ETS INTERNATIONAL, LLC.
PRIVACY POLICY


I. Introduction.
The purpose of this privacy policy is to notify you about the manner in and the purposes for which Expertise Travel Services International, LLC. ("ETS International") may collect and transfer certain personal information.1 When used in this privacy policy, "personal information" refers to data about an identified or identifiable individual, such as defined in the European Community Directive on Data Protection (the "EU Privacy Directive"). This privacy policy should be read in its entirety because anyone who submits personal information to ETS International has certain rights regarding the use, collection and transfer of such personal information.

ETS International processes personal information both as a "data processor" and as a "data controller." Under the EU Privacy Directive, a processor is a person which processes personal information on behalf of a controller, and a controller is a person which actually determines the purposes and means of the processing of personal information. The obligations of ETS International under this privacy policy differ depending on whether it is acting as a data processor or a data controller. (read more)

At ETS International, we are committed to protecting the privacy of your personal information. This privacy policy explains the measures we have implemented to protect the personal information you provide to us..

II. Our Business.
At ETS International, we believe that anyone who submits personal information to us should understand the nature of our business. In order to provide travel arrangement services for our customers and their employees, ETS International needs to share the personal information provided to it with other travel suppliers. Without sharing the information, ETS International will not be able to provide travel management services to its customers.

ETS International provides travel management services to corporate clients (a "Client"). In order to complete these services, ETS International requires personal information on individuals authorized to travel on behalf of a particular Client (a "Traveler"). ETS International obtains such personal information from the Traveler, from the Client, or from other sources such as travel agents. In order to complete travel arrangements requested by a Traveler, ETS International typically provides the Traveler's personal information to one of the global distribution systems or an internet booking engine ("GDS"). The personal information transmitted by ETS International to the
GDS may include, but is not limited to, such information as name, address, age, marital status, medical conditions, passport and visa information and corporate data.

The GDS uses such personal information to fulfill the travel arrangements requested by a Traveler through specific travel suppliers, such as airlines, hotels and rental car agencies. ETS International receives confirmation of the travel arrangements requested by a Traveler. Upon completion, ETS International provides information to the Client on travel arrangements made for a Traveler employed by the Client. This information may include, but is not limited to, information regarding the dates and times of travel, locations traveled to and from, classes of service provided, the names and locations of any hotels, motels, or other lodging arranged for the Traveler by ETS International, the names of other travel suppliers providing services to the Traveler, and the costs incurred for all travel services selected by the Traveler. ETS International does not exercise any control over the use of personal information transmitted to the GDS or other travel supplier. Travel arrangements for a Traveler are shared only with the Client for which the Traveler works.

In addition, ETS International receives personal information regarding its employees and employees of its affiliates. ETS International uses this human resources information for internal purposes only.

III. Privacy Principles.
At ETS International, we are committed to protecting your personal information in accordance with the privacy principles established by the Safe Harbor Program: Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement. This privacy policy describes our efforts to comply with these privacy principles, and applicable Privacy Laws. ETS International will comply with the Onward Transfer and Security privacy principles when it is acting as a data processor, and with all privacy principles, and the privacy protection principles, however expressed, in applicable Privacy Laws, when it is acting as a data controller.

1. Notice
ETS International's primary goal in collecting personal information is to provide our Clients and their Travelers with a customized experience and to ensure that travel arrangements comply with the requirements of Travelers and Clients within our capabilities. In order to provide these services, ETS International needs to collect certain personal information from and about a Traveler, such as contact and credit card information. ETS International collects information in several ways, including telephone calls, voicemail, electronic mail, and from different parts of our website, including but not limited to traveler profile forms and Internet booking engines. The information a Traveler submits is to complete a travel purchase transaction, to enhance a Traveler's travel arrangements and to ensure that a Traveler's travel arrangements are in compliance with any existing travel policy of the Client.

Some of a Traveler's personal information (such as a credit card number) may be stored to facilitate the making of future travel arrangements. Only that personal information which is reasonably required to facilitate travel arrangements is shared among ETS International, its affiliates, a GDS and travel suppliers. Also, information provided by an individual Traveler may be accessed by the Client for which the Traveler works. In addition, we collect personal information when and if a Traveler submits a Contact Us form through our Website. Collecting this information allows us to follow up with a Traveler in order to provide the requested customer service.

ETS International may collect personal information from its employees. This personal information may be transferred among ETS International and its affiliates. Any personal information on employees of ETS International and its affiliates will be used internally only in accordance with this privacy policy and ETS International's human resources policy.

2. Choice
A Traveler may choose not to have any of his or her personal information submitted or transferred to third parties in accordance with the terms of this privacy policy. Please note that, if a Traveler chooses not to submit his or her personal information to ETS International or not to allow ETS International to provide such personal information to a GDS or other travel supplier, then ETS International will not be able to provide the travel services requested.

As explained above, in order to provide travel services, ETS International must disclose a Traveler's personal information to a GDS and to other travel suppliers. A Traveler's personal information also may be shared with the Client for which a Traveler is making travel arrangements.

At times, ETS International also may use a Traveler's personal information internally for quality control purposes. Please note that personal information used internally is only available to ETS International employees who perform quality control functions as part of their job. Any ETS International employee who utilizes personal information improperly will be subject to discipline, which may include termination of employment.

A Traveler or any other person who submits personal information to ETS International may choose not to have such information shared with a third party. For a Traveler, this includes sharing personal information with a GDS or other travel suppliers. If you do not wish to have your personal information disclosed, then please contact the Office of Security at security@etsintl.com. Within a reasonable time after you notify the Office of Information Security of your choice not to have your personal information disclosed to a third party, we will cease disclosure of your personal information. Please keep in mind that ETS International will not be able to provide you with all or certain services if you instruct us not to disclose your personal information to any GDS or travel suppliers.

ETS International will collect to a Traveler's travel arrangements only if the Traveler submits such sensitive personal information to us. Sensitive personal information will only be used by ETS International in order to allow us to help the Traveler obtain the special accommodations for travel arranged by or through ETS International. If a Traveler does not want us to collect and use such sensitive personal information, then the Traveler should not submit such type of information to us. ETS International will not share a Traveler's sensitive personal information with a third party unless authorized to do so by the Traveler.

ETS International may be required or permitted to disclose personal information from time to time in order to comply with legal requirements and will comply with applicable Privacy Laws in doing so.

3. Onward Transfer
Please note that the descriptions of our activities under the "Notice" and "Choice" principles above relate to certain transfers of personal information that ETS International will be making to third parties.

In order to provide travel arrangements, ETS International needs to transfer a Traveler's personal information to its business partners, such as a GDS and travel suppliers, and/or other required third parties ("Transfer Recipients"). This means that an onward transfer of information takes place every time ETS International requests that a reservation be made for a Traveler. ETS International wants each Traveler to understand that, by submitting personal information to ETS International, the Traveler authorizes the use of such personal information to complete the travel arrangements requested by the Traveler, including certain transfers of such personal information to Transfer Recipients. These transfers will occur unless the Traveler informs ETS International otherwise. The Transfer Recipients will be asked to use such personal information in accordance with the provisions of this privacy policy, or will be assumed to use such personal information in accordance with their published privacy policies. ETS International, however, cannot ensure that a Transfer Recipient will use personal information in accordance with the provisions of this privacy policy, or their own privacy policies. In addition, United States or other government and law enforcement authorities may require access to a Traveler's personal information under various laws, rules, regulations, or orders, as well as under various security screening protocols.

Travelers who prefer to make reservations through the Internet need to be aware that ETS International's website provides links to other websites that may collect personally identifiable information about the Traveler. The information practices of those websites linked by ETS International are not covered by this privacy policy.

Personal information of employees of ETS International and its affiliates will not be transferred outside of ETS International and its affiliates except in accordance with this privacy policy and ETS International's human resources policy.

4. Security
ETS International conducts periodic internal reviews of its data collection, storage and processing practices and the security measures it has implemented, and believes that such security measures provide reasonable precautions against unauthorized access, disclosure, alteration or destruction of personal information that ETS International collects commensurate with that generally practiced within the travel management industry. ETS International employees who have access to personal information are bound by confidentiality obligations the violation of which will subject the employee to discipline, which may include termination of employment.

Keeping a Traveler's personal information confidential once we receive it is important to us and ETS International takes reasonable means to protect that information. As with all personal information, ETS International will never rent or sell a Traveler's personal financial information. Any time we ask for a credit card number through ETS International's website, we transmit that credit card number in an encrypted format. To do so, we use standard, SSL (secure socket layer) encryption. ETS International also has implemented certain physical security measures to protect against unauthorized access to its central and backup data centers where personal information is stored. Travelers should use caution when disclosing personal information by telephone or other electronic media, as ETS International has no control over such third party providers.

If a Traveler elects to make reservations through our website, his or her profile information will be password-protected so that only the Traveler has access to his or her personal information online. ETS International employees have access to this information for the express purpose of providing travel management services to the Traveler and providing such information to the Client. We recommend that a Traveler does not divulge his or her password to anyone. A Traveler should remember to sign out of his or her ETS International account, and close the browser window upon completion of the Traveler's work. These measures are to ensure that third parties cannot access a Traveler's personal information and correspondence, in the event the Traveler is sharing a computer with someone else or are using a computer in a public place like a library or Internet cafe.

Personal information regarding employees of ETS International and its affiliates is used for internal purposes only and is protected in accordance with this privacy policy and ETS International's human resources policy.

5. Data Integrity
ETS International conducts periodic internal reviews of its data collection, storage and processing procedures. ETS International collects, stores and processes only that personal information required to provide travel management services for or fulfill contractual obligations with regard to Travelers and Clients. ETS International conducts periodic reviews of its data collection, storage and processing practices to ensure that it only collects, stores or processes personal information that is required in order for ETS International to provide travel management services for or fulfill its contractual obligations.

6. Access
ETS International will use good faith efforts to provide its Clients, Travelers, and others from whom it obtains personal information the opportunity to review and revise the personal information ETS International has collected. Any review and revision of personal information by such persons is subject to the provisions of this privacy policy.

If a Traveler becomes aware of any inaccuracy in his or her personal information or if a Traveler wishes to inquire about his or her personal information, then the Traveler should notify us by contacting the Office of Security at security@etsintl.com.
ETS International will make all corrections and/or deletions of erroneous personal information brought to its attention within a reasonable time period; however, ETS International will make such corrections and/or deletions of erroneous personal information in a manner that does not impose undue burden or expense on ETS International. Further, ETS International may not necessarily allow access to review personal information collected with regard to an individual in the event ETS International reasonably determines such personal information is used in a manner that does not materially adversely affect the person involved, if providing such review privileges would cause undue burden or expense on ETS International. Nevertheless, ETS International will provide access to personal information in accordance with the requirements of applicable Privacy Laws.

An employee may access his or her personal information maintained by ETS International and its affiliates in accordance with ETS International's human resources policy and applicable Privacy Laws in the country in which the employee works.

7. Enforcement
At ETS International, we have established internal procedures to monitor our compliance with the Safe Harbor Program and applicable Privacy Laws. As part of such effort, we perform an annual review of our privacy policy, which includes internal audits and ad hoc reviews conducted by the Office of Information Security and reviews by third party information technology consultants, as appropriate.

In the first instance, a Traveler who thinks that his or her personal information has been misused should direct any questions or complaints to the Client for which the Traveler works. ETS International then will take reasonable efforts to protect personal information, based on the Client's instructions.

If a Traveler thinks that ETS International has mishandled his or her personal information in violation of the Safe Harbor Program, or applicable Privacy Laws, then the Traveler should contact ETS International through its Office of Security at security@etsintl.com with a written description of the complaint. After receiving a written description of the complaint, a representative of ETS International will contact the Traveler in order to discuss his or her concerns. ETS International is interested in addressing all legitimate complaints about its adherence to the Safe Harbor Program and applicable Privacy Laws and will make a good faith effort to resolve promptly any complaint brought to its attention. ETS International will cooperate with the European Union Data Protection Authorities in the applicable Member States and with data protection authorities designated under applicable Privacy Laws to resolve any complaints arising in connection with this privacy policy that cannot be resolved between ETS International and a Traveler.

An employee of ETS International within a Member State who thinks that ETS International has mishandled his or her personal information should contact the Data Protection Authorities in the country in which the employee works. ETS International will cooperate with such Data Protection Authorities in accordance with the provisions of the Safe Harbor Program. An employee of ETS International outside of a Member State who thinks that ETS International has mishandled his or her personal information should contact the ETS International Office of Information Security. Employees may also wish to contact the Data Protection Authority in the country in which the employee works. ETS International will cooperate with such Data Protection Authority in accordance with applicable Privacy Laws.

IV. Contacting Us
You may contact us at security@etsintl.com or if you would prefer to contact us in person, our telephone number is 847-493-8900
In addition to this privacy policy, ETS International may also be subject to the requirements of applicable legislation and regulations and the orders of any court, regulatory body or other lawful authority (collectively "Privacy Laws"). Nothing in this privacy policy will limit ETS International's rights and obligations pursuant to such Privacy Laws.