and the purposes for which Expertise Travel Services International, LLC.
("ETS International") may collect and transfer certain personal
refers to data about an identified or identifiable individual, such as
defined in the European Community Directive on Data Protection (the "EU
because anyone who submits personal information to ETS International has
certain rights regarding the use, collection and transfer of such personal
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
is acting as a data processor or a data controller.
At ETS International,
we are committed to protecting the privacy of your personal information.
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.
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
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.
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
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
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
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 firstname.lastname@example.org.
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
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
Personal information of employees of ETS International and its affiliates
will not be transferred outside of ETS International and its affiliates
human resources policy.
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
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.
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
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
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.
At ETS International, we have established internal procedures to monitor
our compliance with the Safe Harbor Program and applicable Privacy Laws.
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
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 email@example.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
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 firstname.lastname@example.org or if you would prefer to contact
us in person, our telephone number is 847-493-8900
to the requirements of applicable legislation and regulations and the
orders of any court, regulatory body or other lawful authority (collectively
International's rights and obligations pursuant to such Privacy Laws.