Last Updated: July 11, 2019
2. Our Corporate Travel Services and Traveler Data
3. Information We Collect
4. The Purposes for Which We Use Personal Information
5. How We Disclose PII
6. Your Rights and Choices
8. International Data Transfers and Privacy Shield
11. Contact Us
12. Legal Bases for Processing
13. Sensitive Personal Information
15. Your Rights
Please see our Product Privacy Statement for a description of our privacy practices in relation to our corporate travel management services.
Typically, our customers are employers who use our services to facilitate corporate travel and events, and other employee travel. Our use of personal information for the travel services is governed by our customer agreements and privacy policies that our customers may make available to their employees.
Information you provide to us. Personal information you provide to us through the Services or otherwise includes:
- Business and personal contact information, such as your first and last name, email and mailing addresses, phone number, professional title and company name.
- Demographic information, such as your city, state, country of residence, postal code, and age.
- Content you choose to upload to the Websites, such as text comments you may leave on our blog.
- Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
- Usage information, such as information about how you use the Services and interact with us, including information associated with any content you upload to the Websites or otherwise submit to us, and information you provide when you use any interactive features of the Services.
- Marketing information, such as your preferences for receiving communications about our activities and publications, and details about how you engage with our communications
- Information included in your job application, such as professional credentials and skills, educational and work history, and other information of the type that may be included in your resume.
Finally, we may periodically conduct surveys. Participation in any Ovation survey is completely voluntary. Ovation takes the information received from individuals responding to surveys and combines (or aggregates) it with the responses of other individuals to create broader, generic responses to the survey questions.
We use personal information for the following purposes:
- To operate the Services, including to provide, develop, and improve our Services, provide information about our products and services, communicate with you about the Services (including by sending you announcements, updates, security alerts, and support and administrative messages), understand your needs and interests, and personalize your experience with the Services and our communications, provide support and maintenance for the Services, and respond to your requests, questions and feedback.
- For research and development, including to develop new products and services, including by studying user demographics and use of the Services (such as through market research).
- For recruiting purposes, including to manage our recruiting and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics.
- To send you Ovation-related marketing and promotional communications as permitted by law. You will have the ability to opt‐out of our marketing and promotional communications as described in the Opt out of marketing section below.
- To display advertisements. We work with advertising partners to display advertisements on the Service or elsewhere online. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Services or your activity elsewhere online. Please see the Targeted online advertising section below to learn more about your choices in connection with advertisements.
- As we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
- As we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Services; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
- As otherwise described when we specifically ask for your consent to collect, use or share your personal information, such as when required by law.
- To create anonymous, aggregated or de‐identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de‐identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de‐identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.
We may disclose the personal information we collect to the following categories of recipients:
- Other users of the Services and the public, through functionality we provide that enables you to disclose personal information to other users of the Services or the public. For instance, you may be able to submit content to the Services (such as comments, reviews, surveys, blogs, photos, and videos), and we will display your name along with the content you submit. We do not control how other users or third parties use any personal information that you make available to other users or the public.
- Professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
- Law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
- Third parties in connection with a business transfer, in which we may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
All users have the following rights and choices available to them with respect to the personal information we hold about them. Users who are located in the European Union can find additional information about their rights below.
Access or update your information. If you would like to access, update or correct the personal information we hold about you, please submit a request to firstname.lastname@example.org.
Opt out of receiving electronic direct marketing communications from us. You may opt out of marketing‐related emails by following the opt‐out or unsubscribe instructions at the bottom of the respective email. You may continue to receive service‐related and other non‐marketing emails.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive the Services by designating it as required at the time of collection or through other appropriate means.
Ovation maintains commercially reasonable administrative, technical and physical safeguards designed to (i) protect the security and confidentiality of personal information; (ii) identify, assess and protect against any reasonably foreseeable internal and external threats, risks or hazards to the security or integrity of personal information; and (iii) protect against unauthorized access to or use of personal information. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
The Services are not direct to children under the age of 13, and we do not knowingly collect information from children under the age of 13 on the Websites. If a parent or guardian becomes aware that his or her child has provided us with personal information through the Websites, please contact us. We will delete such information from our files as soon as reasonably practicable.
Ovation Travel Group
71 Fifth Avenue
New York, NY 10003
Ovation Travel Group
15 Little Portland Street
Marylebone, London, W1W 8BW
NOTICE TO EUROPEAN USERS
The information provided in this “Notice to European Users” section applies only to individuals in Europe.
Details regarding each processing purpose listed below are provided in the section above titled “How we use your personal information”
Processing is necessary to perform the contract governing our provision of the Service or to take steps that you request prior to signing up for the Service. If we have not entered into a contract with you, we process your personal information based on our legitimate interest in providing the Service you access and request.
These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Processing is necessary to comply with our legal obligations.
Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Service.
We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services, or otherwise to us.
We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information we have otherwise collected about you, we will dissociate such information from the information attached to your content. In some circumstances we may anonymize your personal information (so that it can no longer be associated with you), in which case we may use this information indefinitely without further notice to you.
European data protection laws give you certain rights regarding your personal information. If you are located within the European Union, you may ask us to take the following actions in relation to your personal information that we hold:
- Provide you with information about our processing of your personal information and give you access to your personal information.
- Update or correct inaccuracies in your personal information.
- Delete your personal information.
- Transfer a machine‐readable copy of your personal information to you or a third party of your choice.
- Restrict the processing of your personal information.
- Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You may submit these requests by email to email@example.com. We may request additional information from you to help us confirm your identity and process your request.
Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.