Effective May 25, 2018
WHO ARE WE?
Barrhead Travel and its trading divisions – Barrhead Business Travel, Cruisedirect.co.uk, The-Cruise-Specialists.co.uk, CanadaTravelSpecialists.co.uk, Flightsdirect.com and Brilliant Travel are all part of Travel Leaders Group LLC.
If you have questions not answered in this policy, our Privacy Officer may be contacted directly at firstname.lastname@example.org.
WHAT PERSONAL INFORMATION DO WE COLLECT?
We collect your personal information, and that of your travel companions, that is provided to us either directly by you or through an employer or travel sponsor as the case may be, in order to provide you with the products and services you have requested. In most cases, it consists of:
We may collect other information to assist you with your travel plans including but not limited to, passport number, driver’s license or other government-issued identification number, date of birth, gender, arrival and departure locations and times, airline, hotel or car rental frequent loyalty numbers, known traveler and global entry number, and other related travel information.
INFORMATION WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES
We collect other information, such as your IP address, search terms, and site pages you visit while on our Site, whenever you visit our Site, use our services, or view our online advertisements. The technologies we use for this automatic data collection may include cookies and log data.
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:
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 analyse this 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 at the address below.
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.
HOW WE USE YOUR INFORMATION
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 contract or independent contractor 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 Company or another organisation 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:
Doing Business with You. 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:
Email communications: 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:
HOW DO WE USE PREFERENCE BASED ADVERTISING, ANALYTICS, AND SERVICES?
Disclosures As Required By Law: 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.
WHO ELSE DO WE SHARE YOUR INFORMATION WITH AND WHY?
We may share your personal information with one or several of our business partners to make an initial determination of the services you may need, 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.
Email Communications: We may share your email contact information with our partners to assist with marketing our products and services. You may unsubscribe from receiving future commercial email communications from us by clicking the “unsubscribe” link included at the bottom of any marketing emails we send, or by emailing us as provided in the “Contact Us” section below. However, we reserve the right to send you transactional emails such as customer service communications in connection with the products or services you have purchased. For security reasons, we do not recommend that you send personal information, such as passwords, social security numbers, or bank account information, to us by email.
Transfer of Assets: We do not sell or lease personal information or provide a list of our customers to third parties. However, as we continue to develop our business, we may sell or purchase assets. If another entity acquires us or all (or substantially all) of our assets, the information we have about you will be transferred to and used by this acquiring entity. Also, if any bankruptcy or reorganisation proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.
Legal Necessity: Notwithstanding anything herein to the contrary, we reserve the right to disclose any information about you if we are required to do so by law, with respect to copyright and other intellectual property infringement claims, or if we believe that such action is necessary to: (a) fulfil a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, or our Site; or (d) in an emergency to protect the health and safety of our Site’s users or the general public.
WHAT CHOICES DO YOU HAVE ABOUT OUR USE OF YOUR INFORMATION?
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:
You may have additional rights concerning your personal information if you reside in the European Union. These can be found in the “European Union Privacy Notice” section of this document.
Accuracy of Personal Information: It is important that the personal information we hold about you is accurate and current. Company requires you to keep us informed of changes to your personal information. If your registration information changes, please send your request to us at the email address below. We take reasonable steps to verify your identity prior to honouring any such requests to help protect your privacy and security.
Accessing Your Personal Information: If you want to know what personal information Company holds about you or wish to change personal information that is inaccurate or out of date, or to withdraw your consent to our use of your personal information, please contact us at the email address below. It may not always be possible to completely remove or modify information in our databases, although we will make reasonable efforts to do so upon your request. We do not control how our partners retain, store and destroy data they have accessed in connection with assisting with providing our services. You should check their websites for more information on their practices.
Do Not Track Disclosures: Certain browsers may offer you the option of providing notice to websites that you do not wish for your online activities to be tracked for preference-based advertising purposes (“DNT Notice”). Some browsers are, by default, set to provide a DNT Notice, whether or not that reflects your preference. Providing DNT Notice is often touted as a means to ensure that cookies, web beacons and similar technology are not used for preference-based advertising purposes – that is, to restrict the collection of information your online activities for advertising purposes. Unfortunately, given how preference-based advertising works, DNT Notices may not effectively accomplish this goal. For this and a variety of other reasons, with respect to our Site, we do not take any particular action based on browser based DNT Notices. However, we do not use third-party advertisers or engage in behavioural marketing data collection for resale. Rather, if you do not wish to participate in preference-based advertising activities, you should follow the opt-out process identified above.
YOUR CALIFORNIA PRIVACY RIGHTS
If you are a resident of the State of California, you have certain rights under California law to request information concerning our data sharing activities with third parties.
Residents of the State of California, under certain provisions of the California Civil Code, have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed certain personally identifiable information as defined under California law during the preceding year for third party direct marketing purposes. You may request the information in writing at the email address below. You may learn more about your rights under California’s privacy laws at https://oag.ca.gov/privacy.
SAFEGUARDING PERSONAL INFORMATION
We take the security of your 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 unauthorised access to your password and to your computer. Be sure to sign off / log out when finished using a shared computer.
Company will endeavour 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 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.
PRIVACY OF CHILDREN’S INFORMATION
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 at the email address below. 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.
This Policy does not apply to your use of unaffiliated websites to which our Site is linked. Company is not responsible for the privacy practices or the content on linked sites. We recommend that you carefully read the privacy policies of each site you visit.
By Email: email@example.com
CHANGES TO THIS POLICY
EUROPEAN UNION PRIVACY NOTICE
WHO WE ARE
Travel Leaders Group, LLC is a travel services business with principle offices located in New York, New York. Company, or one of its affiliates as the case may be, is the controller of your personal data that we have collected.
Personal Data is a legal term that describes any information that identifies a particular person and has special meaning under European Union law.
For purposes of the EU’s General Data Protection Regulation (GDPR), personal data is any information that can identify you, either directly or indirectly, such as a name, an identification number, your IP address, data about your location, or information about your physical, physiological, genetic, mental, economic, cultural or social identity.
We are providing you this notice because we have collected some of your personal data from you. We collect your data for a variety of reasons, depending on whether you are an employee, a customer, an agent or a vendor.
WHAT IS THE LEGAL BASIS AND PURPOSE FOR HOLDING YOUR PERSONAL INFORMATION?
If you are a customer, an employee, or a job applicant, the personal information we hold and use is necessary for the performance of the services contract to which you are a party or to perform the services which 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.>
In some cases, our legal basis for collecting your personal data is because you have expressly consented to our collection and use of your personal information.
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
If you are a customer, applicant for employment, vendor or agent, we will keep your personal data on an ongoing basis for so long as we have a legitimate interest to inform you of our services, or until our contractual relationship has terminated, as the case may be. We are required to retain certain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices.
YOUR RIGHTS AS A DATA SUBJECT
You have important rights that you may exercise to protect your personal data. You may access those rights at any time by contacting us at firstname.lastname@example.org.
You have the following rights concerning your personal data that we hold and process that you can exercise at any time:
Please note: 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 at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/.
What forms of ID will I need to provide to access this?
Company accepts the following forms of ID and validation when information on your personal data is requested: You will need to send an email from the email address account associated with your personal data as stored on Company’s systems.
Under what Circumstances will Company Contact me?
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 minimise the risk of unauthorised access or disclosure.
For certain types of personal data, we have asked for your consent to use the data for certain described purposes at the time you provided it. You may withdraw your consent at any time.
When you give us your consent, you are giving us permission to process your personal data specifically for the purpose identified in the consent request. Where we ask you for additional personal data, we will obtain your consent to our proposed use of that data where required, and always tell you why and how the information will be used.
You may withdraw consent at any time by sending an email to email@example.com.
SHARING WITH THIRD PARTIES
We may pass your personal data on to third-party service providers contracted by Company to perform certain services for us, or to collaborate directly with you. For a complete and up-to-date list of the third parties we are currently using, please send an email to firstname.lastname@example.org.
Any third parties that we may share your data with are obliged to keep your details secure, and to use them only for the purposes and to complete the tasks identified by Company. When they no longer need your data to fulfil this service, they will dispose of the details in line with Company’s procedures. If we wish to pass your personal data onto any additional third parties, we will only do so once we have obtained your consent, unless we are legally required to do otherwise.
INTERNATIONAL TRANSFER OF PERSONAL DATA
Company may transfer your personal information within Company and/or to other third parties, such as our third-party service providers. Your personal information may be transferred to, stored, and processed in a country other than the one in which it was collected. This may include the United States. When we do so, we transfer the information in compliance with applicable data protection laws. In particular, we have implemented safeguards in the form of standard data protection clauses adopted by the European Commission. The safeguards ensure compliance with the data protection requirements of the GDPR as well as your rights appropriate to the processing of your personal data. You can obtain a copy of the standard contractual clauses by contacting us at email@example.com.
SAFEGUARDING PERSONAL DATA
Please refer to the “Safeguarding Personal Information” section above for information about our data security measures.
WHO DO I CONTACT TO LODGE A COMPLAINT ABOUT HOW MY PERSONAL DATA IS BEING HANDLED?
If you wish to raise a complaint on how we handle your personal data, you can contact our Privacy Officer by email: firstname.lastname@example.org.
If you are not satisfied with our response you can complain to the Information Commissioner Office for the United Kingdom. Their Help Desk number is 0303 123 1113.