2 Keys Travel LLC and its affiliates (“Company”) is a global travel services company that serves individual client travel needs and offers other travel related services. In order to deliver your services, it is necessary for us to collect and process your personal information. We care about your privacy. This Privacy Policy explains the policies and practices we follow to protect your personal information that we hold. This Privacy Policy applies to information we collect about you either through your use of Company websites (“Site(s)”) or through other means. The server(s) that make(s) this Site available may be located outside the country from which you accessed this site, but we will collect, process and use personal information only in accordance with this policy and as required by local law in the places in which we operate.
If you have questions not answered in this policy, our Privacy Officer may be contacted directly at [email protected].
What Personal Information Do We Collect?
We collect your personal information, and that of your travel companions, that is provided to us either directly by you or through a travel sponsor as the case may be, in order to provide you with the products and services you have requested. In most cases, it consists of • Full Legal Name
We may collect other information to assist you with your travel plans including but not limited to, passport number, driver’s license or other government-issued identification number, date of birth, gender, arrival and departure locations and times, airline, hotel or car rental frequent loyalty numbers, known traveler and global entry number, and other related travel information.
Information We Collect Through Automatic Data Collection Technologies
We collect other information, such as your IP address, search terms, and site pages you visit while on our Site, whenever you visit our Site, use our services, or view our online advertisements. The technologies we use for this automatic data collection may include cookies and log data.
You can learn more about how we use cookie data by reviewing our Cookie Policy which can be found in the “Cookie Policy“ section of this document.
Whenever you use a website, mobile application, or other internet service, certain information is created and retained by the website or application. This happens with our Site as well. We collect technical information when you use our Site, or information that has been made anonymous, such as:
• Log data: Our servers automatically record information when you use our Site, such as your IP address, the type of browser you are using and its settings, the third party website you visited immediately prior to accessing our Site, the operating system you are using, the domain name of your Internet service provider, the search terms you use on our Site, the
specific Site pages you visit, type of product selected, the brand, order, and product identifications, and the duration of your visits.
We may also collect information pertinent to the marketing of our products and services. This information may include marketing channels, User Market IDs (CenterPoint, TNMP, etc.), Site brands and product names, contract terms, financial information and other information.
We collect and analyze this information to measure the number of visitors to the different sections of our Site, to evaluate how visitors use our Site and to provide you with advertisements that are relevant and useful to you, unless you have told us not to. We also use the information we collect to understand customer needs and trends, to carry out targeted promotional activities, and to generally help us make our Site more useful to visitors.
We may use your Site data by itself or aggregate it with similar information we have obtained from others. We may share your Site data with our affiliates and other third parties to achieve these objectives. You may obtain a list of our affiliates and third parties with whom we share your Site data by contacting us at the address below.
We reserve the right to use Internet Protocol (IP) addresses to identify a visitor when we feel it is necessary to enforce compliance with our Site’s Terms and Conditions, or to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our Site, or other users; or (d) in an emergency to protect the health and safety of our Site’s users or the general public.
How We Use Your Information.
If you are a customer, an agent, an employee, or a job applicant, the personal information we hold and use is necessary for the performance of the services contract or independent contractor or other agreement to which you are a party or to perform the services you have otherwise requested.
If you are a prospective customer, the personal information we collect and use is necessary for our legitimate interest in providing you with information about the services we offer, and about which you have expressed an interest or that we believe will be of benefit to you. Where appropriate, we will obtain your consent at the time we communicate with you. In some cases, our purpose for collecting the information is because you have expressly consented to our collection and use of your personal information.
We collect your personal information for a variety of reasons. You may provide the information to us directly, or through a tool or product provided by Company or another organization to your employer in the case of our business clients. We collect your personal information, such as name, address, email address, phone number, and credit card information in order to provide the services you have requested. Other examples of personal information that we collect include:
Doing Business with You. We use the personal information we have collected to allow us to evaluate your employment application, to provide the products and services you have chosen, process payments, or to manage and develop our business and operations, including:
Email communications: If you send us an email with questions or comments, we may use your email address to respond to your questions or comments, and we may save your questions or comments for future reference. We may email you when:
How Do We Use Preference Based Advertising, Analytics, and Services? Disclosures As Required By Law
We do not currently share your information that we collect for preference-based advertising purposes and we do not currently have any plans to do so through this Site.
If we do in the future work with third parties for preference-based advertising, then we will do so in accordance with this section and you can opt out as explained below. Such third parties may include third party advertising networks and website analysis firms who
use cookies and web beacons to collect non-personally identifiable information when you visit our Site and third-party sites. The information collected through cookies and/or web beacons, including your IP address, web browser, pages viewed, time spent on pages, and links clicked, is often used by these advertising networks to serve you with advertisements, while you are on our Site and/or on third party sites, that better reflect your preferences and needs. This information may be used by Company and these third parties to analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our products and services, and better understand your online activity. For more information on how this type of advertising works, go to http://www.aboutads.info/.
Who Else Do We Share Your Information with and Why?
We may share your personal information with one or several of our business partners to make an initial determination of the services you may need, to process your employment application, or to otherwise facilitate our business operations. We also share your personal information as necessary with airlines, hotels and other providers for whose services you have requested our assistance. We may also share your information to protect and defend the rights and property of Company.
Third Party Providers: We may use third parties to assist in processing your employment applications, fulfilling your service requests, or providing other important information to you. We require all such service providers to act in compliance with this Privacy Policy. We may also share your personal information with third parties, including our affiliates, or with employees, agents, consultants and other parties who require the information to assist us to establish, maintain and manage our business relationship with you. Further, we may share your personal information with our partners and affiliates to promote other services to you that you might like or to show you ads in which you might be interested.
Email Communications: We may share your email contact information with our partners to assist with marketing our products and services. You may unsubscribe from receiving future commercial email communications from us by clicking the “unsubscribe” link included at the bottom of any marketing emails we send, or by emailing us as provided in the “Contact Us” section below. However, we reserve the right to send you transactional emails such as customer service communications in connection with the products or services you have purchased. For security reasons, we do not recommend that you send personal information, such as passwords, social security numbers, or bank account information, to us by email.
Transfer of Assets: We do not sell or lease personal information or provide a list of our customers to third parties. However, as we continue to develop our business, we may sell or purchase assets. If another entity acquires us or all (or substantially all) of our assets, the information we have about you will be transferred to and used by this acquiring entity. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.
Legal Necessity: Notwithstanding anything herein to the contrary, we reserve the right to disclose any information about you if we are required to do so by law, with respect to
copyright and other intellectual property infringement claims, or if we believe that such action is necessary to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, or our Site; or (d) in an emergency to protect the health and safety of our Site’s users or the general public.
What Choices Do You Have About Our Use of Your Information?
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
Accuracy of Personal Information: It is important that the personal information we hold about you is accurate and current. Company requires you to keep us informed of changes to your personal information. If your registration information changes, please send your request to us at the email address below. We take reasonable steps to verify your identity prior to honoring any such requests to help protect your privacy and security.
Accessing Your Personal Information: If you want to know what personal information Company holds about you or wish to change personal information that is inaccurate or out of date, or to withdraw your consent to our use of your personal information, please contact us at the email address below. It may not always be possible to completely remove or modify information in our databases, although we will make reasonable efforts to do so upon your request. We do not control how our partners retain, store and destroy data they have accessed in connection with assisting with providing our services. You should check their websites for more information on their practices.
Do Not Track Disclosures: Certain browsers may offer you the option of providing notice to websites that you do not wish for your online activities to be tracked for preference-based advertising purposes (“DNT Notice”). Some browsers are, by default, set to provide a DNT Notice, whether or not that reflects your preference. Providing DNT Notice is often touted as a means to ensure that cookies, web beacons and similar technology are not used for preference-based advertising purposes – that is, to restrict the collection of information your online activities for advertising purposes. Unfortunately, given how preference-based advertising works, DNT Notices may not effectively accomplish this goal. For this and a variety of other reasons, with respect to our Site, we do not take any particular action based on browser based DNT Notices. However, we do not use third-party advertisers or engage in behavioral marketing data collection for resale. Rather, if you do not wish to participate in preference-based advertising activities, you should follow the opt-out process identified above.
Your California Privacy Rights
If you are a resident of the State of California, you have certain rights under California law to request information concerning our data sharing activities with third parties.
Residents of the State of California, under certain provisions of the California Civil Code, have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed certain personally identifiable information as defined under California law during the preceding year for third party direct marketing purposes. You may request the information in writing at the email address below. You may learn more about your rights under California’s privacy laws at https://oag.ca.gov/privacy Safeguarding Personal Information
We take the security of your information very seriously. We have implemented industry standard security measures to protect against the loss, misuse and alteration of the information under our control. To help ensure the confidentiality of your personal information, it is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off / log out when finished using a shared computer. Company will endeavor to safeguard personal information using methods that are appropriate to the sensitivity of the information. We have implemented security measures we consider reasonable and appropriate to protect against the loss, misuse and alteration of the personal information under our control. However, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and are not responsible for the theft, destruction, or inadvertent disclosure of your personal information. In the unfortunate event that your information is compromised, we may notify you by e-mail or U.S. mail to the last e-mail address or postal address you have provided us in the most expedient time reasonable under the circumstances, or as otherwise required by applicable law. We may delay notification as necessary while we take measures to determine the scope of the breach and restore reasonable integrity to our system as well as for the legitimate needs of law enforcement. From time to time we evaluate new technology for protecting information, and when appropriate, we upgrade our information security systems.
Privacy of Children’s Information
Our Site is not directed to children. We do not sell products or services for purchase by children. We will not knowingly collect personal information from children. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed personally identifiable information to us, please contact us at the email address below. A parent or guardian of a child under the age of 13 may review and request deletion of such child’s personally identifiable information as well as prohibit the use of that information. Linked Sites
This Policy does not apply to your use of unaffiliated websites to which our Site is linked. Company is not responsible for the privacy practices or the content on linked sites. We recommend that you carefully read the privacy policies of each site you visit.
Sole Statement
This Privacy Policy as posted on this Site is the sole statement of our privacy policy with respect to this Site, and no summary, modification, restatement or other version thereof, or other privacy statement or policy, in any form, is valid unless we post a new or revised policy to the Site.
Contacting Us
To get more information about Company’s privacy and information security practices, or if you (a) have questions or comments about our Privacy Policy; (b) wish to make corrections to any personal information you have provided; (c) want to opt-out from receiving future commercial correspondence, including emails, from us or our affiliated companies; or (d) wish to withdraw your consent to sharing your personal information with others, contact us as follows:
By Email: [email protected]
Changes to This Policy
Company may from time to time make changes to this Privacy Policy to reflect changes in legal or regulatory obligations or changes in the manner in which we deal with personal information. We will post any revised version of this Privacy Policy on our Site. Any changes will be effective on the effective date stated in the revised Privacy Policy. If there are significant changes we may provide more prominent notice or obtain your consent as required by law. If you do not wish to accept the changes, you should cease using the Site. Your continued use of the Site after we have posted a revised Privacy Policy indicates your agreement to the revisions.
This Privacy Policy was last updated on April 15, 2020 and applies to 2 Keys Travel LLC brands.
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