Ashnil Aruba Lodge

PRIVACY POLICY & ELECTRONIC COMMUNICATIONS POLICY

Cubatur

Fiscal address: Calle 15 entre G y F, Vedado, La Habana, 10400, Cuba

Website: https://cubatur.travelportal.online

Contact: YARIEL ROJAS GONZALEZ – ventasonline@centra.cbt.tur.cu

1. Legal Compliance and Scope

TRAVEL PORTAL LLC (Cubatur, "we”, “us” or “our”) s committed to protecting the privacy and security of personal information collected through our website, platforms, communications and services.

his Privacy Policy has been prepared in accordance with applicable United States federal and state laws, including but not limited to:

-Federal and state consumer protection regulations

-Telephone Consumer Protection Act (TCPA)

-CAN-SPAM Act

-Privacy regulations applicable in the State of Florida

-Office of Foreign Assets Control (OFAC) regulations

-This Policy applies to all users, customers, agencies and partners who access or use our services.

2. Purposes of Data Processing

Primary purposes

-We may collect and process personal data for the following legitimate business purposes:

-User identification and account administration

-Sale, management and administration of travel-related services

-Processing of reservations, confirmations and modifications

-Payment processing, billing and fraud prevention

-Customer service and operational assistance

-Administrative, accounting and legal compliance

-Service quality control and internal audits

-Communication via email, phone, SMS or other authorized means, strictly related to contracted services

Secondary purposes

Subject to user consent where required, we may also use personal data for:

-Marketing and promotional communications

-Market studies, statistical analysis and internal metrics

-Website performance optimization and user experience improvement

Users may opt out of promotional communications at any time.

3. Personal Data We Collect

We may collect the following categories of information:

-Identification data: full name, address, phone number, email address, date of birth, government or tax identification when required for service provision

-Financial data: payment card information, ACH transfers or wire transfers (processed exclusively through secure payment providers)

-Technical data: IP address, browser type, device information, cookies and usage logs

TRAVEL PORTAL LLC does not knowingly collect or process sensitive personal data under applicable U.S. law.

4. Online Privacy Practices

This Privacy Policy is permanently available in the footer of our website.

We do not sell, rent or share phone numbers or SMS consent information with third parties for marketing purposes.

5. SMS Communications and Consent (TCPA Compliance)

Express consent (Opt-in)

When users provide their phone number through our website or other channels, express consent may be required to receive SMS communications.

Sample consent language:

“By checking this box, you agree to receive SMS messages from TRAVEL PORTAL LLC related to reservations, confirmations, billing or authorized promotions. You may reply STOP at any time to unsubscribe. For assistance, reply HELP or contact us at ventasonline@centra.cbt.tur.cu . Message and data rates may apply. Message frequency may vary.”

Types of SMS messages

Reservation confirmations and reminders

-Operational service updates

-Payment or billing-related communications

-Promotional messages (only with express consent)

Opt-out

Users may opt out of SMS messages at any time by replying STOP or contacting ventasonline@centra.cbt.tur.cu

TRAVEL PORTAL LLC fully complies with TCPA requirements.

6. Data Security

We implement reasonable administrative, technical and physical safeguards, including SSL encryption and secure systems, to protect personal information.

However, no internet-based data transmission can be guaranteed to be completely secure, and users acknowledge and accept this inherent risk.

7. Social Media

Any information shared by users through third-party platforms such as Facebook®, Instagram® or similar services is governed by the privacy policies of those platforms.

TRAVEL PORTAL LLC is not responsible for data practices outside its controlled systems.

8. User Rights and Requests

Users may request:

-Access to their personal data

-Correction or update of information

-Deletion of data, where legally permitted

-Restriction or objection to certain processing activities

Requests must be sent to {agency.email} and may require identity verification. We will respond within a reasonable timeframe in accordance with applicable U.S. law.

9. Data Sharing and Disclosure

Personal data may be shared only with:

-Service providers and payment processors necessary to deliver services

-Legal, accounting or compliance advisors

-Government or regulatory authorities when legally required

We do not share SMS consent data or phone numbers with third parties for marketing purposes.

10. Cookies and Tracking Technologies

We may use cookies and similar technologies to:

-Improve website functionality

-Analyze website usage and performance

-Remember user preferences

Users may configure their browsers to reject cookies, although some website features may be affected.

11. OFAC Compliance and Sanctions (Critical Section)

TRAVEL PORTAL LLC operates in strict compliance with United States sanctions laws and regulations, including those administered by the Office of Foreign Assets Control (OFAC).

Accordingly:

-TRAVEL PORTAL LLC does not market, sell, arrange or facilitate travel or services to or within countries designated by the United States as State Sponsors of Terrorism or comprehensively sanctioned jurisdictions, including but not limited to:

Cuba, Iran, North Korea, Syria, and any other country or territory subject to U.S. sanctions.

-Any reservation, transaction or service request that directly or indirectly involves a sanctioned country, entity or individual is strictly prohibited.

-TRAVEL PORTAL LLC reserves the absolute right to:

Cancel such transactions

Void related reservations

Issue refunds when legally permitted

Block or report activity as required by applicable law

Users acknowledge that compliance with U.S. sanctions laws is mandatory and non-negotiable.

12. Policy Updates

TRAVEL PORTAL LLC may modify this Privacy Policy at any time to reflect legal, regulatory or operational changes.

Updates will be available at https://cubatur.travelportal.online

13. Acceptance

By using our website or services, users acknowledge that they have read, understood and accepted this Privacy Policy and the Electronic Communications terms.