We may update this Policy from time to time. If we do, we will let you know about any material changed, either by notifying you on this site or by sending you an email. New versions of this policy will never apply retroactively -- we will tell you the exact date they go into effect. If you keep using ITS after a change, that means you accept this Policy.
Internet Travel Services (ITS), LLC is a global travel management company that focuses on guaranteed savings, advanced technology, and superior service all supported with a guaranteed ROI. Most important, we have adopted an employee culture, creating an environment where we put our employees first, with the intended result that our employees put our customers first.
Non-personal information is information that cannot be used to directly or indirectly identify a person. ITS automatically collects and stores non-personally identifiable information about you to ITS's Websites by tracking the name of the domain and host from which you access the Internet; the Internet protocol (IP) address of the computer you are using; the browsing software you use and your operating systems; the date and time you access our Websites; and the Internet address of the site from which you linked directly to our Websites. We use this information only as anonymous aggregate data to determine the number of visitors to different sections of our Websites, to ensure our Websites are working properly, and to help us make our Web sites more useful. ITS does not collect any other non-personally identifiable information.
Personal Information Personal information is information that can be used to directly or indirectly identify a person. Some examples of personal information are: name, home or email address, home telephone number, identification number (e.g. social security number or social insurance number), financial information and physical characteristics. ITS may collect personal information from you through ITS's Websites to respond to information requests from you about ITS's products and services, and for investor relations material. For example, customers that contact us are asked for their name, address, telephone number, store name/concept, number of stores and email address. Investors are asked for name, company, address, telephone number, email address and what type of investor relations material they are requesting. ITS also collects personal information from customers and business partners for general business purposes (specifically, reviewing customer credit and/or financial history, entering into contracts for products and services, processing orders and payments for products and services and providing support services to customer, all at customer's request).
ITS will only use the information you provide to us for the following actions:
The personal information you provide to us:
You may provide us with your personal data when you:
Whenever possible, we process your personally identifiable information (PII) based on your consent and according to our privacy policy and guidelines of the EU-U.S. Privacy Shield.
ITS may use third-party suppliers to collect, process, store, use, analyze and/or transfer the data on its behalf. We may share your PII with these third party vendors solely to enable them to perform the services for us. We require that those third party vendors maintain at least the same level of data protection that we maintain for such data. However, some of our vendors may process your data outside of the United States
We reserve the right to use, transfer, sell, and share aggregated, anonymous data, which does not include any PII, about our Website’s users as a group for any legal business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, clients, and customers.
We do not provide your PII to parties unconnected with the services we provide. Except as disclosed in this privacy notice, we will not provide your data to third parties.
We are not responsible for the processing of your PII or any of your information by any third party, other than those third parties acting as our subcontractors to process data on our behalf. ITS remains liable and responsible for the data processing operations undertaken by our subcontractors on our behalf.
If you do not want ITS to provide your contact information to a third party in order to offer you products and services related to the products and services that you purchase from ITS, you can choose to opt-out by contacting ITS Privacy Officer as instructed below.
When you access our Website, we automatically collect certain data about your use of our Website. We gather this information by using “cookies” and/or other technologies to collect non-personally identifiable information from your visits to our Website and your browser sessions to enhance your overall site experience and for statistical purposes. Cookies allow Website operators to better customize visits to the site based on each of your preferences. These cookies are used as a convenience to the customer to help them keep track of login information, recent reports viewed and other information in connection with their visit to ITS Website.
We may collect, process or transfer the following information about you: the name of the domain from which you access the Internet; the date and time you access our site; and the Internet address of the Website from which you linked directly to our site. We use the information we collect to measure the number of visitors to the different sections of our site, and to help us make our site more useful to visitors. We may transfer the information we collect to our corporate affiliates. You can set your browser to turn off “cookies” or to warn you when a Website attempts to place a “cookie” on your computer. However, if you turn off the “cookies,” our and other Websites may not work as intended.
ITS Websites follow industry-standard practices to protect the data we collect and maintain, including using Transport Layer Security (TLS) to encrypt information as it travels over the internet. Your account information is protected by a password, which you should choose carefully and keep secure. We have an Incident Response Team and protocol in place in the event of a data breach. We encourage the responsible disclosure of vulnerabilities of our services by emailing security_alerts@its.com.
Storage, Retention, and Accuracy of Personal Information ITS takes reasonable precautions to protect personal information from loss, misuse, or unauthorized access, disclosure, alteration or destruction. Personal information is maintained in secure electronic and manual files at ITS, and access to these files is limited to ITS employees for whom access is necessary to properly process the personal information consistent with the stated purposes. ITS will retain your personal information only for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws. We will retain and use this information as necessary for the purposed set out in this policy and to the extent necessary to comply with our legal obligations, resolve disputes, enforce our agreements and protect ITS’s legal rights. We take all reasonable steps to ensure that your personal information is accurate, up-to-date, complete, and reliable for ITS intended use.
ITS's Websites contain links to other Websites for your convenience and information. ITS is not responsible for the privacy practices, privacy statements, or the content of any Websites linked to ITS's Websites. ITS also has no control over whether the Websites linked to ITS's Websites use cookies to track information about visitors to their Websites.
ITS is a global organization, with business processes, management structures, and technical systems that cross borders. Our privacy practices are designed to provide protection for your personal information provided to us all over the world. We may share your personal information within ITS and transfer it to countries in the world where we do business. Some countries may provide less legal protection for your information. In such countries, we will still handle your information in the manner described in this policy.
EU-U.S. Privacy Shield Compliance ITS is a closely held technology partner of TSI USA, LLC, it is in compliance with the Privacy Shield program, which is administered by the International Trade Administration (ITA) within the U.S. Department of Commerce. The EU-U.S. Privacy Shield Framework was designed to provide companies on both sides of the Atlantic with a mechanism to comply with EU data protection requirements when transferring personal data from the European Union to the United States in support of transatlantic commerce. ITS has been Self-Certified in accordance with the EU Directive on Personal Data Protection. The principles of EU-US Privacy Shield Program are notice, choice, onward transfer, security, data integrity, access and enforcement. Additional information about Privacy Shield principles and to view ITS’s certification, as a covered entity of TSI USA, please visit https://www.privacyshield.gov.
Members of the European Union If you are a resident of a Member State of the European Union and have any concerns or complaints, please first address these issues to the Privacy Officer. ITS is located in the United States, as are the servers that make our websites available. All matters relating to privacy issues and websites are governed by the laws of the United State and the State of Texas. If the Privacy Officer does not satisfactorily address a complaint within thirty (30) days, any dispute, controversy or claim shall be settled by an arbitration administered by an arbitration agency.
We have appointed a representative in the EU and the UK to satisfy Article 27 requirements. Achieved Compliance Advocacy, Ltd is our representative. You may contact our representatives with any questions about our processing of personal data if you live in the EU or UK. The contact information is:
its@gdprrepresentative.eu or its@privacyrep.co.uk
You may contact our representatives by post at the following addresses:
Achieved Compliance Advocacy, Ltd.
Princess House
Princess House Way
Swansea, United Kingdom SA1 3LW
or
Achieved Compliance Advocacy, Ltd
Singel 250, 1016 AB
Amsterdam, Netherlands
ITS has further committed to refer unresolved Privacy Shield complaints to American Arbitration Association, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit AAA for more information or to file a complaint. The services of American Arbitration Association are provided at no cost to you. All arbitrations will be conducted in English. Judgment rendered by the arbitrator may be entered in any court having jurisdiction. Texas, U.S.A. shall be the site of all hearings, and such hearings shall be before a single arbitrator. You may also submit complaints to the Federal Trade Commission at https://www.ftccomplaintassistant.gov or via telephone at (202) 382-4537.
Binding Arbitration If your dispute or compliant can’t be resolved by ITS, nor by the panel established by the EU Data Protection authorities or through the Department of Commerce, you may have the right to require that ITS enter into binding arbitration with you pursuant to the Privacy Shield’s Recourse, Enforcement and Liability Principle and Annex I of the Privacy Shield.
During disclosures Required by Law, In certain circumstances, it is possible that your personal information may be subject to disclosure by us pursuant to judicial or other government subpoenas, warrants or orders.
ITS may decide to sell, buy, merge or otherwise reorganize businesses, whether for strategic or other business reasons. These business transactions may involve the disclosure of personal information to prospective or actual purchasers or the receipt of personal information from sellers. ITS shall seek appropriate protection for your personal information in these types of transactions.
Your Rights Users residing in certain countries, including the EU, are afforded certain rights regarding their personal information. Except where an exception or exemption applies, these rights include the ability to access, correct, and request deletion of your personal information. Users can manage their personal information, in their profile settings.
You may contact ITS's Data Protection Officer to access, correct or delete your personal information. In compliance with the Privacy Shield Principles, ITS commits to resolve complaints about our collection or use of your personal information. Individuals in the European Union with inquiries or complaints regarding our Private Shield policy should first contact ITS at:
Data Protection Officer by Phone (214) 915-9000 or 1-877-915-9009 FREE; by facsimile at: (214) 915-9080; by email at: dataprotectionofficer@its.com; or by mail at ITS, 8750 N. Central Expressway Suite 300, Dallas, Texas, 75231 USA, Attention: Data Protection Officer. We will respond to your inquiries within 30 days of receipt.
