Privacy Policy

Effective: November1st, 2026  

1.  Introduction and Scope

Motor City Travel, LLC, a Michigan limited liability company("Motor City Travel," "we," "us," or"our"), respects your privacy and is committed to protecting it. This Privacy Policy describes the types of information we collect or that you provide to us, and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Policy applies to information we collect when you use or interact with:

• [our mobile application, once launched (the “App”);]

• our website, www.MotorCityTravel.com (the “Website”), [includingself-service registration and account creation pages, once launched];

• our online booking, travel management, reporting, and expense integration services; and

• any other service we provide (collectively with the App and the Website, the “Service”).

This Policy does not apply to:

• information you provide or we collect in an employment or job-applicant context, which is covered by our separate Employee and Applicant PrivacyNotice;

• information you provide directly to, or that is collected by, a thirdparty such as an airline, hotel, car rental company, or payment provider (see Sections 4.6 and 7). Those third parties have their own privacy policies, which we encourage you to read.

This Policy describes our information practices. It is a notice, not a contract. Your use of the Service is governed by our Terms of Use and, where applicable, the written agreement between Motor City Travel and your employer or organization.

2.  Our Role: Controller and Service Provider

Motor City Travel handles personal information in two different capacities, and your rights differ depending on which applies.

2.1  Where We Act on Behalf of an Organization

Travelers use the Service because their employer or organization (a “Client”) has engaged Motor City Travel to manage its travel program. In that case, the Client decides what information is collected about its travelers and how it is used, and we process that information on the Client's behalf and under our written agreement with the Client. For those purposes we act as a service provider, processor, or agent, and the Client actsas the business or controller.

If you are a traveler under a Client's program and you wish to exercise a privacy right with respect to your traveler profile, trip records, or expense data, please contact your employer or program administrator first. We will assist the Client in responding, and we will refer requests we receive directly to the Client where the Client is responsible for responding.

2.2  Where We Act for Ourselves

We act as the business or controller, and this Policy governs directly, when we:

• operate our public Website and market our services to prospective clients;

• process a self-service registration, including business verification, account creation, and billing, before or apart from a Client relationship;

• administer our own security, fraud prevention, sanctions screening, billing, collections, accounting, audit, and legal compliance functions; and

• use information to improve and develop the Service, subject to our agreements with Clients.

3.  Children and Minor Travelers

The Service is not directed to children, and we do not knowingly permit children to register for an account or provide information to us directly. If we learn that we have collected personal information directly from a child under 16 without appropriate consent, we will delete it.

We may, however, receive information about a minor from an adult who is arranging travel on the minor's behalf, such as an organization arranging group travel. This may include the minor's name, date of birth, gender as required by the carrier, passport or other travel document details, and any accessibility or meal requirements the booker provides. We use that information only to arrange and support the requested travel and to comply with carrier and government requirements. If you provide information about a minor, you confirm that you are authorized to do so.

If you believe we hold information about a child that shouldnot have been provided to us, contact us at info@motorcitytravel.com.

4.  Information We Collect and How We Collect It

We collect information from and about users of the Service:

• directly from you when you provide it to us;

• automatically when you use the Service;

• from Clients and program administrators;

• from travel suppliers, distribution systems, and payment providers; and

• from third-party verification, screening, and data providers.

4.1  Information You Provide to Us

When you register for or use the Service, we may ask you to provide information by which you may be personally identified, as well as information that is about you but does not by itself identify you. This may include:

• name, preferred name, and title;

• business and personal email address, telephone number, and mailing address;

• employer name, job title, department, cost center, and employee ortraveler ID;

• date of birth and gender, where a carrier or government requirement makes it necessary;

• passport, visa, national ID, driver's license, Known Traveler Number, Redress Number, and other travel document details;

• frequent traveler and loyalty program memberships and numbers;

• travel preferences, including seat, cabin, room, and vehicle preferences;

• meal requirements and accessibility or assistance requests (see Section6);

• emergency contact information you choose to provide;

• payment card and billing information (see Section 4.3);

• records and copies of your correspondence with us, including email, chat, and recorded telephone calls;

• your responses to surveys and your search queries within the Service; and

• details of transactions you carry out through the Service and the fulfillment of those transactions.

4.2  Business Registration and Business Verification

If you register for the Service through our self-service sign-up, we collect the information you enter on the registration pages. This includes your name, business email address, telephone number, and job title,and the name and Employer Identification Number (EIN) or other taxpayer or registration number of the business you are registering.

We use a third-party identity and business verification provider to confirm that the EIN or registration number you provide corresponds to a validly registered business, and to retrieve business record information about that entity from public records and licensed commercial databases. Information returned by that provider may include the entity's legal name, registered trade names, formation state and date, registered address, entitystatus, industry classification, and the names and titles of officers or registered agents. We use this information to populate your account so that you do not have to enter it manually, to confirm that we are dealing with a real business and with a person connected to it, and to prevent fraud and abuse of the Service.

We also screen the business and, where applicable, its principals against government sanctions and denied-party lists, including theU.S. Treasury Department's Office of Foreign Assets Control lists, as required by law.

This verification is a business identity check. We do not use it to evaluate your personal credit worthiness, and we do not obtain a consumer report about you as an individual for this purpose.

4.3  Payment, Billing, and Fee Information

If you book travel or incur fees through the Service, we collect the information needed to process payment and to bill you. Payment card details you enter are transmitted directly to our PCI DSS validated payment processor and are stored by that processor in tokenized form. We retain a token, the card type, the last four digits, the expiration date, and the billing name and address. We do not store the full card number or the security code on our systems.

Where your organization uses a corporate card program, virtual card, or central billing arrangement, we may receive transaction data from the card issuer or program administrator and reconcile it against your bookings.

Our service fees, including any online booking or transaction fee, are described in our then-current Fee Schedule, which is presented to you before you accept our Terms of Use and is available in your account.

4.4  Information We Collect Automatically

When you access and use the App or the Website, we may automatically collect:

•  Usage details. Traffic data, logs, referring pages, session duration, the resources you access, and other communication data relating to your access to and use of the Service.

•  Device information. Your device's unique identifier, IP address, operating system, browser type, mobile network information, and, where you grant permission, the device telephone number.

•  Location information. Where you enable it, real-time information about the location of your device, which we use for trip notifications, disruption alerts, and traveler safety and duty-of-care reporting to your organization.

•  Stored information and files. Where the App has your permission, metadata and information associated with files stored on your device, such as contacts or images you choose to attach to a receipt or profile.

We use cookies, mobile identifiers, web beacons, pixel tags, and similar technologies for these purposes. Our Cookie Policy describes each category of cookie we use, its purpose, its duration, and how to control it.

4.5  Information We Receive from Clients and Third Parties

We receive personal information about you from the following categories of source:

•  Clients and program administrators. traveler profiles, approval hierarchies, cost centers, policy rules, and employment attributes, provided so we can administer the program and enforce travel policy;

•  Client identity systems. your identity provider or single sign-on system, where your organization uses one to authenticate you to the Service.

•  Travel suppliers and global distribution systems. booking confirmations, ticket numbers, fare and rate details, loyalty status, upgrades, schedule changes, disruptions, cancellations, and refunds.

•  Identity, business verification, and screening providers. business record and entity data used to verify an EIN and populate an account, as described in Section 4.2, and identity signals used to detect fraud.

•  Payment processors, card issuers, and card networks. authorization results, transaction data, chargeback and dispute information, and corporate card feeds.

•  Expense and financial system integrations. data exchanged with expense, ERP, HR, and accounting platforms your organization has connected to the Service.

•  Marketing, event, and data enrichment providers. contact and firmographic information about business prospects, including from lead generation, event registration, and business contact data providers.

•  Analytics providers. aggregated and individual usage measurement for the Website and App.

•  Other travelers and arrangers. the person arranging travel on your behalf, such as a travel arranger, executive assistant, meeting planner, or family member.

4.6  Third-Party Collection on the Service

Certain third parties may use automatic collection technologies to collect information about you or your device when you use the Service or its content. These may include advertising networks and ad servers, analytics companies, your mobile device manufacturer, and your mobile service provider. We do not control these third parties' technologies or how they use the information they collect. If you have a question about an advertisement or other targeted content, contact the responsible provider directly. See Sections 9 and 10 for the choices available to you.

5.  How We Use Your Information

We use the information we collect, including personal information, to:

• provide the Service and the products, information, and services you request;

• create, verify, secure, and administer your account, including the business verification described in Section 4.2;

• search for, price, book, ticket, modify, cancel, and refund travel, and to transmit the information required to complete those transactions to suppliers and distribution systems;

• send you notices about your account, itinerary changes, disruptions, safety alerts, and changes to the Service;

• provide traveler care, support, and after-hours assistance;

• provide reporting, analytics, unused ticket tracking, policy compliance, and duty-of-care information to your organization;

• process payments, invoice and collect our fees, reconcile transactions,and administer refunds and credits;

• carry out our obligations and enforce our rights under any contract between you or your organization and us, including for billing and collection;

• detect, investigate, and prevent fraud, abuse, security incidents, andother unlawful activity, and to comply with sanctions screening obligations;

• maintain, secure, test, troubleshoot, and improve the Service, and to develop new features and products;

• comply with legal, regulatory, tax, accounting, audit, and reporting obligations, including airline, government, and industry requirements described in Section 7; and

• with your consent or as otherwise permitted by law, contact you about our services and offers that may be of interest.

We use the usage information we collect to estimate audience size and usage patterns, store your preferences so we can personalize the Service, speed up your searches, and recognize you when you return.

5.1  Trip Service Communications

We send you messages about trips you have already booked, tohelp you complete and manage them. These include notice that an itinerary has no hotel or car for some of your nights, reminders about unused tickets and expiring credits, check-in and travel document reminders, schedule change and disruption alerts, safety notices, and travel policy reminders. These are part of the Service and are not marketing. You can turn off trip service communications, other than safety and disruption alerts, in your account settings. Marketing is separate, and the choices available to you are describedin Section 9.

5.2  Automated Processing

We use automated systems and, in some features, artificial intelligence to rank and recommend travel options, apply your organization's travel policy, detect fraud and anomalous activity, and verify business registration information. Where an automated process materially affects whetherwe will provide the Service to a business, a person reviews the outcome before it becomes final, and you may contact us at info@motorcitytravel.com to ask about the decision.

6.  Sensitive Information

Please do not provide us with sensitive information unless it is necessary for your travel. Some information we need in order to arrange travel is treated as sensitive under privacy laws, or may indirectly reveal sensitive characteristics. This includes:

• passport, visa, national identification, and driver's license numbers;

• nationality and citizenship, which appear on travel documents and are required for international travel;

• precise geolocation, where you enable location features;

• accessibility, mobility, and medical assistance requests, which may reveal health information; and

• meal preferences, which may indirectly reveal religious belief or ahealth condition.

We collect this information only where it is needed to arrange and support your travel, to comply with carrier and government requirements, to secure our systems, or to prevent fraud, and we disclose itonly to the suppliers, distribution systems, and authorities that require it for those purposes. We do not use or disclose sensitive personal information to infer characteristics about you, and we do not use it for advertising. You may remove optional preferences from your profile at any time, though doing so may mean a supplier cannot accommodate the related request.

7.  Disclosure of Your Information

We may disclose aggregated and deidentified information that does not identify any individual or device without restriction.

We may disclose personal information that we collect or that you provide:

• to the Client whose travel program you travel under, including bookings,trip status, expenses, profile data, travel policy exceptions, unused tickets, and traveler location where duty-of-care features are enabled;

• to our subsidiaries and affiliates;

• to contractors, service providers, and other third parties we use to support our business, under written contracts that limit their use of the information to performing services for us;

• to Christopherson Andavo Travel, Inc., an independent company that operates the booking platform we use and provides marketing, accounting, and administrative support to us under a written services agreement, which limits its use of the information to performing services for us;

• to travel suppliers and distribution systems as described in Section7.1;

• to a buyer or other successor in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including in bankruptcy or a similar proceeding;

• to fulfill the purpose for which you provided it, or for any other purpose we disclose when you provide it;

• with your consent;

• to comply with any court order, law, or legal process, including to respond to a government or regulatory request;

• to enforce our rights under any contract between you or your organization and us, including our Terms of Use, and for billing and collection; and

• where we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Motor City Travel, our clients, or others, including exchanging information with other companies and organizations for fraud prevention and credit risk reduction.

7.1  Travel Suppliers, Distribution Systems, and Government Requirements

Arranging travel necessarily requires us to transmit your information to third parties. Depending on your itinerary, these include:

• airlines, hotels, car rental companies, rail operators, cruise lines, ground transport providers, and travel insurers;

• global distribution systems and booking platforms, including Sabre, Amadeus, and Travelport;

• the Airlines Reporting Corporation, the International Air Transport Association, and the consortia and preferred-supplier programs through which we source rates;

• government agencies where travel law requires it, including the Transportation Security Administration for Secure Flight watch-list matching onflights to, from, over, or within the United States, and U.S. Customs and Border Protection and equivalent foreign authorities for Advance Passenger Information on international itineraries; and

• payment processors, card issuers, and card networks.

Once your information is transmitted to a travel supplier, distribution system, or government authority, that recipient's own privacy practices and legal obligations govern its handling of the information, and we do not control them. Loyalty program information is governed by the program operator's terms.

8.  Retaining Your Personal Information

We retain personal information only for as long as necessary to fulfill the purposes for which we collected it, including to satisfy legal, accounting, tax, audit, and reporting requirements, to resolve disputes, and to enforce our agreements.

Where we process information on behalf of a Client, we retain it for the term of our agreement with that Client and for the period specified in that agreement after it ends, and we then delete or return it asthe agreement requires. For information we hold as a business or controller, our retention periods are set by our internal records retention schedule and are based on the type of information and the purpose for which it is held. Transaction and billing records are held for the period required by tax and accounting rules. Verification and screening records are held for the period required to evidence our compliance obligations. Marketing contact information is held until you opt out and for a short period afterward so we can honor your opt-out.

9.  Your Choices About Our Collection, Use, and Disclosure

9.1  Tracking Technologies

You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. You may also control certain tracking through your device's privacy settings. If you disable or refuse cookies or block other tracking technologies, some parts of the Service may be inaccessible or may not function properly. Our Cookie Policy describes the controls available for each category.

9.2  Location Information

You can choose whether to allow the App to collect real-time location information through your device's privacy settings. If you block location information, location-based features, including certain disruption and safety alerts, will not function.

9.3  Marketing Email

You can opt out of marketing email at any time by using the unsubscribe link in any marketing message, by adjusting your account communication preferences, or by emailing info@motorcitytravel.com. We will continue to send you transactional and service messages about your account, itineraries, and travel disruptions, which are not marketing.

9.4  Marketing Calls and Text Messages

If you provide a telephone number and consent to marketing contact by phone or text, you consent to receive marketing calls and text messages from us at that number, including calls and messages sent using an automatic telephone dialing system or an artificial or prerecorded voice. Consent to marketing calls and texts is not a condition of purchasing any product or service, and you may decline it and still use the Service. Message and data rates may apply. You may revoke consent at any time by replying STOP to any text message, by telling the caller, by adjusting your account preferences, or by emailing info@motorcitytravel.com. We will honor a revocation within a reasonable time and in any event as required by law, and a revocation applies to all marketing calls and texts from us.

9.5  Interest-Based Advertising

We do not control third parties' collection or use of your information to serve interest-based advertising. Those third parties may offer you their own choices. You can opt out of receiving targeted advertising from participating companies through the Network Advertising Initiative at optout.networkadvertising.org and the Digital Advertising Alliance at optout.aboutads.info, and through the AppChoices app on mobile devices.

10.  State Privacy Rights

State consumer privacy laws may give their residents additional rights regarding our use of their personal information. We extend the rights described in this Section 10 to all users of the Service, regardless of where they live.

If you are a traveler under a Client's program, please read Section 2.1 first. For information we process on a Client's behalf, the Client is responsible for responding to your request, and we will refer your request to the Client and assist it in responding.

10.1  Sale, Sharing, and Targeted Advertising

We do not sell personal information for money. We do not share personal information for cross-context behavioral advertising or process it for targeted advertising.

10.2  Right to Know and Data Portability

You have the right to request that we disclose to you the categories of personal information we collected about you, the categories of sources from which we collected it, our business or commercial purpose for collecting or sharing it, the categories of third parties to whom we disclosed it, a list of the disclosures we made for a business purpose identifying the categories of information each category of recipient obtained, and the specific pieces of personal information we collected about you. On request we will look back beyond the preceding twelve months to information collected on or after January 1, 2022, unless doing so proves impossible or would involve disproportionate effort.

10.3  Right to Delete

You have the right to request that we delete personal information we collected from you and retained, subject to exceptions. We may deny a deletion request where retaining the information is necessary for us or our service providers to:

• complete the transaction for which we collected it, provide a product or service you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;

• detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible;

• debug products to identify and repair errors that impair existing intended functionality;

• exercise free speech, ensure another consumer's right to exercise free speech, or exercise another right provided by law;

• comply with the California Electronic Communications Privacy Act;

• engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to applicable ethics and privacy laws, where deletion would render the research impossible or seriously impair it and you previously provided informed consent;

• enable solely internal uses reasonably aligned with consumer expectations based on your relationship with us;

• make other internal and lawful uses of the information compatible with the context in which you provided it; or

• comply with any other legal obligation, including our obligation to retain travel, transaction, tax, and screening records.

We will delete or deidentify personal information not subject to an exception and will direct our service providers and contractors, and where possible any third party to whom we disclosed the information, to take similar action.

10.4  Right to Correct

You have the right to request that we correct inaccurate personal information about you that we collected and retained. We will consider the totality of the circumstances relating to the contested information. If we determine that a correction is appropriate, we will correct it in our systems and instruct our service providers and contractors that maintain the information to do the same. We may, in our discretion, delete rather than correct personal information unless prohibited by law.

10.5  Other Rights

Depending on where you live, you may also have the right to:

• opt out of the sale or sharing of your personal information and of targeted advertising;

• opt out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;

• limit our use and disclosure of sensitive personal information, subject to the permitted purposes described in Section 6;

• withdraw consent where we rely on consent; and

• appeal our denial of a request, as described in Section 10.8.

10.6  Exercising Your Rights

To exercise the rights described in this Section 10, submit a request:

• by email to info@motorcitytravel.com; or

• by telephone at (248) 799-0752.

Only you, or a person legally authorized to act on your behalf, may make a request relating to your personal information. An authorized agent must provide proof of authorization, and we may require you to verify your own identity directly with us and to confirm that you gave the agent permission.

You may submit a request to know no more than twice within a twelve-month period. Your request must provide enough information for us to reasonably verify that you are the person about whom we collected personal information, or that person's authorized agent, and must describe your request in enough detail for us to understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority and confirm that the information relates to you.

You do not need an account to submit a request. Where a request comes through a password-protected account and relates to information associated with that account, we will treat it as sufficiently verified. We use information provided in a request only to verify the requester's identity or authority.

10.7  Response Timing and Format

We will confirm receipt of your request within ten business days. If you do not receive confirmation within that period, contactinfo@motorcitytravel.com. We aim to respond substantively to every verifiable request within forty-five days of receipt. If we need more time, up to an additional forty-five days, we will tell you the reason and the extension period in writing.

We will deliver our response by mail or electronically, at your option, or to your account where you have one. Disclosures will cover the twelve months preceding receipt of your request unless you expressly request older information, and in no case will we be required to disclose information collected before January 1, 2022. Our response will explain any reason we cannot comply with a request. For portability requests we will provide the information in a readily usable format that allows you to transmit it to another entity without hindrance.

We do not charge a fee to process or respond to a verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine a fee is warranted, we will tell you why and give you a cost estimate before completing the request.

10.8  Appeals

If we decline to act on your request, you may appeal by emailing info@motorcitytravel.com with the subject line “Privacy Request Appeal” and a description of the decision you are appealing. We will respond in writing within forty-five days of receipt, explaining the action we have taken or declined to take and the reasons for it. If we deny your appeal, we will provide you with a method to contact your state attorney general to submit a complaint.

10.9  Additional Disclosures for California and Other State Residents

The categories of personal information we collect, the sources from which we collect it, the purposes for which we use it, and the categories of third parties to whom we disclose it are set out in Schedule 1.

11.  Non-Discrimination

We will not discriminate against you for exercising any right described in Section 10. We will not deny you goods or services, charge you different prices or rates, including through discounts or penalties, provide you a different level or quality of goods or services, or suggest that you will receive a different price, rate, level, or quality, because you exercised a privacy right.

We may offer financial incentives permitted by law that result in different prices, rates, or quality levels. Any such incentive will reasonably relate to the value of your personal information and will be described in written program terms. Participation requires your prior opt-in consent, which you may revoke at any time.

12.  Data Security

We maintain administrative, technical, and physical safeguards designed to protect personal information against accidental loss and unauthorized access, use, alteration, and disclosure. These include encryption of information in transit and at rest, access controls and least-privilege provisioning, multi-factor authentication, logging and monitoring, vulnerability management, vendor security review, and a documented incident response program. Payment card data is handled in accordance with the Payment Card Industry Data Security Standard.

The security of your information also depends on you. Where you have a password for access to the Service, you are responsible for keeping it confidential, and we ask that you not share it with anyone.

No method of transmission over the internet or method of electronic storage is completely secure. While we work to protect your personal information, we cannot guarantee its security, and any transmission is at your own risk. We are not responsible for circumvention of privacy settings or security measures on the Service.

13.  International Users and Cross-Border Transfers

We are based in the United States and the Service is operated from the United States. If you access the Service or travel outside the United States, your information will be transferred to, stored in, and processed in the United States and in other countries where we, our service providers, or the travel suppliers fulfilling your booking operate. Those countries may have data protection laws that differ from the laws of your country, and courts, law enforcement, and national security authorities in those countries may be able to access your information. Where we transfer personal information out of a jurisdiction that restricts such transfers, we use a lawful transfer mechanism.

14.  Links to Other Websites

The Service may contain links to websites and applications operated by others, including travel suppliers. We do not control and are not responsible for the privacy practices of those third parties. We encourage youto read the privacy policy of every site or application you visit.

15.  Changes to This Privacy Policy

We may update this Policy from time to time. The date it was last modified appears at the top. If we make material changes to how we treat personal information for which we act as the business or controller, we willprovide notice through a prominent notice on the Website and, where we haveyour email address and the change is material, by email. Changes take effect on the effective date stated in the notice. Where we process information on behalf of a Client, changes are governed by our agreement with that Client.

16.  Contact Information

To ask a question or comment about this Policy or our privacy practices, or to exercise a privacy right, contact us at:

Motor City Travel, LLC

Attn: Privacy

24800 Denso Dr., Suite 260

Southfield, MI 48033

info@motorcitytravel.com

Phone: (248) 799-0752

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Schedule 1

Categories of Personal Information Collected, Used, and Disclosed

 

This Schedule supplements Section 10. It describes the categories of personal information we have collected in the preceding twelve months, using the categories enumerated in the California Consumer Privacy Act as amended by the California Privacy Rights Act. For these purposes, personal information does not include publicly available information from government records, deidentified or aggregated information, or information excluded from the statute's scope.

Table 1.  Categories Collected

    Category      

Examples

     

Collected

       

A. Identifiers

     

Real name, alias, postal address, unique personal  identifier, online identifier, IP address, email address, account name, passport number, driver's license number, Known Traveler Number, employee or  traveler ID.

     

Yes

       

B. California Customer Records categories

     

Name, signature, address, telephone number,  passport number, driver's license or state ID number, insurance policy  number, employment and employment history, bank account number, credit or debit card number and other financial information, medical information.  Overlaps with other categories.

     

Yes

       

C. Protected classification characteristics

     

Age and date of birth, national origin and  citizenship, sex and gender where a carrier or government requires it, disability and medical condition where an accessibility or assistance request  is made, and religion where indirectly revealed by a meal preference.  Collected only as needed to arrange travel and comply with carrier and  government requirements.

     

Yes

       

D. Commercial information

     

Records of products and services purchased,  obtained, or considered, booking and trip history, fares and rates, unused tickets, service fees, and expense records.

     

Yes

       

E. Biometric information

     

Fingerprints, faceprints, voiceprints, iris or  retina scans, keystroke or gait patterns, sleep, health, or exercise data.

     

No

       

F. Internet or other network activity

     

Browsing and search history, information about  your interaction with the Website, App, and advertisements, device and  session data.

     

Yes

       

G. Geolocation data

     

Approximate location derived from IP address, and  precise real-time device location where you enable location features.

     

Yes

       

H. Sensory data

     

Audio, electronic, visual, thermal, olfactory, or  similar information, including recorded telephone calls with our travel advisors and support teams, and chat transcripts.

     

Yes

       

I. Professional or employment-related information

     

Employer, job title, department, cost center, approval hierarchy, travel policy group, and traveler or employee ID,  provided by the Client.

     

Yes

       

J. Non-public education information

     

Education records subject to FERPA.

     

No

       

K. Inferences

     

Travel preferences and profiles derived from  booking history and Service usage, used to personalize and rank options.

     

Yes

 

Table 2.  Sources, Purposes, andRecipients

For every category marked Yes in Table 1, the sources, business and commercial purposes, and categories of recipients are as follows.

           

Detail

       

Sources

     

Directly from you; from Clients and program  administrators; from Client identity and single sign-on systems;  automatically from your device and browser; from travel suppliers and global  distribution systems; from identity, business verification, and screening  providers; from payment processors, card issuers, and card networks; from  expense and financial system integrations; from marketing, event, and data enrichment providers; from analytics providers; and from other travelers and travel arrangers.

       

Business and commercial purposes

     

Providing, securing, and administering the Service  and your account; business verification and fraud prevention; searching,  booking, ticketing, modifying, and refunding travel; traveler care and  support; reporting, analytics, policy compliance, and duty-of-care reporting  to Clients; payment processing, invoicing, reconciliation, and collections;  security, incident detection, and audit; sanctions screening and legal  compliance; service improvement and product development; and marketing our  services, subject to your choices.

       

Categories of recipients

     

The Client whose program you travel under; our  subsidiaries and affiliates; service providers and contractors, including  hosting, IT, security, customer support, communications, analytics, and  professional services firms; travel suppliers, global distribution systems,  and industry bodies including ARC and IATA; government authorities where  travel or other law requires, including TSA and CBP; payment processors, card  issuers, and card networks; identity, business verification, and screening  providers; advertising and analytics partners, subject to Section 10.1;  professional advisors, auditors, and insurers; parties to a corporate  transaction; and law enforcement and regulators where required.

       

Retention

     

As described in Section 8, in accordance with our  internal records retention schedule and, for Client-directed data, the  applicable Client agreement.

 

Table 3.  Sensitive PersonalInformation

We collect the following sensitive personal information,solely for the permitted purposes described in Section 6.

    Type      

What  we collect

     

Why

       

Government identifiers

     

Passport, visa, national ID, and driver's license  numbers.

     

Arranging and documenting travel; carrier and government requirements; identity verification.

       

Citizenship and national origin

     

As shown on travel documents.

     

International travel documentation; APIS and equivalent requirements.

       

Precise geolocation

     

Real-time device location, where you enable it.

     

Trip and disruption notifications; traveler safety and duty of care.

       

Health information

     

Accessibility, mobility, and medical assistance requests.

     

Fulfilling the requested accommodation with the relevant supplier.

       

Religious or philosophical belief

     

Indirectly revealed by a meal preference.

     

Fulfilling the requested meal with the relevant supplier.

       

Account credentials

     

Log-in and authentication data.

     

Securing your account and the Service.

 

Because we use and disclose sensitive personal information only for the purposes permitted by law, the right to limit its use and disclosure described in Section 10.5 does not apply to our processing of it.

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