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Chase Travel Corporate Solutions Privacy Policies

Click on the links below to learn more about the privacy policies that apply to Chase Travel Corporate Solutions.

FROSCH Privacy Policy - covers each of the Chase Travel Corporate Solutions divisions: Corporate Travel; Groups, Meetings & Incentives; Consulting Services; and Entertainment Travel
cxLoyalty Privacy Policy - covers Chase Travel Partner Solutions
cxLoyalty Privacy Notice Canada - covers the Chase Travel Partner Solutions business in Canada

FROSCH Privacy Policy

This privacy policy covers each of these Chase Travel Corporate Solutions divisions: Corporate Travel; Groups, Meetings & Incentives; Consulting Services; and Entertainment Travel.

Effective Date: January 2020

Frosch International Travel LLC, dba Chase Travel, respects your privacy and is committed to honoring the confidence our clients, business partners and our workforce place in us. We have created this Privacy Notice to demonstrate our firm commitment to data protection and compliance with global privacy laws. This Privacy Notice outlines how we handle data that can be used to directly or indirectly identify an individual ("Personal Data").

Who We Are

Frosch International Travel LLC and its Affiliates (FT Global LLC and FT Travel LLC), (collectively known as "Frosch International Travel", "FROSCH", "we" or "us") is a global travel services company that serves corporate and individual client travel needs and other travel related services. Our FROSCH international headquarters are located at One Greenway Plaza, Suite 800, Houston, TX, 77046 in the USA, and we have offices in 40+ countries around the globe.

In this Privacy Policy (the "Policy" or "Notice):

"third party" means someone who is not you or us

"FROSCH International Travel" means FROSCH International Travel LLC and any company or other organization in which FROSCH owns more than 15% of the company

FROSCH International Travel is the Data Processor within the meaning of the General Data Protection Regulation ("GDPR") for global Corporate Travel Management services on behalf of its clients
FROSCH International Travel is the Data Controller within the meaning of the General Data Protection Regulation ("GDPR") for frosch.com and related travel websites; Workforce Administration (including Recruitment) and Leisure related Travel services
FROSCH UK Ltd. is the EU Data Controller within the meaning of the General Data Protection Regulation ("GDPR") for EU Workforce Administration (including Recruitment) and EU Leisure Travel services

FROSCH's data protection officer can be contacted at DPO@frosch.com.

Personal Data We Collect

We collect your Personal Data for a variety of reasons. You may provide the data to us directly, or through a tool or product provided by us or another organization, or to your employer in the case of our business clients.

Corporate Business Travel Services

We collect your Personal Data, and that of your travel companions, either directly from you or through your employer or travel sponsor, in order to provide you with the travel-related services. In most cases, it consists of

Full Legal Name
Email address
Postal address
Phone number
Credit card number or other payment information

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 and accommodations, hotel or car rental frequent loyalty numbers, TSA Known Redress Number and global entry number, Ticket/Document number and other related travel information.

We may receive Personal Data from your employer or travel sponsor, such as your name, job title, employer name, employee identification number/employee ID, email address, work address, and your phone number.

Leisure Travel Services

We collect your Personal Data, and that of your travel companions, directly from you or through a tool or product provided by us or another organization, in order for us to deliver the travel-related services you have requested. In most cases, it consists of

Full Legal Name
Email address
Postal address
Phone number
Credit card number or other payment information

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 and hotel accommodations, hotel or car rental frequent loyalty numbers, TSA Known Redress Number and global entry number, Insurance details, relevant medical data and any special, dietary, religious or disability requests, Ticket/Document number and other related travel information.

Website Data Collection

On our Website through contact forms, job applications or marketing events, we may collect the following information from you that may constitute Personal Data:

Name
Job title
Company name
Type of Industry
Phone number
Email address
Your account login details, such as your username and the password you chose
Details about your travel interests and comments that may include Personal Data
Individual public testimonials
Job Applications: Information included in your job application including, but not limited to, information included in your resume.

Information We Collect Through Automatic Data Collection Technologies

Whenever you visit our Site, use our services, or view our online advertisements, the website software automatically collects the following information, some of which may be considered Personal Data:

Website use event data, such as: which links or buttons you have clicked, search terms and the pages you have viewed
Travel and Social preferences, interests and activities
The type of device you are using to access the Website
The IP address from which you access the Website
The name and version of the device operating system
The logging technology used on the Website automatically collects the URL of the site from which you came and the site to which you are going when you leave the Website
Cookie Data: A "cookie" is data that a website server stores on your computer. Cookies enable websites to recognize your computer and to "remember" your entries as you move from page to page, or even when you revisit the site from time to time using the same computer
Google Analytics: By using cookies, Google Analytics collects and stores data such as time of visit, pages visited, time spent on each page of the website, the IP address, and the type of operating system used in the devices used to access the Website. By using a browser plugin provided by Google, you can opt out of Google Analytics

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.

Other sources of Personal Data

We may use Personal Data from other sources, such as affiliates and 3rd parties that supply information, retail partners and public registers
Your insurance company, their agents and medical staff may exchange relevant Personal Data and special categories of Personal Data with us in circumstances where we/they need to act on your behalf or in the interest of other customers or in an emergency.
If you log-in using your social network credentials to connect to our platforms and online services e.g. Facebook, Google+ and Twitter, you will agree to share your user details with us. For example, your name, email address, date of birth, location and any other information you choose to share with us.

How we use Personal Data

We use Personal Data for the following purposes:

Legal Basis for Personal Data

We will only collect and use your Personal Data, if at least one of the following conditions applies:

A contract is in place with you, such as for travel management. We need to process your Personal Data so that we can manage your account or booking, provide you with the products and services you want to buy, and help you with any bookings, cancellations and refunds.
FROSCH has legitimate business interests, for example: fraud prevention, maintaining the security of our network and services, and the improvement of our services. If you are a prospective customer, the Personal Data 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. Whenever we rely on this lawful basis to process your data, we assess our business interests to make sure they do not override your rights. Additionally, in some cases you have the right to object to this processing. For more information, visit the 'Your rights' section of this policy
Compliance with a mandatory legal obligation, for example, sharing Personal Data with regulatory authorities so you can travel. It may be mandatory (as required by government authorities, such as US secure flight data) to disclose and process your Personal Data for immigration, border control, security and anti-terrorism purposes.
It is necessary to protect your vital interests or those of another individual, for example: in an emergency your insurance company or medical staff may exchange relevant Personal Data and Special categories of Personal Data with us in circumstances where we/they need to act on your behalf.
We have your consent. For instance, you give us permission to process your Personal Data when you register for a customer account. When you give us your consent, you will be given details on how to change your mind or visit the 'Your rights' section of this policy for more information.

How we share Personal Data

We may disclose the Personal Data we collect to the following:

The global distribution systems ("GDS"), a software-based service for making travel reservations;
Service providers such as Travel Suppliers or other third-party service providers necessary to the operation of our business. We require all such service providers to act in compliance with this Privacy Policy
Other 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.
Our clients that request the data relating to travel services utilized by their employees;
Our corporate clients as part of their operational and financial corporate travel management
Subcontractors such as travel support service providers
Industry reporting authorities and other entities necessary in providing travel services;
To public authorities, such as law enforcement, if we are legally required to do so or need to protect our rights or the rights of third parties.
Affiliates or Acquired Companies: As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or we acquire another company, the information we have about you will be transferred to and used by the acquiring entity.
We may disclose information to third parties in an aggregate format that does not constitute Personal Data and does not allow for the direct identification of individual users of the Website or individual travelers.

We do not sell or share information with third parties so that they can independently market their own products or services directly to you.

Sharing Personal Data with FROSCH affiliates

Our Privacy Notice applies to services offered by FROSCH International Travel but excludes services or affiliates that have separate privacy notices. We may share the minimum Personal Data necessary with other companies affiliated with FROSCH, for example, to provide the products and services you request; to manage and improve our products, services and day-to-day operations; where appropriate, to make contact and interact with you; and, if allowed and appropriate, for marketing or market research purposes.

We may also share Personal Data with an organization we sell or transfer (or enter into negotiations to sell or transfer) any of our businesses or any of our rights or obligations under any agreement we may have with you. If the transfer or sale goes ahead, the organization receiving your Personal Data can use your data in the same way as us.

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.

Social media features

Our websites or mobile apps may contain social media features such as Facebook, Twitter, LinkedIn and Instagram that have their own privacy notices. Please make sure you read their terms and conditions and privacy notice carefully before providing any Personal Data as we do not accept any responsibility or liability for these features. When we use social plug-ins on our websites from social networks such as Facebook, Twitter, LinkedIn and Instagram, we integrate them as follows:

When you visit our websites, the social plug-ins are deactivated, i.e. no data is transmitted to the operators of these networks. If you want to use one of the networks, click on the respective social plug-in to establish a direct connection to the server of the respective network
If you have a user account on the network and are logged in when you activate the social plug-in, the network can associate your visit to our websites with your user account. If you want to avoid this, please log out of the network before activating the social plug-in.
When you activate a social plug-in, the network transfers the content that becomes available directly to your browser, which integrates it into our websites. In this situation, data transmissions can also take place that are initiated and controlled by the respective social network. Your connection to a social network, the data transfers taking place between the network and your system, and your interactions on that platform are governed solely by the privacy policies of that network.
The social plug-in remains active until you deactivate it or delete your cookies.

Safeguarding Personal Data

We use adequate technical and organizational security measures to protect your data managed by us against manipulation, loss, destruction and against access by unauthorized persons. We are constantly improving our security measures in line with technological developments. Although FROSCH makes every effort to ensure the protection, integrity and security of FROSCH's network and systems, FROSCH cannot guarantee or warrant that the security measures will protect all Personal Data.

The security of your data also depends on you. For example, where you have chosen a password for access to certain services, you are responsible for keeping this password confidential.

Data Retention

We will retain your Personal Data for only as long as it is necessary for the uses set out in this Privacy Notice and/or to meet legal and regulatory requirements. After this period, we will securely erase Personal Data. If data is needed after this period for analytical, historical or other legitimate business purposes, we will take appropriate measures to anonymize or destroy this data.

Your Rights and Choices

Marketing Communications

If you receive marketing email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving commercial email from us, and any other promotional communications that we may send to you from time to time, by sending your request by email to privacy@frosch.com

Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may receive promotional communications from us that you have opted-out from during that period. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages regarding travel services.

Information Collected by Automated Means

Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of our Site.

Please note that there is currently no uniform way in which to respond to Do Not Track signals, and at this time we do not respond to such signals.

Your European Privacy Rights and Choices

If you live in the EU or Switzerland, you have specific rights for your Personal Data under the European General Data Protection Regulation (GDPR). At FROSCH we address your rights for:

Data Access: You have a right to ask for a copy of the Personal Data we hold about you. You can write to us asking for a copy of other Personal Data we hold about you. Please include any details to help us identify and locate your Personal Data. Where we can provide data access, we will do so free of charge except where further copies are requested, in which case we may charge a reasonable fee based on administrative costs.
Data Correction and Deletion: We want to make sure that the Personal Data we hold about you is accurate and up to date. If any of the details we hold appear to be incorrect, please let us know. We will update or erase your data, unless we have to keep it for legitimate business or legal purposes.
Data portability: You have the right to be able to take with you the Personal Data you provided to us in certain circumstances.
Right to object to use of Personal Data: You have the right, in certain circumstances, to object to FROSCH processing your Personal Data.
To opt out of marketing messages: If you no longer want to receive marketing messages from FROSCH, you can choose to opt out at any time. If you've previously opted in to receive personalized content based on how and where you use our network, you can also opt out at any time.

FROSCH will offer EU and Swiss individuals whose personal information has been transferred to us the opportunity to choose whether the personal information it has received is to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. An individual may opt-out of such uses of their personal information by contacting us at privacy@frosch.com.

If we intend to disclose it to a third party acting as a controller not previously identified, we will offer you the opportunity to opt-out of such uses and/or disclosures where it involves non-sensitive data or opt-in where Sensitive Personal Data is involved.

If we intend to use your Personal Data for a purpose that is materially different from the purposes listed in this Notice, or if we intend to disclose it to a third party acting as a controller not previously identified, we will offer you the opportunity to opt-out of such uses and/or disclosures where it involves non-sensitive data or opt-in where Sensitive Personal Data is involved.

Please note:

We will not be able to delete information that is required to maintain our business purpose or that is required to facilitate your contract with us or to perform the services you have otherwise requested from us.
We may ask you to verify your identity before we can act on your request or complaint. We may also ask you for more information to help ensure that you are authorized to make such a request or complaint when you contact us on behalf of someone else.

For more information or to exercise your rights, please submit a request via post or email to FROSCH. We will respond to inquiries directed to us within thirty (30) calendar days. If the request pertains to data that was provided to us by your employer, please contact your employer (i.e. our client).

By post: FROSCH UK Ltd.
Attn: Data Protection Officer
The Eastcheap Estate: 39 Eastcheap, 4th Floor
London EC3M 1DE
United Kingdom

By email: Privacy@FROSCH.com

Your California Privacy Rights

Access to Specific Information and Data Portability Rights

If you live in California, you have specific rights for your Personal Data under the California Consumer Privacy Act of 2018 ("CCPA") and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice. This section describes your CCPA rights and explains how to exercise those rights.

You have the right to request that we disclose certain information to you about our collection and use of your personal data over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of personal data we collected about you.
The categories of sources for the personal data we collected about you.
Our business or commercial purpose for collecting or selling that personal data.
The categories of third parties with whom we share that personal data.
The specific pieces of personal data we collected about you (also called a data portability request).
If we sold or disclosed your personal data for a business purpose, two separate lists disclosing:
- sales, identifying the personal data categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal data categories that each category of recipient obtained.

In the preceding twelve (12) months, we have not sold any personal data.

Deletion Request Rights

You have the right to request that we delete any of your personal data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and request our service providers to delete) your personal data from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

Complete the transaction for which we collected the personal data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and fix errors that impair existing intended functionality.
Exercise free speech ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Access, Data Portability, and Information Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Emailing us at privacy@FROSCH.com
Writing to us at FROSCH International Travel Attn: Data Privacy; One Greenway Plaza, Suite 800 in Houston, TX 77046 USA

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal data. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal data or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal data provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Time

We try to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal data that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Do Not Track

The California Online Privacy Protection Act ("CalOPPA") requires FROSCH to disclose how it responds to Do Not Track Signals in your web browser. FROSCH does not interpret or respond to Do Not Track Signals. You may set your web browser to not accept new cookies or web beacons or disable cookies altogether. Please note that doing so may hinder your experience on the Website. Please see the Help section of your browser for instructions on managing security preferences.

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 Data 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 this email address: privacy@frosch.com. A parent or guardian of a child under the age of 13 may review and request deletion of such child's Personal Data, as well as prohibit the use of that information.

Arbitration

Frosch International Travel has further committed to refer unresolved Privacy Shield complaints to United States Council for International Business, 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 visit United States Council for International Business for more information or to file a complaint. The services of United States Council for International Business are provided at no cost to you.

How to Contact us

Please contact us with any questions or comments about this Policy, your Personal Data, our privacy and information security practices, your consent choices or if you would like to exercise your rights.

Email at privacy@frosch.com

Data Protection Officer by email at DPO@frosch.com

You may also write to us at:
FROSCH International Travel
One Greenway Plaza, Suite 800
Houston, TX 77046 USA

Changes to This Policy and Definitions

Policy Changes

This Notice replaces all previous versions. We may change the Notice at any time, so please check it regularly on our website(s) for any updates. You can tell when changes have been made to the Privacy Policy by referring to the "Last Updated" legend on top of this page. Any changes will be effective on the effective date stated in the revised Privacy Policy. Your continued use of the Site after we have posted a revised Privacy Policy indicates your agreement to the revisions.

Definitions

For purposes of this Policy, the following definitions shall apply:

"Affiliate" means any partner that FROSCH has 15% or more ownership in.

"Agent" or "Processor" means any third party that collects or uses Personal Data under the instructions of, and solely for, FROSCH International Travel or to which FROSCH International Travel discloses Personal Data for use on FROSCH International Travel's behalf.

"CCPA" or "California Consumer Privacy Act" also known as AB-375, is a bill intended to enhance privacy rights and consumer protection for residents of California, United States.

"FROSCH International Travel" means FROSCH International Travel, its affiliates under common control, predecessors, successors, subsidiaries, divisions and groups in the United States.

"GDPR" or "General Data Protection Regulation", also known as Regulation (EU) 2016/679, is a European Union law drafted on April 27, 2016 and instituted on May 25, 2018 on data protection and privacy for all individual citizens of the European Union and the European Economic Area.

"Personal Data" means any information or set of information that identifies or could be used by or on behalf of FROSCH International Travel to identify an individual. Personal Data does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public Personal Data.

"Sensitive Personal Data" or "Special Categories of Personal Data" This are categories of personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data, biometric data for the purpose of uniquely identifying a natural person; health data; and data concerning a natural person's sex life or sexual orientation. In addition, FROSCH International Travel will treat as sensitive Personal Data any information received from a third party where that third party treats and identifies the information as sensitive.

"Data Controller": The data controller determines the purpose and manner in which personal data is used.

"Data Processor": Processes Personal Data as instructed on behalf of a data controller

"European Economic Area (EEA)" consist of EU Member States plus Norway, Iceland and Lichtenstein.

"Online advertising" refer to Marketing messages that you may see on the internet.

"US Secure Flight Data": The Transportation Security Administration (TSA) requires you to provide your full name, date of birth and gender for the purpose of watch list screening. You may also provide your Redress Number, if available. Failure to provide details may result in denial of transport or denial of authority to enter the boarding area. TSA may share information you provide with law enforcement or intelligence agencies or others under its published system of records notice. Please see the TSA website for more details.

Privacy Shield

We may transfer your Personal Data to countries other than the country where you are located, including to the United States where we are headquartered.

The EU-U.S. and Swiss-U.S. Privacy Shield Frameworks were designed by the U.S. Department of Commerce, and the European Commission and Swiss Administration, respectively, to provide companies on both sides of the Atlantic with a mechanism to comply with data protection requirements when transferring Personal Data from the European Union and Switzerland to the United States in support of transatlantic commerce.

FROSCH International Travel LLC complies with the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union and Switzerland to the United States. FROSCH International Travel LLC has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability. If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit www.privacyshield.gov.

Personal data, including data collected in the European Economic Area ("EEA") or Switzerland, may be transferred, stored, and processed by us and our services providers, partners, and affiliates in the United States and potentially other countries whose data protection laws may be different to the laws of your country.

We will not transfer Personal Data originating in the EU or Switzerland to third parties unless such third parties have entered into an agreement in writing with us requiring them to provide at least the same level of privacy protection to your Personal Data as required by the Principles of the EU-US Privacy Shield Framework or the Swiss-US Privacy Shield Framework. We will only transfer data to our agents, affiliates, or third-party service providers (such as accountants, attorneys, consultants, and other service providers) who need the information in order to provide services to or perform activities on behalf of FROSCH; including in connection with the delivery of services, FROSCHs' management, administration, or legal responsibilities. We shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage.

Dispute Resolution: In compliance with the Privacy Shield Principles, FROSCH International Travel LLC commits to resolve complaints about our collection or use of your Personal Data. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact FROSCH at:

FROSCH International Travel LLC
One Greenway Plaza, Suite 800
Houston, TX 77046

or via email at DPO@FROSCH.com

FROSCH has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism:

for disputes involving all Personal Data received by our company from Switzerland, our company has agreed to cooperate with the Swiss FDPIC: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection—international.html
for disputes involving all Personal Data received by our company from EU countries, we commit to refer unresolved complaints under the Privacy Shield Principles to an independent dispute resolution panel established by European Union Data Protection Authorities. Please contact the Data Protection Authority in your country for your complaint: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

Under certain limited conditions, an individual may be able to invoke binding arbitration as provided under the Privacy Shield to address an otherwise unresolved complaint. For more details about this process, visit the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint.

FROSCH International Travel LLC is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) and under certain conditions, individuals may invoke binding arbitration as well as learn more about our liability in cases of onward transfers to third parties at: https://www.privacyshield.gov/EU-US-Framework.

International Transfers of Personal Data

Cookie Policy

We use or may use the data collected through cookies, log files, device identifiers, and clear GIFs to (a) remember information so in subsequent visits a user will not have to re-enter it; (b) provide custom, personalized content, and information; (c) monitor the effectiveness of our Services; (d) monitor aggregate metrics such as total number of visitors, traffic, and usage on our website and our Services; (e) diagnose or fix technology problems; and (f) help users efficiently access information after signing in.

Clear GIFs, pixel tags, and other technologies: Clear GIFs (also known as web beacons, web bugs or pixel tags) are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer's hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs, in connection with Services to, among other things, track the activities of visitors, help us manage content, and compile statistics about site usage. We and our third-party service providers also use clear GIFs in HTML emails to our customers to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

Third-Party Analytics: We use automated devices, applications, and other means, such as Google Analytics to evaluate usage of our FROSCH websites and Services. We use these tools to help us improve our Services, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. Third-party advertising networks are never allowed to collect information about the users of our websites or Services.

cxLoyalty Privacy Policy

This privacy policy covers Chase Travel Partner Solutions.

International Privacy Notice: Canada (English)

Effective Date: March 10, 2024

This Privacy Notice explains how we collect, use, disclose, and otherwise process personal information in connection with our services. This Privacy Notice is not, however, a contract and does not create any legal rights or obligations.

Who We Are

cxLoyalty Services, LLC dba Chase Travel and its Affiliates (Loyalty Travel Agency, LLC), is a leading provider of loyalty technology services with rewards content in relevant categories including travel, gift cards and merchandise and world-class personalized customer experience. When we use the terms "cxLoyalty", "we", "us", or "our" in this Privacy Notice, we are referring to cxLoyalty Global Holdings, Inc. and its subsidiaries.

Our Services

When we use the term "services", we are referring to our U.S.- facing Internet websites and U.S.-facing programs we offer and manage on our own behalf, including:

Our U.S.-facing corporate websites that link to this Privacy Notice; and
Our travel services.

This Privacy Notice does not cover or address:

Disclosures or rights we may provide to you in relation to the Fair Credit Reporting Act (FCRA);
Disclosures or rights we may provide to you in relation to the Gramm-Leach-Bliley Act (GLB);
Disclosures or rights we may provide to you in relation to state-specific financial privacy laws;
Offerings we make available in other countries;
Offerings that we provide solely on behalf of our clients; or
Personal information and privacy practices relating to job applicants, employees and other cxLoyalty personnel.

For offerings provided on behalf of our clients, please refer to the privacy notice of the client with which you have a relationship for information on how they engage service providers, like us, to process personal information on their behalf.

State-Specific Disclosures

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain states. Please see below for disclosures that may be applicable to you:

If you are a resident of the State of California in the United States, please click here for additional California-specific privacy disclosures.
If you are a resident of the State of Nevada in the United States, please see below for additional Nevada-specific privacy disclosures:

Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at privacy@cxloyalty.com.

What is Personal Information?

When we use the term "personal information" in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. It does not include aggregated or deidentified information that is maintained in a form that is not capable of being associated with or reasonably linked to you.

Our Collection and Use of Personal Information

The personal information we collect, the way we collect it and how we use it will depend on how you are interacting with us and the type of services you use.

Website & Online Services

Collection of Personal Information

As is true of most digital platforms, we and our third-party providers and partners collect certain personal information automatically when you visit or interact with our websites and other online services:

Log Data: Including your internet protocol (IP) address, operating system, browser type, browser ID, the URL you entered and the referring page/campaign, date/time of your visit, the time you spent on our services and any errors that may occur during your visit to our services.
Analytics Data: Including the electronic path you take to our services, through our services and when exiting our services, as well as your usage and activity on our services, such as the links, objects, products and benefits you view, click or otherwise interact with (also known as "Clickstream Data").
Location Data: Including your general geographic location based on the Log Data we collect or more precise location when permitted by law.
Application Data: Some of our services offer mobile or browser applications to allow you to take advantage of our service offerings on the go and/or when visiting third-party websites and other online services. Certain of these applications also allow us to access more precise Location Data about you and collect information about your use and interactions with third- party websites and online services (including the products or services you are interested in or purchase) to better serve you.

For information about our and our third-party providers and partners' use of cookies and related technologies to collect information automatically on our online services, and the choices you may have in relation to those practices, please visit our Cookie Notice.

In addition to the personal information we collect automatically, we also collect personal information directly from you through our websites and online services:

Newsletters and Email Communication: Many of our websites and online services provide you an opportunity to sign up for our newsletters and email communications by providing your email address. We use your email address to communicate with you about our services and exciting developments at cxLoyalty, which may include marketing communications. Please see the Your Communication Preferences section below for additional information about opting out of our marketing communications.
Contact Us: Our websites and online services provide individuals and representatives of prospective business customers and partners the ability to connect with us through an online web form that collects contact information (such as first and last name, email address, phone number, company name, and title with company), area(s) of interest or concern, and a custom message from you. We use this information to communicate with you in connection with your request, including corresponding with you about cxLoyalty's services, offerings, customer service, business partnership opportunities or media inquiries.

Although we often collect the personal information described above directly from you, we also collect this information through service providers and other third parties that collect it on our behalf, such as communications providers, analytics providers, website hosting providers and marketing providers. Please note that our systems may record personal information that you type into our websites and other online services even if you do not choose to submit it.

Use of Personal Information

We use the personal information we collect through our websites and other online services to:

Help to optimize your experience with our websites and other online services
Administer and improve our websites and other online services
Test different configurations of our websites and other online services
Diagnose errors and problems with our websites and other online services
Conduct research and analytics on visitor usage and activity trends relating to our websites and other online services
Remember you and the choices you have made in relation to our services
Connect you to the requests and transactions you make on our websites and other online services
Identify how you use our websites and other online services, determine products/services that may be of interest to you and customize our personalized offerings and marketing efforts accordingly
Provide you with news about products and services we offer
Deliver marketing communications and advertisements based on your interests and interactions with us
Assess the performance of marketing campaigns and facilitate remarketing efforts
and Respond to your comments and questions and provide customer service.

Please note that we link the personal information we collect through our websites and online services with the other personal information that we collect about you and may use it for the purposes we describe in more detail in the other sections of this Privacy Notice.

Surveys, Contest and Promotion Entries

Collection of Personal Information

From time to time we may provide you the opportunity to participate in surveys, contests and/or promotions. If you choose to participate, we will request personal information from you in connection with your entry, which typically includes:

Contact Information: Such as your full name, email address, mailing address, telephone number, company name and title.
Demographic Information: Such as your specific or approximate date of birth, age, gender or annual income.
Survey, Contest or Promotion Entry: Including any personal information you choose to provide in connection with your survey, contest or promotion entry, such as products/services of interest or your satisfaction with us.

Although we often collect the personal information described above directly from you, we also collect this information through service providers and other third parties that collect it on our behalf, such as communications providers, analytics providers, survey, contest and promotion entry providers and marketing providers.

Use of Personal Information

We use the personal information we collect in connection with surveys, contests and promotions to:

Learn how we can improve your experience with our services
Understand our customers and the users of our services, including the service configurations and products that may be of interest to our customers in the aggregate Conduct research and analytics on our customer base, users of our services, and the performance of us and our services
Incorporate ideas from your responses into our business operations and customer service models
Improve and customize our services and product offerings to address the needs and interests of our customers
Develop new services and product offerings
Contact you regarding your survey responses and announce contest and promotion winners
Provide you with news about our business, as well as products and services we offer and
Deliver marketing communications and advertisements based on your interests and interactions with us.

Unless noted otherwise in our initial request, we may link the personal information we collect through your contest, promotion and survey responses with the other personal information that we collect about you and for the purposes we describe in the other sections of this Privacy Notice. The survey, contest, or promotion request you receive may contain additional details about how any personal information you provide may be used or otherwise processed.

Travel Services

Scope of Travel Services

Our travel services include (but are not limited to):

Bookings and savings for flights, hotels, rental cars, cruises and travel activities;
Rewards accrual and redemption on travel products made available through our services; and
Price guarantees, travel protection plans and insurance.

Collection of Personal Information

When you use and interact with our travel services, we collect personal information from you, our travel booking providers, travel partners, payment processors, service providers and other third parties who collect personal information on our behalf, which may include:

Contact Information: Including your full name, email address, mailing address and telephone number.
Traveler Information: Including your travel companions' names and relationships, as well as your and your travel companions' full legal name, age, date of birth, sex, gender, travel loyalty program membership numbers, driver's license number, passport number and passport details (such as expiration date, country of nationality and issuing country), special accommodations or restrictions and events that you report occurring during your travel.
Payment Information: Including payment status, billing address, billing phone number, credit/debit card name, number, expiration date and security code (CVV), and third-party payment identifiers and confirmations.
Flight Information: Including flight confirmation numbers, frequent flyer number, airline name, airline brand name, flight number, departure date & time, arrival date & time, flight origin, flight destination, flight duration, departure airport code, arrival airport code, and seat number.
Hotel Information: Including hotel confirmation numbers, hotel membership number, hotel name, hotel chain, check-in date, check-out date, and number of guests.
Rental Car Information: Including rental car confirmation numbers, rental car membership number, rental car company, rental car, car pickup date & time, car drop-off date & time, car pickup location, and car drop-off location.
Cruise Information: Including cruise confirmation numbers, cruise line, cruise ship, cruise departure date & time, cruise arrival date & time, cruise departure location and cruise arrival location.
Travel Activity Information: Including travel activity confirmation number, travel activity name, travel activity description, travel activity start date, travel activity end date, and travel activity locations.
Coverage Information: Including the travel and activities covered by guarantees, protection plans and warranty extensions, the type and length of coverage provided, and claims made under the coverage.
Rewards Information: Including cash back, points and other rewards earned/redeemed, earning/redemption statements, rewards status, rewards expiration dates, rewards earning cap status, and transaction identifiers used to connect your transactions to you to provide the associated benefits and rewards.
Service Profile Information: Including flights, hotels, rental cars, cruises and travel activities of interest, favorite travel providers, recently viewed travel opportunities and our understanding of your preferences and interests.
Feedback Information: Including feedback and ratings you provide relating to our services, products and rewards.

Use of Personal Information

We use the personal information we collect in connection with our travel services to:

Provide and improve the services, offerings, travel opportunities and rewards that you request and we facilitate
Communicate with you regarding our services, offerings, travel opportunities and rewards (including by sending you service-related emails)
Determine your preferences and interests to better serve you
Personalize your experience, including providing tailored promotions and marketing offers
Determine your eligibility to travel and participate in travel activities, including fulfilling travel provider requirements
Process payment for the services, offerings, travel opportunities and rewards that you request
Facilitate your travel bookings with our travel booking providers, travel partners, service providers and other third parties
Fulfill your travel itineraries in accordance with travel provider requirements
Process claims available under your existing coverage
Process the cash back, points and other rewards you earn and/or redeem
Provide customer support relating to the services, offerings, travel opportunities and rewards
Conduct research and analytics on our customer base, users of our services, and the performance of us and our services
Improve and customize our services and travel offerings to address the needs and interests of our customers
Audit transactions conducted in connection with our services
and Investigate and prevent fraud in connection with your account and/or transactions.

Please note that we link the personal information we collect in connection with your travel services with the other personal information that we collect about you and may use it for the purposes we describe in more detail in the other sections of this Privacy Notice.

Our Disclosure of Personal Information

We disclose personal information in the following ways:

Within cxLoyalty: We are able to offer you the products and services we make available because of the hard work of the entire cxLoyalty team. cxLoyalty entities disclose personal information to other cxLoyalty entities for purposes and uses that are consistent with this Privacy Notice and applicable law. For example, the cxLoyalty entity providing our services to you may share personal information relating to transactions with another cxLoyalty entity that provides the system used to review available offerings and complete transactions for the services we are providing.
Business Partners: We often make our services available to customers and/or employees of our business partners.
Data Analytics Providers: We share personal information with data analytics providers who analyze statistics and trends relating to the usage of and activity relating to our services. These data analytics providers produce reports and make suggestions for our customer and business strategy based on the personal information and other information analyzed.
Affiliate Networks and Merchants: In order to facilitate your orders and provide you the rewards you are eligible to receive, we may disclose personal information to affiliate networks and merchants to enable them to fulfill your orders and identify which of their customers are connected to our services. For example, we often provide affiliate networks and merchants an online identifier showing that you were referred from our services to the affiliate network's and/or merchant's site and connecting your purchases to your rewards account.
Payment Processors and Online Payment Systems: We share personal information with payment processors, online payment system providers and other billing agents to process your payment for the services and products you order, as well as to provide refunds, cash back and/or rebate checks.
Transaction Fulfillment and Delivery Providers: We share personal information with transaction fulfillment and delivery providers in order to fulfill your transactions through our services and deliver the products and experiences that you order through our services.
Insurance and Coverage Providers: We often engage insurance companies, financial institutions and other third parties to provide you with the guarantees, protection plans and extended warranties made available through our services. In order for these third parties to administer and service your coverage in connection with the services, we share personal information about you with them.
Marketing Partners: We coordinate and share personal information with our marketing partners, including advertisement networks, social networks, re-targeting partners and marketing communication providers, in order to communicate with you about our products and services and market our products and services to you. We may also share aggregated demographic information with third parties interested in advertising on our online services to assist them in understanding the audience they would be reaching, but this information is not designed to be identifiable to a specific individual.
Customer Service and Communication Providers: We share personal information with third parties who assist us in providing our customer service experience and facilitating our communications with you, including third parties that provide call center, email and chat support services
Other Service Providers: In addition to the third parties identified above, we engage other third parties to perform certain functions on our behalf in connection with the uses of personal information described in the Our Collection and Use of Personal Information section above, including rewards tracking, communication printing, website hosting, information technology support, content development and fraud monitoring. Depending on the function the third party serves, the service provider may process personal information on our behalf or have access to personal information while performing functions on our behalf.
Public Disclosure: With your consent, we may disclose certain personal information about you, such as first name/initial, last name and city of residence, publicly as an example of representative savings and/or to identify you as a user of our service.
Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
- In connection with the establishment, exercise, or defense of legal claims;
- To comply with laws and regulations or to respond to lawful requests and legal process;
- To protect our rights and property and the rights and property of our agents, customers, and others, including to enforce our agreements, policies, and terms of use; To detect, suppress, or prevent fraud;
- To reduce credit risk and collect debts owed to us;
- To protect the health and safety of us, our customers, or any person; or
- As otherwise required by applicable law.
Consent: We may disclose personal information about you to certain other third parties with your consent.

Your Communication Preferences

In connection with our services, we may send you email messages, direct mail offers, SMS messages, push notifications or other communications, including telephone calls, regarding our services. You may ask us not to send you marketing communications or request a change to the method or frequency of communication by:

Following any available opt-out or communication preferences instructions in the marketing communications;
When available, accessing the "Unsubscribe" or "Communication Preferences" settings in your account profile page;
Sending a request to service@cxloyalty.com with the words "Opt Out" or "Communication Preferences" in the subject line, the address or number at which we contacted you and your request; or
Sending a request to the following address identifying the address or number at which we contacted you and your request:

cxLoyalty
Data Privacy Office
77 North Water Street
Norwalk, CT 06854
1-844-300-4222

Please allow up to 10 days for your request to be processed. If you request to opt out of marketing communications, please note that we may continue to send you non-marketing communications, such as those directly related to the fulfillment of a specific transaction you requested, maintenance of your account or status of our ongoing business relations.

Children's Personal Information

Our websites and online services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If you are under the age of 13, please do not use our websites or online services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child's parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information.

We do, however, process personal information about children, including their Social Security numbers, when it is necessary for the services we are offering and you provide it to us. This personal information is used to provide you the full benefit of the service you have chosen, such as travel services for flights, hotels or cruises.

Third-Party Websites

Our websites and online services may include links to or redirect you to third-party websites, plug-ins and applications, including social media services where you may connect with us. Third-party websites may also reference or link to our websites and online services. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices or policies.

Updates to this Privacy Notice

We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the "Effective Date" at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify you by prominent posting at the beginning of this Privacy Notice.

Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to privacy@cxloyalty.com.

Alternatively, inquiries may be addressed to:

cxLoyalty
Data Privacy Office
77 North Water Street
Norwalk, CT 06854
1-844-300-4222

cxLoyalty Privacy Notice Canada

This privacy notice covers the Chase Travel Partner Solutions business in Canada.

Effective Date: April 1, 2021

This Privacy Notice explains how we collect, use, disclose, retain, destruct and otherwise process personal information in connection with our services. This Privacy Notice is not, however, a contract and does not create any legal rights or obligations.

Who We Are

cxLoyalty is a leading provider of loyalty technology services with rewards content in relevant categories including travel, gift cards and merchandise and world-class personalized customer experience. When we use the terms "cxLoyalty", "we", "us", or "our" in this Privacy Notice, we are referring to cxLoyalty Global Holdings, Inc. and its subsidiaries.

Our Services

When we use the term "services", we are referring to our Canada facing Internet websites and Canada-facing programs we offer and manage on our own behalf, including:

Our corporate websites that link to this Privacy Notice; and
Our travel services.

This Privacy Notice does not cover or address:

Offerings we make available in other countries;
Offerings that we provide solely on behalf of our clients; or
Personal information and privacy practices relating to job applicants, employees and other cxLoyalty personnel.

What is Personal Information?

Chief Privacy Officer and Privacy Authorities

Responsibility: We are the responsible controller for the processing of the Personal Information we collect on our behalf. We have appointed a Chief Privacy Officer (the "CPO") who ensures that cxLoyalty complies with privacy laws applicable in Canada.

Contact details of responsible controller:
cxLoyalty
Data Privacy Office
77 North Water Street, Norwalk, CT 06854 USA
1-844-300-4222

CPO Contact Details: cxLoyalty
Chief Privacy Officer
77 North Water Street, Norwalk, CT 06854
USA Phone: 1-844-300-4222
Email: privacy@cxloyalty.com

Privacy Authorities: If you submit your Personal Information when you are in Canada directly to us you are entitled to file a complaint at any time, depending on your location, to the Access to Information Commission (www.cai.gouv.qc.ca) if you are in Quebec, the Office of the Information and Privacy Commissioner of Alberta (https://www.oipc.ab.ca/) if you are in Alberta, the Office of the Information and Privacy Commissioner for British Columbia (www.oipc.bc.ca/) if you are in British Columbia or the Office of the Privacy Commissioner of Canada (https://www.priv.gc.ca/en) if you are elsewhere in Canada.

We would however appreciate being able to answer your questions or discussing your issue with you before you contact such authority. We would appreciate if you would contact us first at privacy@cxloyalty.com.

Our Collection and Use of Personal Information

The personal information we collect, the way we collect it and how we use it will depend on how you are interacting with us and the type of services you use.

Website & Online Services

Collection of Personal Information

Log Data: Including your internet protocol (IP) address, operating system, browser type, browser ID, the URL you entered and the referring page/campaign, date/time of your visit, the time you spent on our services and any errors that may occur during your visit to our services.
Analytics Data: Including the electronic path you take to our services, through our services and when exiting our services, as well as your usage and activity on our services, such as the links, objects, products and benefits you view, click or otherwise interact with (also known as "Clickstream Data").
Location Data: Including your general geographic location based on the Log Data we collect or more precise location when permitted by law.
Application Data: Some of our services offer mobile or browser applications to allow you to take advantage of our service offerings on the go and/or when visiting third-party websites and other online services. Certain of these applications also allow us to access more precise Location Data about you and collect information about your use and interactions with third- party websites and online services (including the products or services you are interested in or purchase) to better serve you.

In addition to the personal information we collect automatically, we also collect personal information directly from you through our websites and online services:

Newsletters and Email Communication: Many of our websites and online services provide you an opportunity to sign up for our newsletters and email communications by providing your email address. We use your email address to communicate with you about our services and exciting developments at cxLoyalty, which may include marketing communications. Please see the Your Communication Preferences section below for additional information about opting out of our marketing communications.
Contact Us: Our websites and online services provide individuals and representatives of prospective business customers and partners the ability to connect with us through an online web form that collects contact information (such as first and last name, email address, phone number, company name, and title with company), area(s) of interest or concern, and a custom message from you. We use this information to communicate with you in connection with your request, including corresponding with you about cxLoyalty's services, offerings, customer service, business partnership opportunities or media inquiries.

Use of Personal Information

We use the personal information we collect through our websites and other online services to:

Help to optimize your experience with our websites and other online services
Administer and improve our websites and other online services
Test different configurations of our websites and other online services
Diagnose errors and problems with our websites and other online services
Conduct research and analytics on visitor usage and activity trends relating to our websites and other online services
Remember you and the choices you have made in relation to our services
Connect you to the requests and transactions you make on our websites and other online services
Identify how you use our websites and other online services, determine products/services that may be of interest to you and customize our personalized offerings and marketing efforts accordingly
Provide you with news about products and services we offer
Deliver marketing communications and advertisements based on your interests and interactions with us
Assess the performance of marketing campaigns and facilitate remarketing efforts
and Respond to your comments and questions and provide customer service.

Surveys, Contest and Promotion Entries

Collection of Personal Information

Contact Information: Such as your full name, email address, mailing address, telephone number, company name and title.
Demographic Information: Such as your specific or approximate date of birth, age, gender or annual income.
Survey, Contest or Promotion Entry: Including any personal information you choose to provide in connection with your survey, contest or promotion entry, such as products/services of interest or your satisfaction with us.

Although we often collect the personal information described above directly from you, we also collect this information through service providers and other third parties that collect it on our behalf, such as communications providers, analytics providers, survey, contest and promotion entry providers and marketing providers.

Use of Personal Information

We use the personal information we collect in connection with surveys, contests and promotions to:

Learn how we can improve your experience with our services
Understand our customers and the users of our services, including the service configurations and products that may be of interest to our customers in the aggregate
Conduct research and analytics on our customer base, users of our services, and the performance of us and our services
Incorporate ideas from your responses into our business operations and customer service models
Improve and customize our services and product offerings to address the needs and interests of our customers
Develop new services and product offerings
Contact you regarding your survey responses and announce contest and promotion winners
Provide you with news about our business, as well as products and services we offer
and Deliver marketing communications and advertisements based on your interests and interactions with us.

Travel Services

Scope of Travel Services

Our travel services include (but are not limited to):

Bookings and savings for flights, hotels, rental cars, cruises and travel activities;
Rewards accrual and redemption on travel products made available through our services; and
Price guarantees, travel protection plans and insurance.

Collection of Personal Information

Contact Information: Including your full name, email address, mailing address and telephone number.
Traveler Information: Including your travel companions' names and relationships, as well as your and your travel companions' full legal name, age, date of birth, sex, gender, travel loyalty program membership numbers, driver's license number, passport number and passport details (such as expiry date, country of nationality and issuing country), special accommodations or restrictions and events that you report occurring during your travel.
Payment Information: Including payment status, billing address, billing phone number, credit/debit card name, number, expiry date and security code (CVV), and third-party payment identifiers and confirmations.
Flight Information: Including flight confirmation numbers, frequent flyer number, airline name, airline brand name, flight number, departure date & time, arrival date & time, flight origin, flight destination, flight duration, departure airport code, arrival airport code, and seat number.
Hotel Information: Including hotel confirmation numbers, hotel membership number, hotel name, hotel chain, check-in date, check-out date, and number of guests.
Rental Car Information: Including rental car confirmation numbers, rental car membership number, rental car company, rental car, car pickup date & time, car drop-off date & time, car pickup location, and car drop-off location.
Cruise Information: Including cruise confirmation numbers, cruise line, cruise ship, cruise departure date & time, cruise arrival date & time, cruise departure location and cruise arrival location.
Travel Activity Information: Including travel activity confirmation number, travel activity name, travel activity description, travel activity start date, travel activity end date, and travel activity locations.
Coverage Information: Including the travel and activities covered by guarantees, protection plans and warranty extensions, the type and length of coverage provided, and claims made under the coverage.
Rewards Information: Including cash back, points and other rewards earned/redeemed, earning/redemption statements, rewards status, rewards expiry dates, rewards earning cap status, and transaction identifiers used to connect your transactions to you to provide the associated benefits and rewards.
Service Profile Information: Including flights, hotels, rental cars, cruises and travel activities of interest, favorite travel providers, recently viewed travel opportunities and our understanding of your preferences and interests.
Feedback Information: Including feedback and ratings you provide relating to our services, products and rewards.

Use of Personal Information

We use the personal information we collect in connection with our travel services to:

Provide and improve the services, offerings, travel opportunities and rewards that you request and we facilitate
Communicate with you regarding our services, offerings, travel opportunities and rewards (including by sending you service-related emails)
Determine your preferences and interests to better serve you
Personalize your experience, including providing tailored promotions and marketing offers
Determine your eligibility to travel and participate in travel activities, including fulfilling travel provider requirements
Process payment for the services, offerings, travel opportunities and rewards that you request
Facilitate your travel bookings with our travel booking providers, travel partners, service providers and other third parties
Fulfill your travel itineraries in accordance with travel provider requirements
Process claims available under your existing coverage
Process the cash back, points and other rewards you earn and/or redeem
Provide customer support relating to the services, offerings, travel opportunities and rewards
Conduct research and analytics on our customer base, users of our services, and the performance of us and our services
Improve and customize our services and travel offerings to address the needs and interests of our customers
Audit transactions conducted in connection with our services
and Investigate and prevent fraud in connection with your account and/or transactions.

Other Uses of Personal Information

In addition to the uses identified above, we use the personal information we collect to:

Facilitate our day-to-day business operations, such as maintaining accounts and processing transactions
Develop new products and services, and improve existing products and services
Aggregate information we receive from you and third parties to help understand your needs, customize our services and offerings to you, and provide you better service
Conduct research and analytics designed to understand our customer base and improve our products, services and customer experience
Prevent, investigate or provide notice of fraud or unlawful or criminal activity
Enforce and carry out contracts and agreements
and Comply with legal obligations.

Retention

We retain Personal Information for only as long as is reasonably necessary to fulfil the purpose for which it was collected, including for the purposes of satisfying any legal, accounting or reporting requirements and to assert or defend our legal rights.

To determine the appropriate duration of the retention of your Personal Information, we consider the number, nature and sensitivity of the Personal Information, the potential risk level and the seriousness of the unauthorized use or disclosure of your Personal Information and if we can attain our objectives by other means, as well as the legal, regulatory, tax, accounting and other applicable obligations.

Therefore, we retain your data for as long as you continue to use the product/service for the purposes explained above. When you cease your membership of the product/service, we will retain your Personal Information for as long as necessary to comply with our legal obligations, to resolve disputes and defend claims, as well as, for any additional purpose based on the choices you have made such as to receive marketing communications that you provided your consent to. In particular, we will retain call recordings, the data you supplied when joining the product, including complaints, claims (for insurance products) and any other Personal Information you supplied during the duration of your contract with us for your product/service for a period of up to 7 years from termination or expiry of your service in line with industry standards and Canada statutory limitation periods for the defence of contractual claims.

For any questions about the retention of Personal Information, please contact cxLoyalty's CPO, whose contact details are shown above.

Accuracy

We use reasonable efforts to ensure the accuracy of your Personal Information and that it is kept as complete and up to date as possible. We will not routinely update your Personal Information unless this is necessary. If you note any inaccuracies in our records or if your Personal Information changes, please immediately update such information in your online account, if any, or notify our CPO.

Protection of Personal Information

We are committed to protecting the confidentiality, integrity, availability and privacy of your Personal Information. We employ security safeguards that are in line with industry standards and which are reasonable considering the sensitivity of the Personal Information, including physical, electronic and organizational measures.

Unfortunately, the transmission of information by Internet is not completely secure and we cannot guarantee the security of information transmitted by Internet. Such transmission by you is done at your own risk. Once we have received information from you, we will apply our security practices to try to prevent any unauthorized access, use and disclosure.

We have entered into agreements and uses controls with our third-party service providers who have access to your Personal Information requiring that they use the information for the purpose received and protect your Personal Information in accordance with applicable laws and industry standards.

Your Rights and How to Exercise Them

You have various rights with respect to our use of your Personal Information:

Access: You have the right to request a copy of the Personal Information that we hold about you or to consult it. Access to your Personal Information is free of charge. In certain circumstances, for example, if the request is excessive or unfounded, we may charge administration fees for the transcript, reproduction or transmission of your Personal Information. We may also charge for additional copies. Before completing a request for access, we shall notify you if any fees are to be charged. We will generally answer any access requests within 30 days following the receipt of all of the required information. If we are unable to grant access, or if extra time is required to complete the request, we shall notify you in writing.

However, we may not transmit some type of information to you due to exceptions provided by applicable law (for example, when cxLoyalty's records contain information about other person, if the information was produced in a dispute settlement process, if the information was collected for the purposes of an investigation about the breach of an agreement or of applicable laws or if the information is covered by legal privilege). We will to the extent possible, delete the information that is not transmitted and shall grant access to the other information to you. If we are unable to grant access to the Personal Information to you, or to disclose it to you, we shall give an explanation, subject to restrictions.
Accuracy: We aim to keep your Personal Information accurate, current and complete. We invite you to update such information in your online account, if any, or to contact the CPO using the contact details given above to let us know if any of your Personal Information is inaccurate or changes, so we can keep your Personal Information up to date.
Complaints: If you believe that your data and Personal Information protection rights have been breached you have the right to lodge a complaint with the applicable privacy authority or to seek a remedy through the courts.

You may exercise any of the above-mentioned rights at any time by contacting the CPO using the contact details above.

Our Disclosure of Personal Information

We disclose personal information in the following ways:

Within cxLoyalty: We are able to offer you the products and services we make available because of the hard work of the entire cxLoyalty team. cxLoyalty entities disclose personal information to other cxLoyalty entities for purposes and uses that are consistent with this Privacy Notice and applicable law. For example, the cxLoyalty entity providing our services to you may share personal information relating to transactions with another cxLoyalty entity that provides the system used to review available offerings and complete transactions for the services we are providing.
Business Partners: We often make our services available to customers and/or employees of our business partners.
Data Analytics Providers: We share personal information with data analytics providers who analyze statistics and trends relating to the usage of and activity relating to our services. These data analytics providers produce reports and make suggestions for our customer and business strategy based on the personal information and other information analyzed.
Affiliate Networks and Merchants: In order to facilitate your orders and provide you the rewards you are eligible to receive, we may disclose personal information to affiliate networks and merchants to enable them to fulfill your orders and identify which of their customers are connected to our services. For example, we often provide affiliate networks and merchants an online identifier showing that you were referred from our services to the affiliate network's and/or merchant's site and connecting your purchases to your rewards account.
Payment Processors and Online Payment Systems: We share personal information with payment processors, online payment system providers and other billing agents to process your payment for the services and products you order, as well as to provide refunds, cash back and/or rebate checks.
Transaction Fulfillment and Delivery Providers: We share personal information with transaction fulfillment and delivery providers in order to fulfill your transactions through our services and deliver the products and experiences that you order through our services.
Insurance and Coverage Providers: We often engage insurance companies, financial institutions and other third parties to provide you with the guarantees, protection plans and extended warranties made available through our services. In order for these third parties to administer and service your coverage in connection with the services, we share personal information about you with them.
Marketing Partners: We coordinate and share personal information with our marketing partners, including advertisement networks, social networks, re-targeting partners and marketing communication providers, in order to communicate with you about our products and services and market our products and services to you. We may also share aggregated demographic information with third parties interested in advertising on our online services to assist them in understanding the audience they would be reaching, but this information is not designed to be identifiable to a specific individual.
Customer Service and Communication Providers: We share personal information with third parties who assist us in providing our customer service experience and facilitating our communications with you, including third parties that provide call center, email and chat support services
Other Service Providers: In addition to the third parties identified above, we engage other third parties to perform certain functions on our behalf in connection with the uses of personal information described in the Our Collection and Use of Personal Information section above, including rewards tracking, communication printing, website hosting, information technology support, content development and fraud monitoring. Depending on the function the third party serves, the service provider may process personal information on our behalf or have access to personal information while performing functions on our behalf.
Public Disclosure: With your consent, we may disclose certain personal information about you, such as first name/initial, last name and city of residence, publicly as an example of representative savings and/or to identify you as a user of our service.
Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
- In connection with the establishment, exercise, or defence of legal claims;
- To comply with laws and regulations or to respond to lawful requests and legal process;
- To protect our rights and property and the rights and property of our agents, customers, and others, including to enforce our agreements, policies, and terms of use;
- To detect, suppress, or prevent fraud;
- To reduce credit risk and collect debts owed to us;
- To protect the health and safety of us, our customers, or any person; or
- As otherwise required by applicable law.
Consent: We may disclose personal information about you to certain other third parties with your consent.

Limited Authorization. We require that any third-party service providers respect the security of your Personal Information and process such pursuant to law. Our own service providers agree to deal with your Personal Information for specific purposes and according to our instructions. We have entered into agreements with our third-party service providers to require that they protect your Personal Information which they store, handle and process in a manner that is comparable to what is specified in this Privacy Notice and industry standards.

International Transfers

We are based in the United States; therefore, we process store and transfer your Personal Information in the United States. We may also process, store, and transfer your Personal Information in and to a foreign country other than the United States, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of the United States or that country may be able to obtain access to your Personal Information through the laws of such foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to applicable privacy legislation.

You are welcome to contact our CPO whose contact information is given above to obtain further information about our policies regarding service providers based outside of Canada.

By submitting your Personal Information or engaging in the Services, you consent to this transfer, storage, or processing.

Your Communication Preferences

Following any available opt-out or communication preferences instructions in the marketing communications;
When available, accessing the "Unsubscribe" or "Communication Preferences" settings in your account profile page;
Sending a request to service@cxloyalty.com with the words "Opt Out" or "Communication Preferences" in the subject line, the address or number at which we contacted you and your request; or
Sending a request to the following address identifying the address or number at which we contacted you and your request:

cxLoyalty
Data Privacy Office
77 North Water Street Norwalk, CT 06854 USA 1
1-844-300-4222

Children's Personal Information

Third-Party Websites

Updates to this Privacy Notice

Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to privacy@cxloyalty.com.

Alternatively, inquiries may be addressed to: cxLoyalty Data Privacy Office 77 North Water Street Norwalk, CT 06854 USA 1-844-300-4222

cxLoyalty
Data Privacy Office
77 North Water Street
Norwalk, CT 06854
1-844-300-4222

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