This is the Privacy Policy for the web site.  We can be reached by email at [email protected].

The website is designed to facilitate the sharing of ideas, and providing insider travel information for the CONWAY CONFIDENTIAL™ audience.

Paula Conway LLC, (“CC”), the sponsor of the web site, values individual privacy, and we want to give our web site visitors the opportunity to know what information we collect about them and how CC collects, protects, uses, discloses and otherwise manages the information gathered, in conformance with applicable law.  At certain points on the web site, you may be asked to submit information that may personally identify you (“Personal Information” or “Personally Identifiable Information”).  All Personally Identifiable Information that we gather is collected in a fair and non-intrusive manner, with your consent, in order to better serve you.  Personally Identifiable Information that you submit via this web site is only accessible to CC’s employees, contractors and service providers who need the information for the purposes for which it is collected or as you consent.

This privacy policy applies to the collection of Personal Information at  Different privacy policies and procedures may apply to information that CC obtains offline.

Unless otherwise stated by CC, the content for this website, including images, artwork, graphics, commercials, photography, text and information is subject to copyrights, trademarks and is intellectual property that is owned, controlled or licensed by CC.  All title, rights and interest to the referenced properties are reserved by CC.  Access to the website and any downloading, printing or other authorized use of the content does not transfer any title, right or interest in the property or otherwise from CC.  Hard copies of material from this website must include copyright notices found with the material.

CC reserves the right to limit authorization to this site at will.  CC does not authorize the reproduction, publication, display, modification, sale or distribution of content of this site in any manner or by any medium, or to create any hyperlink or other reference or connection to or from this site without the express written permission of CC.


The content of this website may contain substantive and typographical errors or omissions and CC disclaims any responsibility for any such errors.  CC retains the right to discontinue, edit or delete content from the website at any time without notice.

Collection and Use of Personal Information

For the areas of the web site where the collection of Personally Identifiable Information is necessary, you will be aware that such information is required because you will have to complete an online form.  We may collect Personally Identifiable Information from you, for example, when you visit areas on the where you can submit your name, address and/or other Personal Information.  The Personal Information that you submit is gathered only on a voluntary basis; you may choose not to provide Personal Information and you will still be able to visit most of the web site, although you may not be able to participate in certain interactive activities.

We may collect limited Personally Identifiable Information, including, but not limited to your name and/or any “nickname”, date of birth, email and postal address and any other information that would allow someone to identify or contact you, as well as information about your personal/product preferences, survey responses and online activities, if any, that is known by CC.  We may also collect limited Personal Information about others from you including, but not limited to, name and email address.

We may collect Personal Information for one of several different purposes, for example:

  • to administer your participation in a contest or sweepstakes and for other purposes stated on the entry form, such as to allow us to contact you notification of a potential prize you may have won;
  • to allow us to send you the specific information or materials that you have requested, such as a newsletter, or other materials;
  • to inquire regarding employment or business opportunities with CC;
  • to help improve our web site and our services, or to customize your experience at our web site.

We may combine this information with other generally or publicly available information to help us identify our visitors’ preferences or interests.

You can choose not to allow us to use or your Personally Identifiable Information for direct marketing purposes by indicating your preference at the time of collection, by responding to the promotional email in the manner provided for or by contacting our Privacy Officer at [email protected].  If you have not opted-out of receiving marketing materials, we may also use, but will not disclose, your Personal Information to promote and market additional goods, services and special offers from us and our affiliates. Otherwise, we do not provide your information to third parties for their own direct marketing purposes.  At any time you may “opt out” of future contacts by un-subscribing from our contact list or contacting the Company Privacy Officer at [email protected].

We sometimes use the non-Personally Identifiable Information and Use Information that we collect to improve the design and content of our site and to enable us to personalize your Internet experience, showing you content that we think you might be interested in, and displaying content according to your preferences.  We may use this information in the aggregate (grouped with information from other users) to analyze site usage, as well as to offer you products, programs, or services.  We may also share this non-Personally Identifiable Information and/or Use Information with others, such as advertisers interested in advertising in, in aggregate, anonymous form, which means that the information will not contain any personally identifiable information about you or any other person.

Typically, we will seek consent for the use of your Personal Information at the time of collection.  In certain circumstances, consent may be sought after the information has been collected but before use (for example when we want to use information for a use not previously identified).  The form of consent we seek, including whether it is express or implied, will largely depend on the sensitivity of the information and the reasonable expectations of the individual in the circumstances.  You may withdraw consent at any time, subject to legal and contractual restrictions and reasonable notice.  If you wish to withdraw consent, please contact our Privacy Officer in the manner described below.  We will inform you of the implications of withdrawing consent at or before the time of withdrawal.

We will not, as a condition of the supply of a product or service, require you to consent to the collection, use or disclosure of information beyond that required to fulfill the explicitly specified and required purposes for which the information is being required.

Sharing of Personal Information

Except as described in this Privacy Policy, CC will not disclose your Personal Information to a third party, unless you request or otherwise consent to such disclosure, or disclosure is required or authorized by law.

We do not sell information to third parties.  We may share information with agents, affiliates or service providers who act for or on behalf of CC in connection with the business of CC, or for further processing in accordance with the purpose(s) for which the data were originally collected.  We require our agents, affiliates and service providers to agree in writing to maintain the confidentiality and security of Personal Information they maintain on behalf of CC and not to use it for any purpose other than the purpose for which we retained them.  We also require any third parties we retain to protect Personal Information disclosed by us [in accordance with all applicable state, federal, and foreign privacy requirements and the general privacy principles described in this Privacy Policy].  Your Personal Information may be provided to a courier or freight forwarder in order to fulfill an order you may have requested from us or supply a promotion prize or award.  CC may also share statistical or demographic information in aggregate form with service providers for marketing or research purposes.  This aggregate data will not contain any information that personally identifies you.

Although we make every effort to preserve user privacy, we may need to disclose Personally Identifiable Information in certain limited circumstances, specifically: (1) to comply with a judicial proceeding, a court order, or subpoena, or as otherwise may be required by law; (2) to enforce our policies or contracts, or to collect amounts owed to us; (3) to protect users of our sites and our sites from fraudulent or abusive use; (4) to protect CC’s rights or property (including without limitation in the event of a bankruptcy, merger, acquisition, or transfer of control or assets or other business venture involving CC, or any of the business or assets of CC); (5) during emergencies when safety is at risk, as determined by CC, or (6) otherwise where necessary for the establishment, exercise or defense of legal claims.  The Personally Identifiable Information you provide is considered a company asset and may be included among transferred assets if CC, or any or all of CC’s subsidiaries or affiliates or any of their assets is ever acquired by a third party.  In addition, from time to time, server logs may be reviewed for security purposes; for example, to detect unauthorized activity on the web site.  In such cases, server log data, containing IP addresses, would be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.

Cookies and Other Information Collected Using Technology

When you visit the web site, we may collect some information about you using software or other technology where it may not be readily apparent to you that it is being collected.  When you visit our web site, we place a text file called a “cookie” in the browser directory of your computer’s hard drive.  Cookies are pieces of information that a web site sends to your computer while you are viewing the web site.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies.  If you turn cookies off, you won’t have access to many features that make your experience on our web site more efficient and some of our services will not function properly.

Our websites may also use small pieces of software code called “web beacons” or “clear gifs” to collect anonymous and aggregate advertising matrix, such as counting page views, promotion views, or advertising responses.  These web beacons may be used to deliver cookies that conform with our cookie policy above.

Banner Advertisements and Links to Other Sites

This Privacy Policy applies only to CC and and does not include third-party web sites.  Our site may include banner advertisements or contain links to other sites operated by third parties whose information practices may be different than those at this site.  Other Internet sites you visit may have their own privacy policies or no policy at all.  Other web sites might use Personal Information differently than our policy permits.  CC does not guarantee the standards of any web site not related to this site.  CC is not responsible for the content, practices, or password information practices of the web sites operated by these third parties.  In addition, these banner advertisements and links do not constitute sponsorship, endorsements, or approval by CC of the content, policies, or practices of these web sites.  In the course of serving advertisements to, our third-party advertisers may place or recognize a unique cookie on your browser.

Please note that the privacy policies of affiliates and/or third party web sites may differ from those of CC.  You should carefully review the relevant third party web site’s privacy policy and terms of use in order to understand its policies and practices regarding the collection and use of Personally Identifiable Information before providing any Personal Information.

A Note to Parents/Guardians

CC takes special measures to help maintain and protect the personal privacy of children under 13 years of age for the purposes of complying with the Children’s Online Privacy and Protection Act of 1998 (“COPPA”) in the United States.

The web site is a general audience site that is neither designed nor intended to collect any Personally Identifiable Information from children under the age of 13.

At the web site we have put in to place certain screens to ensure that children under 13 do not submit Personally Identifiable Information, and we do not knowingly accept any information from children under the age of 13.  However, if the parent or legal guardian of a child under 13 believes that the child has provided us with Personally Identifiable Information, the parent or guardian of that child should contact us at [email protected] if they want this information deleted from our files.  If CC otherwise obtains knowledge that it has Personally Identifiable Information about a child under 13 in its files, we will delete that information from out existing files so that it is not in retrievable form.

Data Integrity and Security

We strive to keep any information you provide as secure as possible, and we require our agents, affiliates and service providers to follow the same high standards.  We have implemented technical and organizational measures designed to help secure your Personally Identifiable Information from theft, accidental loss, and from unauthorized access, use, alteration, disclosure or destruction.

CC takes reasonable steps to ensure that data is reliable for its intended use, accurate, complete, and current.

International Visitors

While we operate internationally, the servers that will host, store and process information relating to are currently based in the United States.  Unless otherwise specified, data submitted to will be processed by us in the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world.  By providing Personally Identifiable Information to us you authorize the export of such Personally Identifiable Information to the United States and its storage and use as specified herein, which includes the use of cookies as described above.


CC will maintain Personal Information in accordance with this Privacy Policy.  In the future, we may modify this Privacy Policy.  If we decide to change our Privacy Policy, we will post those changes to this Privacy Policy.  We will use information in accordance with the Privacy Policy under which the information was collected.  However, if we are going to use Personally Identifiable Information in a manner different from that stated at the time of collection we will notify users by email.  Users will have a choice as to whether or not we use their information in this different manner.  If users have opted-out of all communications with the site, or deactivated their account, then they will not be contacted, nor will we use their Personally Identifiable Information in this new manner.

How You Can Access, Control and Update Information About You

We want to be sure that we keep only the most accurate and up-to-date Personal Information in our records.  Therefore, whenever you believe that your Personal Information needs to be updated, you can email us at [email protected] to update your contact information.

You may choose at any time to remove your name, telephone numbers, and postal and email addresses from the lists we use to send notices or updates and elect not to receive correspondence from us by sending us an email at [email protected].

You may contact the Privacy Officer to access or update your Personal Information.  If necessary, the Privacy Officer will contact another employee to assist in completing your requested task.

To protect your privacy, we will take reasonable steps to help verify your identity before granting access or making changes.

Contact Us

If you have any questions or complaints, please contact the Privacy Officer.  The Privacy Officer can be reached by email at: [email protected].

We will address your concern and attempt to resolve any problem. If the Privacy Officer does not satisfactorily address a complaint within thirty (30) days, any dispute, controversy or claim shall be settled by an arbitration administered by the American Arbitration Association (“AAA”).  All arbitrations will be conducted in English. Judgment rendered by the arbitrator may be entered in any court having jurisdiction.  The costs of the arbitration will be borne equally by the parties. New York, New York, U.S.A. shall be the site of all hearings, and such hearings shall be before a single arbitrator.

This Privacy Policy was last updated on April 15, 2009.