Traverse360 Global Privacy Policy and Notice

Last updated September 2023

Your Privacy is Our Priority

Traverse360, along with its affiliated entities, specializes in providing top-notch corporate travel management services to businesses of all sizes, governmental agencies, and non-governmental organizations around the world.

We are deeply committed to safeguarding your privacy by ensuring the proper collection, use, and protection of your personal information, which may be received from our corporate clients and their employees, contractors, or guests.

This Global Privacy Policy and Notice outlines the personal information we gather, how we utilize and share it within the scope of our services, and your associated rights.

Why Do We Collect Your Personal Information and Under What Legal Basis?

Traverse360 collects personal information from our corporate clients, their employees, contractors, or guests (referred to as “travelers and attendees”) for the execution of commercial agreements related to travel, hospitality, meetings, and event services. Specifically, we collect and process personal information for the following purposes:

Managing travel, transportation, hospitality, meetings, and event reservations and bookings.
Assisting with visa applications.
Handling event badges, stationary, catering, and audio-visual services.
Reporting on corporate clients’ travel policy compliance and travel expenses.
Managing corporate clients’ travel spend and budget analysis.
Quality assurance and training.
Fraud detection and prevention.
Managing corporate client relationships, account administration, reconciliation, and invoicing.
Communicating travel information, itineraries, safety alerts, and fare optimization.
Providing customer support online and offline.
Conducting travel satisfaction surveys.

Additionally, we process personal information for sanction screening to comply with international laws and regulations. When collecting meal preferences that may reveal religious beliefs or health data (considered special categories of personal data under European data protection laws), we rely on prior consent.

What Personal Information Do We Collect?

We gather various types of personal information to fulfill our services effectively, including but not limited to:

Name, surname, phone number, email, address, country of residence.
Company name and job title.
Employee identification number.
Internet Protocol (IP) address.
Gender, date, and place of birth.
Payment card information.
Travel preferences (e.g., seat, meal, smoking, special assistance services).
Government-issued photo identification documents (passport or identity card).
Visa details.
Emergency contact information.
Ticket number and itinerary details.
Fare information.
Frequent flyer and loyalty card information.
Information related to travel requests.
Occasional audio recordings for quality assurance.

How Do We Collect Your Personal Information?

Upon establishing commercial agreements with our corporate clients, Traverse360 typically collects a minimal set of personal information (name, business email and address, employee number, job title) and creates an online ‘self-service Traveler Profile’ in our proprietary Profile Management database. Travelers or their authorized travel arrangers may enter additional personal information, as needed, in compliance with corporate travel policies and Traverse360 terms and conditions.

For meetings and events, we receive minimal personal information about attendees from our corporate clients, and this information may also come from online booking service providers contracted by the client.

With Whom Do We Share Your Personal Information?

To fulfill our service objectives, Traverse360 shares your personal information with relevant third-party service providers, including:

Travel suppliers (e.g., airlines, hotels, car rental companies).
General Distribution Systems (GDS), facilitating preliminary reservations with travel suppliers.
Online Booking Tools (OBT) as Profile Management tools, chosen by corporate clients.
Safety and security service providers.
Card payment companies.
Governmental bodies, as required by applicable laws.
Providers of conference badges, stationary, catering, and audio-visual services.

Additionally, our corporate clients may request that we share traveler or attendee information with designated third parties of their choice, as part of the services we provide. We employ third-party subcontractors for managing our information technology tools and platforms, ensuring they adhere to Traverse360 policies, procedures, and applicable data privacy laws.

Traverse360 reserves the right to disclose your personal data if required by law or in good faith belief that such action is necessary to comply with applicable regulations.

Cross-Border Transfers of Your Personal Data

Traverse360’s global travel services involve cross-border transfers of personal data within the Traverse360 group, its affiliates, joint ventures, and external partners as described above. We take measures to ensure your data is protected when transferred to countries without data protection laws similar to those in your country of residence. This includes using appropriate data transfer agreements, such as European Standard Contractual Clauses issued by the European Commission.

Storage of Your Personal Data

Due to our global presence, Traverse360 stores personal data in various locations worldwide. The residency of the traveler determines where their Traveler Profile information is stored. European resident data are stored in a data center in Spain, while data from other residents are stored in a U.S.-based data center. Financial data is regionally stored in data centers in the U.S., Spain, and Singapore. Personal information collected in the People’s Republic of China is stored in China.

Ensuring the Security of Your Personal Data

We continually implement and maintain administrative, organizational, technical, and physical security measures to ensure the confidentiality, integrity, availability, and resilience of our systems that process your personal data.

Retention of Your Personal Data

We retain your personal data for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, and within limits prescribed by applicable regulations. For more details, please refer to our Retention Policy.

Compliance with This Policy and Data Protection Laws

Traverse360 is dedicated to complying with this Global Privacy Policy and Notice as well as applicable data protection and privacy laws, including but not limited to:
The European General Data Protection Regulation (GDPR).
The UK Data Protection Act (UK DPA).
The California Consumer Privacy Act (CCPA).
The Brazilian Law for the Protection of Personal Data (LGPD).
The Australian Privacy Act.
The Singaporean Personal Data Protection Act.
The Chinese Cybersecurity Law (CSL).
The Chinese Data Security Law (DSL).
The Chinese Personal Information Protection Law (PIPL).

Direct-Marketing Data Protection Notice

We may use your personal contact information to send you direct-marketing communications. You may receive these communications because you or your company have requested them, or because we believe they are of interest based on the services we provide to you.

If you no longer wish to receive direct-marketing communications, you can click on the ‘unsubscribe’ link at the bottom of the communication. We rely on our legitimate interests to keep you informed about our products and services.

Your Rights

You have several rights concerning your personal data under applicable data protection laws, including the right to access, rectify, and erase your personal data where pertinent. Depending on your country of residence, you may also have the right to restrict processing, data portability, and the right to object to processing based on legitimate interests.

If you wish to exercise your rights, please complete our Subject Access Request (SAR) Form, which will initiate the processing of your request.

Contact Information

To contact Traverse360’s Data Protection Officer with questions or concerns about this Global Privacy Policy and Notice, please use data.protection@traverse360.com. Depending on your country of residence, you may also have the right to lodge a complaint with your local supervisory data protection authority.

For Traverse360 Employees

For Traverse360 employees, personal information processing for employment-related purposes is subject to internal company policies and notices.

List of Traverse360 Entities

This policy is subject to change. Any modifications will be posted periodically on Traverse360 websites, so please ensure you check this policy regularly.

At Traverse360, your privacy and data protection are of utmost importance, and we remain dedicated to upholding the highest standards in safeguarding your personal information.

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