FROSCH International Travel Privacy Notice 2018

TRUSTe
 

FROSCH International Travel respects individual privacy and values the confidence of its customers, employees, clinical trial participants, consumers, business partners and others. Not only does FROSCH International Travel strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices. This Privacy Shield Privacy Policy Statement (the “Policy”) sets forth the privacy principles FROSCH International Travel follows with respect to transfers of personal information from the European Economic Area (EEA) (which includes the twenty-seven member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) and from Switzerland to the United States.  This Policy applies to www.frosch.com and discusses the collection, use and transfer of personal information.

EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
FROSCH International Travel participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework.  We are committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles.  To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov]

FROSCH International Travel is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf.  FROSCH International Travel complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, FROSCH International Travel is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.  In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted. 

Scope
This Privacy Shield Privacy Policy Statement (the “Policy”) applies to all personal information received by FROSCH International Travel in the United States from the EEA and from Switzerland, in any format, including electronic, paper or verbal.

Definitions
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.

Privacy Principles
The privacy principles in this Policy have been developed based on the Privacy Shield 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, 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.
In addition, this site collects information through technologies such as: cookies, beacons, tags and scripts are used by FROSCH International Travel and service providers for marketing analytics and to provide tools. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about the user base as a whole. FROSCH International Travel may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.  FROSCH International Travel uses cookies for authentication and to remember individuals’ settings. Individuals can control the use of cookies at the individual browser level. If individuals reject cookies, they may still use the site, but their ability to use some features or areas of the site may be. For example the site my not remember the users sign-in ID from a previous visit. Users may however choose to tell the site to not remember this information.

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.
This site includes social media features, which may collect an individual’s IP addresses, which page an individual is visiting on this site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on this site. Individuals’ interactions with these features are governed by the privacy policy of the company providing it. This site includes links to other sites whose privacy practices may differ from those of FROSCH International Travel. If individuals submit personal information to any of those sites, personal information is governed by their privacy policies. FROSCH International Travel encourages individuals to carefully read the privacy policy of any site visited.
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 via the Contact Us page.

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 Privacy Shield Principles, Privacy Shield 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. If you would like FROSCH International Travel to provide reasonable access to, update or delete your information at any time (subject to any applicable legal exceptions), please contact us via the Contact Us page.

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 Privacy Shield Principles:

  1. 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;
  2. 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;
  3. for disputes involving unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

FROSCH International Travel
One Greenway Plaza, Suite 800
Houston, TX 77046

If you have questions about our privacy policy, please contact us through the Contact Us page

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.

Our role as a Data Processor: In our role as a Data Processor, FROSH International Travel collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.

An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the FROSH International Travel’s Client (the data controller). If requested to remove data we will respond within a reasonable timeframe.

We will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. FROSH International Travel will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Effective Date:  26 March 2018