Effective as of June 12, 2019
Ovation Travel Group, Inc. and its affiliates (collectively, “Ovation”) provide business travel services, bespoke luxury travel experiences and meeting and special events planning.
This Product Privacy Statement explains how we collect, use, disclose, and otherwise process traveler personal information on behalf of business customers in connection with our corporate travel products and services, including the GOvation mobile app (collectively, the “Services”). Ovation is the data processor and Ovation customers are the data controllers with respect to such personal information.
Ovation’s processing of personal information in connection with the Services is governed by this Product Privacy Statement and our customer agreements. In the event of any conflict between this Product Privacy Statement and a customer agreement, the customer agreement will control to the extent permitted by applicable law.
This Product Privacy Statement is not a substitute for any privacy notice that Ovation customers are required to provide to their employees or other travelers.
Information We Collect
Information provided to us by travelers in connection with their use of the Services. This may include personal information that travelers provide about themselves or other individuals on the traveler’s itinerary, when they:
- Register for an account or create a user profile (such as first and last name, email address, telephone number(s), employer name, job title, department or department number, and employee identification number);
- Use the Services to book travel or otherwise complete a reservation with an airline carrier, hotel, car rental agency, or other supplier named on the traveler’s itinerary (such as first and last name, middle initial, salutation, date of birth, gender, passport number or other government identification number; TSA known redress number, airline frequent flyer number, and credit card information); and
- Contact Ovation support or otherwise correspond with us by phone, email, or other means.
How We Use Information
We use the information that we collect at the instruction of our customers and in accordance with our customer agreements, to provide the Services and for related internal purposes, including to:
- Enable travelers and other authorized users to access and use the Services;
- Book travel or otherwise complete a reservation with an airline carrier, hotel, car rental agency, or other supplier named on the traveler’s itinerary;
- Provide information about the Services, such as important updates or changes to the Services and security alerts;
- Customize the user experience, such as personalizing content and features to better match interests and preferences;
- Improve the Services and develop new products and services; and
- Respond to inquiries, complaints, and requests for customer support.
We may also use personal information as we believe necessary or appropriate to (a) comply with applicable law; (b) enforce the terms and conditions that govern the Services; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
How We Share Information
We share the information we collect with:
- Ovation’s global distribution system, a software-based service for making travel reservations;
- Third party service providers, subcontractors, and other entities such as industry reporting authorities that help or enable us to provide, manage and improve the Services; airline carriers, hotels, car rental agencies, or other suppliers named on a traveler’s itinerary;
- Ovation customers, to the extent the information relates to the utilization of the Services under the customer’s contract; and
- Ovation’s subsidiaries and corporate affiliates.
We may also share personal information with government, law enforcement officials or private parties as required by law, when we believe such disclosure is necessary or appropriate to (a) comply with applicable law; (b) enforce the terms and conditions that govern the Services; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
We may sell, transfer or otherwise share some or all of Ovation’s business or assets, including personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy.
Ovation uses appropriate, commercially reasonable physical, electronic, and procedural safeguards to protect personal data from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction in accordance with applicable law. We cannot, however, guarantee that any safeguards or security measures will be sufficient to prevent a security problem. See the customer contract for additional information regarding Ovation’s information security practices.
Data Subject Rights
Ovation customers are the data controllers of travelers’ personal information. As the data controllers, Ovation customers are responsible for receiving and responding to travelers’ requests to exercise any rights afforded to them under applicable data protection law. Ovation will assist customers in responding to such requests as set forth in the customer contract.
Cross Border Data Transfer
Ovation retains personal information for as long as necessary to (a) provide the Services; (b) comply with legal and accounting obligations; (c) resolve disputes; and (d) enforce the terms of customer agreements. See the customer contract for additional information regarding Ovation’s data retention practices.
Creation of Anonymous Data for Analytics
We may create anonymous data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by excluding information that makes the data personally identifiable to you, and use that anonymous data for our lawful business purposes.
Third Party Services
The Services may integrate with or facilitate engagement with third party services. Such third party services are governed by those third party providers’ privacy notices. Please review those notices carefully, as Ovation does not control and cannot be responsible for those providers’ privacy or information security practices.
If you have any question about this Product Privacy Statement, you can contact our privacy team at firstname.lastname@example.org.