PRIVACY NOTICE

Last Updated: 11/04/2024

1. Introduction

This privacy notice (“Privacy Notice”) governs how TravelNet Solutions, LLC (along with its affiliates, collectively, “TNS”, “we” or “us”) collects, processes, and uses Personal Information (as defined below) relating to the users and visitors (collectively, “you”) of this website, and any other related websites (collectively, the “Site”,) and your rights with respect to your Personal Information. The Site and any services provided by TNS are collectively referred to as the “Services.”

Your use of the Services is subject to this Privacy Notice, which is incorporated into our Terms of Use. By using the Services, you agree to this Privacy Notice, which may be updated by us at any time. You should review this Privacy Notice carefully. If you do not agree with it, you may not use the Services. Please note that if you do not provide certain Personal Information to TNS when requested, we may not be able to provide you with access to all areas of the Services.

California residents, please read our California Privacy Notice. If you are a TNS employee in California, you will have separately received our California Employee Privacy Notice.

European Union or United Kingdom residents, please read our GDPR Privacy Notice. If you are a TNS employee in the European Union or United Kingdom, you will have separately received our EU/UK Employee Privacy Notice.

2. Definitions

1. “Personal Information” means any information that identifies, relates to, describes, could be used to identify or is otherwise associated with an individual person or household, which is in the possession of, or is likely to come into our possession (or the possession of our representatives or service providers), and includes the definition of “personal information,” “personal data,” and similar terms under applicable laws and regulations relating to data protection and privacy.

3. Our Collection and Sources of Personal Information

We may collect the categories of Personal Information listed below from or about you in connection with your access and/or use of the Services.

1. Communications Data. If you contact us directly, we may collect Personal Information about you, such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide.
2. Registration and Profile Information. When you register for an account, we may collect Personal Information such as your name, company name, address, email address, and telephone number.
3. Information Collected by Cookies. Like any other website, we use ‘cookies’. Via cookies, we may collect Personal Information including visitors’ preferences and the pages on the website that the visitor accessed or visited. For more information on our cookies usage, please read our Cookies Policy.
4. Technical Information. We may automatically receive and record technical information from your computer, web browser, and/or mobile device, such as your IP address or other device address or ID, web browser and/or device type, hardware and software settings and configurations, Internet Service Provider (ISP), the web pages or sites that you visit just before or just after visiting the Site, the pages you view on the Site, your actions on the Site, and the dates and times that you visit, access, or use the Site. This includes information about how you use and navigate the Site, such as which links you click on, which pages or content you view and for how long, and other similar information and statistics about your interactions with the Site (together, “Usage Data”).
5. Payment Information. If you choose to use a paid account or service, a third-party vendor may collect payment information on our behalf. We utilize the services of AWS, FreedomPay, Spreedly, SlimCD, Yapstone, Payrix, and Authorize.net to collect, process, and store your credit card information, and we may gain access to certain information about your method of payment, such as your name, email address, billing address, and the last four (4) digits of your credit card.

4. How We Use Your Information

We use the information we collect in various ways, including to:

1. Provide, operate, and maintain our Services;
2. Improve, personalize, and expand our Services (including customizing our web page content based on browser type and/or other information);
3. Understand and analyze how you use our Services (including analyzing trends, administering the site, tracking users’ movement on the website, and gathering demographic information);
4. Develop new products, services, features, and functionality of our Services;
5. Communicate (including by email) with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the website, and for marketing and promotional purposes;
6. For ongoing review and improvement of the information, content, and Services provided to ensure they are user-friendly;
7. Conduct analysis required to detect malicious data and understand how this may affect your IT system;
8. Perform in-depth threat analysis, prevent any potential disruptions such as cyber-attacks, and conduct statistical monitoring and analysis of current attacks on devices and systems for the ongoing adaptation of the solutions provided to secure systems and devices against current attacks;
9. Find and prevent fraud and other crimes or malpractice, and improve fraud detection and information security;
10. For the purpose of, or in connection with, any legal proceedings (including prospective legal proceedings), and obtain legal advice or to establish, exercise, or defend our legal rights;
11. Confirm and verify your identity and conduct due diligence;
12. Manage and administer our business, and comply with our contractual obligations;
13. For all purposes otherwise set out in this Privacy Notice; and
14. If you are located in a jurisdiction that requires us to obtain your consent to collect, use, store, process, and disclose your Personal Information, you understand that by accepting the terms of this Privacy Notice, you expressly provide your consent to us collecting, using, storing, processing, and disclosing your Personal Information as set out in this Privacy Notice.

5. Our Disclosure of Personal Information

TNS does not share Personal Information with unaffiliated third parties except when we have your permission, as required by law, and/or under the following circumstances:

1. We work with third-party service providers to provide website development, hosting, data storage, maintenance, and other services for us. To the extent necessary for these third-party service providers to complete their contractual obligations to us, they may have access to or process information about you.
2. We may partner with certain third parties to collect information regarding your use of our Services in order to improve our maintenance and support. These third parties may also engage in analysis, auditing, research, and reporting and may use web logs or web beacons, and they may set and access cookies on your computer or other device. If you prefer to prevent third parties from setting and accessing cookies on your computer, you may set your browser to block cookies. Please note that certain aspects of our Services may not work correctly if you block cookies. Any third-party plugins and components are governed by the privacy notice of the company providing them (and not this Privacy Notice), so we advise you to read their privacy statements.
3. In some cases, to provide the Services, we share information about you with trusted partners who work on our behalf under confidentiality agreements.
4. We may partner with third parties to manage our advertising on other websites. Our partners may use tracking technologies to gather information about your activities to provide you with advertising based on your browsing activities and interests.
5. We may share information about you to protect TNS, customers, and others, such as to enforce our agreements, policies, and terms of use.
6. We may share information in response to subpoenas, court orders, or legal processes, or to establish or exercise our legal rights or defend against legal claims.
7. We may share information about you in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person or as otherwise required by law.
8. No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
9. In the event of a corporate transaction, such as a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of any or all of our assets or liabilities, some of the Personal Information that we hold may be among the assets or liabilities transferred to a buyer or other successor. We may also transfer Personal Information to another entity or its affiliates or service providers in connection with, or during negotiations of, any merger, acquisition, sale of assets or liabilities or any line of business, change in ownership control, financing transaction, or in the unlikely event of a bankruptcy.

6. Your Rights

Depending on the jurisdiction in which you reside, you may have legal rights in relation to your Personal Information. These rights may include:

1. Declining to share certain information with us (in which case we may not be able to provide to you some of the features and functionality of the Services);
2. Requesting and obtaining information regarding how we may use your Personal Information;
3. In some circumstances, requesting and receiving some Personal Information about you that you have provided to us;
4. In some circumstances, requesting that we correct your Personal Information if it is inaccurate or incomplete;
5. In some circumstances, requesting that we erase your Personal Information (but please note that there may be circumstances where we are legally entitled to retain Personal Information regardless of any such request);
6. In some circumstances, requesting that we restrict or block our processing of your Personal Information (again, there may be circumstances where we are legally entitled to refuse that request); and
7. Where applicable, the right to lodge a complaint with the data protection regulator in your jurisdiction if you think that any of your rights have been infringed by us.

You can inquire about your rights by contacting us using the contact details below.

7. How We Protect Your Information

1. Data Security. We maintain physical, technical and administrative safeguards designed to protect the integrity and security of your information. We cannot, however, ensure or warrant the security of any information you transmit to us through the Services and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of any of our physical, technical or administrative safeguards. Although we may allow you to adjust your privacy settings to limit access to your information, no security measures are perfect or impenetrable. We cannot control the actions of other users or other third parties with whom you may choose to share your information. Therefore, we cannot and do not guarantee that information you provide through the Services will not be viewed by unauthorized persons. We are not responsible for circumvention by any third party of any privacy settings or security measures contained within the Services.
2. Data Retention. We only store your Personal Information for as long as may be needed to provide the Services to you, with the exception of Personal Information that we may need to store for a longer period of time to comply with legal or regulatory obligations, resolve disputes, enforce our agreements or for records management purposes. We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site, or we are legally obligated to retain this data for longer periods. Even after removal, copies of information that you have posted may remain viewable in cached and archived pages or if other users have copied or stored such information.
3. Protecting Minors. Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity. We do not knowingly collect any Personal Information from children under the age of thirteen (13). If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

8. International Visitors

The Services are controlled and operated by TNS in the United States. If you choose to access the Services from outside the United States, you acknowledge that you will be transferring your information, including Personal Information, outside of those regions to the United States for storage and processing, as necessary to provide to you the Services and you consent to such transfer.

9. Other Important Information

1. Changes and Updates to this Privacy Notice. We reserve the right to make changes to this Privacy Notice at any time. We will notify you about significant changes in the way we treat your information, such as by placing a prominent notice on the Site or by sending you an email so that you can choose whether to continue using the Services. Material modifications are effective thirty (30) calendar days after our initial notification or upon your acceptance of the modified Privacy Notice. Immaterial modifications are effective upon posting of the updated Privacy Notice on the Site. Please revisit this page periodically to stay aware of any changes to this Privacy Notice. For the avoidance of doubt, disputes arising hereunder will be resolved in accordance with the Privacy Notice in effect at the time the dispute arose.
2. Third-Party Websites. The Services may provide links to, or features from, other third-party websites. If you link to or use such third-party sites or features, you do so at your own risk. We do not control and are not responsible for the content or practices of any third-party website, application or other product or service.

10. Our Contact Information

If you have any questions or comments about this Privacy Notice or our practices regarding your Personal Information, please email us at [email protected] or call us at 844-757-0800.

TNS PRIVACY REQUEST CENTER

If you are a resident in the European Union, United Kingdom or California, you have certain rights with respect to your Personal Information under applicable data protection laws. If you wish to exercise any of these rights, please fill in the form applicable to the request you wish to make.

Please note it is our responsibility to comply with any request only where we are the data controller of your Personal Information and subject to data protection laws in the European Union, United Kingdom or California in respect of your Personal Information. Please see our Privacy Notice, GDPR Privacy Notice, and California Privacy Notice for further details on our processing as a data controller. For the avoidance of doubt, where providing services to our customers who are property owners or managers, we typically act as the data processor and that customer is the data controller. Please contact directly the relevant data controller entity with whom you have a relationship to exercise any data protection rights.

Please note that where you submit a request, we may request further information from you to verify your identity. We will respond to your request within the statutory timeframes required, subject to any extensions or exemptions to which we are lawfully entitled. If we do not think we have to comply with your request, we will always tell you.
If you wish to exercise any of the below rights on behalf of another individual, please contact us on: [email protected].

Definitions

Capitalized terms used herein but not otherwise defined shall have the meaning assigned to it in the Privacy Notice.

Personal Information Access Request

Personal Information Access Request Form

Personal Information Correction Request

Personal Information Correction Request Form

Personal Information Deletion Request

Personal Information Transfer Request

Personal Information Transfer Request Form

Personal Information Processing Objection or Restriction Request

Personal Information Processing Objection Request Form

COOKIE POLICY

Last updated: 11/04/2024

This Cookie Policy (“Policy”) applies to the website https://tnsinc.com/ (“Website”) operated by Travelnet Solutions, LLC at 9900 Hemingway Avenue, South Cottage Grove, Minnesota 55016 United States (“TNS“, “we“, “us“, “our“).

When you use our Website, we set and access cookies on your device. This Policy describes what cookies we use and how you may manage these.

1. What Are Cookies?

Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. You can find more information about cookies at http://www.allaboutcookies.org/.

Other similar files such as pixels and beacons work in the same way and we use the word ‘cookie’ in this Policy to refer to all technologies that collect information in this way.

2. Cookies That We Use

We use the following browser cookies for the following purposes:

1. Necessary cookies. These cookies are required to enable the basic features of this site, such as providing secure log-in or adjusting your consent preferences. We do not need your consent for these cookies.
2. Analytics cookies. These cookies are used to understand how visitors interact with the Website. These cookies help provide information on metrics such as the number of visitors, bounce rate, traffic source, etc. We ask for your consent for these cookies.
3. Functional cookies. Functional cookies help perform certain functionalities like sharing the content of the Website on social media platforms, collecting feedback, and other third-party features. We ask for your consent for these cookies.
4. Performance cookies. These cookies are used to understand and analyze the key performance indexes of the Website, which helps in delivering a better user experience for the visitors. We ask for your consent for these cookies.
5. Advertisement cookies. These cookies are used to provide visitors with customized advertisements based on the pages you visited previously and to analyze the effectiveness of the ad campaigns.

3. Managing Cookies

We will always ask for your consent to use cookies, expect for necessary cookies.

If you have accepted any non-necessary cookies, most web browsers allow some control of cookies through the browser settings. You can change your cookie preferences by deleting cookies using your browser and refreshing any page on our Website. You may wish to visit http://www.allaboutcookies.org/ which contains comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your device.

You can choose to enable or disable some or all of the cookies we use, but disabling some of them may affect your browsing experience.

4. Changes To This Policy

We may make changes to this Policy at any time by posting a copy of the revised policy on the Website.

5. Contact Us

If you have any questions about this Policy, please contact [email protected].

Subprocessors

Introduction

Under Data Protection Laws (as defined in the TravelNet Solutions Data Processing Addendum or “DPA”), TravelNet Solutions, in its role as data processor, is required to disclose third-parties who process personal data on our customer’s behalf. The below listed subprocessors perform an important role in the Services TravelNet Solutions provides.

What is a subprocessor?

A subprocessor is a third party, acting on behalf of TravelNet Solutions. Subprocessors process personal data of which TravelNet Solutions is a processor. Subprocessors only process personal data pursuant to a written contract between TravelNet and the subprocessor which includes necessary and appropriate security, privacy and compliance obligations.

TravelNet Solutions’ commitments with respect to subprocessors, including how we add or replace subprocessors, are outlined in the TravelNet Solutions DPA.

Subprocessors

Third-Party Software Subprocessors

TERMS OF USE

Last updated: 11/04/2024

Introduction

These terms of use (the “Terms of Use”), together with our Privacy Notice, set forth the terms and conditions (“Terms”) that apply to your access and use of this website, and any other related websites (collectively, the “Site”). “TNS” means Travelnet Solutions, LLC and its officers, directors, employees, consultants, affiliates, subsidiaries, and agents.

By using or accessing the Site you agree to these Terms, as updated from time to time in accordance with Section 8 below. The Terms apply only to your use of this Site. If you are a customer of TNS, you are subject to separate terms, including the terms set forth in the Master Services Agreement, available here.

1. Use of Site

To use the Site you must (A) be at least eighteen (18) years of age; (B) have not previously been suspended or removed from the Site; and (C) use the Site in compliance with any and all applicable laws and regulations.

2. Accuracy of Information

To access some features of the Site, you may be required to provide additional information (e.g., booking a demo). When you request a demo, we may ask you to give us certain identifying information about yourself, including but not limited to your email address and other contact information (“Registration Information”). When providing such information, you agree to provide true, accurate, current, and complete information about yourself. You also agree not to impersonate anyone, misrepresent any affiliation with anyone else, use false information, or otherwise conceal your identity from TNS for any purpose.

3. Prohibited Conduct

You agree not to:

1. Use the Site for any illegal purpose, or in violation of any local, state, national, or international law;
2. Violate or encourage others to violate the rights of third parties, including intellectual property rights;
3. Post, upload, or distribute any content that is unlawful, defamatory, libelous, inaccurate, or that a reasonable person could deem to be objectionable, profane, indecent, pornographic, harassing, threatening, hateful, or otherwise inappropriate;
4. Interfere in any way with security-related features of the Site;
5. Interfere with the operation or any user’s enjoyment of the Site, including by uploading or otherwise disseminating viruses, adware, spyware, worms, or other malicious code, making unsolicited offers or advertisements to other users, or attempting to collect personal information about users or third parties without their consent;
6. Access, monitor or copy any content or information of the Site using any robot, spider, scraper, or other automated means or any manual process for any purpose without TNS’ express written permission;
7. Frame the Site, place pop-up windows over its pages, or otherwise affect the display of its pages;
8. Perform any fraudulent activity, including impersonating any person or entity, claiming false affiliations, or falsifying your identity or any information about you, including age or date of birth; or
9. Sell or otherwise transfer the access granted herein.

4. Third-Party Content.

The Site may contain links to third party websites and services. TNS provides such links as a convenience and does not control or endorse these websites and services. You acknowledge and agree that TNS has not reviewed the content, advertising, products, services, or other materials that appear on such third party websites or services, and is not responsible for the legality, accuracy, or appropriateness of any such content, and shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with the use of any such third party websites or services.

5. Intellectual Property and User Content.

You acknowledge and agree that you relinquish all ownership rights in any ideas or suggestions that you submit to TNS through this Site. You acknowledge that TNS has full rights to use and implement any such ideas and suggestions. The Site are protected by applicable copyright and other intellectual property laws, and no materials from the Site may be copied, reproduced, republished, uploaded, posted, transmitted, or distributed in any way without our express permission. All trademarks and service marks on the Site belong to TNS, except third-party trademarks or service marks, which are the property of their respective owners.

6. Indemnification.

You agree that you will be personally responsible for your use of the Site, and you agree to defend, indemnify, and hold harmless TNS from and against any and all claims, liabilities, damages, losses, and expenses (including attorneys’ and accounting fees and costs), arising out of or in any way connected with (a) your access to, use of, or alleged use of the Site; (b) your violation of the Terms or any applicable law or regulation; (c) your violation of any third party right, including without limitation any intellectual property right, publicity, confidentiality, property, or privacy right; or (d) any disputes or issues between you and any third party. TNS reserves the right, at our own expense, to assume the exclusive defense and control of any matter otherwise subject to indemnification by you, and in such case, you agree to cooperate with our defense of such claim.

7. Termination.

If you violate these Terms, your permission to use the Site will automatically terminate. In addition, TNS in its sole discretion may suspend or terminate some or all of your access to the Site at any time, with or without notice to you. After your access is terminated, TNS may continue to store information and content previously provided by you.

8. Modification of Terms.

TNS reserves the right at any time to modify these Terms and to impose new or additional terms or conditions on your use of the Site. Such modifications and additional terms and conditions will be effective immediately upon notice and incorporated into these Terms. We will make reasonable efforts to notify you of any material changes to the Terms, including, but not limited to, by posting a notice to our website or by sending an email to any address you may have provided to us. Your continued use of the Site following notice will be deemed acceptance of any modifications to the Terms.

9. Disclaimer of Warranties.

The Site are provided “as is” and on an “as available” basis, without warranty or condition of any kind, either express or implied. Although TNS seeks to maintain safe, secure, accurate, and well-functioning services, we cannot guarantee the continuous operation of or access to our Site, and there may at times be inadvertent technical or factual errors or inaccuracies. TNS specifically (but without limitation) disclaims (a) any implied warranties of merchantability, fitness for a particular purpose, quiet enjoyment, or non-infringement; and (b) any warranties arising out of course-of-dealing, usage, or trade. You assume all risk for any/all damages that may result from your use of or access to the Site. TNS does not guarantee the accuracy of, and disclaims all liability for, any errors or other inaccuracies in the information, content, recommendations, and materials made available through the Site.

10. Limitation of Liability.

In no event will TNS be liable to you for any incidental, special, consequential, direct, indirect, or punitive damages, whether based on warranty, contract, tort (including negligence), statute, or any other legal theory, whether or not TNS has been informed of the possibility of such damage. By accessing the Site, you expressly and unconditionally release and hold us harmless from any and all liability for any injuries, loss or damage of any kind arising from or in connection with the use and/or misuse of such information. Some jurisdictions do not allow the disclaimer of warranties or limitation of liability in certain circumstances. Accordingly, some of the above limitations may not apply to you.

11. Governing Law.

These Terms are governed by the laws of the State of Minnesota, without regard to conflict of law principles. Subject to Section 12, which provides that disputes are to be resolved through binding arbitration or small claims court, to the extent that any lawsuit or court proceeding is permitted hereunder, you and TNS agree to submit to the exclusive personal jurisdiction of the state courts and federal courts located within Hennepin County, Minnesota for the purpose of litigating all such disputes.

12. Dispute Resolution by Binding Arbitration.

In the interest of resolving disputes between you and TNS in the most expedient and cost effective manner, you and TNS agree to resolve disputes through binding arbitration or small claims court instead of in courts of general jurisdiction (“Agreement to Arbitrate”). Arbitration is more informal than a lawsuit in court. Arbitration uses a neutral arbitrator instead of a judge or jury, allows for more limited discovery than in court, and is subject to very limited review by courts. Arbitrators can award the same damages and relief that a court can award. Any arbitration under these Terms will take place on an individual basis; class arbitrations and class actions are not permitted. You acknowledge and agree that the arbitrator may award relief (including monetary, injunctive, and declaratory relief) only in favor of the individual party seeking relief and only to the extent necessary to provide relief necessitated by that individual party’s claim(s). Any relief awarded cannot affect other users.

13. Modification of the Site.

TNS reserves the right to modify or discontinue, temporarily or permanently, some or all of the Site at any time without any notice or further obligation to you. You agree that TNS will not be liable to you or to any third party for any modification, suspension, or discontinuance of any of the Site.

14. General.

1. Entire Agreement. These Terms, together with the Privacy Notice, constitute the entire and exclusive understanding and agreement between you and TNS regarding your use of and access to the Site, and except as expressly permitted above may only be amended by a written agreement signed by authorized representatives of the parties.
2. No Waiver. The failure to require performance of any provision shall not affect our right to require performance at any time thereafter, nor shall a waiver of any breach or default of the Terms constitute a waiver of any subsequent breach or default or a waiver of the provision itself.
3. Paragraph Headers. Use of paragraph headers in the Terms is for convenience only and shall not have any impact on the interpretation of particular provisions.
4. Severability: In the event that any part of the Terms is held to be invalid or unenforceable, the unenforceable part shall be given effect to the greatest extent possible and the remaining parts will remain in full force and effect.

15. Notice to California Residents.

Under California Civil Code Section 1789.3, you may contact the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs in writing at 1625 N. Market Blvd., Suite S-202, Sacramento, California 95834, or by telephone at (800) 952-5210 in order to resolve a complaint regarding the service or to receive further information regarding use of the service.

CALIFORNIA PRIVACY NOTICE

Last updated: 10/17/2024

1. Introduction

TravelNet Solutions, LLC along with its affiliates, collectively, “TNS,” “we” or “us”) recognizes the importance of, and is committed to, maintaining the privacy of personal information that it receives relating to individuals. This supplemental privacy notice (“California Privacy Notice”), which is provided in addition to the Privacy Notice, governs how TNS collects, processes, and uses Personal Information (as defined below) relating to residents of the State of California (collectively, “you”) covered by the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act, collectively, the “CCPA”) and provides information regarding how such California residents can exercise their rights under the CCPA. In case of conflict between the Privacy Notice and this California Privacy Notice, this California Privacy Notice will control with respect to California residents covered by this California Privacy Notice.

This California Privacy Notice is only relevant to you if you are a resident of California as determined in accordance with the CCPA. This California Privacy Notice is available in alternative formats upon request. Please contact [email protected] or 844-757-0800 to request this California Privacy Notice in an alternative format. If you are a TNS employee in California, you will have separately received our California Employee Privacy Policy.

2. Definitions

1. Capitalized terms used herein but not otherwise defined shall have the meaning assigned to them in the Privacy Notice.

3. Our Collection, Use, Retention and Disclosure of Personal Information

1. Sales and Sharing of Personal Information. We do not and have not sold any categories of Personal Information to third parties or shared any categories of Personal Information for the purpose of cross-context behavioral advertising.
2. Collection, Sources and Use of Personal Information. We have collected and used the following categories of Personal Information from the following sources and for the following business purposes during the 12-month period prior to the “last updated” date of this California Privacy Notice:

3. Protecting Minors. Our Services are intended for use by individuals over the age of 13. We do not knowingly collect Personal Information from individuals under the age of 13. If you are under 13 years of age, then please do not use or access the Services at any time or in any manner.
4. Anonymized or De-Identified Data. TNS may share anonymous or aggregated data in order to facilitate our business operations. To the extent such data constitutes anonymized or de-identified data under the CCPA and other applicable privacy and data protection laws, we will maintain and use such data without attempting to re-identify the data.
5. No Automatic Decision-making. We may process some of your Personal Information automatically, but we do not use computer algorithms to make automated decisions based on your Personal Information.
6. Sensitive Personal Information. Sensitive Personal Information may include social security numbers, driver’s license numbers, passport numbers, and account credentials. To the extent we collect your Sensitive Personal Information, we will not use or disclose such information for purposes other than (i) to perform services/goods that you reasonably expect from us; (ii) to prevent, detect, and investigate security incidents; (iii) to resist illegal actions directed at the business and prosecute or defend our rights; (iv) to ensure the physical safety of others; (v) for short-term, transient use; (vi) to perform services necessary for the business; (vii) to verify and maintain the quality and safety of our products or services; and (viii) generally for purposes that do not infer characteristics about you.
7. Retention of Personal Information. We retain Personal Information for as long as is reasonably necessary in connection with the purposes for which the Personal Information was collected. For additional information on how we store your Personal Information, please refer to Section 7 of the Privacy Notice.
8. Disclosures of Personal Information for Business Purposes. We have disclosed the following categories of Personal Information to the following categories of recipients for the following business purposes during the 12-month period prior to the “last updated” date of this California Privacy Notice:

4. Your California Privacy Rights

1. Your CCPA Privacy Rights. You have certain choices regarding our use and disclosure of your Personal Information, as described below.
   1. Know. You have the right to request, twice in a 12-month period, that we provide (a) certain information about the (1) the categories of Personal Information we have collected about you, (2) the categories of sources from which the Personal Information is collected; (3) the business or commercial purpose for collecting your Personal Information; and (4) the categories of third parties with whom we have shared your Personal Information; and/or (b) the specific pieces of Personal Information we have collected, used, and disclosed about you during the past 12 months.
   2. Deletion. You have the right to request that we delete certain Personal Information we have collected from you and to tell our service providers to do the same.
   3. Correction. You have the right to request that we correct or amend certain Personal Information we maintain about you if it is inaccurate.
   4. Limit. You have the right to request that we limit the use and disclosure of Sensitive Personal Information we have collected. If TNS collects any sensitive personal information, it will use it only for purposes listed above in Section 3(F). As such, any sensitive personal information that we collect does not come within this right to limit use.
   5. Opt-out. You have the right to opt out of the sale of your Personal Information to third parties and/or the sharing of your Personal Information for certain purposes. As noted above, we do not sell or share Personal Information to or with third parties.
   6. Non-Discrimination. You have the right to not experience discriminatory treatment, and we will not discriminate against you, because you have exercised any California consumer privacy rights. We do not use the fact that you have exercised or requested to exercise any CCPA rights for any purpose other than facilitating a response to your request.
2. How To Submit a Request. You may submit a request by using one of the following methods.
   1. Email. Email us at [email protected].
   2. Call. Call us at 844-757-0800.
   3. Form. Submit a request at the TNS Privacy Request Center.
3. Verifying Your Request. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your Personal Information or complying with your request. If we are successful in validating your identity, we will respond to your request within the time and in the manner required by CCPA. If we are unable to verify your identity, we will need to deny your request. We reserve the right to deny requests in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.
   1. Consumer Verification. If you request to know, access, delete, and/or correct your Personal Information, we may require you to provide any of the following information: address, date of birth, state or country of residence, telephone number, email address, or details of a transaction. In addition, if you ask us to provide you with specific pieces of Personal Information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request. We will use the information you submit and the information we have in our systems to try to verify your identity and to match the Personal Information we have collected about you, if any, to your identity.
   2. Authorized Agent. If you designate an authorized agent to make an access or deletion request on your behalf, we may require you to (a) provide the authorized agent written permission (e.g., via a notarized letter) to do so, and (b) verify your own identity directly with us (as described above), and confirm with us that you provided the authorized agent permission to submit the request.
4. Additional California Privacy Disclosures.
   1. Do Not Track Signals. Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals via your browser settings to express your preferences regarding online tracking. Due to the lack of any standard for how do-not-track should work on commercial websites, we do not currently respond to such signals.
   2. Shine the Light Notice. California residents may request and obtain from us, once a year and free of charge, information about categories of Personal Information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal 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 using the contact information provided in Section 4(B), above.

GDPR PRIVACY NOTICE

Last updated: 11/04/2024

1. Introduction

Travelnet Solutions, LLC along with its affiliates listed in Section 9 of this GDPR Privacy Notice (defined below), collectively, “TNS,” “we” or “us”) recognizes the importance of, and is committed to, maintaining the privacy of personal information that it receives relating to individuals.

This supplemental privacy notice (“GDPR Privacy Notice”), which is provided in addition to the Privacy Notice, governs how TNS collects, processes, and uses Personal Information (as defined below) relating to residents of the European Union (“EU”) and the United Kingdom (“UK”) (collectively, “you”) covered by the EU General Data Protection Regulation (“EU GDPR”) and the UK General Data Protection Regulation (“UK GDPR” and together with the EU GDPR, “GDPR”) and provides information regarding how such EU and UK residents can exercise their rights under the GDPR. In case of conflict between the Privacy Notice and this GDPR Privacy Notice, this GDPR Privacy Notice will control with respect to EU and UK residents covered by this GDPR Privacy Notice.

This GDPR Privacy Notice is only relevant to you if you are a resident of EU or the UK and we are a data controller of your Personal Information and subject to the GDPR in respect of our processing of your Personal Information. By using the Services, you confirm that you understand and acknowledge the provisions of the Privacy Notice and this GDPR Privacy Notice.

If you are a TNS employee in the EU or UK, you will have separately received our GDPR Employee Privacy Notice.

2. Definitions

Capitalized terms used herein but not otherwise defined shall have the meaning assigned to it in the Privacy Notice.

3. How we collect your Personal Information

We collect Personal Information about you directly from you, for example, when you request to receive Services from us or, where you are our customer, you are using our website.

If you fail to provide certain Personal Information when requested, we may not be able to perform the contract we have entered into with you to provide you services, or we may be prevented from complying with our legal obligations.

4. Purposes and Lawful Basis of Processing

The GDPR requires that we only process your Personal Information for purposes that we tell you about and only where we have a lawful basis to do so. The table below sets out our purposes of processing (as set out in Section 4 of the Privacy Notice) and the lawful basis of processing we rely on. For additional information on the Personal Information we collect, please refer to Section 3 of the Privacy Notice.

5. International Transfers

We may transfer your Personal Information to a recipient based in a country outside of the European Economic Area and the UK. Where we do so, we will ensure that such transfer is in accordance with our obligations under the GDPR. For example, this may involve transferring your Personal Information to a jurisdiction deemed to provide an adequate level of protection of your Personal Information under the GDPR. Other times, the recipient may be in a jurisdiction that has less stringent laws relating to Personal Information. In these circumstances, we will put in place appropriate safeguards to ensure that your Personal Information remains adequately protected, which may include entering into European Commission or UK Information Commissioner’s Office approved standard contractual clauses with the recipient of your Personal Information. If you would like more details about the safeguards we rely on, please contact us using the details set out in Section 8 of this GDPR Privacy Notice.

For additional information on how we store your Personal Information, please refer to Section 8 of the Privacy Notice.

6. Your GDPR Rights

You have certain choices regarding your Personal Information, as described below.

1. Access. You have the right to obtain a copy of the Personal Information we hold about you and other supplementary information from us.
2. Deletion. You have the right to request that we delete certain Personal Information we have collected from you and to tell our service providers to do the same.
3. Correction. You have the right to request that we correct or complete certain Personal Information we maintain about you if it is inaccurate or incomplete.
4. Transfer. You have the right to ask us to transfer your Personal Information to a different data controller.
5. Restriction. You have the right to request that we limit the use and disclosure of your Personal Information in certain circumstances.
6. Objection. You have the right to object to our processing of your Personal Information where we are processing it on the legitimate interests lawful basis, including where we are using it for direct marketing purposes.
7. Withdraw consent. While we do not typically rely on consent to process your Personal Information, where we do so you have the right at any time to withdraw your consent.

However, please note that some of these rights may not always apply, as there are sometimes requirements and exemptions, which may mean we need to keep processing the Personal Information or not disclose it, or other times when the rights may not apply at all. We will always tell you if we think we do not have to comply.

To exercise any of these rights, please visit the TNS Privacy Request Center or contact us using the details set out in Section 8 of this GDPR Privacy Notice.

You also have the right to complain to your local data protection regulator about our processing of your Personal Information, although we would always ask you to speak to us or, if you are resident in the EU, our EU representative or, if you are resident in the UK, our UK representative first if possible on the contact details set out in the ‘Contact Us’ section below. In the UK, the data protection regulator is the ICO and their contact details are available here: https://ico.org.uk/make-a-complaint/. If you live in an EU member state, you can find your local data protection regulator here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

7. Other GDPR Disclosures

1. No Automatic Decision-making. We may process some of your Personal Information automatically, but we do not use computer algorithms to make automated decisions based on your Personal Information.
2. Retention of Personal Information. We retain Personal Information for as long as is reasonably necessary in connection with the purposes for which the Personal Information was collected. For additional information on how we store your Personal Information, please refer to Section 7 of the Privacy Notice.

8. Contact Us

If you have any questions about this Privacy Notice or our processing of your Personal Information, or to exercise any of your rights, then please contact [email protected].

9. TNS Data Controllers