DATA PROTECTION & PRIVACY NOTICE

The data privacy regulations of some countries require that a person making a report containing personal data must be notified of certain collection and retention practices regarding information submitted through this system, as well as certain terms and conditions regarding the information submitted by that person.

Please review the terms contained below before submitting any information through this system.

1. General

   This service is a web and phone-based intake system provided by Booking Holdings Inc. of companies, with its global headquarters at 800 Connecticut Avenue, Norwalk, Connecticut, 06854, USA ("Booking Holdings Inc.") to its employees, vendors, suppliers and business partners (“Reporters”) for reporting suspected violations of laws or regulations, or company policies related to financial, accounting, auditing and bribery matters.

   For more information click here.

   In certain countries, such as the United States, this service may also be used to report suspected violations of other matters. It and the database in which the personal data and information that you may report is stored, are operated by NAVEX Global, Inc. in the United States.

   You may contact Booking Holdings Inc. with any questions relating to this Notice or this service as follows: bookingholdingscompliance@bookingholdings.com

2. Use of This Service

   Use of this service is entirely voluntary. You are encouraged to report possible violations directly to your supervisor or manager, a representative from HR, Legal or Compliance, depending on the nature of the possible violation. If you feel that you are unable to do so, you may use this service to make your report.

   For more information click here.

   In certain countries, Booking Holdings Inc. may only accept reports through this service that relate to financial, accounting, auditing or bribery matters. If your concern pertains to a matter that, under local law, may not be accepted by Booking Holdings Inc. through the system, you will need to contact a representative from HR, Legal or Compliance to report the matter.

   Please be aware that the information you supply about yourself, your colleagues, or any aspect of the company’s operations may result in decisions that affect others. Therefore, we ask that you only provide information that, to the best of your knowledge, is correct and factual. You will not be subject to retaliation from Booking Holdings Inc. for any report of a suspected legal or compliance violation that is made in good faith, even if it later turns out to be incorrect. Please be aware, however, that knowingly providing false or misleading information will not be tolerated. The information you submit will be treated confidentially except in cases where this is not possible because of legal requirements or in order to conduct a proper investigation, in which case the information will be handled sensitively. We encourage you to identify yourself in order for us to follow up with questions we may have.

3. What personal data and information is collected and processed?

   This service captures the following personal data and information that may be shared by you: (i) your name, your contact details and whether you are employed by Booking Holdings Inc.; (ii) the name and other personal data of the persons you name in your report if you provide such information (i.e., description of functions and contact details); and (iii) a description of the alleged misconduct as well as a description of the circumstances of the incident. Note that depending upon the laws of the country in which you are residing, the report may not be made anonymously; however, your personal data will be treated confidentially and will only be disclosed as set out below.

4. How will the personal data and information be processed after your report and who may access personal data and information?

   The personal data and information you provide will be stored in a database which is located on servers hosted and operated by NAVEX Global, Inc. in the United States. NAVEX Global and Booking Holdings Inc. have implemented other appropriate cross-border transfer solutions, such as Standard Contractual Clauses, to provide adequate protection for transfers of personal data and information where required by applicable law.

   For more information click here.

   For the purpose of processing your report and subject to the provisions of local law, the personal data and information you provide may be accessed, processed and used by the relevant personnel of Booking Holdings Inc., including Human Resources, Finance, Internal Audit, Legal, Security, Compliance, management, external advisors (e.g., legal advisors), or, in limited circumstances, by technical staff at NAVEX Global, Inc. Those individuals may be located in the United States or elsewhere.

   Personal data and information you provide may also be disclosed to the police and/or other enforcement or regulatory authorities. The relevant bodies that receive and process personal data can be located in the US or in another country that may not provide a level of data protection as available in the EU.

   The personal data you provide will be kept as long as necessary to process your report, or, if applicable, as long as necessary to initiate sanctions or if the data needs to be kept for legal reasons. Otherwise data will be deleted within a limited timeframe after closing the report or immediately in the event the report falls outside the scope of this service.

5. Rights of Report Subjects and Reporters

   Booking Holdings Inc. will promptly notify any person who is the subject of a report to this service except where notice needs to be delayed to ensure preservation of relevant information.

   For more information click here.

   The subject of the report has the right to access information concerning the report (with the exception of the identity of the complainant) and to request correction of personal data that is inaccurate or incomplete in accordance with applicable law. The notice will inform the subject of a report on how to exercise these rights.

   Reporters also have the right to access information about them and to request corrections in accordance with applicable law. To exercise these rights, please contact a representative from HR, Legal or Compliance.

6. Special Country Regulations

   Throughout much of the European Union and surrounding areas, reports can only be made relating to bribery, financial, accounting and auditing matters or similar issues. Further, some countries restrict reports such that only employees in key or management functions may be reported upon.

   For more information click here.

   Austria
   Reports can only be made relating to bribery, financial, accounting and auditing matters. Additionally, only employees in key or management functions may be reported upon. Any issues or concerns relating to competition law, conflict of interest, securities law, employment conditions or other improper conduct that could affect Booking Holdings Inc. should be reported directly to your supervisor or manager, or a representative from HR, Legal or Compliance.

   Netherlands
   Reports can only be made relating to bribery, financial, accounting and auditing matters. Any issues or concerns relating to competition law, conflict of interest, securities law, employment conditions or other improper conduct that could affect Booking Holdings Inc. should be reported directly to your supervisor or manager, or a representative from HR, Legal or Compliance.

   Portugal
   Anonymous reports are not permitted under the law and reports can only be made relating to bribery, financial, accounting and auditing matters. Additionally, only employees in key or management functions may be reported upon. Any issues or concerns relating to competition law, conflict of interest, securities law, employment conditions or other improper conduct that could affect Booking Holdings Inc. should be reported directly to your supervisor or manager, or a representative from HR, Legal or Compliance.

   Spain
   Anonymous reports are not permitted under the law and reports can only be made relating to bribery, financial, accounting and auditing matters. Any issues or concerns relating to competition law, conflict of interest, securities law, employment conditions or other improper conduct that could affect Booking Holdings Inc. should be reported directly to your supervisor or manager, or a representative from HR, Legal or Compliance.

Any issues or concerns relating to topics not permissible to be reported via this service should be reported directly to your supervisor or manager or a representative of HR, Legal or Compliance, depending on the nature of the possible violation. In some countries, anonymous reports may not be permitted under the law save under extremely restrictive circumstances.

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We are able to receive and process reports only if you confirm that you have read and taken note of this Data Protection and Privacy Notice and expressly consent to the processing of the reports and your personal data as described above by clicking the I CONSENT box. To proceed further, you must read this notice in its entirety, and if you agree, check the I CONSENT box that follows. If you do not consent then you may not use this service to file a report and should contact a representative from HR, Legal or Compliance.

I CONSENT
I have read and expressly consent to the processing of my personal data as described in sections 3 and 4 above.

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