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You can submit a request to access or update your information, close your account or delete your data. We will ensure that our dedicated privacy team gets back to you directly.
Last updated: May 2018
- What information do we collect?
- Who do we share your personal information with?
- How do we use personal information?
- How can you manage the information you have given us?
- How do we protect your information?
- How to contact us
What does Egencia do?
Egencia provides a suite of corporate travel management services for planning, booking and managing business travel which it offers directly and/or through its network of dedicated third-party travel management service providers. Bookings can be made via the Egencia Services. We offer customer support to you through our customer services team who will assist you with any issues you have about your booking.
Corporate Travel Program
To manage its business travel needs, your organisation has enrolled in the Egencia Corporate Travel Program. Under this Program, your organisation may designate a travel manager (“Travel Manager”) to manage and administer the travel needs of your organisation and may appoint one or more travel arrangers (“Arranger” or “Travel Director”) to book and manage the travel of individual employees (“Travellers”), as well as non-employees as deemed appropriate by the company (“Guests”).
Bookings by Travellers
To book and manage their own travel, Travellers must register to become a member of Egencia or have profile data loaded in our system by the Egencia implementation team. In the event that Travellers do not register to become members of Egencia, they must rely on their Travel Manager, Arranger or Travel Director to make a booking on their behalf. If you are a Traveller, this Privacy Statement applies to how we collect and use your personal information regardless of whether you are booking and managing travel yourself or through your Travel Manager, Arranger or Travel Director. Accordingly, unless we expressly provide otherwise, when we refer to “you” in this Privacy Statement, we are referring to you as the Traveller, whether you are acting on behalf of yourself or through a Travel Manager, Arranger or Travel Director.
Travel Managers, Arrangers and Travel Directors
While this Privacy Statement is primarily directed at Travellers and Guests, it also applies to Travel Managers, Arrangers and Travel Directors.
Any personal information that a Travel Manager, Arranger or Travel Director provides to us about himself or herself in connection with our Corporate Travel Programme is managed as set out in this Privacy Statement. Egencia, however, reserves the right to contact Travel Managers, Arrangers and Travel Directors as contemplated by their organisation’s Corporate Travel Agreement with us (e.g., for feedback on the Programme, to discuss the business relationship, or to discuss new or updated services). This contact may occur via phone, email, text message or post.
When booking and managing travel on behalf of any Traveller or Guest, Travel Managers, Arrangers and Travel Directors must obtain the relevant Traveller’s or Guest’s consent. Travel Managers, Arrangers and Travel Directors must also ensure that the relevant Traveller or Guest receives and reviews this Privacy Statement.
Whether you book travel directly from us or allow your Travel Manager, Arranger or Travel Director to do so on your behalf, authorised individuals within your company may have access to your member ID and name of your member account, as well as your travel itineraries and all other information in your account, and may also direct that we share this information with third parties for record-keeping or other authorised purposes. Your Travel Manager, Arranger or Travel Director will also be able to update your profile settings (excluding your member ID and password) and travel preferences in accordance with your instructions to them. Your Travel Manager, Arranger or Travel Director will also be able to view, change or cancel any of your trip itineraries as necessary to fulfil your instructions or in accordance with your agreements with them.
Key things you should know about how we use your information:
- We use your information (and the information of those travelling with you) for purpose of enabling travel bookings.
- This includes sharing your booking information with our Suppliers or Property Owners in order for them to fulfil your booking and with your organization as part of your corporate travel program.
- We also engage other third-party vendors who provide services or functions on our behalf.
- Where you choose to receive marketing information, we will let you know about any special offers that may be of interest to you, including our loyalty programs. You are able to opt-out at any time through your account page.
- You can contact us about updating or accessing your information through our contact information within the Contact Us section.
- We use information like cookies to improve your experience on Online Services and provide us with analytics information that will help us improve our Services generally.
- From time to time and usually following an interaction with us, we will ask you for your feedback to ensure we are providing the best service we can.
- The data controller of your personal information is Egencia LLC. Egencia stores and processes your information in secure environments in the United States and other countries. To provide its services, Egencia must transfer your information to its affiliates and/or service providers for processing in the U.S. and potentially other countries outside of your country of residence. Please rest assured that we take appropriate steps to protect your privacy and security.
If you have any questions or concerns about our use of your personal information, then please contact us via the “Contact Us” section at the bottom of this policy.
If any parts of our Online Services link you to other websites or Apps, those newly opened links do not operate under this Privacy Notice. We therefore recommend you examine the privacy notices/statements/policies posted on those other online areas to understand their procedures for collecting, using, and disclosing personal information.
- Information that you provide directly to us
We may ask you to provide personal information directly to us. For example, we may ask you to provide your contact details such as full name, telephone number and email address in order to:
– enable your travel booking;
– create or register an account with us;
– enable Travel Arranger service;
– provide the services and information you request such as details about your booking;
– have an emergency contact number for you;
– update frequent flyer or loyalty program information;
– subscribe you to our marketing communications; and/or
– submit enquiries to us.
You will also need to provide your billing information (such as credit card number, cardholder name and expiration date) to make a payment.
You may also provide information about any travellers on your booking, your marketing preferences and when you participate in a survey or competition. When creating an account, you will provide a login name/member ID as well as a password.
If you’re an employee of a corporate account, a vendor or other type of business partner, other information collected can include employer, employee identification number, or other relevant details.
o Special Categories of Personal Information
Certain types of personal information, such as some government-issued identification numbers and information about religion, health or sexuality, are considered sensitive and require additional protection under applicable laws. We limit the circumstances under which we may collect sensitive personal information; examples of this information include the following:
– Health-related information may be needed to provide appropriate travel accommodation and accessibility or facility requirements.
– Government-issued identification numbers like passport or driver’s license number may be required for flights, vehicle rental or other travel reservation.
– Other information that you can specify at your option and which may imply or suggest information like religion, health or other information, such as dietary needs.
- Information Voluntarily Provided About Your Travel Companion(s) / Guest(s)
When you make a reservation for someone else through our Online Services, we will request personal information and travel preferences about that individual. You should obtain the consent of any other individual(s) prior to providing us with their personal information and travel preferences. Your travel companion’s information will only be available to view and amend through your account. Should your travel companion want to amend or delete their information themselves they can contact us directly at the information in the “Contact Us” section at the bottom of this policy.
- Information that we collect automatically
When you visit us on our Online Services, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type (such as Firefox, Safari, or Internet Explorer), your Internet Service Provider (ISP), your operating system and carrier. For website users, details of any referring website or exit pages as well as broad geographic location (e.g., country or city-level location) are also collected.
We may also collect other technical information such as how your device has interacted with our Online Services, including the pages accessed and links clicked, i.e., trips viewed and the time and date of these.
Collecting this information enables us to better understand the visitors who come to our Online Services, where they come from, and what content on our Online Services is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Online Services for our visitors, for example, to customize your user experience, tailor your searches and show you advertisements that may be of interest. We also use this automatic information to prevent and detect fraud.
Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology”.
- Information we collect when you use App
When you use one of your smart phone app, tablet app, or applications for other platforms (collectively “App” or “Apps” as applicable), we may also collect:
Information about the functionality of the Apps you access and use. This allows us to identify those areas of the Apps that are of interest to our customers so that we can refine and continuously improve the Apps.
Each App may send us the device’s unique device identifier (or “UID”), a sequence of numbers or characters that are unique to your device. We would use this only on the first opening of the App so that we can confirm to our advertising networks the number of downloads resulting from clicks on their respective ad banners and other marketing tools. When an email address is provided, we may associate this with your current UID/cookie ID for the purposes of providing a seamless experience across your devices.
When you use an App’s ’find hotels near your current location’ or similar features that suggest relevant content based on location, we use information about your current location – provided by your device using GPS or similar technologies – to show relevant content. We do not collect location data unless you expressly use a location-based feature, and you can switch off location data collection at any time through your phone settings menu.
Each App will also send us error-reporting information in the event that it crashes or hangs. This enables us to investigate the error and to improve the stability of the App for future releases. As part of these error reports, the App sends us information about the mobile device type and version, the UID, the time the error occurred, the feature being used and the state of the application when the error occurred. We do not use this information for any purpose other than investigating and remedying the error.
We may send push notifications concerning changes in flight status or other items coming up on your trips. In addition, we may also use push notifications to issue key communications from your travel manager/employer in case of an emergency. These permissions can always be managed from your mobile device settings.
If you select “Contact an agent” and choose the “Call back” option under Egencia AssistMe, where this feature is available, the App will send your customer ID, itinerary information and potentially other information about recent App usage to the travel consultant. This is done to expedite the customer service interaction and make for a smoother, more knowledgeable exchange.
You always have the ability to control what information a App sends to us. You can exercise this control either by changing the settings of the App under its setting menu or changing the settings of your mobile device. Alternatively, you can remove the App from your device entirely and access our services through our website.
- Information we collect when you communicate with us via the following methods
Other Online Communications:
- Cookies and similar tracking technology
In general, we will use the personal information we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information.
We may disclose your personal information to the following categories of recipients:
- Third party services providers who provide data processing services to us (for example, to support the delivery of; provide functionality on; or help to enhance the security of our Online Services), or who otherwise process personal information for purposes such as credit card processing, business analytics, customer service, marketing, distribution of surveys or sweepstakes programs, to facilitate the delivery of online advertising tailored to your interests and fraud prevention. Where third-party service providers have access to data they will only collect information as needed to perform their functions. They are not permitted to share or use the information for any other purpose.
- Business partners with whom we may jointly offer services, or whose services may be offered on our Online Services. You can tell when a third-party business partner is involved in a service you have requested because their name will appear, either alone or with ours. If you choose to access these optional services, we will on occasions share information about you, including your personal information, with those partners. An example of a business partner would be a third-party loyalty program that you will earn points for, through a booking.
- Others within your organisation, such as your Travel Manager, Arranger or Travel Director, as described above in the “Travel Managers, Arrangers, and Travel Directors” section.
- Any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person. For example, under U.S. Law, the U.S. Department of Homeland Security Bureau of Customs and Border Protection requires that certain travel and reservation information, known as Passenger Name Record or PNR data, relating to people travelling to or from the U.S.A, or through U.S. airspace, be provided to the Department prior to such travel. We may disclose this information to airlines or other travel providers so that they can forward it to the applicable law enforcement agencies and governments;
- When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company or others, our customers, or others; and in connection with our Terms of Service and other agreements;
- Any other person with your consent to the disclosure.
On occasion, we share aggregate or anonymous information with third parties, including advertisers and investors. For example, we may tell our advertisers the number of visitors our website receives or the most popular hotels and destinations. This information does not contain any personal information and is used to develop content and services we hope will be of interest to our users.
Our legal bases for processing personal information
If you are a visitor from the European Economic Area, our legal basis for collecting and using the personal information described in this Privacy Notice will depend on the personal information concerned and the specific context in which we collect it.
We will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we will have a legal obligation to collect personal information from you such as where it is necessary to use your transaction history to complete our financial and tax obligations under the law.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our platform and communicate with you as necessary to provide our services to you, for security verification purposes when you contact us and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.
How do we determine what our Legitimate Business Interests are?
We carry out an assessment to ensure that:
(i) Our interest in the use of your data is legitimate (i.e., we have a clear business need); and
(ii) The business need, on balance, does not override your privacy rights.
When determining this, we assess the potential impact a specific use of the data may have on you as a customer and weigh this against our own business needs to ensure that we get the balance right. We also apply a series of security measures to minimise any potential risks.
By way of example in practice we would consider that the collection of our customers’ marketing preferences in the course of a booking is a legitimate business interest to have as an online ecommerce company. We believe that this does not unduly impact your privacy rights as you may, most definitely, want to hear about our products and services going forward. However, to protect your privacy rights we ensure that you can opt out of these communications at any time, in your account, in the email itself or through customer services.
In accordance with the legal grounds above, we use the information we collect to:
- fulfil the transactions that you make, such as booking a hotel;
- provide you with travel confirmations and important travel updates for your upcoming trip (via email or SMS);
- verify your identity for fraud prevention purposes;
- manage your account, including processing payments;
- communicate with you in general, particularly if there is a change to your booking;
- provide customer services related to your booking or to respond to any inquiry you make;
- administer and operate our Egencia Corporate Travel Program;
- measure interest in and improve our products, services, and website functionality;
- notify you about special offers, coupons, sweepstakes and travel-related products and services that may be of interest to you. You may receive these by email, post or via advertisements on third-party sites, including through social media;
- otherwise customize your experience with this website or App;
- reward you as part of any reward and recognition program you choose to join (whether this is our program or that of a third party);
- obtain information from you, including through feedback you give or surveys you complete;
- carry out statistical analysis about the use of our website and Apps and the services we offer to improve each aspect of what we do;
- protect our rights as a company including our intellectual property, for example;
- resolve disputes, collect fees, or troubleshoot problems;
- prevent potentially prohibited or illegal activities;
- as otherwise described to you at the point of collection.
How do we protect your personal information?
We want you to feel confident about using our Online Services to make travel arrangements, and we are committed to protecting the information we collect. While no Online Services can guarantee absolute security, we have implemented appropriate technical and organisational measures to protect the personal information that we collect and process about you. For example, we use encryption when transmitting your sensitive personal information between your system and ours, and we employ firewalls and intrusion detection systems to help prevent unauthorised persons from gaining access to your information. In addition, only authorised employees are permitted to access personal information, and they may only do so for permitted business functions.
International data transfers
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident and outside of the EEA. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective). Specifically, Egencia stores and processes Personal Data about Travellers in secure environments in the United States and other countries. In relation to the processing of non-U.S. Traveller data, in order to provide its services, Egencia must transfer your Personal Data to its affiliates and/or service providers for processing in the U.S. and potentially other countries outside of your country of residence.
We ensure that any of our third party service providers to whom a data transfer is made has appropriate safeguards in place to protection your personal information. The adequacy mechanism may be (i) adequate country status, i.e., based in a country that the European Commission has deemed “adequate” since its data protection standards are similar to the European Union; (ii) Standard Contractual Clauses; or (iii) the EU-US and Swiss-US Privacy Shield.
We retain the personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise the data or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
We will anonymise or aggregate your data if we intend to use it for analytical purposes or trend analysis over longer periods.
Your information rights
As a participant in the Egencia Programme, you may receive communications from us providing you with travel news and updates. You can discontinue your subscription to such email newsletters at any time on the My Profile page under the heading “Email settings,” or by telling your Travel Manager, Arranger or Travel Director that you no longer wish to receive such communications from Egencia. You will also be given the opportunity to unsubscribe from such newsletter in any such email we send. Please note that we reserve the right to send you other communications, including service announcements, administrative messages, and surveys relating either to your Egencia account or to your transactions with Egencia, without offering you the opportunity to opt out of receiving them.
- You can access, add, update or delete information on the My Profile and My Trips pages and close your account as described below. If you make such a request, Egencia is entitled to request appropriate identification before servicing such a request.
- You may also submit a written request to access the personal data that we hold on you. If you make such a request, Egencia is entitled to request appropriate identification before servicing such a request. You can make a written request for access to your personal data by contacting us via the contact information provided below in the “Contact Us” section.
Your data protection rights
If you are a resident of the European Economic Area, you have the following data protection rights:
- If you request access to your personal data we will confirm whether we hold your information and provide you with a copy, explaining how we process it and why, how long we store it for and your rights associated with it.
- If you request deletion of your personal information, we will erase it. Please do note that we will need to retain any information that we require to fulfil our legal obligations or to establish, exercise or defend a legal claim.
- You can request to close your Egencia account by contacting us. Once you close an account, you will not be able to sign in or access any information associated with the account, but you can open a new account at any time. We will send you an e-mail confirming your account closure to the e-mail address contained in your member profile. Please do note that we will need to retain any information that we require to fulfil our legal obligations or to establish, exercise or defend a legal claim.
- Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available here).
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Information Collected by third parties/Display of tailored advertising
Do-Not-Track Signals and Similar Mechanisms. Some web browsers may transmit “do-not-track” signals to websites with which the browser communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Participants in the leading Internet standards-setting organisation that is addressing this issue are in the process of determining what, if anything, websites should do when they receive such signals. Egencia currently does not take action in response to these signals. If and when a final standard is established and accepted, we will reassess how to respond to these signals.
Changes to This Notice and How to Contact Us
Email: firstname.lastname@example.org. We will do our best to respond to your request within 24 hours.
We want to make sure you have control over your online travel experience as an Egencia customer, from planning and booking your travel to protecting your personal information. Egencia customer service travel agents are ready to help with your Egencia travel concerns 24 hours a day, seven days a week. You may also call at any time the customer service number given to you upon company sign-up. In addition, you may directly contact the travel supplier at the phone number or address provided on your travel itinerary.