INTERNET PRIVACY POLICY – COMMITMENT TO YOUR PRIVACY

Last Updated: May 25, 2018

Travel and Transport, Inc. and its wholly-owned subsidiaries, Ultramar Travel Management, Inc. d/b/a Travel and Transport Ultramar, Statesman Travel Limited d/b/a Travel and Transport Statesman, Travel and Transport France SAS, Travel Design Lounge and Data Visualization Intelligence, Inc. (collectively, "Travel and Transport", "we", "our", or "us") know that you care how information about you is used and shared, and we are committed to protecting your privacy through our compliance with this policy. This policy describes our practices in connection with personal information we collect through our domestic and international websites (collectively, our "Sites") and through our web-based and mobile software applications and services (collectively, our "Applications").

Please review this policy carefully and in its entirety to understand our policies and practices regarding the collection of personal information about you, whether via our Sites, our Applications or from other sources, and how we will treat such personal information. 

INFORMATION WE COLLECT

In order to provide our services, Travel and Transport may collect, use and disclose your information, including your personal data.  Personal data is any information that can be used to identify you or that we can link to you. You may be asked to provide certain information when you use our services; however, you do have choices about the data we collect.  When you are asked to provide personal data, you may decline, but if you choose not to provide data that is necessary to provide the services or a particular product or feature, you may not be able to receive the services or use that product or feature.  The data we collect can include the following:

  • Names and contact information (e.g., telephone number, fax number, e-mail address);
  • Travel information (e.g., passport number, visa, driver's license number, TSA number, citizenship, date of birth, gender);
  • Travel preferences and trip/meeting preferences and other information (e.g., seat preferences, meal preferences, frequent flyer miles, other personal data provided by you via your profile or other requests);
  • Payment and bank information (e.g., credit card data); and
  • Credentials, such as logins, employee IDs, passwords and user IDs.


Unless you provide consent, Travel and Transport will not collect or share your information for direct marketing purposes. 

HOW WE COLLECT YOUR INFORMATION

Travel and Transport may collect your information, including personal data:

Directly from you when you access certain of our services, including when you communicate with us via e-mail or other channels;

From other third party sources, including the company you are employed by or are otherwise traveling or attending a meeting on behalf of; and

From the Sites and Applications used by Travel and Transport or accessible through our services. 

Each Travel and Transport Site or Application will contain a notice that describes the data collection practices applicable to the use of that particular Site or Application. 

HOW WE USE YOUR INFORMATION

Travel and Transport may use the information concerning you that we collect or that is provided to us, including personal data, for any of the following purposes:

To provide our services and fulfill our obligations to you and/or your employer or the company you are otherwise traveling or attending a meeting on behalf of;

To fulfill a request made by you, your employer or the company you are otherwise traveling or attending a meeting on behalf of;

To communicate with you via e-mail, postal mail, telephone/mobile devices or our Sites or Applications;

To provide customer care and support services;

To process payments for purchases made by you, your employer or the company you are otherwise traveling or attending a meeting on behalf of;

To send you information or materials about products or services that may be of interest to you.  Where required, we will obtain your consent before sending such marketing messages.

To generate pseudonymized or aggregated profiles and use such data for reporting and analytic purposes;

As we believe to be reasonably necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to carry out our obligations and enforce our terms and conditions applicable to our products and services, including for billing and collection purposes; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to protect against or identify fraudulent transactions;

To fulfill any other purpose for which you provide it or with your consent.  

HOW WE SHARE YOUR INFORMATION

Your information, including personal data, collected by Travel and Transport may be shared with or disclosed to:

Travel and Transport affiliates, joint ventures, partners, subcontractors and agents as necessary to provide our products and services;

Travel and Transport contractors, service providers and other third parties providing ancillary services to support our business (e.g., payment processors, data analytics providers, technology development);

Third party service providers to fulfill travel arrangements and reservations (e.g., Global Distribution Systems (GDSs), airlines, trains, rental car and other ground transportation companies, hotels, cruise lines and other related travel vendors for booking/ticketing purposes, industry reporting authorities, technology vendors, including, without limitation, online booking tool providers, meeting registration software providers and audio visual companies, and visa and passport providers and/or verification services);

Your employer or the company you are otherwise traveling or attending a meeting on behalf of for reporting, auditing, tracking and other purposes as necessary;

Third party service providers you, your employer, or the company you are otherwise traveling or attending a meeting on behalf of request we send personal data to (e.g., safety and tracking information providers, companies providing weather information or travel alerts, successor organizations and other travel management companies);

A third party in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Travel and Transport's assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by Travel and Transport is among the assets transferred; 

As we believe to be reasonably necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to carry out our obligations and enforce our terms and conditions applicable to our products and services, including for billing and collection purposes; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain (e.g., exchanging information with other companies and organizations for the purposes of fraud protection and risk reduction); and

For any other purpose with your consent.   

LINKS TO THIRD PARTY WEBSITES

For the convenience of, or the ease of use by, users, our Sites and Applications may contain links to third party websites, some of which may ask you to provide information such as your name, address, e-mail address phone number, and credit/debit card information.  If you decide to use these third party websites and/or provide your information to these websites, the privacy policy and terms of service on those websites will apply.  Travel and Transport is not responsible for and expressly disclaims any and all liability related to the actions of such third party websites, their privacy policies, or the terms and content of such websites. 

CROSS-BORDER TRANSFERS OF YOUR INFORMATION

When sharing with or disclosing your personal data to other parties, including Travel and Transport's related companies, affiliates, subsidiaries, joint ventures, partners, subcontractors and agents who provide products or services, your personal data may be transferred to countries with data protection laws providing a lower standard of protection for your personal data than your country of residence. 

Travel and Transport will transfer your personal data in compliance with applicable data protection laws, including having adequate mechanisms in place to protect your personal data when it is transferred internationally (e.g., complying with the EU-U.S. Privacy Shield Framework, Standard Contractual Clauses).  Additional information about Travel and Transport's compliance with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data transferred from the European Union to the United States can be found here. 

HOW WE PROTECT YOUR INFORMATION

Travel and Transport uses appropriate technical and organizational security measures to protect the personal data Travel and Transport holds on its network and systems from unauthorized access, disclosure, destruction, and alteration.  We conduct periodic reviews of our data collection, storage, processing, and security measures to verify we are only collecting, storing and processing personal data that is required for our products and services and to fulfill our contractual obligations.  While we make every effort to protect the integrity and security of our network and systems, we cannot guarantee, ensure, or warrant that our security measures will prevent illegal or unauthorized activity related to your personal data.  When using our services, you should be aware that no data transmission over the Internet or storage system can be guaranteed as totally secure.  Although we strive to protect your personal data, we do not warrant the security of any data and information that you transmit to us over the Internet and you do so at your own risk.  Please notify us immediately if you believe your password or any of your personal data has been misused. 

 

HOW LONG WE KEEP YOUR INFORMATION

Travel and Transport retains personal data for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by applicable law. When determining how long to retain personal data, we take into account our need to collect personal information for the provision of our products and services, applicable laws and regulations (including data protection laws) and our contractual and legal obligations.  We may retain records to investigate or defend against potential legal claims.

 

COOKIES

WHAT ARE COOKIES?

Cookies are small pieces of information created by a website that is stored in your computer either temporarily for that session only (session cookie) or permanently on the hard drive (persistent cookie).  Cookies provide a way for the website to recognize you and keep track of your preferences.  The use of cookies is an industry standard and, as such, you will find that most major websites use them. 

Session cookies, also called a transient cookie, is stored in temporary memory and does not collect information from your computer.  This type of cookie is tied to your web browser and is typically utilized for website administration, such as keeping your website login (or session) active for a period of time.  They will expire if you reach a default time-out limit, if you clear your browser cache, or when you completely close down your web browser. 

Persistent cookies are not deleted when you close your browser but are stored on your computer's hard drive.  These types of cookies can be used to track your browsing across different sites in order to show you targeted advertisements when you visit.  Other uses of persistent cookies may be stored when that site requires information, such as your preferences, for the next time you visit that site. 

Most web browsers are initially set up to accept cookies.  You can reset your web browser to refuse cookies or to indicate when a cookie is being sent.  However, please note that some parts of a website, including this Site, may not function properly if you refuse cookies.  For example, without cookies, the website will not be able to keep you logged in.

 

OUR USE OF COOKIES

Travel and Transport utilizes session cookies in order to keep your website login active for a period of time and to track your preferences selected for that session.  Additionally, we utilize a persistent cookie in order to track that you have accepted our use of cookies so that we do not prompt you again the next time you visit our Site.  Travel and Transport does NOT utilize any cookies to track information about your computer or browsing activity from other websites.   

COLLECTION OF INFORMATION FROM CHILDREN UNDER THE AGE OF 13

Travel and Transport will never knowingly request personal data from anyone under the age of 13 without first requesting consent from a parent or legal guardian.  Once parental consent is granted, the child's personal data is treated much like anyone else's personal data.  Parents or legal guardians can change or revoke the consent choices previously made, and review, edit or request the deletion of their minor children's personal data by contacting us as set forth below. 

YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA

You may choose what personal data (if any) you wish to provide to us.  However, if you choose not to provide certain details, your experience with some or all of our services or products may be affected. 

Some data privacy or protection laws may require us to obtain a separate express consent for the processing of your personal data.  Your consent may also be implied in some circumstances, as permitted by applicable law, such as when communications are required to fulfill your requests. 

To the extent required by applicable law, you have the right to access your personal data and confirm the processing of your personal data.  Also, where applicable, you have the right to rectify inaccuracies or errors, erase, restrict the processing, object to processing, withdraw consent to the processing of your personal data (or opt-out where applicable), and where applicable, the right to data portability of your personal data.  Travel and Transport will handle those requests in the time specified by applicable law. 

Please note that oftentimes Travel and Transport collects personal data under the direction of its customers, including the company you are employed by or are otherwise traveling or attending a meeting on behalf of.  Your use of our products and services may be subject to such company's policies, if any.  If such company is administering your use of our products or services, please direct your privacy inquiries to the administrator of such company. 

HOW TO CONTACT US

If you have any questions about this privacy policy or wish to exercise any of your rights as described in this privacy policy, please contact us as follows: 

Travel and Transport, Inc.

Attn: Office of the Data Protection Officer

Address: 2120 South 72nd Street

City/State/Zip: Omaha, Nebraska 68124

Email: PrivacyOffice@tandt.com

 

Except as is otherwise stated or determined by Travel and Transport, Travel and Transport is a data controller for personal data we collect through the services and products subject to this policy.  Our address is Office of the Data Protection Officer, Travel and Transport, Inc., 2120 South 72nd Street, Omaha, Nebraska 68124. 

Statesman Travel Limited d/b/a Travel and Transport Statesman is our data protection representative for the European Economic Area.  Their address is Senator House, 85 Queen Victoria Street, London EC4V 4AB. 

Travel and Transport will respond to your requests to the email address or phone number that you have registered with us or we otherwise have on file for you or any other suitable method.  Depending on your request, we may review the request with you or the company you are employed by or are otherwise traveling or attending a meeting on behalf of to assist in resolving and responding to the request. 

If you feel we have not been able to assist you with your complaint or concern, you may have the right to make a complaint to the data protection authority in your country (if one exists).

 

CHANGES TO THIS PRIVACY POLICY

Travel and Transport reserves the right to revise, amend or modify this privacy policy at any time and in any manner.  When we post changes to this privacy policy, we will revise the "last updated" date at the top of this privacy policy.  We encourage you to periodically review this privacy policy to learn how Travel and Transport is protecting your information.