Privacy Policy

Privacy Policy

Updated May 1, 2018

Your privacy is important to Us. To better protect your privacy We provide this notice explaining Our online information practices and the choices you can make about the way your information is collected and used. To make this notice easy to find, We make it available on Our homepage and from every internal Webpage in the footer. The notice describes the principles and practices that apply to the Personal Information collected from the Users of Our services via Our Web site, telephone or e-mail communications, or other surveys and interactions.

This Privacy Policy applies to the Web site


“Disclose” means to release, transfer, disseminate, or otherwise communicate all or any part of any record orally, in writing, or by electronic or any other means to any person or entity.

“User” means an individual who has registered or who has provided personal information with the Web site.

“Minor” means any individual under 18 years of age, or as defined under the laws of their jurisdiction or residence.

“Personal Information” means any recorded information about specific individual whose identity may be inferred from the information. This information includes, for example, name, e-mail and mailing address, phone number, account and billing information, and other information provided by a visitor to Our Web site or incidental to providing products and services to you.

“Web site” means

“We”, “Us” or “Our” means ATLA Group, Ltd. (Doing Business As [d.b.a.] “Havana VIP” and/or the “Havana VIP Tours”).


By submitting Personal Information to Us or Our Web site, you agree that We may collect, use and Disclose such Personal Information in accordance with this Privacy Policy and as permitted or required by law.

If you do not agree with these terms, do not provide any Personal Information to Us. If you choose to refuse or withdraw your consent, we may not be able to provide you with services normally offered by Us.

We do not sell or market products to Minors. Minors are not eligible to register with, use or purchase services via the Web site . We do not knowingly collect Personal Information from any Minor, and will not deliberately use such information. If you are under 18, you may use the Web site only with the involvement of a parent or guardian.

If you provide Personal Information regarding any third party, including parties traveling or vacationing with you, you must obtain consent prior to your disclosure of this information. By providing Personal Information of any third party, you represent that you have all necessary authority and/or have obtained all necessary consents from such person to allow Our collection of Personal Information as set forth in this Privacy Policy.

Personal Information We Collect

We only collect Personal Information that you voluntarily provide to Us, or that is incidental to your use of Our services. The information We learn helps Us personalize and continually improve your experience with Us, and assists Us in providing for your travel needs. Here are the types of information We gather:

  • Information You Give Us: We receive and store any information you enter on Our Web site or give Us in any other way. You can choose not to provide certain information, but then you might not be able to take advantage of many of Our features. We use the information that you provide for such purposes as responding to your requests, customizing future travel for you, improving Our Web site and communicating with you. Such information may include service and purchase information, User and billing information, when you call or write to Our Customer Service and other volunteered information.
  • Automatic Information: We receive and store certain types of information whenever you interact with Us. For example, like many Web sites, We use “cookies,” and We obtain certain types of information when your Web browser accesses the Web site. Such information may include login information, browsing history, preferences and other personalization information.
  • E-mail Communications: We may retain copies of Our e-mail correspondence, or if you have received and opened correspondence.
  • Incidental Information: We may collect information incidental to your visit of the Web site or purchase of products or services. Such information may include when you have visited the Web site.

How We Use Personal Information

We use your Personal Information for the purposes of responding to and processing your requests for Our products and services:

  • To record your travel preferences, to provide travel quotes, or make travel reservations on your behalf or to communicate with you about your travel plans;
  • To process and track your transactions;
  • To issue invoices, administer accounts, and collect and process product and services payments;
  • To personalize the service We provide to you, tailor your experience at Our Web site to your interests and make more appropriate travel recommendations;
  • To manage Our Web site, diagnose technical problems, improve content and allocate the resources of Our systems so that your experience with Our Web site is as efficient as possible;
  • To process and track your transactions and to send you information about Our products and services and other information and materials that may be of interest to you;
  • To develop, enhance, market, sell or provide Our products or services;
  • To audit compliance with Our policies and contractual obligations;
  • As permitted by, and to comply with, any legal or regulatory requirements or provisions; or for any other purpose to which you consent.

We are required to collect Passport identification numbers and photocopies of our customers’ passports to plan and book travel as required for compliance with regulations governing travel to Cuba by the U.S. Department of the Treasury, Office of Foreign Asset Control (OFAC). Any such information is kept and maintained in accordance with Section III below.

  1. We do not at any time collect or record Our customers’ credit card numbers. We never interact with our customers’ credit card numbers in any way. Our customers make credit card payments to Us by providing their own credit card information directly to our third party credit card service provider, currently Square.
  2. We retain digital and physical photocopies of Our customers’ payments made to us by check. We retain such photocopies for no less than five (5) years as required for compliance with regulations governing financial transactions regarding travel to Cuba by the U.S. Department of the Treasury, Office of Foreign Asset Control (OFAC).
  3. We maintain Our digital records in encrypted format on storage devices at Our location of business, and on servers leased by Us from Amazon Web Services, and Dropbox, Inc. Amazon Web Services and Dropbox, Inc are solely and severally responsible for the maintenance and security of their servers. We accept no liability whatsoever for any security failure by Amazon Web Services or Dropbox, Inc that causes your personal information to be made public.

To Whom We Disclose Personal Information

Information about Our customers is a requirement of Our business, but We are not in the business of selling it to others. We will only share your Personal Information with Our authorized service providers that perform services or functions on Our behalf, when required by law, or as described below.

From time to time, We may Disclose Personal Information as follows:

  • To those travel service providers with which We have or may make arrangements for Our customers’ travel. For example, airlines, cruise lines, tour operators, wholesalers, travel agents and agencies, hotel or ground transport, attraction and travel insurance companies. We provide them only with the Personal Information needed to prepare your travel.
  • To protect Our Web site and Our rights under Our Travel Terms and Conditions and Legal Information; to protect Ourselves against liability or prevent fraudulent activity; or where it is necessary to permit Us to pursue available remedies or limit any damages that We may sustain.
  • Where the information is public.

How We Retain Personal Information

If you provide Us with your information via Our Web site, We will retain your Personal Information in Our database record in accordance with Our records management policy and applicable laws. This record consists of address and contact information, travel preferences, reservation and booking information and a messaging section for communications between you and Us.

While this information may be periodically purged, the retention period may extend beyond the end of your relationship with Us. We may also need to retain certain information to prevent fraudulent activity; to protect Ourselves against liability, permit Us to pursue available remedies or limit any damages that We may sustain; or if We believe in good faith that a law, regulation, rule or guideline requires it.

Your Personal Information will be stored in secured locations and on servers controlled by Us, located either at Our offices or at the offices of service providers.

How You Can Control the Use of Your Information

As discussed above, you can always choose not to provide Personal Information. Guest browsing is available on the Web site, even though Personal Information might be needed to make a purchase or to take advantage of certain services.

We provide you with choice and control over the collection and use of your Personal Information, as well as a means of updating, correcting, or removing any Personal Information stored in your database record.

This Web site uses third-party cookies or pixels (transparent image files) to track Our online advertising activity and your response to it, allowing Us to tailor offers and information to your interests. This technology also allows Our advertising partners to recognize a unique cookie on your Web browser, which in turn enables Us to learn which advertisements bring users to Our website. Data collected from these cookies, or pixels, is anonymous and not personally identifiable. It does not contain your name, address, telephone number, or e-mail address. The cookies We use do not detect any information that is stored on your computer.

Most Web browsers automatically accept cookies, and typically, you can adjust browser settings to control the use of cookies. To access this control use your browser toolbar and reference the “help” section, or visit one of the many websites dedicated to cookie education to learn more.

We currently do not publish any email newsletter, nor do we have plans to do so in the future.

How We Protect Your Information

To protect the confidentiality of your Personal Information, We employ physical, administrative, and technical safeguards to help protect the confidentiality and integrity of the information and to reduce the risk of loss, misuse, unauthorized access disclosure or modification of Personal Information.

Changes to the Privacy Policy

By providing you with this Privacy Policy Statement, We pledge Our continued commitment to protecting the information you provide Us. We regularly examine Our information privacy practices to determine whether We are adhering to the disclosures about the collection, use, sharing, and protection of your Personal Information made in this Privacy Policy statement.

We may change or supplement this Privacy Policy from time to time. We may also undergo a change of ownership. Privacy Policy changes will apply to the information collected from the date We post the revised Privacy Policy to the website, as well as to existing information held by Us.

If We decide to change this Privacy Policy in a material way, We will obtain the necessary consents required under applicable privacy laws if We seek to collect, use or disclose Personal Information for purposes materially different than those to which consent has been obtained, unless otherwise required or permitted by law. If any proposed change is unacceptable to you, you may request that We remove your Personal Information from Our records, as described above.


We share your concerns over privacy disputes. Your visit and any dispute over privacy is subject to this Notice and Our Travel Terms and Conditions, including any limitations on damages, resolution of disputes, and application of the law of the Commonwealth of Pennsylvania. If you have questions or concerns regarding Our privacy practices, you can contact Us. We will investigate and attempt to resolve complaints regarding violations of its published Privacy Policy directly with the complainant. In the event that the complaint cannot be resolved internally, the complainant shall submit the matter to binding arbitration before the American Arbitration Association in Philadelphia, Pennsylvania.

California Privacy Rights

Under California Law, California residents have the right to request in writing from a business, (a) a list of the categories of personal information, such as name, address, e-mail address, and the type of services provided to the customer, that a business has disclosed to third parties (including Independent Affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (b) the names and addresses of all such third parties. To request the above information, please contact us by contacting our Customer Care department at
We will respond to such written requests within 30 days following receipt at the e-mail or mailing address stated above. If we receive your request at a different e-mail or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received. Please note that we are only required to respond to each customer once per calendar year.

Contact Information

If you have any questions or concerns about access to Personal Information, the collection, use, management or disclosure of Personal Information, this Privacy Policy or Our information handling practices, with whom your Personal Information is shared, or if you need further assistance with respect to Our Privacy Policy, you may contact Us as indicated below. We will attempt to respond to your questions or concerns promptly after We receive them.

ATLA Group, Ltd
2130 Arch Street, Suite 101
Philadelphia, PA 19103
Telephone Number:  914-999-2822
Email Address:

Updated May 1, 2018

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