PRIVACY POLICY
Last updated: January 1, 2023
1. WHO WE ARE & SCOPE
This Privacy Policy (“Policy”) describes how Walter Wanell LLC d/b/a Garry x Olivia (“Garry x Olivia,” “we,” “us,” or “our”) collects, uses, and shares personal information in connection with our websites, forms, proposals, and services (the “Services”). By using the Services, you agree to this Policy and our Terms & Conditions.
2. INFORMATION WE COLLECT
We collect information directly from you, automatically, and from third parties (e.g., travel partners), including:
• Identifiers & contact info: name, email, phone, postal address, date of birth (as needed for travel), and government ID details strictly as required for bookings.
• Booking & itinerary data: traveler profiles, preferences, trip dates, destinations, loyalty numbers (if provided), room/seat choices, special occasions.
• Payment data: cardholder name, masked card details, billing address (processed by our PCI-compliant payment processor; we do not store full card numbers).
• Communications & concierge requests: emails, texts, and call notes related to trip planning and hosted experiences.
• Device/usage data: cookies, IP address, device and browser type, pages viewed, and interactions with our sites (see Cookies & Tracking).
• Guest/submitted lists: where a client provides guest information to coordinate a group itinerary, registrations, or concierge services.
We do not intentionally collect sensitive characteristics (e.g., race, religion, union membership, political opinions) unless strictly necessary for the trip (for example, accessibility or dietary needs you choose to share) and handled per applicable law and your instructions.
3. SOURCES OF PERSONAL INFORMATION
• You (forms, emails, phone, questionnaires, SMS/MMS opt-ins).
• Your organizer (for group trips) and authorized representatives.
• Travel partners and platforms (e.g., hotels, airlines, venues, destination partners) to quote, book, modify, and support your itinerary.
• Public sources and anti-fraud service providers.
4. HOW WE USE INFORMATION
• Plan and deliver trips & hosted experiences (perform a contract; legitimate interests).
• Process payments and invoices (perform a contract; legal obligations).
• Client support & communications, including SMS/MMS for itinerary updates and concierge needs (consent where required; legitimate interests).
• Personalize proposals and improve our Services (legitimate interests).
• Security, fraud prevention, and legal compliance (legal obligations; legitimate interests).
• Marketing (with consent where required; you can opt out anytime).
5. HOW WE SHARE INFORMATION
We share information with:
• Service providers/“processors” (e.g., payment processors, email/SMS platforms, IT, analytics, and security vendors) under contract.
• Travel partners (e.g., hotels, airlines, cruise lines, venues, and DMCs) to quote, book, modify, and support your itinerary.
• Authorities when required by law, to protect rights/safety, or to prevent fraud.
• Business transfers (e.g., merger, acquisition) subject to this Policy or equivalent safeguards.
We do not sell personal information for money and we do not “share” personal information for cross-context behavioral advertising as defined by applicable U.S. privacy laws. If our practices change, we will update this Policy and provide required links/choices.
6. COOKIES & TRACKING
We use cookies and similar technologies for site functionality, analytics, and to remember your preferences. You can manage preferences through browser settings and, where available, a “Cookie Settings” link. Blocking some cookies may affect site functionality.
7. RETENTION
We retain personal information only as long as necessary for the purposes set out in this Policy, including to provide the Services, comply with legal/booking record obligations, resolve disputes, and enforce agreements. Retention periods vary by record type.
8. INTERNATIONAL TRANSFERS (EU/UK VISITORS)
We are based in the United States. Where applicable, we rely on lawful transfer mechanisms such as Standard Contractual Clauses and, if/when we participate, the EU-U.S. Data Privacy Framework (and UK Extension) with appropriate supplementary measures. Details are available upon request.
9. YOUR PRIVACY CHOICES & RIGHTS
Depending on your location, you may have rights to:
• Access, correct, or delete personal information.
• Receive a portable copy (data portability).
• Limit or object to certain processing (including withdraw consent).
• Opt out of marketing communications (unsubscribe link in emails; reply STOP to SMS).
• Appeal a decision (where provided by law).
California and certain other U.S. state residents: you may have additional rights (access, deletion, correction, and non-discrimination). We do not sell or share personal information as defined by those laws and do not use or disclose sensitive personal information for purposes that require a right-to-limit notice.
To exercise a right, email privacy@walterwanell.com with “Privacy Request,” or use the contact details below. We may verify your identity and, where applicable, process requests through an authorized agent per law.
10. SMS/MMS TERMS
By providing a mobile number, you consent to receive trip/itinerary, concierge, and event-related texts. Message frequency varies. Message and data rates may apply. Reply STOP to opt out; HELP for help. We may send non-marketing, critical service messages even if you opt out of marketing texts.
11. CHILDREN
Our Services are not directed to children under 13. We do not knowingly collect personal information from children under 13. If you believe a child has provided personal information, contact us so we can delete it.
12. SECURITY
We implement reasonable administrative, technical, and physical safeguards appropriate to the nature of the information. No method of transmission or storage is 100% secure.
13. CHANGES TO THIS POLICY
We may update this Policy from time to time. The “Last updated” date reflects the latest changes. For material changes, we will highlight updates on this page and, where required, notify you.
14. CONTACT US
Email: privacy@walterwanell.com
Mail: Walter Wanell LLC, 500 7th Avenue, 8th Floor, New York, NY 10018
For general questions, use the contact details listed on our website footer or those provided in your proposal/invoice communications.