FROSCH International Travel Privacy Notice 2015
The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EEA to the United States (the “U.S.-EU Safe Harbor”). The EEA also has recognized the U.S.-EU Safe Harbor as providing adequate data protection (OJ L 45, 15.2.2001, p.47). The United States Department of Commerce and the Federal Data Protection and Information Commissioner (FDPIC) of Switzerland have agreed on a similar set of principles and frequently asked questions to enable U.S. companies to satisfy the requirement under Swiss law that adequate protection be given to personal information transferred from Switzerland to the United States (the “U.S.-Swiss Safe Harbor”). Consistent with its commitment to protect personal privacy, FROSCH International Travel adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor programs, and to view FROSCH International Travel’s certification, please visit http://www.export.gov/safeharbor/.
FROSCH International Travel has received TRUSTe’s Privacy Seal signifying that this Policy and practices have been reviewed for compliance with the TRUSTe program viewable on the validation page available by clicking the TRUSTe seal.
The TRUSTe program covers only information that is collected through FROSCH International Travel’s Corporate Travel site, www.frosch.com, and does not cover information that may be collected through software downloaded from the site or other FROSCH International Travel sites or Services.
For purposes of this Policy, the following definitions shall apply:
“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, FROSCH International Travel or to which FROSCH International Travel discloses personal information for use on FROSCH International Travel’s behalf.
“FROSCH International Travel” means FROSCH International Travel, its affiliates under common control, predecessors, successors, subsidiaries, divisions and groups in the United States.
“Personal information” means any information or set of information that identifies or could be used by or on behalf of FROSCH International Travel to identify an individual. Personal information does not include information that is encoded oranonymized, or publicly available information that has not been combined with non-public personal information.
“Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, views or activities, that concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, FROSCH International Travel will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.
The privacy principles in this Policy have been developed based on the Safe Harbor Principles.
NOTICE: Where FROSCH International Travel collects personal information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses personal information about them, the types of non–agent third parties to which FROSCH International Travel discloses that information, the choices and means, if any, FROSCH International Travel offers individuals for limiting the use and disclosure of personal information about them, and how to contact FROSCH International Travel. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to FROSCH International Travel, or as soon as practicable thereafter, and in any event before FROSCH International Travel uses or discloses the information for a purpose other than that for which it was originally collected.
Where FROSCH International Travel receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.
This site collects personal information such as name, email address, and phone number. FROSCH International Travel will use this information to provide travel-related services and information, such as airline tickets, hotel accommodations and travel deals, to individuals. FROSCH International Travel also receive certain information from individuals’ employers, such as name, work address, and phone number.
As is true of most web sites, FROSCH International Travel gathers certain information automatically and stores it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. This information is not automatically linked to collected data to other information collected about individuals.
FROSCH International Travel offers individuals the ability to make public testimonials online. Individuals who no longer want their testimonials posted online should contact FROSCH International Travel.
Options: FROSCH International Travel will offer individuals the opportunity to choose (opt-out) whether their personal information 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 sensitive personal information, FROSCH International Travel will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. FROSCH International Travel will provide individuals with reasonable mechanisms to exercise their choices. Individuals may log into their account here to update their contact preferences.
Integrity of data: FROSCH International Travel will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. FROSCH International Travel will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current. FROSCH International Travel will retain individual’s personal information for as long as the account is active or as needed to provide services. FROSCH International Travel will retain and use personal information as necessary to comply with legal obligations, resolve disputes, and enforce agreements.
Transfer to Agents: FROSCH International Travel will transfer personal information (but not sensitive personal information) to agents that provide travel services that an individual (or someone authorized on behalf of such individual) requests. FROSCH International Travel does not control the travel suppliers’ use of such information. For other agents, FROSCH International Travel will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), being subject to Swiss Federal Act on Data Protection, Safe Harbor certification by the agent, or being subject to another European Commission or Swiss FDPIC adequacy finding (e.g., companies located in Canada). Where FROSCH International Travel has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, FROSCH International Travel will take reasonable steps to prevent or stop the use or disclosure.
FROSCH International Travel may also transfer personal information as required by law, investigate fraud, or respond to a government request. FROSCH International Travel may transfer personal information if it merges with or is acquired by a third party, or goes bankrupt and will post a notice on this site regarding choices individuals have with respect to their personal information.
Access and correction: Upon request, FROSCH International Travel will grant individuals reasonable access to personal information that it holds about them. In addition, FROSCH International Travel will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. FROSCH International Travel will respond to individuals’ request to access within 30 days.
Security: FROSCH International Travel will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, FROSCH International Travel cannot guarantee its absolute security.
Enforcement: FROSCH International Travel will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that FROSCH International Travel determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.
Dispute Resolution: Any questions or concerns regarding the use or disclosure of personal information should be directed to the FROSCH International Travel at the address given below. FROSCH International Travel will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Policy. For complaints that cannot be resolved between FROSCH International Travel and the complainant, FROSCH International Travel has agreed to participate in the following dispute resolution procedures in the investigation and resolution of complaints to resolve disputes pursuant to the Safe Harbor Principles:
- for disputes involving all personal information received by FROSCH International Travel from Switzerland, FROSCH International Travel has agreed and to cooperate with the Swiss FDPIC;
- for disputes involving employment-related personal information received by FROSCH International Travel from the EEA, FROSCH International Travel has agreed to cooperate with the data protection authorities in the EEA and to participate in the dispute resolution procedures of the panel established by the European data protection authorities;
- for disputes involving personal information received through FROSCH International Travel’s Corporate Travel site that FROSCH International Travel has not addressed satisfactorily, please contact TRUSTe at https://feedback-form.truste.com/watchdog/request
FROSCH International Travel
One Greenway Plaza, Suite 800
Houston, TX 77046
FROSCH International Travel may update this Policy to reflect changes to its information practices and will place a notice on this site prior to significant changes becoming effective. FROSCH International Travel encourages individuals to periodically review this page for the latest information on the company’s privacy practices.
Effective Date: 01 February 2015