Privacy Policy

pops.gourmand.dev

Last Updated: January 10, 2026


1. Introduction and Scope

Pops Technologies, LLC ("Company," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Pops browser extension, website at pops.gourmand.dev, and related services (collectively, the "Service").

This Privacy Policy applies to all users of the Service worldwide, including residents of the European Economic Area ("EEA"), United Kingdom, California, and other U.S. states with comprehensive privacy laws. Jurisdiction-specific rights and disclosures are provided in Sections 11-14.

BY INSTALLING OR USING THE SERVICE, YOU CONSENT TO THE COLLECTION, USE, AND PROCESSING OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICE.


2. Data Controller Information

For purposes of the General Data Protection Regulation ("GDPR") and other applicable data protection laws, the data controller is:

Pops Technologies, LLC
Email: privacy@gourmand.dev
Website: pops.gourmand.dev

2.1 EU/UK Representative

For users in the European Economic Area or United Kingdom, our representative can be contacted at:

Email: gdpr@gourmand.dev

2.2 Data Protection Officer

For data protection inquiries:

Email: dpo@gourmand.dev


3. Information We Collect

We collect information in the following categories:

3.1 Information You Provide Directly

When you create an account or contact us, we may collect:

3.2 Hotel and Travel Data Collected Automatically

When you browse hotel and travel websites with the Service active, we automatically collect data from the pages you view, including:

Important: We only collect hotel data from pages you actively view. We do not crawl, scrape, or collect data from pages you have not visited. All data originates from your direct browsing activity.

3.3 Real User Monitoring (RUM) Data

To improve the Service and learn your preferences, we collect Real User Monitoring data including:

RUM data is used exclusively to understand your preferences and improve recommendations. We do not record keystrokes, form inputs, passwords, or any text you type outside the Service interface.

3.4 Browser Fingerprint Data

⚠️ IMPORTANT DISCLOSURE: We use browser fingerprinting technology to create a unique identifier based on technical characteristics of your browser and device.

This includes:

Unlike cookies, browser fingerprint data cannot be deleted through your browser settings.

This data is used for:

You may withdraw consent for personalization-related fingerprinting through your account settings, which may affect certain Service features. Fingerprinting used for security and fraud prevention cannot be disabled.

3.5 Device and Technical Information

We automatically collect:

3.6 Information from Third Parties

We may receive information from:


4. How We Use Your Information

We use collected information for the following purposes and legal bases:

Purpose Data Used Legal Basis (GDPR)
Providing core Service functionality Hotel viewing data, account info Contract performance (Art. 6(1)(b))
AI preference learning and personalization RUM data, viewing patterns, hotel data Consent (Art. 6(1)(a))
Browser fingerprinting for personalization Browser/device technical data Consent (Art. 6(1)(a))
Browser fingerprinting for security Browser/device technical data Legitimate interest (Art. 6(1)(f))
Fraud prevention and security IP address, fingerprint, usage patterns Legitimate interest (Art. 6(1)(f))
Affiliate commission tracking Click data, booking attribution Legitimate interest (Art. 6(1)(f))
Service improvement and analytics Aggregated usage data Legitimate interest (Art. 6(1)(f))
Customer support Communications, account data Contract performance (Art. 6(1)(b))
Legal compliance As required Legal obligation (Art. 6(1)(c))

4.1 Legitimate Interest Assessment

Where we rely on legitimate interests, we have conducted balancing tests to ensure our interests do not override your fundamental rights. You may request details of these assessments by contacting dpo@gourmand.dev.


5. Artificial Intelligence and Automated Processing

5.1 How AI Processes Your Data

The Service uses artificial intelligence and machine learning to:

5.2 Data Integrity — No Hallucination

Our AI system does not fabricate or "hallucinate" hotel information. All recommendations are based exclusively on real hotel data that you have viewed during your browsing sessions. If information becomes outdated, the Service will indicate when data was last seen.

5.3 Third-Party AI Training Restrictions

We do not permit our AI service providers or subprocessors to use your Inputs or data to train their own AI models. When we use third-party AI services, contractual restrictions prevent them from using your data for their model improvement.

5.4 Your Rights Regarding Automated Decisions (GDPR Article 22)

The recommendations provided by the Service are suggestions to assist your decision-making and do not constitute automated decisions that produce legal effects or similarly significant effects on you. You always retain full control over booking decisions.

However, you have the right to:

To exercise these rights, contact us at privacy@gourmand.dev.


6. Affiliate Marketing Disclosure

💰 IMPORTANT: The Company participates in affiliate marketing programs with hotel booking platforms, online travel agencies, and travel partners. When you click on hotel recommendations or make bookings through links provided by the Service, we may receive compensation from our affiliate partners.

This affiliate relationship means:

We disclose this relationship in compliance with the Federal Trade Commission's Endorsement Guides (16 CFR Part 255).

6.1 Data Shared with Affiliate Partners

We share limited information with affiliate partners:

We do not share your complete browsing history, AI preference profiles, email address, or other personal contact information with affiliate partners.


7. How We Share Your Information

We may share your information with the following categories of recipients:

7.1 Service Providers and Subprocessors

We share data with third-party service providers who perform services on our behalf, including:

Category Purpose Data Shared
Cloud hosting Infrastructure All data (encrypted)
Analytics Usage analysis Aggregated/pseudonymized data
Customer support Support tickets Account and communication data
Email services Notifications Email address, name
Security services Fraud prevention IP, device fingerprint

These providers are contractually obligated as data processors under GDPR Article 28 agreements to:

A list of our current subprocessors is available upon request at privacy@gourmand.dev.

7.2 Affiliate Partners

As described in Section 6.1, we share limited attribution data with affiliate partners.

7.3 Legal Requirements and Law Enforcement

We may disclose your information when required by law or in good faith belief that such action is necessary to:

Law Enforcement Request Procedures: We evaluate all government and law enforcement requests and may challenge requests we believe are overbroad or legally deficient. We will notify affected users of requests for their data unless prohibited by law or court order.

7.4 Business Transfers

In the event of a merger, acquisition, bankruptcy, reorganization, or sale of assets, your information may be transferred to the acquiring entity. We will:

7.5 With Your Consent

We may share your information with third parties when you have given us explicit consent to do so.

7.6 No Sale of Personal Information

We do not sell your personal information to third parties for monetary consideration.

We do not share your personal information for cross-context behavioral advertising.

See Section 13 for specific disclosures regarding California law definitions of "sale" and "sharing."


8. Data Retention

We retain your information for the following periods:

Data Type Retention Period Justification
Account information Until account deletion + 30 days Backup and legal compliance
Hotel viewing history 24 months from viewing Service functionality
AI preference models Until deletion/opt-out + 30 days Service improvement
RUM session data 90 days (identifiable) Product analytics
RUM session data 2 years (aggregated) Long-term analytics
Browser fingerprint 12 months from last activity Security and fraud prevention
Server/access logs 90 days Security and debugging
Support communications 3 years Legal compliance
Affiliate attribution 2 years Partner reconciliation

8.1 Retention After Account Deletion

When you delete your account:


9. Data Security

We implement appropriate technical and organizational measures to protect your information:

9.1 Technical Measures

9.2 Organizational Measures

9.3 Data Breach Notification

In the event of a personal data breach that poses a risk to your rights and freedoms:

No method of transmission or storage is 100% secure. We cannot guarantee absolute security of your data.


10. International Data Transfers

Your information may be transferred to and processed in countries outside your country of residence, including the United States.

10.1 Transfer Mechanisms

When we transfer data from the EEA, UK, or Switzerland, we ensure appropriate safeguards:

10.2 Transfer Impact Assessments

We conduct transfer impact assessments to evaluate the legal framework of destination countries and implement supplementary measures where necessary.

You may request a copy of the transfer safeguards we use by contacting privacy@gourmand.dev.


11. Your Rights Under GDPR (EEA and UK Residents)

If you are located in the European Economic Area or United Kingdom, you have the following rights:

Right Description How to Exercise
Access (Art. 15) Obtain a copy of your personal data Email privacy@gourmand.dev
Rectification (Art. 16) Correct inaccurate or incomplete data Account settings or email
Erasure (Art. 17) Request deletion ("right to be forgotten") Account settings or email
Restriction (Art. 18) Limit processing in certain circumstances Email privacy@gourmand.dev
Portability (Art. 20) Receive data in machine-readable format Email privacy@gourmand.dev
Object (Art. 21) Object to processing based on legitimate interests Email privacy@gourmand.dev
Withdraw Consent Withdraw consent at any time Account settings or email
Automated Decisions (Art. 22) Not be subject to solely automated decisions Email privacy@gourmand.dev

11.1 How to Exercise Your Rights

11.2 Right to Lodge a Complaint

You have the right to lodge a complaint with your local supervisory authority. A list of EEA supervisory authorities is available at: https://edpb.europa.eu/about-edpb/board/members_en

For UK residents: Information Commissioner's Office (ICO) at https://ico.org.uk


12. Global Privacy Control and Do Not Track

12.1 Global Privacy Control (GPC)

We recognize and honor the Global Privacy Control (GPC) signal.

When we detect a valid GPC signal from your browser or device, we will automatically treat it as:

You can enable GPC in supporting browsers or through browser extensions. Learn more at https://globalprivacycontrol.org

12.2 Do Not Track (DNT)

We also recognize Do Not Track browser signals. When we detect a DNT signal, we will limit non-essential tracking to the extent technically feasible.


13. Your Rights Under CCPA/CPRA (California Residents)

If you are a California resident, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) provides you with specific rights.

13.1 Right to Know

You have the right to request disclosure of:

13.2 Right to Delete

You have the right to request deletion of your personal information, subject to certain exceptions (legal obligations, security, completing transactions).

13.3 Right to Correct

You have the right to request correction of inaccurate personal information.

13.4 Right to Opt-Out of Sale/Sharing

We do not "sell" personal information for monetary consideration.

We may "share" personal information with affiliate partners for attribution purposes, which may constitute "sharing" under CCPA. You may opt out by:

13.5 Right to Limit Use of Sensitive Personal Information

We do not use sensitive personal information for purposes beyond those permitted under CCPA.

13.6 Right to Non-Discrimination

We will not discriminate against you for exercising your CCPA rights. However, opting out of certain processing may affect Service functionality.

13.7 Categories of Personal Information Collected

In the preceding 12 months, we have collected:

CCPA Category Examples Sold? Shared?
Identifiers Email, IP address, device IDs, fingerprint No Limited (attribution)
Commercial information Hotel viewing history No No
Internet activity Browsing on travel sites, clicks, RUM data No No
Geolocation Approximate location from IP No No
Inferences AI-derived preferences No No

13.8 How to Submit a Request


14. Additional U.S. State Privacy Rights

We comply with comprehensive privacy laws in the following states. Residents of these states have rights similar to those described in Section 13:

14.1 Virginia (VCDPA)

Virginia residents have rights to access, correct, delete, obtain a copy, and opt out of targeted advertising, sale, and profiling. Appeal requests can be submitted to privacy@gourmand.dev within 45 days of denial.

14.2 Colorado (CPA)

Colorado residents have rights to access, correct, delete, obtain a copy, and opt out of targeted advertising, sale, and profiling. We honor universal opt-out mechanisms including GPC.

14.3 Connecticut (CTDPA)

Connecticut residents have rights to access, correct, delete, obtain a copy, and opt out of targeted advertising, sale, and profiling.

14.4 Utah (UCPA)

Utah residents have rights to access, delete, and obtain a copy, and to opt out of targeted advertising and sale.

14.5 Other States

We monitor privacy legislation and will update this policy as new state laws take effect, including laws in Oregon, Texas, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, and others.

14.6 Appeal Process

If we deny your privacy request, you may appeal by:

If your appeal is denied, you may contact your state's Attorney General.


15. Cookies and Tracking Technologies

15.1 Types of Technologies Used

Technology Purpose Duration
Essential cookies Authentication, security Session
Preference cookies Remember settings 1 year
Analytics cookies Usage statistics 2 years
Browser fingerprinting Security, personalization 12 months

15.2 Managing Cookies

You can control cookies through:

Note: Disabling cookies may affect Service functionality.

15.3 Browser Fingerprinting

For browser fingerprinting, use the opt-out mechanism in your account settings. Security-related fingerprinting cannot be disabled.


16. Children's Privacy

The Service is not intended for users under the age of 18.

We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will:

If you believe we have collected information from a child, please contact us immediately at privacy@gourmand.dev.


17. Third-Party Links

The Service may contain links to third-party websites. We are not responsible for the privacy practices of these websites. We encourage you to read the privacy policies of any third-party sites you visit.


18. Changes to This Privacy Policy

We may update this Privacy Policy periodically. We will notify you of material changes by:

Your continued use of the Service after the effective date constitutes acceptance of the updated policy. If you do not agree, you must discontinue use before the effective date.


19. Contact Us

If you have questions about this Privacy Policy, your personal data, or wish to exercise your rights:

Purpose Contact
General privacy inquiries privacy@gourmand.dev
GDPR/EU inquiries gdpr@gourmand.dev
Data Protection Officer dpo@gourmand.dev
CCPA/California requests ccpa@gourmand.dev
Other U.S. state requests privacy@gourmand.dev
Website pops.gourmand.dev

Response Times:

If you are unsatisfied with our response, you may lodge a complaint with your local data protection authority or state Attorney General.


20. Acknowledgment

BY USING THE SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY AND AGREE TO THE COLLECTION, USE, AND PROCESSING OF YOUR INFORMATION AS DESCRIBED HEREIN.

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