Effective Date: January 2020
Effective Date: January 2020
Frosch International Travel LLC respects your privacy and is committed to honoring the confidence our clients, business partners and our workforce place in us. We have created this Privacy Notice to demonstrate our firm commitment to data protection and compliance with global privacy laws. This Privacy Notice outlines how we handle data that can be used to directly or indirectly identify an individual (“Personal Data”).
Frosch International Travel LLC and its Affiliates (FT Global LLC and FT Travel LLC), (collectively known as “Frosch International Travel”, “FROSCH”, “we” or “us”) is a global travel services company that serves corporate and individual client travel needs and other travel related services. Our FROSCH international headquarters are located at One Greenway Plaza, Suite 800, Houston, TX, 77046 in the USA, and we have offices in 40+ countries around the globe.
In this Privacy Policy (the “Policy” or “Notice):
“third party” means someone who is not you or us
“FROSCH International Travel” means FROSCH International Travel LLC and any company or other organization in which FROSCH owns more than 15% of the company
FROSCH’s data protection officer can be contacted at DPO@frosch.com.
We collect your Personal Data for a variety of reasons. You may provide the data to us directly, or through a tool or product provided by us or another organization, or to your employer in the case of our business clients.
We collect your Personal Data, and that of your travel companions,either directly from you or through your employer or travelsponsor, in order to provide you with the travel-related services.In most cases, it consists of
We may collect other information to assist you with your travel plans including but not limited to, passport number, driver’s license or other government-issued identification number, date of birth, gender, arrival and departure locations and times, airline and accommodations, hotel or car rental frequent loyalty numbers, TSA Known Redress Number and global entry number, Ticket/Document number and other related travel information.
We may receive Personal Data from your employer or travel sponsor, such as your name, job title, employer name, employee identification number/employee ID, email address, work address, and your phone number.
We collect your Personal Data, and that of your travel companions, directly from you or through a tool or product provided by us or another organization, in order for us to deliver the travel-related services you have requested. In most cases, it consists of
We may collect other information to assist you with your travel plans including but not limited to, passport number, driver’s license or other government-issued identification number, date of birth, gender, arrival and departure locations and times, airline and hotel accommodations, hotel or car rental frequent loyalty numbers, TSA Known Redress Number and global entry number, Insurance details, relevant medical data and any special, dietary, religious or disability requests, Ticket/Document number and other related travel information.
On our Website through contact forms, job applications or marketing events, we may collect the following information from you that may constitute Personal Data:
Whenever you visit our Site, use our services, or view our online advertisements, the website software automatically collects the following information, some of which may be considered Personal Data:
You can learn more about how we use cookie data by reviewing our Cookie Policy which can be found in the “Cookie Policy” section of ths document.
We use Personal Data for the following purposes:
We will only collect and use your Personal Data, if at least one of the following conditions applies:
We may disclose the Personal Data we collect to the following:
We do not sell or share information with third parties so that they can independently market their own products or services directly to you.
Our Privacy Notice applies to services offered by FROSCH International Travel but excludes services or affiliates that have separate privacy notices. We may share the minimum Personal Data necessary with other companies affiliated with FROSCH, for example, to provide the products and services you request; to manage and improve our products, services and day-to-day operations; where appropriate, to make contact and interact with you; and, if allowed and appropriate, for marketing or market research purposes.
We may also share Personal Data with an organization we sell or transfer (or enter into negotiations to sell or transfer) any of our businesses or any of our rights or obligations under any agreement we may have with you. If the transfer or sale goes ahead, the organization receiving your Personal Data can use your data in the same way as us.
This Policy does not apply to your use of unaffiliated websites to which our Site is linked. Company is not responsible for the privacy practices or the content on linked sites. We recommend that you carefully read the privacy policies of each site you visit.
Our websites or mobile apps may contain social media features such as Facebook, Twitter, LinkedIn and Instagram that have their own privacy notices. Please make sure you read their terms and conditions and privacy notice carefully before providing any Personal Data as we do not accept any responsibility or liability for these features. When we use social plug-ins on our websites from social networks such as Facebook, Twitter, LinkedIn and Instagram, we integrate them as follows:
We use adequate technical and organizational security measures to protect your data managed by us against manipulation, loss, destruction and against access by unauthorized persons. We are constantly improving our security measures in line with technological developments. Although FROSCH makes every effort to ensure the protection, integrity and security of FROSCH’s network and systems, FROSCH cannot guarantee or warrant that the security measures will protect all Personal Data.
The security of your data also depends on you. For example, where you have chosen a password for access to certain services, you are responsible for keeping this password confidential.
We will retain your Personal Data for only as long as it is necessary for the uses set out in this Privacy Notice and/or to meet legal and regulatory requirements. After this period, we will securely erase Personal Data. If data is needed after this period for analytical, historical or other legitimate business purposes, we will take appropriate measures to anonymize or destroy this data.
If you receive marketing email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving commercial email from us, and any other promotional communications that we may send to you from time to time, by sending your request by email to privacy@frosch.com
Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may receive promotional communications from us that you have opted-out from during that period. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages regarding travel services.
Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of our Site.
Please note that there is currently no uniform way in which to respond to Do Not Track signals, and at this time we do not respond to such signals.
If you live in the EU or Switzerland, you have specific rights for your Personal Data under the European General Data Protection Regulation (GDPR). At FROSCH we address your rights for:
FROSCH will offer EU and Swiss individuals whose personal information has been transferred to us the opportunity to choose whether the personal information it has received is to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. An individual may opt-out of such uses of their personal information by contacting us at privacy@frosch.com.
If we intend to disclose it to a third party acting as a controller not previously identified, we will offer you the opportunity to opt-out of such uses and/or disclosures where it involves non-sensitive data or opt-in where Sensitive Personal Data is involved.
If we intend to use your Personal Data for a purpose that is materially different from the purposes listed in this Notice, or if we intend to disclose it to a third party acting as a controller not previously identified, we will offer you the opportunity to opt-out of such uses and/or disclosures where it involves non-sensitive data or opt-in where Sensitive Personal Data is involved.
Please note:
For more information or to exercise your rights, please submit a request via post or email to FROSCH. We will respond to inquiries directed to us within thirty (30) calendar days. If the request pertains to data that was provided to us by your employer, please contact your employer (i.e. our client).
By post: FROSCH UK Ltd.
Attn: Data Protection Officer
The Eastcheap Estate: 39 Eastcheap, 4th Floor
London EC3M 1DE
United Kingdom
By email: Privacy@FROSCH.com
If you live in California, you have specific rights for your Personal Data under the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice. This section describes your CCPA rights and explains how to exercise those rights.
You have the right to request that we disclose certain information to you about our collection and use of your personal data over the past 12 months. Once we receive and confirm your verifiableconsumer request, we will disclose to you:
In the preceding twelve (12) months, we have not sold any personal data.
You have the right to request that we delete any of your personal data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and request our service providers to delete) your personal data from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal data. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We try to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal data that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
The California Online Privacy Protection Act (“CalOPPA”) requires FROSCH to disclose how it responds to Do Not Track Signals in your web browser. FROSCH does not interpret or respond to Do Not Track Signals. You may set your web browser to not accept new cookies or web beacons or disable cookies altogether. Please note that doing so may hinder your experience on the Website. Please see the Help section of your browser for instructions on managing security preferences.
Our Site is not directed to children. We do not sell products or services for purchase by children. We will not knowingly collect Personal Data from children. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed personally identifiable information to us, please contact us at this email address: privacy@frosch.com. A parent or guardian of a child under the age of 13 may review and request deletion of such child’s Personal Data, as well as prohibit the use of that information.
Frosch International Travel has further committed to refer unresolved Privacy Shield complaints to United States Council for International Business, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit United States Council for International Business for more information or to file a complaint. The services of United States Council for International Business are provided at no cost to you.
Please contact us with any questions or comments about this Policy, your Personal Data, our privacy and information security practices, your consent choices or if you would like to exercise your rights.
Email at privacy@frosch.com
Data Protection Officer by email at DPO@frosch.com
You may also write to us at:
FROSCH International Travel
One Greenway Plaza, Suite 800
Houston, TX 77046 USA
This Notice replaces all previous versions. We may change the Notice at any time, so please check it regularly on our website(s) for any updates. You can tell when changes have been made to the Privacy Policy by referring to the “Last Updated” legend on top of this page. Any changes will be effective on the effective date stated in the revised Privacy Policy. Your continued use of the Site after we have posted a revised Privacy Policy indicates your agreement to the revisions.
For purposes of this Policy, the following definitions shall apply:
“Affiliate” means any partner that FROSCH has 15% or more ownership in.
“Agent” or “Processor” means any third party that collects or uses Personal Data under the instructions of, and solely for, FROSCH International Travel or to which FROSCH International Travel discloses Personal Data for use on FROSCH International Travel’s behalf.
“CCPA“ or “California Consumer Privacy Act” also known as AB-375, is a bill intended to enhance privacy rights and consumer protection for residents of California, United States.
“FROSCH International Travel” means FROSCH International Travel, its affiliates under common control, predecessors, successors, subsidiaries, divisions and groups in the United States.
“GDPR” or “General Data Protection Regulation”, also known as Regulation (EU) 2016/679, is a European Union law drafted on April 27, 2016 and instituted on May 25, 2018 on data protection and privacy for all individual citizens of the European Union and the European Economic Area.
“Personal Data” 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 Data does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public Personal Data.
“Sensitive Personal Data” or “Special Categories of Personal Data” This are categories of personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data, biometric data for the purpose of uniquely identifying a natural person; health data; and data concerning a natural person’s sex life or sexual orientation. In addition, FROSCH International Travel will treat as sensitive Personal Data any information received from a third party where that third party treats and identifies the information as sensitive.
“Data Controller”: The data controller determines the purpose and manner in which personal data is used.
“Data Processor”: Processes Personal Data as instructed on behalf of a data controller
“European Economic Area (EEA)” consist of EU Member States plus Norway, Iceland and Lichtenstein.
“Online advertising” refer to Marketing messages that you may see on the internet.
“US Secure Flight Data”: The Transportation Security Administration (TSA) requires you to provide your full name, date of birth and gender for the purpose of watch list screening. You may also provide your Redress Number, if available. Failure to provide details may result in denial of transport or denial of authority to enter the boarding area. TSA may share information you provide with law enforcement or intelligence agencies or others under its published system of records notice. Please see the TSA website for more details.
We may transfer your Personal Data to countries other than the country where you are located, including to the United States where we are headquartered.
The EU-U.S. and Swiss-U.S. Privacy Shield Frameworks were designed by the U.S. Department of Commerce, and the European Commission and Swiss Administration, respectively, to provide companies on both sides of the Atlantic with a mechanism to comply with data protection requirements when transferring Personal Data from the European Union and Switzerland to the United States in support of transatlantic commerce.
FROSCH International Travel LLC complies with the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union and Switzerland to the United States. FROSCH International Travel LLC has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability. If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit www.privacyshield.gov.
Personal data, including data collected in the European Economic Area (“EEA”) or Switzerland, may be transferred, stored, and processed by us and our services providers, partners, and affiliates in the United States and potentially other countries whose data protection laws may be different to the laws of your country.
We will not transfer Personal Data originating in the EU or Switzerland to third parties unless such third parties have entered into an agreement in writing with us requiring them to provide at least the same level of privacy protection to your Personal Data as required by the Principles of the EU-US Privacy Shield Framework or the Swiss-US Privacy Shield Framework. We will only transfer data to our agents, affiliates, or third-party service providers (such as accountants, attorneys, consultants, and other service providers) who need the information in order to provide services to or perform activities on behalf of FROSCH; including in connection with the delivery of services, FROSCHs’ management, administration, or legal responsibilities. We shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage.
Dispute Resolution: In compliance with the Privacy Shield Principles, FROSCH International Travel LLC commits to resolve complaints about our collection or use of your Personal Data. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact FROSCH at:
FROSCH International Travel LLC
One Greenway Plaza, Suite 800
Houston, TX 77046
or via email at DPO@FROSCH.com
FROSCH has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism:
Under certain limited conditions, an individual may be able to invoke binding arbitration as provided under the Privacy Shield to address an otherwise unresolved complaint. For more details about this process, visit the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint.
FROSCH International Travel LLC is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) and under certain conditions, individuals may invoke binding arbitration as well as learn more about our liability in cases of onward transfers to third parties at: https://www.privacyshield.gov/EU-US-Framework.
Personal data, including data collected in the European Economic Area (“EEA”) or Switzerland, may be transferred, stored, and processed by us and our services providers, partners, and affiliates in the United States and potentially other countries whose data protection laws may be different to the laws of your country.
We will not transfer Personal Data originating in the EU or Switzerland to third parties unless such third parties have entered into an agreement in writing with us requiring them to provide at least the same level of privacy protection to your Personal Data as required by the Principles of the EU-US Privacy Shield Framework or the Swiss-US Privacy Shield Framework. We will only transfer data to our agents, affiliates, or third-party service providers (such as accountants, attorneys, consultants, and other service providers) who need the information in order to provide services to or perform activities on behalf of FROSCH; including in connection with the delivery of services, FROSCHs’ management, administration, or legal responsibilities. We shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage.
We use or may use the data collected through cookies, log files, device identifiers, and clear GIFs to (a) remember information so in subsequent visits a user will not have to re-enter it; (b) provide custom, personalized content, and information; (c) monitor the effectiveness of our Services; (d) monitor aggregate metrics such as total number of visitors, traffic, and usage on our website and our Services; (e) diagnose or fix technology problems; and (f) help users efficiently access information after signing in.
Clear GIFs, pixel tags, and other technologies: Clear GIFs (also known as web beacons, web bugs or pixel tags) are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs, in connection with Services to, among other things, track the activities of visitors, help us manage content, and compile statistics about site usage. We and our third-party service providers also use clear GIFs in HTML emails to our customers to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.
Third-Party Analytics: We use automated devices, applications, and other means, such as Google Analytics to evaluate usage of our FROSCH websites and Services. We use these tools to help us improve our Services, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. Third-party advertising networks are never allowed to collect information about the users of our websites or Services.