Who we are and what this policy covers
This policy explains how Oasis Travel Network collects, uses, shares and protects personal information.
Oasis Travel Network (“OTN,” “we,” “us”) is a d/b/a of Smolinski & Associates, Inc., a Florida corporation headquartered in Boca Raton, Florida. Palm Coast Travel is a d/b/a of the same corporation, and insurance products are offered under that name. This policy covers both.
It covers personal information we handle about three groups:
- Visitors to oasistravelnetwork.com, members.oasistravelnetwork.com and our other websites and online forms.
- Member travel advisors and applicants — the independent advisors and agencies affiliated with our host agency network, and people who apply to join.
- Travelers whose information reaches us because a member advisor booked their travel through our systems.
It does not cover:
- The privacy practices of travel suppliers, consortium partners or any other third party, including sites we link to. Each has its own policy.
- Personal information a member advisor collects and holds in their own systems. On that information the advisor is responsible for their own privacy practices, and we handle it only as described below.
- Employee and job applicant information, which is handled under separate internal notices.
Information we collect
We collect four kinds of information, from four sources.
Information you give us directly. Your name, business and personal mailing address, email address, telephone number, and — if you apply to join our network or register for an event — information about your agency, your travel sales experience, professional credentials and licenses, and your travel preferences for events we host. If you contact us, we keep the content of that correspondence.
Information we need to pay you or bill you. For member advisors, the banking or payment details required to remit commissions, and the tax identification information required to issue tax forms. For plan fees and event registrations, billing address and payment card details, which are entered into and held by our payment processors rather than by us.
Information created by your use of our sites and systems. IP address, browser type and version, device and operating system, the pages you view, the links you follow, the dates and times of your visits, and referring URLs. For member advisors, log and activity records from the booking, CRM and commission systems we provide.
Information from member bookings and from suppliers. When a member advisor books travel through our systems, we receive traveler names, contact details, travel dates and itineraries, booking and confirmation numbers, supplier and commission records, and — where a supplier or insurer requires it — dates of birth, and passport or other travel document details. Suppliers, insurers and our consortium send us booking, commission, override and marketing-program records that include this same category of information.
We do not ask for, and ask that you not send us, Social Security numbers or government identification numbers except where a tax form or an insurance license filing requires one.
How we use information
We use personal information to run the host agency and for no unrelated purpose.
- To provide our services. Enrolling and supporting member advisors, operating the booking, CRM, website and commission systems we make available to them, and answering questions from advisors and travelers.
- To process bookings and pay commissions. Transmitting reservations to suppliers, tracking commission due, reconciling supplier payments and remitting commissions to advisors.
- To administer membership. Billing plan fees, verifying production against plan requirements, and administering incentive programs such as the Chairman’s Club.
- To report to suppliers and our consortium. Reporting sales production, booking activity and program participation as our supplier and consortium agreements require. This reporting is ordinarily aggregated or identified at the agency or advisor level.
- To run conferences, events and training. Managing registration, travel arrangements and communications for events we host.
- To communicate with you. Sending service messages, program announcements, supplier offers, newsletters and marketing. You can opt out of marketing at any time; service and account messages continue.
- To advertise our services. Measuring how our advertising performs, and showing advertisements for OTN to people who have visited our sites, through Google Ads and similar services.
- To improve and secure our sites and systems. Analyzing usage, diagnosing problems, preventing fraud and unauthorized access, and maintaining backups.
- To meet legal and regulatory obligations. Tax reporting, insurance licensing, seller-of-travel registration, recordkeeping, responding to lawful requests, and establishing or defending legal claims.
We do not sell personal information for money. We do use advertising services that, under California law and several other state privacy laws, count as “sharing” personal information for cross-context behavioral advertising. You can opt out at any time — see Opting out of advertising below.
How we share information
We do not sell personal information for money. We disclose it in six situations, and no others.
Service providers acting on our instructions
Like most businesses, we do not run every system ourselves. We use service providers and vendors that process personal information on our behalf, on our instructions, and only to provide services to us. These include providers of:
- Website hosting, content delivery and website security
- Customer relationship management, booking, commission and accounting systems
- Email delivery, newsletters and event registration
- Payment processing and banking services
- Data storage, file sharing and backup
- Analytics, telephony and IT support
- AI-assisted document processing and business analysis, described below
We require these providers by contract to protect the information, to use it only for the services they perform for us, and not to sell it or use it for their own purposes.
AI-assisted processing
We use artificial intelligence tools to help process business documents and correspondence — for example, reading supplier statements and commission reports, organizing records, drafting communications and preparing internal analysis. Business documents handled this way may contain personal information such as names, contact details and booking or commission records.
These tools are provided under contract, process information on our instructions, and are not permitted to use our information to train their general models. We do not use AI tools to make decisions that produce legal or similarly significant effects about any individual without human review.
Advertising and measurement partners
We advertise Oasis Travel Network online. To do that our websites pass limited information to Google — an advertising cookie identifier, the pages you viewed, and whether you completed an action such as submitting a form.
Google uses that information to measure how our advertising performs and, where ads personalization is enabled, to show OTN advertisements to people who have visited our sites while they browse other websites and apps. Under California law and several other state privacy laws this counts as sharing personal information for cross-context behavioral advertising, even though we receive no money for it. It is not a sale.
You can stop it at any time. See Opting out of advertising below.
Travel suppliers, insurers and our consortium
To make and service a booking, we transmit the traveler information the supplier requires — typically name, contact details, travel dates, and where the supplier requires it, date of birth and travel document details. We also report sales production and program participation to suppliers, insurers and Signature Travel Network as our agreements require. Once a supplier receives this information it handles it under its own privacy policy.
Member advisors and their agencies
A member advisor sees the booking, traveler and commission records associated with their own bookings and, where an agency has associates, the records rolling up to that agency.
Legal, safety and business transfers
We disclose personal information when we believe in good faith that it is required by law, subpoena or other legal process; to protect the rights, property or safety of OTN, our members, travelers or the public; to our attorneys, accountants, auditors and insurers under professional duties of confidentiality; and, if OTN is involved in a merger, acquisition, financing or sale of assets, to the parties involved in that transaction, subject to confidentiality protections.
We may also publish or share aggregated or de-identified statistics — such as total network sales or booking volume by supplier — that do not identify any individual.
Cookies, analytics and tracking
Our websites use cookies and similar technologies. A cookie is a small file a website places on your device so it can recognize your browser on a later visit.
We use them for four purposes:
| Type | What it does |
|---|---|
| Strictly necessary | Keeps you signed in to member areas, remembers form entries, and protects against fraud and abuse. The sites do not work properly without these. |
| Preference | Remembers choices such as language or a dismissed notice. |
| Analytics | Counts visits and measures which pages and links are used, so we can improve the sites. |
| Advertising | Measures whether an advertisement led to a visit or an inquiry, and allows OTN advertisements to be shown to past visitors on other websites. Set by Google. |
Most browsers let you refuse or delete cookies through their settings. Blocking strictly necessary cookies will break parts of the member area.
We do not build advertising profiles ourselves, and we do not allow third parties to collect information on our sites for their own independent purposes. We do use Google’s advertising and measurement cookies, as described under Opting out of advertising. Our Cookie Policy lists every cookie we set by name, purpose and duration.
Our sites honor the Global Privacy Control (GPC) signal. If your browser or a browser extension sends one, we treat it as a valid request to opt out of sharing for targeted advertising: advertising cookies stay switched off for that browser, and we do not ask you to consent to them. You do not need to sign in or identify yourself. We do not respond to browser Do Not Track headers, which have no agreed standard.
Retention and security
How long we keep information. We keep personal information for as long as we need it for the purpose it was collected, and then for as long as required by law or by our supplier, tax and insurance obligations. In practice:
| Record | Kept for |
|---|---|
| Booking, commission and accounting records | At least seven years after the transaction, for tax, audit and supplier reconciliation |
| Member advisor and agency records | For the term of the membership and at least seven years afterward |
| Marketing contact records | Until you unsubscribe, and then only the minimum needed to honor the opt-out |
| Website analytics and server logs | Generally no more than 24 months |
| Applicant records for advisors who do not join | Generally no more than 24 months |
How we protect it. We use encryption in transit for our websites and member systems, access controls that limit staff and contractor access to what their role requires, unique credentials and multi-factor authentication on our core business systems, and contractual security obligations on our service providers.
No method of transmitting or storing information is completely secure, and we cannot guarantee absolute security. If we become aware of a breach affecting your personal information, we will notify you and the appropriate authorities as the law requires.
Your choices and privacy rights
Everyone
Marketing email. Click the unsubscribe link in any marketing email, email support@oasistravelnetwork.com, or call (800) 613-8380. Service and account messages are not marketing and continue while your account is active.
Correcting your information. Member advisors can update their profile in the member systems. Anyone else can email us and we will correct what we hold.
Cookies. Use your browser settings, as described above.
Opting out of advertising
You can opt out of sharing for targeted advertising in any of these ways. You do not have to live in a particular state to use them.
- Use the Do Not Sell or Share My Personal Information link in the footer of any page on our sites.
- Turn off the advertising category in our cookie banner, which you can reopen at any time from the Cookie Policy page.
- Turn on Global Privacy Control in your browser or with a browser extension. We honor it automatically.
- Email support@oasistravelnetwork.com with “Do Not Share” in the subject line.
Opting out does not stop you seeing advertising. It stops that advertising being selected based on your activity across other sites. It does not affect your membership, your bookings, or the price of anything.
Residents of states with comprehensive privacy laws
Several states give residents rights over their personal information. Where a state law applies to us and to you, you have the right to:
- Confirm whether we process your personal information and obtain a copy of it
- Correct inaccurate personal information
- Request deletion of personal information, subject to our legal and recordkeeping obligations
- Obtain a portable copy of information you provided to us
- Opt out of the sale of personal information (we do not sell it), of sharing for targeted advertising (we do share — see Opting out of advertising), and of profiling that produces legal or similarly significant effects (we do not profile)
- Be free from discrimination for exercising these rights
California residents additionally have the right to know the categories of personal information collected, the sources, the business purposes, and the categories of third parties to which it is disclosed. Those categories are set out in the sections above. In the preceding 12 months we shared one category — internet or other electronic network activity, meaning advertising cookie identifiers, pages viewed and actions taken on our sites — with Google for cross-context behavioral advertising. We did not sell personal information, and we did not share the personal information of anyone we know to be under 16. California residents may also limit the use of sensitive personal information; we use sensitive information only to provide our services and as permitted without a right to limit.
How to make a request. Email support@oasistravelnetwork.com with “Privacy Request” in the subject line, or write to the address below. We will verify your identity before acting, usually by confirming details already in our records, and will respond within 45 days. We may extend that once by a further 45 days and will tell you if we do.
Authorized agents. You may use an authorized agent. We will ask for written authorization and will still verify your identity directly.
Appeals. If we decline a request, you may appeal by replying to our decision or writing to the address below with “Privacy Appeal” in the subject line. We will respond within 45 days with our decision and the reasons for it. If we deny the appeal, you may complain to your state attorney general.
Children, other websites, and changes to this policy
Children. Our websites and services are for travel professionals and adult travelers. We do not knowingly collect personal information from children under 13, and we do not knowingly sell or share the personal information of anyone under 16. A member advisor booking family travel may give us a minor traveler’s name and date of birth because the supplier requires it; we use that information only to make and service the booking. If you believe we hold a child’s information collected without a parent’s involvement, contact us and we will delete it.
Other websites. Our sites link to supplier websites, booking engines, consortium resources and other third-party services. We do not control those sites and are not responsible for their privacy practices. Read their policies before giving them information.
Information outside the United States. We are based in the United States and our systems are operated here. Some of our service providers and contractors, including staff in Poland, may access information from outside the United States under contractual protections. If you use our services from outside the United States, you understand that your information will be processed in the United States, where privacy laws may differ from those of your country.
Changes to this policy. We may update this policy. We will post the revised policy here with a new effective date, and if the changes are material we will notify member advisors by email before they take effect. Continued use of our sites and services after a change means you accept the revised policy.
How to contact us
For any question about this policy, or to make a privacy request:
Oasis Travel NetworkA d/b/a of Smolinski & Associates, Inc.
5030 Champion Blvd., Ste. G11 #302
Boca Raton, FL 33496
Email: support@oasistravelnetwork.com
Phone: (800) 613-8380