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ITN (“ITN”, “we”, “our”, “us”) respects your privacy and is committed to protecting your personal information. This policy describes ITN practices regarding personally identifiable information or personal data (“personal information/ PI”). This policy applies to our websites, applications, email, voice calls and text messages, and social media accounts(the “Platforms”). When you use the Platforms, you agree to the terms in this policy.
TN is the company (business) responsible for your PI.
Full name of legal entity: International Travel Network, LLC
Email address: firstname.lastname@example.org
When you give us PI, 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 It is important that the PI we hold about you is accurate and current. Please keep us informed, if your PI changes during your relationship with us.
We may collect, use, store and transfer different kinds of PI about you which we have grouped together as follows:
Customer support If you choose to contact our customer support services we will collect any inquires, complaint or other information that you may submit to our support team. We do not collect any Special Categories of PI 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.
ITN does not knowingly collect PI from minors, except if the minor is one of travelers. If we become aware that a minor is attempting to submit PI, we will remove this information from our records. If you are the parent/legal guardian of a minor who has given us PI, please contact us so we can delete it.
Where we collect PI required by law or under the terms of a contract, and you fail to provide that PI 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 PI from and about
you including through:
PI you give to us We collect your PI directly from you (using life chat, online forms or via voice call/ messenger). Any contact data (emails, phones etc.) provided by you throughout any interaction will be treated as your personal contacts and saved in your profile for future communications, unless specifically requested not to be stored (one-time communication only). For example, when you provide us with your PI by requesting a quote, registering or booking travels, contacting our customer support. This includes PI you provide when you:
When we chat with you (e.g. WhatsApp, Facebook, regular sms etc.) the chat might be accidentally closed/ removed, there might be interruptions, slow internet connection etc. We may contact you later via automated phone and text messages or email (if available) in order to restore our communication started within the chat. No purchase necessary. You can opt out from further communication by replying to sms/ email or notifying us during the phone call.
One of the main collection methods are VOICE CALLS We have vested interest to ensure you have chosen the best possible option. Voice calls are an exclusive opportunity to provide you with an immediate customer support and disclose additional product features, you might not notice on website. Usually, we call back on your request. Sometimes there might be unfinished conversations regarding current flights (misunderstanding in live chat, email system error, poor internet connection etc.), which require immediate response. We don’t make unwanted telemarketing robocalls or any annoying advertising campaigns. You can opt-out this communication any time by contacting us via phone or email.
PI we receive from service providers: We collect your PI using service providers. This can include when you log in using a service provider platform, such as Facebook. In addition, we also integrate service providers` software that collects information about users for security reasons. The categories of PI ITN has collected/disclosed/sold for a business purpose in the preceding 12 months you can find HERE.
We will use your PI for the following purposes:
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.
Regular customers If you have ever requested a price quote or purchased our services, we treat you as the Regular (loyal) Customer. Regular Customers have plenty of benefits:
According to our policy, we may contact you as a Regular Customer via email/phone saved within previous requests and transactions. Such cases may be, for example, when you have accidentally provided the wrong email/phone or when you cannot be reached via email/ phone left in the last request/ purchase. If you want to opt-out, please contact us.
Bookings We and our travel partners use your PI to process your bookings and store your itinerary information where applicable.
Marketing activities We use your information for marketing purposes. These activities may include:
Performance of a contract The use of your PI 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 PI from you in order to complete the booking.
Consent We may rely on your consent to use your PI 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 PI.
|Purpose||Activity||Category of PI|
|To Complete the transaction, provide a service requested by you or otherwise perform a contract (ticket purchase; car rental; hotel booking etc.)||To register you as a new or a Regular customer / to start a business relationship||
To process and deliver your order including:
|For solely internal uses that are based on your relationship with us or compatible with the context in which PI was collected||
To manage our relationship with you which will include:
|To deliver relevant Platform content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||
|To use data analytics to improve our Platforms, products/services, marketing, customer relationships and experiences||
|To make suggestions and recommendations to you about goods or services that may be of interest to you||
|To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity||To administer and protect our business and Platforms (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
|To identify and repair errors that impair existing intended functionality||To administer and protect our business and Platforms (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
|To comply with a legal obligation||(a) To manage tax matters;
(b) Bookkeeping and accountancy of transactions;
(c) To manage consolidated reports and annual financial reports
(d) To comply with the requirements of licenses, registrations and permissions obtained by ITN, including industry standards (airline safety rules, PCI DSS etc.)
|To exercise or defend legal claims||(a) To manage complaints
(b) To comply with requests, subpoenas and other enforcement notices issued by regulators, courts and law enforcement agencies
(c) To protect and exercise legal claims of ITN before court, authority or law enforcement agency
We will only use your PI 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.
As a customer-oriented business we respect and value your expectations. As a result, you are able to make announcements and queries at any time regarding your concerns in privacy matters. Each of our marketing email has an opt-out button and you can change preferences or unsubscribe at all from such communication at any time. Each ITN website is targeted to the current audience and region, therefore subscribe/unsubscribe options are also different. You cannot unsubscribe from servicing emails and administrative messages.
Corporate affiliates and change of control We may share your PI 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 PI for the uses set out herein.
Service providers We may share your PI 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 PI with the payment service providers, acquirer banks 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 PI as data controllers in accordance with their own privacy policies. If you contact our customer 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 PI with various business partners. Some of these business partners may use your PI for fraud detection, including, but not limited Identifiers, Contact Data and Network Activity Information , also to detect, prevent, or otherwise address fraud, security or technical issues. We may also share your PI to ask our partner to create a survey, form, application, or questionnaire, so we know the degree of your satisfaction with our services. Some of these business partners may use your PI 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 PI 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 PI 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 PI 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.
We will only retain your PI 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 PI 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 PI, we consider the amount, nature and sensitivity of the PI, the potential risk of harm from unauthorised use or disclosure of your PI, the purposes for which we process your PI and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Under certain circumstances set by applicable law, you are entitled to:
Due to the remote nature of our services, it is important for us to keep communicating through the same email (Verified Email), which was used by you to request a price quote or purchase air tickets and other related services. The Verified Email is the key communication channel for us, so we can give quick answers and not to divulge your data to any malicious person. You might also submit request through the voice call, but still we must use the Verified Email to reply, due to law requirements and in order to protect our legal claims.
NONDISCRIMINATION: We shall not discriminate (deny services, charge different prices, provide different levels of quality) against you because you exercised any of the rights set herein. This right might be limited in case, if the difference in prices or levels or quality is reasonably related to the value provided to you by your PI. We might obtain your opt-in consent and provide to you financial incentives, so you agree to provide additional PI or not to request the deletion of your PI.
FEES and DENIALS: You will not have to pay a fee to access your PI (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive (more than twice in a 12-month period) or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We might also refuse to act on your request, when we are not in a position to identify you and verify your request. We may need to request specific information from you to help us confirm your identity and ensure your right to access your PI (or to exercise any of your other rights). This is a security measure to ensure that PI is not disclosed to any person who has no right to receive it. We may also contact you (via email, phone or messenger) to ask you for further information in relation to your request to speed up our response. Due to law limitations we might deny your request to know if you are asking us to disclose a high-risk data (e.g. SSN, driver's license number, financial account data, passwords etc.). In such cases we will definitely inform you that we have collected such types of information, unless prohibited from doing so by law.
TERMS: 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. The maximum response time shall not exceed 90 days.
CONTACTS: you can submit your complaint/ request to DPO email (see above).
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.
Cookies is a small piece of data sent from Platform and stored on your device (computer, smartphone etc.) by your web browser while you are browsing our Platforms and sometimes down the line1. Without Cookies it would be impossible to provide you information and services you are requesting through the Internet. Cookies remember stateful information (such as items added in the shopping cart in an online store) or record your browsing activity. They can also be used to remember arbitrary pieces of information that the user previously entered into form fields such as names, addresses, passwords and billing address.
By using the Platforms, you agree to the use of any of the cookies and tracking tools mentioned in this policy, unless you opted out (available only for some cookie types).
Functionality and Preferences Cookies Such Cookies help us to optimize and make more user-friendly our Platforms, enhance security level, facilitate faster and more convenient use of Platforms, receive valuable statistics in anonymized way, including, but not limited to:
In case we are collecting Cookies for statistical purposes, we are committed to apply a “functional separation” principle, so the results of the processing shall be without any negative impact to Your privacy or there should not be any decisions made against You. Retention period of Functionality Cookies usually is very short. In case of longer periods, please, be aware that we always assess the risk level of such processing, so it does not adversely affect Your privacy. Under the strict supervision we might allow service providers to collect Functionality Cookies on our Platforms in order to provide us with aggregated statistics. In such cases we require service providers to aggregate or erase data obtained from Your device.
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.
Your browser gives 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.