I. Scope and Limitations on Use of Platform and Services
To access certain functionality of the Platform and certain Services made available through the Platform requires a user account. To access these functions and Services you will be required to establish a user account, which will be accessible upon input of an authorized e-mail address, a designated password, and/or other required information that is requested from you at either log in or initial user account registration. For any user accounts of yours, you are responsible for maintaining the security of any user passwords and other account details created for or issued to you for use with the Platform, and you are also responsible for the integrity and security of the operating environment from which you access the Platform.
II. Privacy Matters
III. Links to Third Party Applications and Websites
Travel Incorporated Platform and Services: To the extent permitted by applicable law, you consent to receive communications from Travel Incorporated by use of the Platform or Services. With any form of communication from us, you have the option to opt-out of future communications. We will normally communicate with you by posting notices on our Platform, by email and/or by fax. You agree that all notices, disclosures, agreements, and other communications that we provide to you electronically (including by email or fax) satisfy any legal requirements that communications be in writing.
In addition, the following additional information applies to the types of communications noted below:
- Newsletters: If a user wishes to subscribe to any of our newsletters, we ask for contact information, such as name and email address.
- Service Announcements: On occasion, it is necessary for us to send out a strictly service related announcement. For instance, if our Platform or Services are temporarily suspended for maintenance we might send users an email about this situation. Generally, users may not opt-out of these communications unless you discontinue all use of the Platform or Services.
- Customer Service: We communicate with users and customers on a regular basis to provide requested Services and in regards to issues relating to their the account we reply via email, fax or telephone call.
If you would like to contact us, you may do so at the following address:
4355 River Green Parkway
Duluth, Georgia 30096
V. Information and Liability Disclaimer
Although we strive at all times to maintain the accuracy of information maintained on this Platform, including pricing information and service details, occasionally pricing or other information errors may occur on this Platform. In the event that any Services that are available through this Platform is mistakenly listed at an incorrect rate or other price or with other incorrect information, we reserve the right to refuse or cancel any applications or orders placed for any such Service listed at the incorrect rate price or based on incorrect information.
ALL OF THE INFORMATION PROVIDED BY THE TRAVEL INCORPORATED PLATFORM AND SERVICES IS PROVIDED “AS-IS” AND WITH NO WARRANTIES. TRAVEL INCORPORATED MAKES NO REPRESENTATIONS NOR EXTENDS WARRANTIES OF ANY TYPE AS TO THE ACCURACY OR COMPLETENESS OF ANY INFORMATION OR CONTENT WITHIN THE TRAVEL INCORPORATED PLATFORM AND SERVICES.
IN NO EVENT SHALL TRAVEL INCORPORATED OR ANY OF ITS SUBSIDIARIES AND AFFILIATES OR ANY OF THEIR RESPECTIVE DIRECTORS, OFFICERS, SHAREHOLDERS, EMPLOYEES, AGENTS, MEMBERS, REPRESENTATIVES, SUCCESSORS AND ASSIGNS BE LIABLE FOR ANY INDIRECT, SPECIAL INCIDENTAL, CONSEQUENTIAL, EXEMPLARY OR PUNITIVE DAMAGES ARISING FROM OR DIRECTLY OR INDIRECTLY RELATED TO THE USE OF ACCURACY, OR THE INABILITY TO USE TRAVEL INCORPORATED’S PLATFORM AND SERVICES.
VII. Governing Law
Your use of this Platform shall be governed in all respects by the laws of the State of Georgia, without regard to such state’s choice of law provisions. Any cause of action or claim you may have with respect to the Website must be commenced within one (1) year after the claim or cause of action arises.
2. The personal data we collect
We may collect and process the following personal data about you:
2.1 Information that you give us.
2.1.1 This includes information you may give us so we can provide you with access to the Platform or Services and may include your name, address, email address, phone number and other information necessary to use the Platform or Services.
2.1.2 When using the Platform or Service, you may also provide us with personal information about you and your employees so we can provide the Services.
2.2 Information that we collect automatically. We automatically collect the following information from your use of the Platform:
2.2.1 technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information (if applicable), browser type and version, browser plug-in types and versions, operating system and platform; and
2.2.2 information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Platform (including date and time); products you viewed or searched for; page response times, length of visits to certain pages, and methods used to browse away from the page and any phone number used to call our customer service number.
2.3 Information that we receive from third parties. We are working closely with third parties (including, for example, business partners, resellers, sub-contractors
in technical and payment services, advertising networks, analytics providers and search information providers) and may receive information from them.
3. Why we collect personal data and what we do with it
3.1 When you provide your personal data to us, we will make reasonable efforts to ensure that the purpose for which you are providing that personal data is clear.
3.2 Depending on who you are and your relationship with us, we may process your personal data as follows:
3.2.1 to carry out our obligations to you from your use of our Platform, the Services or under another agreement with you;
3.2.2 to administer your account with us;
3.2.3 to provide you with information about our products, the Platform, the Services and any other services we provide;
3.2.4 to administer the Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
3.2.5 to allow you to participate in interactive features of the Platform or Service when you choose to do so;
3.2.6 internally, to inform decisions about our business operations and strategy; and
3.2.7 to contact you from time to time to market any other services we provide and we think may be of interest to you.
4. Who we share your personal data with
4.1 We may disclose your personal information:
4.1.1 to business partners, suppliers, and sub-contractors for the performance of any contract we or you enter into with them or to fulfill our Services to you;
4.1.2 to our customers in order to allow them to use our Service;
4.1.3 in the event that we sell or transfer any part of our business or assets (whether by merger, asset sale or otherwise), in which case we may
disclose and transfer your personal data to the prospective buyer of such business or assets;
4.1.4 if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request; and
4.1.5 to third parties to enforce agreements between us or to investigate potential breaches of those agreements or to protect the rights, property or safety of our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
5. Security Measures for the Platform
5.1 We implement a variety of technical, administrative and organizational security measures for the Platform and Services that we believe are commercially reasonable to help us maintain the safety of your personal information when you place an order or enter, submit or access your personal information. These security measures include using one or more servers for the Platform and Services that are secured by commercially reasonable measures.
5.2 You are responsible for keeping confidential your access credentials for the Platform or Service, including password(s), and you should not share your password(s) with anyone.
5.3 Notwithstanding the above, you should be aware that the transmission of information via the Internet is not completely secure. Although we will use commercially reasonable measures to protect your personal data, we cannot guarantee the security of your data transmitted using the Services or the Platform, and as a result, any transmission of personal data is at your own risk.
6.2 A cookie is a small file that a site or its service provider transfers to the hard drive of your computer or other devices through your Web browser and enables the site or service provider systems to recognize your browser and capture certain information for use during your visit to our Platform and for future visits to our Platform.
6.3 We use the following cookies:
6.3.1 Strictly necessary cookies. These are cookies that are required for the operation of the Platform. They include, for example, cookies that enable you to log into secure areas of the Platform, use a shopping cart or session tracking.
6.3.2 Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around the Platform when they are using it. This helps us to improve the way the Platform works, for example, by ensuring that users are finding what they are looking for easily.
6.3.3 Functionality cookies. These are used to recognize you when you return to the Platform. This enables us to personalize our content for you, greet you by name and remember your preferences.
6.3.4 Targeting cookies. These cookies record your visit to the Platform, the pages you have visited and the links you have followed. We may also share this information with third parties that assist us with our Platform and fulfilling our Services for you.
6.4 You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Platform and use the Services. In addition, if you delete any Platform cookies on a given visit, you would need to block them again in subsequent visits to our Platform.
7. Children’s Privacy and Age Limitations for the Platform
7.1 The Platform is intended for use by persons aged 18 or older. We do not knowingly collect personally identifiable information from persons under the age of 18. If we discover or are made aware that we have received personally identifiable information from an individual who indicates that he or she is, or whom we otherwise have reason to believe is, under the age of 18, we will delete such information from our systems. If you are a parent or guardian of a child under the age of 18 and believe he or she has disclosed personally identifiable information to us, please contact us as provided below. In any such event, a parent or guardian of a child under the age of 18 may review and request deletion of such child’s personally identifiable information as well as prohibit the use thereof.
8. Additional Notices to California Residents
8.1 California Do-Not-Track Disclosure. At this time, the Platform is not set up to honor web browser do-not-track settings.
8.2 Information on Marketing Disclosures. California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us at Travel Incorporated, 4355 River Green Parkway, Duluth, Georgia 30096 or at firstname.lastname@example.org.
9. Links to Other Websites
11. General Information to Contact Us
12. Additional Notices to European Union Citizens
Persons who are residents of the member countries of the European Union (“EU”) or other data subjects covered by the EU’s General Data Protection Regulation, (EU) 2016/679 (the “GDPR”), have certain additional privacy rights under applicable law. The following provisions of this Section 12 provide an overview of these additional rights.
12.1 Legal Bases for Processing Personal Information of European Union Citizens
When processing your personal information, Travel Incorporated may rely on one or more of the following legal bases (or other available legal grounds), depending on the circumstances:
(a) Legitimate Interests – Travel Incorporated may process your personal information where Travel Incorporated has a legitimate interest in such processing for managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights or freedoms.
(b) Consent – Travel Incorporated may process your personal information where Travel Incorporated has obtained your consent to the processing.
(c) Contractual Necessity – Travel Incorporated may process your personal information where such processing is necessary in connection with any contract that Travel Incorporated has with you.
(d) Legal Requirements – Travel Incorporated may process your personal information where such processing is required by applicable law.
12.2 Disclosures to Third Parties
Travel Incorporated may also disclose any information (including personal information) relating to you to law enforcement authorities or any regulatory or government authority in response to any request including requests in connection with the investigation of any suspected illegal activities.
12.3 Security of Personal Information of European Citizens
Travel Incorporated has policies and technical and organizational measures in place which are intended to safeguard and protect your personal information against unauthorized access, accidental loss, improper use and disclosure. However, you should be aware that information transmitted over the internet is not completely secure because of the nature of the internet and that systems and measures used to secure information are not flawless. For these reasons, although Travel Incorporated will use reasonable efforts to protect your personal information, Travel Incorporated does not warrant the security of personal information transmitted to Travel Incorporated or stored by Travel Incorporated, and personal information that is transmitted to Travel Incorporated by you electronically is done at your own risk.
12.4 Retention of Personal Information of European Citizens
Travel Incorporated’s policy is to retain your personal information only for as long as is necessary to fulfill the purposes for which Travel Incorporated collected such personal information, including for the purposes of satisfying any professional, legal, accounting or reporting requirements to which Travel Incorporated is subject. To determine the appropriate retention period for personal information, Travel Incorporated considers the scope, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which Travel Incorporated collected and processed your personal information and whether Travel Incorporated can achieve those purposes through other means, and any applicable legal and professional requirements.
12.5 Your Rights as a European Citizen You have a number of rights concerning your personal information that Travel Incorporated holds and uses, including the following:
(a) Right of Access – You have the right to be informed about what personal information Travel Incorporated holds about you and to a copy of this personal information.
(b) Right to Rectification – You have the right to have any inaccurate personal information which Travel Incorporated holds about you updated or corrected.
(c) Right to Erasure – In certain circumstances you may request that Travel Incorporated delete the personal information that Travel Incorporated holds about you.
(d) Right to Complain – You have the right to lodge a complaint regarding the processing of your personal information to an applicable governmental or supervisory authority in your country.
(e) Right to Withdraw Consent – Where processing of personal information is based on your consent, you have the right to withdraw such consent at any time.
(f) Right to Object – Where Travel Incorporated relies on our legitimate interests to process your personal information, you have the right to object to such use and Travel Incorporated is required to discontinue such processing unless Travel Incorporated can demonstrate an overriding legitimate interest in such processing.
(g) Right to Restriction – You have the right to request that Travel Incorporated stop using your personal information in certain circumstances including if you believe that the personal information Travel Incorporated holds about you is inaccurate or that Travel Incorporated’s use of your personal information is unlawful. If you validly exercise this right, Travel Incorporated will store your personal information and will not carry out any other processing until the issue is resolved.
You may exercise any of the above requests in writing to Travel Incorporated, 4355 River Green Parkway, Duluth, Georgia 30096 or at email@example.com. You are also free at any time to request that Travel Incorporated stop using your personal information for marketing purposes by contacting us at Travel Incorporated, 4355 River Green Parkway, Duluth, Georgia 30096 or at firstname.lastname@example.org.
Travel Incorporated Privacy Shield Statement
I. Privacy Shield/Enforcement
The Privacy Shield Statement is made on behalf of Travel Incorporated for itself and its affiliates and trade name entities, Premier Golf, LLC, Vacations by Travel Inc., Group Travel Partners, DTI, and Travel Technology Solutions (collectively, “Travel Incorporated“). Travel Incorporated respects individual privacy and values the confidence of its customers, employees, vendors, business partners and others. Travel Incorporated strives to collect, use and disclose Personal Identifiable Information/Sensitive Personal Identifiable Information (“PII/SPII”) in a manner consistent with the laws of the countries in which it does business and has a tradition of upholding the highest ethical standards in its business practices. Travel Incorporated abides by the Privacy Shield Principles developed by the U.S. Department of Commerce and the European Commission and the Frequently Asked Questions (FAQs) issued by the Department of Commerce on August 1, 2016 (collectively the “U.S.-EU Privacy Shield Framework“). Travel Incorporated has certified that it adheres to the Privacy Shield Privacy Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement and liability. This Privacy Shield Statement (the “Statement“) sets forth the privacy principles that Travel Incorporated follows with respect to transfers of PII/SPII from the European Economic Area (“EEA”) (which includes the twenty-seven member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) to the United States. To learn more about the Privacy Shield program, and to view Travel Incorporated’s certification, please visit https://www.privacyshield.gov/.
Travel Incorporated has a Chief Privacy Officer who is responsible for Travel Incorporated’s compliance with and enforcement of this Statement and data security issues. Travel Incorporated educates its employees concerning compliance with this Statement and has self-assessment procedures in place to assure compliance. Travel Incorporated’s Chief Privacy Officer is available to any of its valued customers, employees, vendors, business partners and others who may have questions concerning this Statement or data security practices. Relevant contact information is provided herein.
This Statement applies to all PII/SPII received by Travel Incorporated in any format including electronic, paper or verbal, from the EEA. As an integral part of its business, Travel Incorporated collects and processes PII/SPII from its customers and potential customers in a variety of ways, including manually, via telephonic means (including facsimiles), electronic mail or its platform and services.
PII/SPII collected by Travel Incorporated from prospective customers and customers may be maintained at its data centers in Suwanee, Georgia, and Irving, Texas. Travel Incorporated collects PII/SPII for, among other things, legitimate business reasons such as customer service, travel-related reporting and records requirements, maintenance of accurate accounts payable and receivable records, and performance management, financial and sales data, and contact information. All PII/SPII collected by Travel Incorporated will be used for legitimate business purposes consistent with this Statement.
For purposes of this Statement, the following definitions shall apply:
“Agent” means any third party that uses PII/SPII provided by Travel Incorporated to perform tasks on behalf of or at the instruction of Travel Incorporated.
“Personal Identifiable Information” or “PII” means any information or set of information that identifies or could be used by or on behalf of Travel Incorporated to identify an individual. It does not include information that is encoded or anonymized or publicly available information that has not been combined with non-public personal information.
“Sensitive Personal Identifiable Information” or “SPII” means Personal Identifiable Information, which if lost, compromised, or disclosed without authorization, could result in substantial harm, embarrassment, inconvenience, or unfairness to an individual.
IV. Privacy Principles
The privacy principles in this Statement are based on the seven Privacy Shield Principles.
NOTICE: Where Travel Incorporated collects PII/SPII directly from individuals, it will inform them about the purposes for which it collects and uses that information about them, the types of non-agent third parties to which Travel Incorporated discloses that information, and the choices and means, if any, Travel Incorporated offers individuals the ability to limit the use and disclosure of their PII/SPII. Notice will be provided in clear and conspicuous language when individuals are first asked to provide PII/SPII to Travel Incorporated, or as soon as practicable thereafter, and in any event before Travel Incorporated uses the information for a purpose other than that for which it was originally collected. Travel Incorporated may disclose PII/SPII if required to do so by law or to protect and defend the rights or property of Travel Incorporated.
CHOICE: Travel Incorporated will offer individuals the opportunity to choose (opt-out) whether their PII/SPII is (a) to be disclosed to a non-Agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
For SPII information, Travel Incorporated will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a nonAgent third party or to the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
Travel Incorporated will provide customers and other covered individuals with reasonable mechanisms to exercise their choices should requisite circumstances arise.
DATA INTEGRITY: Travel Incorporated will use PII/SPII only in ways that are compatible with the purposes for which it was collected or subsequently authorized by our customers. Travel Incorporated will take reasonable steps to ensure that PII/SPII is relevant to its intended use, accurate, complete, and current.
ONWARD TRANSFERS (INCLUDING TRANSFERS TO AGENTS): Travel Incorporated will obtain assurances from third parties (including its Agents) that they will safeguard PII/SPII consistently with this Statement. Examples of appropriate assurances that may be sought from such third parties and Agents include: a contract obligating the third party or Agent to provide at least the same level of protection as is required by the relevant Privacy Shield Principles, being subject to the relevant provisions of the EU General Data Protection Regulation, (EU) 2016/679 (the “GDPR”), Privacy Shield certification by the Agent, standard contractual clauses as specified in the GDPR, or being subject to another European Commission adequacy finding (e.g., companies located in Hungary and Switzerland). Where Travel Incorporated has knowledge that a third party or Agent is using or disclosing PII/SPII in a manner contrary to this Statement, Travel Incorporated will take reasonable steps to prevent or stop such use or disclosure. Travel Incorporated holds it Agents accountable for maintaining the trust its customers place in us. In addition, with respect to onward transfers of PII/SPII to third parties by Travel Incorporated, Travel Incorporated has responsibility for the processing of PII/SPII that it receives under the Privacy Shield and subsequently transfers to a third party acting as an Agent for Travel Incorporated. Because of this, Travel Incorporated shall remain liable under the Principles if its Agent processes such PII/SPII in a manner inconsistent with the Principles, unless Travel Incorporated proves that it is not responsible for the event giving rise to the applicable damages.
ACCESS AND CORRECTION: Upon request, Travel Incorporated will grant customers and other covered individuals reasonable access to PII/SPII that it holds about them. In addition, Travel Incorporated will take reasonable steps to permit customers and other covered individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. Any customer or other individual covered by this Statement who desires to review, correct or delete their information can do so by contacting Travel Incorporated, Account Management, 4355 River Green Parkway, Duluth, GA 30096.
SECURITY: Travel Incorporated will take reasonable precautions to protect PII/SPII in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. Security is designed to prevent unauthorized access to database equipment and hard copies of PII/SPII and to monitor access to its servers to provide protection from hacking or other unauthorized access.
Travel Incorporated limits access to PII/SPII and data to those persons in Travel Incorporated’s organization, or Agents of Travel Incorporated or other third parties, that have a specific business purpose for maintaining and processing such information and data. Individuals who have been granted access to PII/SPII by Travel Incorporated are made aware of their responsibilities to protect the security, confidentiality and integrity of that information.
ENFORCEMENT: Travel Incorporated will conduct reviews of its relevant privacy practices to verify adherence to this Statement and the US Department of Commerce Privacy Shield Principles. Any employee who Travel Incorporated determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment. The U.S. Federal Trade Commission (“FTC”) has jurisdiction over Travel Incorporated’s compliance with the Privacy Shield.
V. Dispute Resolution
Any questions or concerns regarding the use or disclosure of PII/SPII should be directed to the Travel Incorporated Chief Privacy Officer at Travel Incorporated, 4355 River Green Parkway, Duluth, GA 30096. Travel Incorporated will investigate and attempt to resolve complaints and disputes regarding use and disclosure of PII/SPII in accordance with the principles contained in this Statement and shall be governed by, and construed in accordance with laws of the State of Georgia, USA. For complaints that cannot be resolved between Travel Incorporated and the complainant, Travel Incorporated has agreed to participate in the dispute resolution procedures of the panel established by the relevant European data protection authorities to resolve disputes pursuant to the Privacy Shield Principles. In addition, individuals covered by this Privacy Shield Statement may, under certain conditions, invoke binding arbitration to address complaints regarding Privacy Shield compliance that are not otherwise resolved by other mechanisms. More information about such binding arbitration may be found by accessing https://www.privacyshield.gov/article?id=ANNEX-I-introduction on the Department of Commerce’s official Privacy Shield website maintained by the Department of Commerce.
VI. Contact Information
Persons who wish to obtain access to their Personal Identifiable Information or Sensitive Personal Identifiable Information for purposes of access, correction or deletion should contact the following: Travel Incorporated, Account Management, 4355 River Green Parkway, Duluth, GA 30096
Persons who wish to resolve a dispute with Travel Incorporated over the practices described in this Statement should contact the following: Travel Incorporated, Chief Privacy Officer, 4355 River Green Parkway, Duluth, GA 30096
VII. Changes to this Privacy Shield Statement
The practices described in this Statement are current personal data protection policies as of the date set forth in the heading of this Statement. Travel Incorporated reserves the right to modify or amend this Statement at any time consistent with the requirements of the U.S.-EU Privacy Shield Framew