VAX VacationAccess Privacy Policy

Effective March 1st, 2022

  1. Introduction

    VAX is an award winning travel platform specifically designed for Travel Agencies and Travel Agents. VAX VacationAccess Worldwide, LLC. works with contractors to provide you with access to a variety of benefits described herein as “VAX Content” which includes but is not limited to VAX applications, products and services. VAX VacationAccess is powered by Trisept, an Apple Leisure Group (“ALG”) company.

    Except as otherwise noted in this Privacy Policy, VAX VacationAccess is a data processor and a member of the ALG companies, which means that we manage how and why the information you provide to us is processed. This Privacy Notice may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of your information, or changes in applicable law.

    We encourage you to read this Privacy Notice carefully, and to regularly check this page to review any changes we might make

  2. Part of Trisept Solutions and Hyatt

    The VAX family of platforms and services is managed by Trisept Solutions which is part of Apple Leisure Group (“ALG”) and operates under the policies of ALG. Trisept processes customer travel data from its data centers in the USA. Trisept is not responsible for the content of the information it processes or responsible for the way its clients treat personal information they collect or control.

    Accordingly, neither VAX VacationAccess nor Trisept directly interfaces with the traveling public (with the exception of “VAX Web” which allows travelers to interact with the platform services directly) and does not collect Personally Identifiable Information (“PII” under the General Data Protection Regulation (GDPR) of the European Union) or Personal Information (“PI” under the California Consumer Protection Act (CCPA)) from consumers. However, limited PII/PI is collected from representatives of its clients such as Travel Agents or Travel Merchandisers. This policy describes what information is collected directly as well as protections that are incorporated in the products and services Trisept/VAX VacationAccess provides to its clients that protect the information of their customers.

    Please note that VAX VacationAccess Worldwide, LLC, Trisept and the Apple Leisure Group of companies are now subsidiaries of Hyatt Hotels Corporation.  However, this Privacy Notice only applies to the processing of Personal Information undertaken by VAX VacationAccess and Trisept.  It does not apply to processing by other members of the Apple Leisure Group or processing by the Hyatt Group.

  3. Definitions

    “Client” – means any Travel Agency or Travel Agent that contracts for or agrees to use the VAX VacationAccess platform(s).

    “Contractor” – means an independent provider of goods or services on behalf of VAX VacationAccess Worldwide, LLC.

    “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

    “Customer” – means an individual for whom the Travel Agency undertakes researching, shopping, booking, or purchasing of products and services on the VAX VacationAccess web sites.

    “Hyatt Group” means Hyatt Hotels Corporation, its direct and indirect subsidiaries (with the exception of the Apple Leisure Group companies), its affiliates, and the separate and distinct legal entities that manage, operate, franchise, license, own and/or provide services to the various locations operating under or in connection with a Hyatt brand.

    “Personal Information” means information from which any individual is directly or indirectly identifiable.

    “Process”“Processing” or “Processed” means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

    “Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.

    “Third Party” – means a company other than VAX VacationAccess Worldwide, LLC or a domain name other than

    “Trisept” – means the company that is part of Apple Leisure Group that provides solutions and services to travel agents and agencies and in some cases to the traveling public directly.

    "VAX" – means the VAX VacationAccess technology owned by VAX that enables the Travel Agency to access the VAX Content, various customer’s inventories (all of which are maintained separately and are not owned or controlled by VAX) and make purchases on behalf of their agency and/or customers.

  4. What information is collected and how we collect it.

    We may Process the following categories of Personal Information about you:

    • Personal details: your name; username or log in details; password;
    • Contact details: postal address; telephone and/or mobile number; email address;
    • Consent records: records of any consents you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
    • Purchase and payment details of your customers: records of purchases and prices; invoice records; payment records; billing address; payment method; cardholder or accountholder name; payment amount; and payment date.

    We may also collect:

    • Information about your use of the services, such as usage data and statistical information, which may be aggregated.
    • Searches for and interactions with e-commerce opportunities, such as merchants and offers contained in the services.
    • Non-precise information about the approximate physical location (for example, at the city or postal code level) of a user’s computer or device derived from the IP address of such computer or device (“GeoIP Data”).
    • Device identification (“ID”), which is a distinctive number associated with a smartphone or similar handheld device but is different than a hardware serial number.
    • Advertising ID, which is a unique, user-resettable identification number for advertising associated with a device (e.g., iOS uses the Identifier for Advertising (or “IDFA”) and Android uses Google Advertising ID).
    • Internet Protocol (“IP”) address, which is a unique string of numbers automatically assigned to your device whenever you access the Internet.
    • Internet connection means, such as internet service provider (“ISP”), mobile operator, WiFi connection, service set identifier (“SSID”), International Mobile Subscriber Identity (“IMSI”) and International Mobile Equipment Identity (“IMEI”).
    • Information collected through the use of cookies, eTags, Javascript, pixel tags, device ID tracking, anonymous identifiers and other technologies, including information collected using such methods and technologies about (i) your visits to, and interaction and engagement with, the services, content and ads on third party websites, applications, platforms and other media channels (“Channels”), and (ii) your interaction with emails including the content and ads therein (collectively, “Online Data”).
    • Device type, settings and software used.
    • Log files, which may include IP addresses, browser type, ISP referring/exit pages, operating system, date/time stamps and/or clickstream data, including any clicks on customized links.
    • Web Beacons, which are electronic files that allow a website to count users who have visited that page or to access certain cookies.
    • Pixel Tags, also known as clear GIFs, beacons, spotlight tags or web bugs, which are a method for passing information from the user’s computer to a third-party website.
    • Local Shared Objects, such as Flash cookies, and Local Storage, such as HTML5.
    • Mobile analytics to understand the functionality of our mobile applications and software on your phone.

    Children. The services are not intended for use by children, especially those under 13. No one under the age of 13 should provide any Personal Information or use our public discussion areas, forums or chats. Minors under the age of 18 are not permitted to make purchases through the services or to obtain coupons or codes from the services to purchase goods or services on third party websites. If, notwithstanding these prohibitions, your children or your customer’s children disclose information about themselves in our public discussion areas, consequences may occur that are not intended for children (for example, they may receive unsolicited messages from other parties). If it is discovered that we have collected Personal Information from someone under 13, we will delete that information immediately.

  5. Uses of information

    The PII/PI is collected and used for processing transactions through the platform to provide services to your customers. The agreement between VAX VacationAccess and our clients ensures the information will be used for the purpose it was intended.

    • Accounts and Personalization: providing personalization for services from VAX VacationAccess or its partners including (i) management of your account, (ii) posting of your personal reviews, testimonials or comments, (iii) offering of contests, as well as chat areas, forums and communities, and (iv) customer support and relationship management.
    • Offering and Improving the services: operating and managing the services for you; providing personalized content to you; communicating and interacting with you via the services; identifying issues with the services and planning improvements to or creating new services; and notifying you of changes to any of our services.
    • Surveys: engaging with you for the purposes of obtaining your views on our services.
    • Communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) regarding news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required. We may provide direct marketing to you.
    • Advertising: providing advertising based on your interests and interactions with the services and channels, including using Personal Information to serve you advertisements on the services and Channels.
    • User Engagement and Purchases: tracking purchase traffic and activity across the Service and on Channels, including review of your browsing history (if available); provision of analytics and measurement of cost of traffic against money being made.
    • Commerce Offerings: using cookies to track your browsing history and the amount of money spent at a particular third-party merchant’s site to offer coupons and other offers that are relevant to your shopping experience; offering of coupons via SMS messages if a mobile phone number is provided.
    • IT Administration: compliance audits in relation to internal policies; identification and mitigation of fraudulent activity; and compliance with legal requirements.
    • Security: Cyber-security measures (including monitoring of login records and access details) to help mitigate the risk of and provide the ability to identify and rectify a security incident.
    • Legal Compliance: Subject to applicable law, we reserve the right to release information concerning any user of services when we have grounds to believe that the user is in violation of our Terms and Conditions or other published guidelines or has engaged in (or we have grounds to believe is engaging in) any illegal activity, and to release information in response to court and governmental orders, other requests from government entities, civil subpoenas, discovery requests and otherwise as required by law or regulatory obligations. We also may release information about users when we believe in good faith that such release is in the interest of protecting the rights, property, safety or security {company’s name}, any of our users or the public, or to respond to an emergency.

    When we process your Personal Information as a customer or someone else with whom we do business, we do so in the legitimate interests of the purposes listed above, because of the legal compliance we are subject to, or because the information is required to fulfil contractual obligations to you.

  6. Disclosures

    We may have to share your personal data with the parties set out below for the purposes set out above.

    • Service Providers:
      • Other companies in the Apple Leisure Group or the Hyatt Group acting as processors or controllers who provide the services that make up any booking of travel services that you make with us.
      • Suppliers of accommodation and travel services acting as processors or controllers who provide the services that you booked with us.
      • Marketing companies to send information and offers on our behalf.
      • Other companies that provide IT and System administration services.
    • Third Parties:
      • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
      • Regulatory and governmental bodies and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
      • Third parties to whom we may choose to transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
        • Apple Leisure Group companies and Hyatt Group companies. How Hyatt Group companies use your personal data is set out in the Hyatt Privacy Policies available here:
    • Businesses who we have a partnership with to provide related services to our customers.

    We require all service providers and third parties to respect the security of your personal data and to treat it in accordance with the law.

    We do not allow our third parties and service providers to use your personal data for their own purposes without your consent and only permit them to process your personal data for specified purposes and in accordance with our instructions.

  7. International transfers

    Because of the international nature of our business, we may need to transfer your Personal Information within the ALG group of companies, and to third parties, in connection with the purposes set out in this Privacy Notice. For this reason, we may transfer your Personal Information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located. 

    Transfers of Personal Information often occur so that we may provide you with services you’ve asked for. Having a contractual relationship is usually a permissible reason for transferring Personal Information in countries with privacy regulations.  Where it’s not, we’ll seek to put in place additional technical and contractual measures to protect your Personal Information.

    In accordance with the above, we may send your Personal Information to the following countries where Apple Leisure Group has operations and partnership with services providers:

    • United States of America

    • Mexico

    • Dominican Republic

    • Panama

    • Curacao

    • Jamaica

    • Costa Rica

    • Spain

    • St Martin

    • Netherlands

    • United Kingdom

    • Canada

    • Switzerland

    • Aruba

    • Bahamas

    • Colombia

    • St. Lucia

    • Trinidad & Tobago

    Where your personal data is shared with the Hyatt Group, your personal data may be shared with any of the locations in which an entity in that group operates a hotel or where you or someone you are connected with has booked a stay (a list of these can be found by selecting “All” at and their major business locations, which, in addition to those set out in the bullet point list above, includes locations in Hong Kong (SAR) and Germany. 

    We have implemented appropriate technical security measures in order to protect Personal Information during international transfers, in compliance with applicable laws. 

    Where you have made a reservation for accommodation or travel arrangements which are located or otherwise due to be fulfilled outside your origin country, we will have to transfer your personal data to the suppliers fulfilling or providing those travel arrangements in order to make your booking and for those suppliers to be able to provide you with the travel arrangements you have booked.

  8. Rights

    Access to data controlled by VAX VacationAccess

    Under the data protection laws in Europe and other jurisdictions, you have various rights in relation to the Personal Information about you that we process.

    Where we are the data controller, with some limited exceptions, you have rights to access and update Personal Information held about you. If you want to inquire about any Personal Information we may have about you, you can do so by sending us a written request by letter or email to the addresses set out below. Please be sure to include your full name, address and telephone number and a copy of a document evidencing your identity (such as an ID card) so we can ascertain your identity and whether we have any Personal Information regarding you, or in case we need to contact you to obtain any additional information we may require to make that determination. Where you make more than one request in quick succession, we may respond to your subsequent request by referring to our earlier response and only identifying any items that have changed materially.

    You may request that we correct, delete, and/or stop or restrict processing or using Personal Information that we hold about you by sending a letter or email to the addresses set out below. If we agree that the Personal Information is incorrect, or that the processing should be stopped, we will delete or correct the Personal Information. If we do not agree that the Personal Information is incorrect we will tell you that we do not agree, explain our refusal to you and record the fact that you consider that Personal Information to be incorrect in the relevant file(s).

    You may also seek to exercise your right to data portability by sending a letter or email to the addresses set out below.

    Finally, you may in some circumstances have the ability to object to the processing of your Personal Information on the grounds of your particular situation. You may do so by sending us a written request by letter or email to the addresses set below. If we agree that you are entitled to so object, we will cease to process your Personal Information.

    If you are unhappy with the way we have handled your request, you can let us know using the contact details below.

    Access to Data Controlled by our Clients

    VAX VacationAccess acknowledges that persons have the right to access their personal information. As explained above, for the most part, VAX VacationAccess has no direct relationship with the individuals whose personal data is processed (the only persons for whom we have access are our employees and the PII/PI of travel agents or authorized representatives of our clients). Where we hold data on behalf of one of our clients, an individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his/her query to the specific client (the data controller) that collected it. If the client requests us to remove the data, we will respond to that request within 30 business days.

    If you are unsure whether VAX VacationAccess or one of our clients is the data controller, please contact us using the details below.

  9. California Residents

    If you reside in California, you may also make the following more specific requests with respect to your Personal Information in accordance with applicable law:

    • Access – You can request that we disclose to you the categories of Personal Information collected about you, the categories of sources from which the Personal Information is collected, the categories of Personal Information sold or disclosed, the business or commercial purpose for collecting and selling the Personal Information, the categories of third parties with whom we share the Personal Information, and the specific pieces of Personal Information collected about you over the past 12 months.
    • Deletion – You can request that we delete your Personal Information that we maintain about you, subject to certain exceptions.
    • Opt-out – You can request to opt out of the sale of your Personal Information to an outside party. We may also use cookies and related technology for advertising purposes, which could constitute a sale of your Personal Information. If you would like to opt out of cookie-based tracking for advertising purposes, you can update your cookie preferences by clicking on the Cookie Center link that may be in the footer of our websites. Additionally, you can opt out of certain uses of cookies for advertising purposes by visiting Your opt-out of cookie-based tracking for advertising purposes is specific to the device, website, and browser you are using, and is deleted whenever you clear your browser’s cache. This means you need to adjust your cookie preferences on each website, device, and browser you use. For purposes of this Privacy Notice, “sell” means the sale, rental, release, disclosure, dissemination, availability, transfer, or other oral, written, or electronic communication of your Personal Information to an outside party for monetary or other valuable consideration, subject to certain exceptions in applicable law.

    As is the case for all consumers regardless of residency, we will not discriminate against you because you exercised any of these rights. Note that for purposes of these rights, Personal Information does not include information about job applicants, employees and other of our personnel; information about employees and other representatives of third-party entities we may interact with in their business or commercial capacity; or information we have collected as a service provider to our clients.

    California residents can exercise these rights by contacting us using the contact information below. We may deny certain requests, or fulfil a request only in part, based on our legal rights and obligations. For example, we may retain Personal Information as permitted by law, such as for tax or other record-keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests.

    We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the Personal Information and whether you have an account with us.

    California residents may designate an authorized agent to make a request on their behalf. When submitting the request, please ensure the authorized agent is identified as an authorized agent and ensure the agent has the necessary information to complete the verification process.

    For purposes of exercising these rights, please note the following regarding how we collect and use your Personal Information as described in this Privacy Notice, including in the previous 12 months:

    • We may collect, and use for our business and commercial purposes, the following categories of Personal Information as set forth in applicable California law: Identifiers; California customer records (such as birthdate, contact information, and payment information); characteristics of protected classifications under California or federal law (such as demographic information like age and gender); commercial information; biometric information; Internet or other electronic network activity information; geolocation data; audio, electronic or visual information; and inferences. Please see above for more details about the information we collect.
    • We use the above categories of Personal Information for the business and commercial purposes described above.
    • We collect Personal Information from the sources described above.
    • We may disclose each of these categories of Personal Information for our business and commercial purposes to the extent permitted by applicable law with the categories of parties described above.
    • We may sell the following categories of Personal Information: Identifiers; California customer records; demographic information; commercial information; Internet or other electronic network activity; geolocation data; and inferences.
  10. Other

    Several other items are relevant in this Privacy Policy. These are:

    Cookies and Other Tracking Technologies

    VAX VacationAccess uses cookies or similar tracking technologies. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about the user base as a whole. Reports based on the use of these technologies may be produced, generally on an aggregate basis.

    Cookies are used to identify a return visitor or used as a way to measure activity and traffic patterns on the site. Users can control the use of cookies at the individual browser level. If the use of cookies is rejected, you may still use the sites, but your ability to use some features or areas of the sites may be limited.

    Behavioral Targeting / Re-Targeting

    VAX VacationAccess partners with a third party to either display advertising on the website or to manage advertising on other sites. The third party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising click here [or if located in the European Union click here]. Please note this does not opt you out of being served ads. You will continue to receive generic ads.

    Log Files

    As is true of most web sites, VAX VacationAccess gathers certain information automatically and stores it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. This automatically collected data is not linked to other information we collect about you.

  11. Contact Information

    Questions, comments or complaints regarding the company’s policy or data collection and processing practices can be emailed to: