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Conlin Travel Privacy Policy


Last Updated: May 23, 2018

Purpose

We at Conlin Travel, Inc provide this Privacy Policy to explain our practices regarding the collection, use and disclosure of information we receive through our Services. This Privacy Policy is incorporated by reference into the Conlin Travel Terms of Service (the “Terms”). The terms “Conlin Travel,” “we,” and “us” include Conlin Travel, Inc. our affiliates and subsidiaries.

This Privacy Policy explains our online and offline information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can opt out of a use or correct or change such information. Also, please note that, unless we define a term in this Privacy Policy, all capitalized terms used in this Privacy Policy have the same meanings as in our Terms of Service. Therefore, please be sure you have read and understand our Terms of Service.

Scope

This Privacy Policy applies to Personal Information that is Processed by Conlin Travel, Inc in the course of business, including on Conlin Travel websites (each a “Site”), mobile applications, event registration sites, and other online or offline offerings (together with any and all future online and offline offerings operated by or on behalf of Conlin Travel, the “Services”). This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services. All individuals whose responsibilities include the Processing of Personal Information on behalf of Conlin Travel, Inc are expected to protect that data by adherence to this Privacy Policy. This Privacy Policy is intended to meet requirements globally, including those in North America, Europe, APAC, and other jurisdictions. The primary third parties accessing your information through Conlin Travel are Sabre and Concur SAP. Pursuant to the agency's policies, Sabre and Concur SAP will not sell or give the personal information individuals provide through the use of any Sabre or Concur SAP product or service to any unaffiliated party other than those involved in providing the requested transportation or Services without the individual's permission, except when required by law or when data is requested by government or law enforcement authorities or in the unlikely event of a sale of the business or transfer of assets.

Other third parties that access your information include but are not limited to airlines, hotels, car rental agencies, and tour operators. Conlin Travel, Inc cannot guarantee the privacy of information you provide to those sites. Conlin Travel employees who have access to customer information have signed confidentiality agreements for data made available to them during their course of employment at Conlin Travel, Inc.

Transparency Notice –Personal Information We Collect and How We Use It

Our primary goals in collecting information are to provide and improve our Services, to administer your use of the Services (including your Travel Profile), provide support for our Services and to enable you to easily navigate our Services. The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Conlin Travel, Inc and the requirements of applicable law. Some of the ways that Conlin Travel, Inc may collect Personal Information include:

  • You may provide Personal Information directly to Conlin Travel, Inc through interacting with the Services, making travel reservations through online and mobile booking tools licensed from a third party, speaking directly with a travel agent, through email, event registration and profile creation.
  • Your requests for support or information on Services, participation in surveys, and during events such as sweepstakes.
  • As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.

We collect only information relevant for the purposes of completing reservations, fulfillment of requested Services and providing support. Below are the ways we collect Personal Information and how we use it.

Types of Personal Information We Collect

Conlin Travel collects Personal Information regarding current and prospective clients, customers, users, visitors and guests. (collectively “Individuals”).

Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as creating a profile to secure travel reservations, registering for an event, responding to surveys, requesting Services or information, we may ask you to provide some or all of the following types of information:

  • Creating a Travel Profile. Before a traveler takes their first trip we will request specific personal information to insure a high service level for each trip. This personal information may include but is not limited to home phone numbers, credit card numbers, passport and visa information, birth dates, frequent flyer information, hotel and car id numbers, office address and phone numbers. In addition, we ask for email addresses to facilitate delivery of travel information including invoices, trip itineraries and trip specific updates.
  • Communications with Us. We may collect Personal Information from you such as email address and phone number when you choose to request information about our Services, create a profile, request to receive customer or technical support, or otherwise communicate with us.
  • Surveys. From time to time, we may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products, Sites and/or Services and in any manner consistent with the policies provided herein.
  • Registration for Sweepstakes or Contests. Occasionally, Conlin Travel, Inc may run sweepstakes and contests. We ask those who enter in the sweepstakes or contests to provide contact information (e.g., an e-mail address). If you participate in a sweepstakes or contest, your contact information may be used to reach you about the sweepstakes or contest and business purposes. All sweepstakes/contests entry forms will provide a way for participants to opt-out of any communications that are not related to awarding prizes.
  • Automatic Data Collection. Our servers automatically record certain information about how Individuals use our Services (we refer to this information as “Event Data”). Event Data may include information such as an Individual’s Internet Protocol (IP) address, cookie identifiers, MAC address, IMEI, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, operating system, browser type and language, hardware type, the web page that a User was visiting before accessing our Services, the pages or features of our Services to which a User browsed and the time spent on those pages or features, search terms, the links on our Services that a User clicked on and other statistics. We use Event Data to administer the Services and we analyze (and may engage third parties to analyze) Event Data to improve, customize and enhance our Services. We may use a person’s IP address to generate aggregate, non-identifying information about how our Services are used.
  • Location Information. We may collect and store information about your location by converting your IP address into a rough geo-location. If you do not want us to collect location information, you may disable that feature on your mobile device.

How Conlin Travel, Inc Uses Your Information

We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:

To Provide Products, Services, or Information Requested. Conlin Travel may use information about you to fulfill requests for Services, provide information, and technical support, including to:

  • Generally manage Individual information and Profiles;
  • Respond to questions, comments, and other requests;
  • Provide access to certain areas, functionalities, and features of Services;
  • Contact you to answer requests for customer support or technical support;
  • Allow you to complete surveys.

Administrative Purposes. Conlin Travel, Inc may use Personal Information about you for its administrative purposes, including to:

  • Provide overall metrics about our Services;
  • Ensure internal quality control;
  • Verify Individual identity;
  • Communicate about Individual Activity as requested in reporting Services;
  • Send email to the email address you provide to us to verify your Profile and for operational purposes, such as Profile management, customer service, or system maintenance;
  • Process payment for products or services purchased;
  • Process transactions;
  • Prevent potentially prohibited or illegal activities;
  • Enforce our Terms.

Marketing Conlin Travel, Inc Products and Services. Conlin Travel, Inc may use Personal Information to provide you with materials through our Customer Relationship Management tools about industry information, industry announcements, Conlin Travel, Inc announcements, products, and Services that may be of interest. Conlin Travel, Inc may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law.

Research and Development. We may share aggregated information and non-identifying information with third parties for industry research and analysis, demographic profiling and other similar purposes.

Cookies, Pixel Tags/Web Beacons and Analytics Information

We, as well as Third Parties that provide content or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a "device") that allow us to record certain pieces of information whenever you visit or interact with our sites, services, applications, messaging, and tools, and to recognize you across devices.

  • Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.

  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular link.

  • Social Media Widgets: Our Website includes social media features such as the Facebook “Like” button and LinkedIn (that might include widgets such as the share this button or other interactive mini-programs). These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy policy of the company providing it.

  • Analytics. We use Google Analytics, a service provided by Google, Inc. (“Google”), to gather information about how users engage with our Services. For more information about Google Analytics, visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.

Our uses of such Technologies fall into the following general categories:

  • Operationally Necessary. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our sites, services, applications, and tools. This includes technologies that allow you access to our sites, services, applications, and tools; that are required to identify irregular site behavior, prevent fraudulent activity and improve security;
  • Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our websites, applications, services, and tools, including as part of our analytic practices to help us understand how our visitors use our websites, determine if you have interacted with our messaging, determine whether you have viewed a link, or to improve our website content, applications, services, or tools;

If you would like to opt out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.

Third-party websites, Social Media platforms, and Software Development Kits

The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and Conlin Travel, Inc does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

Third-Party Payment Processing

When you make purchases through the Services, we process your payments through a Third-Party application. The Third-Party application may collect certain financial information from you to process a payment on behalf of Conlin Travel, Inc, including your name, email address, address and other billing information.

Onward Transfer - Conlin Travel, Inc May Disclose Your Information

Information We Share

We may share your information as described in this Privacy Policy (e.g., with our Third-Party service providers; to comply with legal obligations; to protect and defend our rights and property) or with your permission.

  • Information Shared with Our Services Providers. We may engage third-party services providers to work with us to administer and provide the Services. Some of examples of these third-party’s services are online booking tools, payment processing, registrations and surveys. These third-party services providers have access to your Personal Information only for the purpose of performing services on our behalf and are expressly obligated not to disclose or use your Personal Information for any other purpose. Conlin Travel, Inc has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
  • Business Partners. Conlin Travel, Inc may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. Conlin Travel, Inc requires our affiliates and business partners to agree to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Conlin Travel, Inc provided them.

  • Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other Account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Conlin Travel, Inc policies or contracts; (v) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vi) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.

Data Transfers

All Personal Information collected via or by Conlin Travel, Inc may be stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, and on the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Conlin Travel, Inc you consent to the storage of your Personal Information in these locations.

Opt-Out (RIGHT TO RESTRICT PROCESSING)

General

We offer you choices regarding the collection, use and sharing of your Personal Information, and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Information that we request, we may not be able to fulfill Services. You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to Conlin Travel, Inc Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting eservices@conlintravel.com. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on Third-Party websites for non-interest based purposes.

Email and Telephone Communications

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding Conlin Travel, Inc and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy).

We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.

Rights of Access, Rectification, Erasure, and Restriction

You may inquire as to whether Conlin Travel, Inc is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate. Where otherwise permitted by applicable law, you may send an email to eservices@conlintravel.com or use any of the methods set out in this Privacy Policy to request access to, receive, seek rectification, or request erasure of Personal Information held about you by Conlin Travel, Inc. Please include your full name, email address associated with your Account, and a detailed description of your data request. Such requests will be processed in line with local laws.

Data Retention

Conlin Travel, Inc retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

Security of Your Information

We take reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you (including your PII) from unauthorized access, use, or disclosure. When you enter sensitive information on our forms, we encrypt this data using SSL or other technologies. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.

By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.

International Users

By using our Services, Conlin Travel, Inc will transfer data to the United States. By choosing to visit the Site, utilize the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of Michigan, United States and the adjudication of any disputes arising in connection with Conlin Travel, Inc or the Site will be in accordance with the Terms.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.

Redress/Compliance and Accountability

If you have any questions about our privacy practices or this Privacy Policy, please contact Conlin Travel, Inc by email at eservices@conlintravel.com. We will address your concerns and attempt to resolve any privacy issues in a timely manner.

Other Rights and Important Information

Changes To Our Privacy Policy and Practices

This Privacy Policy may change from time to time. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Services after the updated Privacy Policy is posted on the Services. If at any point you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the Services.

  • Revision to the Privacy Policy. Any information that is collected via our Services is covered by the Privacy Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time in our sole discretion, so review it periodically. If we make any material changes to this Privacy Policy, we’ll endeavor to notify you of those changes by posting them on the Services or by sending you an email or other notification, and we’ll update the “Last Updated Date” above to indicate when those changes will become effective.
  • Posting of Revised Privacy Policy. If there are any material changes to this Privacy Policy, Conlin Travel, Inc will notify you by email or as otherwise required by applicable law. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective immediately when it is posted (or upon notice as applicable). If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.
  • New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Conlin Travel, Inc will endeavor to comply with the law or contract.