Last updated: February 2020
We, TravelClick, an Amadeus company (“TravelClick”), want you to be familiar with how we collect, use, and disclose personal data (information that identifies you as an individual).
TravelClick is committed to protecting the privacy of personal data it collects and processes. TravelClick will act in compliance with applicable data protection legislation.
Who is collecting and processing the personal data?
This TravelClick.com Privacy Notice (“Privacy Notice”) applies to personal data that TravelClick, Inc. may collect through this website (“Site”). This Privacy Notice does not address the collection, use, or disclosure of information through any other means other than the Site. This Privacy Notice does not apply to the personal data that TravelClick may process about you as a traveler.
What is the legal basis for the processing of the personal data?
The legal basis for processing your personal data is that the processing is necessary for the performance of the relationship with you, which is regulated by the Terms and Conditions, and also by the specific forms used when collecting your data.
The legal bases for processing the personal data for research, analytical, statistical purposes, and to identify products and services that may be of interest to individuals, is on the bases of the legitimate interest of TravelClick. Where personal data is processed for these purposes, the privacy impact on the individuals whose data is being processed will be considered.
What types of information do we collect?
TravelClick collects and processes information from you at various stages during your time using the Site.
The types of personal data that we collect and process includes:
a. Personal data:
a. Salutation, name, last name, address, company name, job title, country, industry, mobile phone, and email address; and
b. Any other information you provide to us in contact forms (you will see exactly what information we collect from you by filling in the fields in the form).
b. IP details and location data
c. Cookies in accordance with this Privacy Notice and the Cookie Notice.
For what purpose is your personal data used?
We use the personal data collected from you:
- To fulfill your requests (e.g. to send you news and updates and answers to your questions), according to the forms you may fill.
- To obtain your feedback (e.g. through a survey), in case you want to provide us with it.
- To inform you by e-mail of our products and services, special offers and promotions, and any other marketing materials which we think may interest you.
- To send you information regarding the Site such as changes to our terms, conditions, policies, and/or other administrative information.
- For our internal business purposes, such as data analysis, audits, developing new products, enhancing our website, improving our services, and identifying usage trends. This information used may be personal data and non-personal data.
- To detect, prevent, or otherwise address security or technical issues in connection with services provided through this Site.
We may combine personal data collected from your navigation with the information provided by you through different channels (e.g. newsletters, specific campaigns, contests, etc.) obtaining a set of all your data provided to TravelClick. We will use this combined information to understand your preferences regarding the TravelClick services and products, and to be able to provide you with a targeted experience. By having that knowledge we are able to understand you and your needs, and can offer you the experience you expect from us.
If you change your mind, and no longer wish to receive marketing-related e-mails from us on a going-forward basis, you may unsubscribe from receiving such marketing-related e-mails or from such sharing at any time by using the tool provided to you.
Who is the personal data shared with?
We may share personal data with TravelClick affiliates, who, due to the nature of the services TravelClick provides as a global travel technology supplier, may be located in any location around the world. These TravelClick affiliates may process personal data for the purposes described in this Privacy Notice.
In addition, we may also disclose your information to:
- Third parties, business partners, suppliers, subcontractors, and service providers for the performance of any contract we enter into with them;
- Analytics and search engine providers that assist us in the improvement and optimization of our Site;
- Affiliates or other third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings); and
- If necessary: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal processes; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety, property, and/or that of our affiliates, you, or others; and (g) to permit us to pursue available remedies or limit the damages that we may sustain.
Where such disclosures take place TravelClick requires the appropriate technical and organizational security measures to be in place to protect personal data, and for personal data to be processed lawfully.
TravelClick only allows affiliates and third party service providers to use personal data for specified purposes and in accordance with TravelClick’s instructions. Any sharing of personal data using third party platforms would be governed by the terms of the third party platform used.
International transfers of traveler personal data
When TravelClick shares personal data with its affiliates and third party service providers who process personal data on behalf of TravelClick, this will involve transferring personal data outside the European Economic Area (“EEA”). When personal data is transferred to another country it will continue to receive adequate protection through contractual or other arrangements put in place with affiliates and third party service providers. For these transfers at least one of the following appropriate safeguards will be implemented:
- Personal data will be transferred to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
- Standard data protection clauses approved by the European Commission which give personal data transferred the same protection it has in EEA; or
- With affiliates and third party service providers based in the US, Privacy Shield which gives personal data similar protection it has in EEA.
Further information on the appropriate safeguards used when transferring personal data outside the EEA can be requested through using the contact details found in the “Legal rights” section of this Privacy Notice. When requesting this information please make a reference to the transfer of personal data outside the EEA.
Third party sites and sending messages through the Site
This Privacy Notice does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including without limitation any third party operating any site to which this Site contains a link; or any third party platform such as social media platforms where TravelClick shares personal data at your request. Where personal data is shared in this way the use of the personal data will be governed by the terms of the third party platform which you have requested personal data be shared with. The inclusion of a link on the Site does not imply endorsement of the linked site by TravelClick.
This Site may permit you to send messages regarding Site-related content to another individual though the Site. If you wish to use this feature, you may be required to provide us with the individual’s email address. By using this functionality, you affirm that you are entitled to use and provide us with the recipient’s name and email address for this purpose. TravelClick shall not assume any liability that may arise from sending this kind of messages to the recipient(s) as we are doing this at your request.
Information that you share
Some services may allow you to share information with others. As a recommendation, we urge you to exercise discretion and caution when deciding to disclose your personal data, or any other information on the Site.
Data security and integrity
We use reasonable organizational, technical, and administrative measures to protect personal data under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. Please do not send us sensitive information through e-mail. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the problem by contacting us in accordance with the “Contact Us” section of this Site. Please note that e-mail communications will not necessarily be secure and so you should not include credit card information in your e-mail correspondence with us.
When personal data is processed on behalf of TravelClick, access is limited to those who require access on a business need-to-know basis, personal data will be processed in accordance with the instructions of TravelClick, and those who have access are subject to a duty of confidentiality.
TravelClick has in place procedures to deal with any suspected personal data breach, and will notify individuals and any applicable regulator of a breach where they are legally required to do so.
Retention of personal data
TravelClick retains personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purpose of satisfying any legal, accounting, or reporting requirements. Please note that on any forms where you provide us with your details, we may specify the period of time that we intend keep the data according to the specific proposes defined in the form.
Use of the site by children
The Site is not directed to children, and we request such individuals to not provide personal data through the Site.
Under certain circumstances individuals can exercise rights under data protection laws. Individuals may exercise these rights relating to their own personal data or contact TravelClick for other data protection related questions by emailing email@example.com.
TravelClick will require authentication of the identity of the individual wishing to exercise their rights under data protection laws, and may require additional information to assist in responding to requests
For the following rights please make a reference to the following in the request:
- Right to access: “Request for access to personal data”
- Right to object: “Object to processing of personal data for the purpose of analytics”
- Right to information about:
- “TravelClick affiliates and third party service providers who process personal data on behalf of TravelClick”
- “Transfers to third countries – information about data transfers outside EEA”
TravelClick intends to carefully address any request and/or claim from you, as well as carefully process personal data. You are entitled to file any claim or complaint before the relevant data protection authorities if the answer provided by TravelClick does not meet your expectations.
This Privacy Notice is published by TravelClick, Inc. and may be changed at any time. The date it was updated is shown here: 10th February 2020.
Additional Privacy Disclosures for the United States California and Nevada
If you are a California or Nevada (United States) resident, please see our Additional Privacy Disclosures for the United States California and Nevada here, which is incorporated by reference into this policy.