Last updated: January 1, 2020
We collect Personal Data about you when you use our Site(s) or in providing our Services to you. “Personal Data” consists of any information that relates to you and/or information from which you can be identified, directly or indirectly. For example, information which identifies you may consist of your name, address, telephone number, photographs, location data, an online identifier (e.g. cookies identifiers and your IP address) or one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.
Whenever you use a website, mobile application, or other internet service, certain information is created and retained by the website or application. This happens with our Site as well. We collect Technical Information when you use our Site, or information that has been made anonymous, such as:
- Log data: Our servers automatically record information when you use our Site, such as your IP address, the type of browser you are using and its settings, the third party website you visited immediately prior to accessing our Site, the operating system you are using, the domain name of your Internet service provider, the search terms you use on our Site, the specific Site pages you visit, type of product selected, the brand, order, and product identifications, and the duration of your visits.
- Cookie data: A “cookie” is data that a website server stores on your computer. Cookies enable websites to recognize your computer and to “remember” your entries as you move from page to page, or even when you revisit the site from time to time using the same computer.
We may also collect information pertinent to the marketing of our products and services. This information may include marketing channels, User Market IDs (CenterPoint, TNMP, etc.), Site brands and product names, contract terms, financial information and other information.
We collect and analyze this Technical Information to measure the number of visitors to the different sections of our Site, to evaluate how visitors use our Site and to provide you with advertisements that are relevant and useful to you, unless you have told us not to. We also use the information we collect to understand customer needs and trends, to carry out targeted promotional activities, and to generally help us make our Site more useful to visitors.
We may use your Site data by itself or aggregate it with similar information we have obtained from others. We may share your Site data with our affiliates and other third parties to achieve these objectives. You may obtain a list of our affiliates and third parties with whom we share your Site data by contacting us here.
We reserve the right to use Internet Protocol (IP) addresses to identify a visitor when we feel it is necessary to enforce compliance with our Site’s terms and conditions, or to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our Site, or other users; or (d) in an emergency to protect the health and safety of our Site’s users or the general public.
If you are a customer, an agent, an employee, or a job applicant, the Personal Information we hold and use is necessary for the performance of the services or independent contractor agreement or other agreement to which you are a party or to perform the services you have otherwise requested.
If you are a prospective customer, the Personal Information we collect and use is necessary for our legitimate interest in providing you with information about the services we offer, and about which you have expressed an interest or that we believe will be of benefit to you. Where appropriate, we will obtain your consent at the time we communicate with you.
In some cases, our purpose for collecting the information is because you have expressly consented to our collection and use of your Personal Information.
We collect your Personal Information for a variety of reasons. You may provide the information to us directly, or through a tool or product provided by us or another company to your employer (in the case of our business clients). We collect your Personal Information, such as name, address, email address, phone number, and credit card information in order to provide the services you have requested. Other examples of Personal Information that we collect include:
We use the Personal Information we have collected to allow us to evaluate your employment application, to provide the products and services you have chosen, process payments, or to manage and develop our business and operations, including:
If you send us an email with questions or comments, we may use your email address to respond to your questions or comments, and we may save your questions or comments for future reference. We may email you when:
We do not currently share your information that we collect for preference-based advertising purposes and we do not currently have any plans to do so through this Site.
We may share your Personal Information with one or several of our business partners to make an initial determination of the services you may desire, to process your employment application, or to otherwise facilitate our business operations. We also share your Personal Information as necessary with airlines, hotels and other providers for whose services you have requested our assistance. We may also share your information to protect and defend the rights and property of Company.
We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||YES|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||NO|
|G. Geolocation data.||Physical location or movements.||NO|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||YES|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K. Inferences drawn from other Personal Information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
Personal Information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from our clients. For example, from documents that our clients provide to us related to the Services for which they engage us.
- Indirectly from our clients. For example, through information we collect from our clients in the course of providing Services to them.
- Directly and indirectly from activity on our Site and the Sites of Travel Leaders Group’s brand companies. For example, from submissions through our website portal or website usage details collected automatically.
- From third parties that interact with us in connection with the Services we perform. For example, from third party travel suppliers.
We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose:
- Category A: Identifiers.
- Category B: California Customer Records personal information categories.
- Category C: Protected classification characteristics under California or federal law.
- Category I: Professional or employment-related information.
We disclose your Personal Information for a business purpose to the following categories of third parties:
- Our affiliates.
- Service providers.
- Third parties to whom you authorize us to disclose your personal information in connection with products or Services we provide to you.
In the preceding twelve (12) months, we have not sold any Personal Information.
- Access to Specific Information and Data Portability Rights: You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting or selling that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about you (also called a data portability request).
- If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
- sales, identifying the Personal Information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
- Deletion Request Rights: You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
- Exercising Access, Data Portability, and Deletion Rights: To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us here.Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
- Response Timing and Format: We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not be able to delete information that is required to maintain our business purpose or that is required to facilitate your contract with us or to perform the Services you have otherwise requested from us. All the above requests will be forwarded on to other parties holding and processing your data where appropriate.
For more information about your Personal Data rights please visit the Information Commissioner Office for the United Kingdom’s website here.
In order to provide your access to your Personal Data, we will need to validate your identity and require that you send an email from the email address account associated with your Personal Data as stored on Company’s systems. Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimize the risk of unauthorized access or disclosure.
To make this Site work properly, we sometimes place small data files called cookies on your device.
- To assist you in navigation of our Sites;
- To help you provide feedback to us;
- To analyze your use of our products, Services or applications.
We use the following cookies and classify cookies in the following categories:
- Strictly necessary cookies;
- Advertising cookies;
- Analytics cookies;
- Performance cookies;
- Session cookies;
- Targeting cookies.
You can opt-out of each cookie category (except strictly necessary cookies).
Enabling these cookies is not strictly necessary for the Site to work but it will provide you with a better browsing experience. You can delete or block these cookies, but if you do that some features of this Site may not work as intended. The cookie-related information is not used to identify you personally and the pattern data is fully under our control. These cookies are not used for any purpose other than those described here.
We take the security of your Personal Information very seriously. We have implemented industry-standard security measures to protect against the loss, misuse and alteration of the information under our control. To help ensure the confidentiality of your Personal Information, it is important for you to protect against unauthorized access to your passwords and to your computer. Be sure to sign off and/or log out when finished using a shared computer.
We strive to safeguard Personal Information using methods that are appropriate to the sensitivity of the information. We have implemented security measures we consider reasonable and appropriate to protect against the loss, misuse and alteration of the Personal Information under our control. However, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and are not responsible for the theft, destruction, or inadvertent disclosure of your Personal Information. In the unfortunate event that your Personal Information is compromised, we may notify you by e-mail or U.S. mail to the last e-mail address or postal address you have provided us in the most expedient time reasonable under the circumstances, or as otherwise required by applicable law. We may delay notification as necessary while we take measures to determine the scope of the breach and restore reasonable integrity to our system as well as for the legitimate needs of law enforcement. From time to time we evaluate new technology for protecting information, and when appropriate, we upgrade our information security systems.
Our Site is not directed to children. We do not sell products or services for purchase by children. We will not knowingly collect Personal Information from children. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed personally identifiable information to us, please contact us here. A parent or guardian of a child under the age of 13 may review and request deletion of such child’s personally identifiable information as well as prohibit the use of that information.