.2 Discovery of Children’s Information
If Palmera becomes aware that Personal Information has been collected from a child in violation of applicable law, we will take commercially reasonable steps to:
investigate the matter;
restrict access to the Account where appropriate;
delete the relevant Personal Information where legally required;
comply with applicable legal obligations.
Parents or legal guardians who believe a child has submitted Personal Information to Palmera inappropriately are encouraged to contact us using the information provided in Section 15 (Contact Information).
12.3 Parental Rights
Where applicable law grants parents or legal guardians rights relating to a child’s Personal Information, Palmera will honor those rights in accordance with applicable legal requirements after verifying the identity and authority of the requesting individual.
12.4 Educational or Group Programs
If Palmera ever participates in educational initiatives, student programs, group travel programs, or other services involving minors, additional privacy notices, parental consent procedures, or contractual arrangements may apply where required by applicable law.
12.5 Our Commitment
Palmera is committed to designing its Platform responsibly and will continue to review its practices as youth privacy laws evolve around the world.
13. THIRD-PARTY SERVICES, LINKS, AND INTEGRATIONS
The Platform may contain links to, integrate with, or otherwise interact with third-party products, services, websites, applications, technologies, merchants, payment providers, mapping providers, authentication services, social platforms, and other independent organizations.
These third parties operate independently from Palmera and maintain their own privacy practices.
For information regarding categories of third parties with whom Personal Information may be shared, see Section 5 (How Palmera Shares Personal Information).
13.1 Independent Providers
Experiences available through the Platform are generally offered by independent Providers.
When users interact directly with a Provider, including after completing a reservation or leaving the Platform, that Provider may independently collect, process, or retain Personal Information under its own privacy practices.
Palmera is not responsible for the privacy practices of independent Providers.
Users are encouraged to review any privacy information made available by Providers before sharing additional Personal Information directly with them.
13.2 Payment Providers
Payments may be processed through authorized third-party payment providers.
These providers operate under their own privacy policies, contractual obligations, and regulatory requirements.
Palmera encourages users to review the privacy practices of payment providers when completing transactions.
13.3 Authentication Providers
Users may choose to authenticate their Accounts using supported third-party authentication services.
Depending upon available functionality, these services may include providers supporting:
Apple Sign In;
Google Sign In;
future authentication providers introduced by the Platform.
Information shared through these authentication services is governed by both this Privacy Policy and the privacy practices of the applicable authentication provider.
13.4 Mapping and Location Services
Certain Platform functionality may rely upon third-party mapping, navigation, geolocation, or location services.
These providers may process location information in accordance with their own privacy practices.
Users should review the applicable privacy policies of such providers before using location-enabled features.
13.5 Artificial Intelligence Providers
Certain AI-powered functionality may utilize trusted third-party technologies supporting artificial intelligence services.
Where applicable, Palmera seeks to configure these services in a manner consistent with our privacy commitments, contractual obligations, and applicable law.
Additional information regarding Palmera’s use of AI appears in Section 9 (Artificial Intelligence, Automated Processing, and Personalization).
13.6 Communications Providers
Palmera may utilize third-party providers supporting:
email communications;
SMS delivery;
push notifications;
messaging infrastructure;
customer support systems;
future communications technologies.
These providers process information only as necessary to provide their authorized services.
13.7 External Links
The Platform may contain links to external websites, businesses, social media pages, or other online resources that are not owned or controlled by Palmera.
Palmera does not control the privacy practices of those third parties.
Users who choose to visit third-party websites should review the applicable privacy policies before providing Personal Information.
13.8 Future Integrations
As Palmera expands, the Platform may integrate with additional technologies, applications, payment providers, loyalty programs, travel partners, authentication providers, mapping services, communications platforms, or other third-party services.
Where such integrations materially affect the processing of Personal Information, Palmera will update this Privacy Policy as required by applicable law.
13.9 Our Commitment
Palmera carefully evaluates third-party relationships that support our Platform.
Although we strive to work with reputable providers maintaining commercially reasonable privacy and security practices, each independent organization remains responsible for its own privacy obligations.
14. CHANGES TO THIS PRIVACY POLICY
Technology, privacy laws, and the services offered through the Platform continue to evolve.
Accordingly, Palmera may update this Privacy Policy from time to time to reflect:
new Platform features;
legal developments;
regulatory guidance;
technological advancements;
changes to business operations;
security improvements;
new service providers;
international expansion;
AI developments;
user feedback;
operational improvements.
14.1 Version Control
Each version of this Privacy Policy will identify:
the effective date;
the last updated date;
the applicable version number.
Palmera encourages users to review this Privacy Policy periodically to remain informed regarding our privacy practices.
14.2 Material Changes
Where changes materially affect users’ privacy rights or the processing of Personal Information, Palmera will provide additional notice where required by applicable law.
Depending upon the nature of the changes, such notice may be provided through:
the Platform;
email;
push notifications;
Account notifications;
other reasonable communication methods.
Where legally required, Palmera will obtain user consent before implementing certain material changes.
14.3 Continued Use
Unless otherwise required by applicable law, continued use of the Platform after the effective date of an updated Privacy Policy constitutes acknowledgment of the revised Privacy Policy.
Nothing in this section limits any rights users may have under applicable law.
14.4 Our Commitment
Palmera is committed to maintaining a Privacy Policy that evolves alongside our Platform, applicable laws, technological innovation, and responsible data governance practices.
15. CONTACT INFORMATION AND PRIVACY OFFICE
Palmera welcomes questions, comments, requests, and concerns regarding this Privacy Policy and our privacy practices.
We are committed to responding to privacy inquiries in a timely, professional, and transparent manner consistent with applicable law.
Depending upon the nature of your inquiry, you may contact Palmera using the appropriate contact method below.
15.1 General Privacy Inquiries
For general questions regarding this Privacy Policy or Palmera’s privacy practices, please contact:
Palmera Privacy Office
Email: palmeraexp@gmail.com (or your designated privacy email address)
Mailing Address:
Palmera Services LLC
1057 Barbey St
Brooklyn, NY 11207
United States
15.2 Privacy Rights Requests
If you wish to exercise any privacy rights described in Section 11 (Your Privacy Rights), including requests to:
access Personal Information;
correct Personal Information;
delete Personal Information;
restrict processing;
object to certain processing;
withdraw consent;
obtain a copy of Personal Information;
exercise rights available under applicable privacy laws;
please contact:
Privacy Rights Team
Email:
palmeraexp@gmail.com
Before fulfilling certain requests, Palmera may require reasonable identity verification as described in Section 11.6 (Identity Verification).
15.3 Data Protection Questions
Questions relating to:
international data transfers;
GDPR;
UK GDPR;
Senegalese privacy law;
cross-border processing;
data governance;
data retention;
privacy compliance;
may be directed to:
Data Protection Office
palmeraexp@gmail.com
Palmera will review and respond in accordance with applicable legal requirements.
15.4 Security Reporting
If you believe you have discovered:
a security vulnerability;
unauthorized access;
suspicious Account activity;
suspected fraud;
a data security concern;
another issue affecting Platform security;
Please notify Palmera as soon as reasonably possible.
Security reports may be submitted to:
palmeraexp@gmail.com
Palmera appreciates responsible disclosure of legitimate security vulnerabilities.
Where appropriate, Palmera may coordinate with security researchers to investigate reported issues.
15.5 Law Enforcement and Government Requests
Government agencies, regulatory authorities, law enforcement agencies, or courts seeking information relating to the Platform should submit requests through appropriate legal channels.
Such requests may be directed to:
palmeraexp@gmail.com
Palmera reviews requests carefully and discloses information only where legally required or otherwise permitted by applicable law.
Additional procedures governing governmental requests may be described in Palmera’s separate Law Enforcement & Government Requests Policy.
15.6 Intellectual Property and Copyright Notices
Questions regarding:
copyright;
trademarks;
intellectual property;
DMCA notices;
infringement claims;
may be directed to:
palmeraexp@gmail.com
Additional procedures governing copyright complaints will be described in Palmera’s DMCA & Copyright Policy.
15.7 Business, Regulatory, and Compliance Inquiries
Businesses, regulators, enterprise partners, merchants, payment providers, investors, auditors, or other organizations seeking information regarding Palmera’s compliance, governance, or privacy practices may contact:
palmeraexp@gmail.com
Palmera may request additional information to appropriately evaluate and respond to such inquiries.
15.8 Response Commitment
Palmera strives to acknowledge privacy-related inquiries promptly and to respond within the timeframes required by applicable law.
The time necessary to respond may depend upon:
the nature of the request;
applicable legal requirements;
identity verification;
the complexity of the matter;
the volume of requests received.
Where additional time is reasonably necessary, Palmera will notify the requesting individual when required by applicable law.
15.9 International Users
Because Palmera serves users in multiple jurisdictions, privacy inquiries may involve international privacy laws and cross-border processing requirements.
Palmera will review privacy requests in accordance with the laws applicable to the requesting individual and the nature of the Personal Information involved.
15.10 Accessibility
Palmera is committed to making its privacy practices understandable and accessible.
Individuals requiring reasonable accommodations to submit privacy requests or understand this Privacy Policy are encouraged to contact us, and we will make commercially reasonable efforts to provide appropriate assistance where practicable.
15.11 Our Commitment
Privacy is fundamental to the trust users place in Palmera.
We recognize that protecting Personal Information is an ongoing responsibility—not a one-time obligation.
Accordingly, Palmera is committed to continuously evaluating and improving our privacy practices, governance processes, security safeguards, transparency, and compliance efforts as our Platform evolves.
Our objective is not only to comply with applicable privacy laws, but to foster lasting trust with our users, Providers, employees, business partners, regulators, and the communities we serve.
APPENDIX A — DEFINITIONS
The following capitalized terms have the meanings set forth below whenever used in this Privacy Policy.
Account means a registered user account created to access and use the Platform.
AI Concierge means Palmera’s artificial intelligence-powered features that assist with recommendations, itinerary planning, customer support, intelligent search, personalization, and related Platform functionality.
Booking means any reservation, purchase, request, inquiry, transaction, or similar interaction initiated through the Platform.
Concierge Services means planning assistance, reservation coordination, itinerary services, customer support, AI-assisted services, and other assistance provided through the Platform.
Experience means any restaurant reservation, hotel stay, beach club, transportation service, wellness offering, nightlife venue, tourism activity, event, membership benefit, or other offering available through the Platform.
Favorites means functionality allowing users to save businesses, Experiences, destinations, or other content.
Friend Connections means social functionality allowing users to connect, collaborate, communicate, or plan Experiences together.
Merchant or Provider means any independent individual or business offering goods or services through the Platform.
Palmera Gold means Palmera’s premium membership and loyalty program, together with any successor membership programs.
Personal Information means information that identifies, relates to, describes, can reasonably be associated with, or could reasonably be linked to an identifiable individual, as defined under applicable law.
Platform means the Palmera mobile applications, websites, APIs, software, AI systems, concierge services, messaging systems, social features, and all related products and services operated by Palmera.
Stories means temporary or persistent user-generated content shared through the Platform.
Tracking Technologies means cookies, SDKs, pixels, APIs, local storage, web beacons, device identifiers, and similar technologies used by Palmera.
User, you, or your means any individual accessing or using the Platform.