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This policy describes ITN practices regarding personally identifiable information and data (“personal information”). This policy applies to our websites, applications, email and text messages, and social media accounts (the “Platforms”). When you use the Platforms, you agree to the terms in this policy.
The Platforms are not intended for children and we do not knowingly collect data relating to children.
ITN is the controller and responsible for your personal data.
Full name of legal entity: International Travel Network, LLC
Email address: firstname.lastname@example.org
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
1. Identity Data includes [first name, maiden name, last name, username or similar identifier, title, date of birth and gender].
2. Contact Data includes [billing address, delivery address, email address and telephone numbers].
3. Financial Data includes [bank account and payment card details].
4. Transaction Data includes [details about payments to and from you and other details of products and services you have purchased from us].
5. Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website].
6. Profile Data includes [your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses].
7. Usage Data includes [information about how you use our website, products and services].
8. Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].
Platform information: When you visit the Platforms, we may collect information from you. Some of it may be personal information. This information can include search history, IP address, screen resolution, browser used, operating system and settings, access times and referring URL. If you are using a mobile device, we may also collect data that identifies your device, your settings and your location.
Booking information: If you book a travel product via the Platforms, we may need additional information from you. This information can include your name (and traveler’s if different) name, age, birthday, gender, passport number, redress control number, email address, telephone number, credit card information, billing address, itinerary and frequent flyer details.
Information: We will collect your email address, password and home airport, and other preference information you provide us.
Consumer support: If you choose to contact our consumer support services we will collect any inquires, complaint or other information that you may submit to our support team.
When you give us personal information, you are telling us that the information is true, accurate, complete and current. You are also telling us that you have the authorization to provide it to us.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
Personal information you give to us: We collect your personal information directly from you. For example, when you provide us your personal information when you register or book travel, contact our customer support. This includes personal data you provide when you:
1. apply for our products or services;
2. subscribe to our service or publications;
3. request marketing to be sent to you;
4. give us feedback or contact us.
Personal information we collect passively: We also collect your personal information passively. For example, we collect information about you over time and across different Web sites when you visit this Platform. We also use tracking tools like cookies and beacons. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
Platform features may make use of your device attributes and settings that will allow us to determine your physical location. Such technologies may include IP address mapping, WiFi, GPS signals, cell tower positioning or other technologies. We use this information to enhance and personalize your experience and provide you with offers and services that may be of interest to you. For example, we may help you find your closest hotel or send you messages that may be of interest to you based on your current location. ITN does not have control over your device settings, but we do recommend enabling location services on your device so you can take advantage of the location based features and functionality offered.
Personal information we receive from third parties: We collect your personal information from third parties. This can include when you log in using a third party platform, such as Facebook. In addition, we also integrate third party software that collects information about users for security reasons.
We will only use your personal data when the law allows us to. Your personal information may be used in the following ways:
Improving our services: To provide you and improve our Platforms and services, to better understand the users of our Platforms and services, and to protect our property and to prevent damage to them.
Bookings: We and our travel partners use your personal information to process your bookings and store your itinerary information where applicable.
Marketing activities: We use your information for marketing purposes. These activities may include:
To communicate with you, including as follows:
Performance of a contract: The use of your personal information may be necessary to perform the services and provide you products that you have requested from us. For example, if you make a booking on our Platform, we need to collect personal information from you in order to complete the booking.
Legitimate interest: We may use your personal information for our legitimate interests, such as displaying relevant advertising and recommendations and for legal purposes.
Consent: We may rely on your consent to use your data for certain direct marketing purposes. You can withdraw your consent anytime by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||
|Performance of a contract with you|
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message.
Marketing email has an opt-out URL and you can unsubscribe from such communication at any time. You cannot unsubscribe from servicing emails and administrative messages.
Corporate affiliates and change of control: We may share your personal information with our corporate affiliates and if ITN itself (or part of its business) is sold or otherwise changes control, owners would have access to your personal information for the uses set out herein.
Service providers: We may share your personal information with suppliers who perform services on our behalf and have agreed in writing to protect and not further disclose your information.
Payment service providers and travel vendors: If you book through the Platforms, we may share your personal information with the payment service providers and the travel vendors you have booked with. This can include online travel agencies, hotels, airlines, car rental companies, and travel insurance providers. These third parties will process your personal information as data controllers in accordance with their own privacy policies. If you contact our consumer support, they may need to share information about your request with the relevant travel vendor in order to assist you.
Business partners: We may share your personal information with various business partners. Some of these business partners may use your personal information for fraud detection found, include, but not limited, for an email address, for detect, prevent, or otherwise address fraud, security or technical issues. We may also share your information for ask our partner to create a survey, form, application, or questionnaire, for the purpose to know the degree of your satisfaction with our services. Some of these business partners may use your personal information for online behavioral advertising purposes, or to offer you services or products that we believe you may be interested in. We may also share your information as otherwise described to you at the time of collection. We may also share anonymous aggregated usage information with partners.
We enter into confidentiality and data processing terms with partners to ensure they comply with high levels of confidentiality and best practice in privacy and security standards and we regularly review these standards and practices.
Trips shared by you: If you use or have itineraries as part of our Service, you can send or grant access to your itinerary to anyone you choose. Your itinerary may contain enough details (for example, booking reference codes) to allow the recipient to cancel or modify your booking, perform a check-in, etc. You should only share your itinerary with people you trust. If you choose to display your itinerary on publicly-viewable web pages (Facebook, for instance), that information may be collected and used by others.
Information shared in public: If you provide us a review of your trip, you authorize us to publish it on all our Platforms under the screen name you provided. You also authorize us to aggregate it with other reviews.
Authorities: We may disclose personal information if required by law, for example to law enforcement or other authorities. This includes court orders, subpoenas and orders arising from legal processes, and administrative or criminal investigations. We may also disclose your personal information if the disclosure is necessary for the prevention, detection or prosecution of criminal acts or to prevent other damage, or in response to a legal action or to enforce our rights and claims.
We may also share anonymous aggregated usage information with others.
Our servers and data centers are located in the U.S and our service providers may be located there and in other countries. By providing us personal information, you agree that your personal information may be transferred to and stored in these countries. These countries may have different and/or less stringent privacy/data protection and data security rules than those of your own country. As a result, your personal information may be subject to access requests from governments, courts, or law enforcement in those countries according to laws in those countries. Subject to the applicable laws in such other countries, we will provide the necessary safeguards to maintain protections of your personal information, e.g. by obtaining from the data recipients contractual commitments based on the EU model clauses.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you..
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
ITN does not knowingly collect personal information from minors. If we become aware that a minor is attempting to submit personal information, we will remove this information from our records. If you are the parent/legal guardian of a minor who has given us personal information, please contact us so we can delete it.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by contacting us at any time.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
1. If you want us to establish the data’s accuracy.
2. Where our use of the data is unlawful but you do not want us to erase it.
3. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
4. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We (or our suppliers) use several common tracking tools. We use these tools to collect usage and demographic information about you over time and across different Web sites when you use our Platforms. We also have third parties (e.g. advertisers) that collect personal information this way. Tools we use may include browser cookies. Your browser will store these cookies on your computer in a small file.
We and our advertising partners may also use web beacons (single pixel GIF images). These web beacons are placed in the code of a Web page or an email newsletter. When you access a partner site within our mobile applications, we may track your activity on that site.
By using the Platforms, you give us your free, unambiguous and informed consent to the use of any of the cookies and tracking tools mentioned in this policy.
ITN uses tracking tools for following purposes
Your browser may give you the ability to control cookies. How to do this varies from browser to browser. You should view the Help menu on the browser you use for further information. Your opt out choice is stored in opt out cookies only in that browser, so you should separately set your preferences for other browsers, computers, or devices you may use. If your browser blocks cookies, your opt out preferences may not be effective. Deleting browser cookies can remove your opt out preferences, so you should visit this page periodically to review your preferences. If you block or delete cookies or opt out of online behavioral advertising, not all of the tracking that we have described in this policy will stop.
Please also note that opting out of a third party cookie does not mean that you will no longer receive or be subject to online advertising or marketing. It means that the third party service from which you opted out will no longer deliver ads tailored to your web preferences and online behavioral.
Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. These features are not yet uniform, so we are not currently set up to respond to those signals.