Last Updated: [05.10.2021]
At Egencia ("Egencia," "we", "us" and "our"), we understand that booking travel online involves significant trust on your part. We take this trust very seriously, and make it a priority to ensure the security and confidentiality of the personal information you or your organization provides to us (such as your name, phone number, email address, or payment details.)
This Privacy Statement sets out our information privacy practices as follows:
- Corporate Travel Program – Overview
- What information we collect from you
- Use of your information
- Disclosure of information
- Your choices with respect to collection and use of your information
- Using the Egencia mobile phone and tablet apps (the “Mobile Apps”)
- How we protect your information
- How you can access your information
- External links
- Where your data is stored
- Privacy Shield
- Data Retention
- Changes to this Privacy Statement
- How to contact us
When you book travel through Egencia, we have to make certain decisions about how and why to process your personal information in order to fulfill your travel booking. We are therefore responsible for protecting your personal information throughout the travel booking process.
This is what we explain in this Privacy Statement, which sets out Egencia’s policies concerning the management of personal information and describes the types of personal information Egencia holds, the purposes for which it holds that personal information, and the ways in which Egencia collects, holds, uses and discloses that information.
CORPORATE TRAVEL PROGRAM – OVERVIEW
To manage its business travel needs, your organization has enrolled in the Egencia Corporate Travel Program. Under this Program, your organization may designate a travel manager (“Travel Manager”) to manage and administer the travel needs of your organization and may appoint one or more travel arrangers (“Arranger” or “Travel Director”) to book and manage the travel of individual employees (“Travelers”), as well as non-employees, as deemed appropriate by the company (“Guests”).
- Rules relating to bookings by Travelers
To book and manage their own travel, Travelers must register to become a member of Egencia or have profile data loaded in our system by the Egencia implementation team. In the event that Travelers do not register to become members of Egencia, they must rely on their Travel Manager, Arranger or Travel Director to make a booking on their behalf. If you are a Traveler, this Privacy Statement applies to how we collect and use your personal information regardless of whether you are booking and managing travel yourself or through your Travel Manager, Arranger or Travel Director. Accordingly, unless we expressly provide otherwise, when we refer to “you” in this Privacy Statement, we are referring to you as the Traveler, whether you are acting on behalf of yourself or through a Travel Manager, Arranger or Travel Director.
- Travel Managers, Arrangers, and Travel Directors
While this Privacy Statement is primarily directed at Travelers and Guests, it also applies to Travel Managers, Arrangers and Travel Directors.
Any personal information that a Travel Manager, Arranger or Travel Director provides to us about himself or herself in connection with our Corporate Travel Program is managed as set out in this Privacy Statement. Egencia, however, reserves the right to contact Travel Managers, Arrangers and Travel Directors as contemplated by their organization’s Corporate Travel Agreement with us (e.g., for feedback on the Program, to discuss the business relationship, or to discuss new or updated services). This contact may occur via phone, email, text message or postal mail.
When booking and managing travel on behalf of any Traveler or Guest, Travel Managers, Arrangers and Travel Directors must obtain the relevant Traveler's or Guest’s consent. Travel Managers, Arrangers and Travel Directors must also ensure that the relevant Traveler or Guest receives and reviews this Privacy Statement.
Whether you book travel directly from us or allow your Travel Manager, Arranger or Travel Director to do so on your behalf, authorized individuals within your company may have access to your member ID and name of your member account, as well as your travel itineraries and all other information in your account, and may also direct that we share this information with third parties for recordkeeping or other authorized purposes. Your Travel Manager, Arranger or Travel Director will also be able to update your profile settings (excluding your Member ID and password) and travel preferences in accordance with your instructions to them. Your Travel Manager, Arranger or Travel Director will also be able to view, change or cancel any of your trip itineraries as necessary to fulfil your instructions or in accordance with your agreements with them.
- Scope of Statement
This Privacy Statement sets out the information, collection and use practices of Egencia. The policies or practices of your organization may differ, and we are not responsible for any use or disclosure of your personal information by anyone at your organization or any acts or omissions of your organization, Travel Manager, Arranger or Travel Director. If you have any questions about the manner your organization, Travel Manager, Arranger or Travel Director handles your personal information or books or manages travel on your behalf, please contact the appropriate representative of your organization or refer to your organization's privacy statement.
WHAT INFORMATION WE COLLECT FROM YOU
Before you access the Egencia website, you must be authenticated and sign in as a member. Generally, Egencia collects and stores all information you provide to Egencia including, without limitation, all personal information about you that you specifically and voluntarily provide or give us in any other way. This includes information that can identify you (“personal information”), including first name, surname, telephone number and email address, passport information and billing information (such as credit card number, cardholder name, and expiration date). We also may request information about your travel preferences, including meal requests, seat selection, frequent flyer/hotel/car rental program information, and ticketing options. Your Travel Manager, Arranger or Travel Director may provide us additional personal information about you such as your employer ID number.
Circumstances where Egencia collects personal information include, without limitation, when you:
- Become an Egencia member
- Complete a traveler profile
- Book travel
- Use the Travel Arranger service
- Participate in a survey
- Contact us
When you use our site, App, or associated tools or services, we may collect the following categories of personal information from you as needed:
Passenger information: Egencia collects the full name, contact number and other personal information necessary for the travel reservation, such as passport number and billing information, of a Traveler when a travel reservation is made through Egencia. We may also collect information about each Traveler's preferences, including meal requests, seat selection, frequent flyer/hotel/car hire programs and membership numbers, and ticketing options.
Travel Guest information: When you make a reservation for someone else through this website, we may request personal information and travel preferences about that individual. You must obtain the consent of other individuals and ensure such other individuals review this privacy statement prior to providing us with their personal information and travel preferences, as any access to view or change their information will be available only through your account. We will collect, use and disclose that individual’s personal information only for the purpose of making a reservation.
Automatic information: We automatically collect some information about your computer when you visit this website. For example, we will collect your IP address, web browser software (such as Firefox, Safari, or Internet Explorer), and referring website. We also may collect information about your online activity, such as trips viewed and bookings made. Our goals in collecting this automatic information include helping customize your user experience and detecting and preventing fraud. For more information, please see our Cookie Statement.
Call monitoring: Calls to and from our customer service help desk may be recorded or monitored for the purpose of quality control and for staff training. Call recordings will be maintained as long as reasonably necessary or required by law and will then be deleted. Any personal information obtained from you during the call will be treated in accordance with this Privacy Statement.
Other Online Communications: Any interactions you have with us through our website or other technology, such as chat, will be recorded and monitored for quality control purposes, to protect us in the event of a legal dispute and for staff training. This information will be processed and maintained consistent with this Privacy Statement.
Special Categories of Personal Information: Certain types of personal information, such as some government-issued identification numbers and information about religion, health or sexuality, are considered sensitive and require additional protection under applicable laws. We limit the circumstances under which we may collect sensitive personal information; examples of this information include the following:
- Health-related information may be needed to provide appropriate travel accommodation and accessibility or facility requirements.
- Government-issued identification numbers like passport or driver’s license number may be required for flights, vehicle rental or other travel reservation.
- Other information that you can specify at your option and which may imply or suggest religious, health or other information, such as dietary needs.
Failure to provide information: In order to access the Egencia website, you must sign in as a member, using your Member ID and password. When making travel plans or a booking using this web site, you must provide the requested contact information and financial information. We will use your contact information to reserve the required services, to send you details of the confirmation, for billing purposes and to inform you of any updates or changes to your travel plans. If you do not provide the requested information, you will not be able to access the Egencia website, and we may not be able to complete your requests or orders.
Lawful bases for processing: We will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests (or those of any third party) and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we will have a legal obligation to collect personal information from you such as where we need to use your transaction history to complete our financial and tax obligations under the law.
If we ask you to provide personal information to comply with a legal obligation or to perform a contract with you, we will make the reason clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our platform and communicate with you as necessary to provide our services to you, for security verification purposes when you contact us and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will clarify those legitimate interests at the relevant time.
DISCLOSURE OF YOUR INFORMATION
Egencia and its service providers may share your personal information with the following entities:
- Suppliers, such as hotels, airlines, rail companies, car rental companies, or activity providers, who fulfill your travel reservations. Throughout this website, all services provided by a third-party supplier are described as such. These suppliers will process your data in accordance with their privacy policies. Therefore, we encourage you to review the privacy policies of any travel supplier whose products you book through Egencia. Please note that these suppliers also may contact you as necessary to obtain additional information about you or to facilitate your travel reservation.
- Third-party vendors vendors who may provide services or functions on our behalf, including without limitation credit card processing, business analytics, customer service after hours, distribution of newsletter or survey emails and fraud prevention. Upon direction by your employer, we may also share your personal information with third-party vendors providing such services as expense tracking and reimbursement. These companies have access to personal information needed to perform these functions, but are not permitted to share or use the information for any other purpose. For more information on the manner in which our service providers treat your personal information, contact us as set out under “How to Contact Us” below.
- Others within your organization, such as your Travel Manager, Arranger or Travel Director, as described above in the “Travel Managers, Arrangers, and Travel Directors” section.
- Others within our corporate family We may share certain information with our corporate affiliates, for hosting, storage, analytics and reporting purposes. To the extent that a corporate affiliate has access to your information in order to provide services on our behalf, it will follow practices that are at least as restrictive as the practices described in this Privacy Statement.
We and our service providers may also share your information:
- When it has been explicitly requested by you.
- In response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required or permitted by applicable law. In such cases, we reserve the right to raise or waive any legal objection or right available to us.
- When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of Egencia, our customers, or others; and in connection with our Terms of Service and other agreements.
- With law enforcement agencies and governments around the world for security, customs, and immigration purposes. For example, under U.S. Law, the U.S. Department of Homeland Security Bureau of Customs and Border Protection requires that certain travel and reservation information, known as Passenger Name Record or PNR data, relating to people travelling to or from the U.S.A, or through U.S. airspace, be provided to the Department prior to such travel. We may disclose this information to airlines or other travel providers so that they can forward it to the applicable law enforcement agencies and governments.
- In connection with a proposed or completed corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
YOUR RIGHTS AND CHOICES WITH RESPECT TO COLLECTION AND USE OF YOUR INFORMATION
You can access, add, update or delete information on the My Profile and My Trips pages and close your account as described below.
You may also submit a written request to access the personal information that we hold on you. If you make such a request, Egencia is entitled to request appropriate identification before servicing such request. You can make a written request for access to your personal information by contacting us via the contact information provided below in the “How to Contact Us” section. We will endeavor to respond within an appropriate timeframe and, in any event, within any timescales required by law.
Certain countries and regions provide residents with additional rights relating to personal information. These additional rights vary by country and region, and may include the ability to:
- Request a copy of your personal information
- Request information about the purpose of the processing activities
- Request deletion of your personal information
- Object to our use or disclosure of your personal information
- Restrict the processing of your personal information
- Opt-out of the sale of your personal information
- Port your personal information
- Request information about the logic involved in automated decision-making used in our fraud prevention practices, and the result of such decisions
The easiest way to submit your request to us is through the “Contact Us” section at bottom of this Privacy Statement. For more information on what data subject rights may be available to you, please click here.
In addition to the above rights, you may have the right to complain to a data protection authority about our collection and use of your personal information. However, we encourage you to contact us first so that we can do our best to resolve your concern. You may submit your request to us using the information in the “Contact Us” section. We respond to all requests that we receive from individuals wanting to exercise their personal data protection rights in accordance with applicable data protection laws.
As a participant in the Egencia program, you may receive communications from us providing travel news and updates. You can discontinue your subscription to such email newsletters at any time on the My Profile page under the heading "Email settings" or by telling your Travel Manager, Arranger or Travel Director that you no longer wish to receive such communications from Egencia. You will also be given the opportunity to unsubscribe from such newsletter in any such email we send. Please note that we reserve the right to send you other communications, including service announcements, administrative messages, and surveys relating either to your Egencia account or to your transactions with Egencia, without offering you the opportunity to opt out of receiving them.
USING THE EGENCIA MOBILE PHONE AND TABLET APPS (THE “MOBILE APPS”)
When you use an Egencia Mobile App, we collect and use information about you in the same way and for the same purposes as we do when you use our website. In addition, we use some other information that we collect automatically when you use our Mobile Apps. Specifically:
- We collect information about Mobile App functionality that you access and use. This information allows us to identify those areas of the Mobile App that are of interest to our customers so that we can refine and continuously improve the Mobile App.
- If you use a Mobile App’s “find hotels” feature using your “current location,” we use information about your current location – provided by your mobile device using GPS or similar technologies – to show nearby facilities. We do not collect location data unless you consent by expressly clicking on the “find hotels” feature using “current location” as your destination or you switch on location data collection through your phone settings menu. If you agree to share location information with us through your app or device settings, we may use and share this location information to offer you localized hotel or transportation options, or to provide you with other relevant information or services.
- Each Mobile App will also send us error reporting information in the event that it crashes or hangs. The error report enables us to investigate the error and to improve the stability of the Mobile App for future releases. As part of these error reports, the Mobile App sends us information about the mobile device type and version, your customer ID, the time the error occurred, the feature being used and the state of the application when the error occurred. We do not use this information for any purpose other than investigating and remedying the error.
- We may send push notifications concerning changes in flight status or other items coming up on your trips. In addition, we may also use push notifications to issue key communications from your travel manager/employer in case of emergency. These permissions can always be managed from your mobile device settings.
- If you select “Contact Egencia by phone” and choose the “Call back” option under Egencia AssistMe, where this feature is available, the Mobile App will send your customer ID, itinerary information and potentially other information about recent Mobile App usage to the travel consultant. This is done to expedite the customer service interaction and make for a smoother, more knowledgeable exchange.
You always have the ability to control certain information a Mobile App sends to us. You can switch off location data collection at any time through your phone settings menu. Alternatively, you can remove the Mobile App from your mobile device entirely and access our services through our website or phone.
HOW WE PROTECT YOUR INFORMATION
We want you to feel confident about using our services to plan and book your travel, and we are committed to protecting the information we collect. While no company can guarantee security, we have implemented appropriate administrative, technical, and physical security procedures to help protect the personal information in our custody and control. For example, only authorized employees are permitted to access personal information, and they only may do so for permitted business functions. In addition, we use encryption when transmitting your sensitive personal information between your system and ours, and we employ firewalls and intrusion detection systems to help prevent unauthorized persons from gaining access to your information.
HOW YOU CAN ACCESS YOUR INFORMATION
You have access to your information in the following areas of this website:
The My Profile pages on Egencia allows you to view and change your account settings. The email settings option lets you change your email address and manage your communication preferences. You may also adjust your email preferences by clicking ‘unsubscribe’ via the link in the footer of an email we send you. You can also change your password and elect to have an automatic password sign-in when logging on to this web site. After a Travel Manager logs into their Egencia profile, the Travel Manager has the ability to add new users, update the status or delete existing user profiles, update or correct names, phone numbers, passport information, and emergency contacts for Travelers associated with your profile; and update your travel preferences.
Request to close an account
You can close your Egencia account by contacting us as described below. Once you close an account, you will not be able to sign in or access any information associated with the account, but you can open a new account at any time. We will send you an e-mail confirming your account closure to the e-mail address contained in your member profile.
The My Trips page on the Egencia website allows members to view, update, or delete their saved itineraries. In the event that you notify Egencia that certain personal information about you is not accurate, complete and up to date, Egencia shall take reasonable steps to correct the personal information so that it is accurate, complete and up to date.
If any part of this website links you to other websites that we do not own or operate, those websites do not operate under this Privacy Statement. We recommend you examine the privacy statements posted on those other websites to understand their procedures for collecting, using, and disclosing personal information.
WHERE YOUR DATA IS STORED
Egencia stores and processes personal information about Travelers in secure environments in the United States and other countries. In relation to the processing of non-U.S. Traveler data, in order to provide its services, Egencia must transfer your Personal Data to its affiliates and/or service providers for processing in the U.S. and potentially other countries outside of your country of residence, whose data protection laws may be different to the laws in your country. Egencia will ensure that your personal information is protected in accordance with this Privacy Statement and the requirements of applicable data protection law wherever your personal information is processed. We ensure that any of our third party service providers to whom a data transfer is made has appropriate safeguards in place to protect your personal information. The adequacy mechanism may be (i) adequate country status, i.e., based in a country that the European Commission has deemed "adequate" since such country’s data protection standards are similar to the European Union; or (ii) Standard Contractual Clauses.
For Personal Data from Europe, Egencia will carry out such data transfers in accordance with this Privacy Statement and applicable laws.
Egencia has certified to the EU-U.S. and Swiss-U.S. Privacy Shield frameworks and that we adhere to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfers, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability for personal information from the EU, Switzerland, and the United Kingdom. Egencia will continue to adhere to the Privacy Shield frameworks and Principles even though the European Court of Justice (CJEU) determined in July 2020 that the EU-U.S. Privacy Shield framework is no longer an adequate transfer mechanism for the transfer of EU personal information to the U.S. In addition, Expedia Group maintains intra-group Standard Contractual Clauses where applicable to cover the transfer of EU personal information to the U.S. Our certifications can be found here. For more information about the Privacy Shield principles, please visit: www.privacyshield.gov. For more on our adherence to the Privacy Shield Frameworks, please see the information posted here.
We will not retain your information for longer than is necessary for our business purposes or for legal requirements. However, please be advised that we may retain some information after you have closed your account with us, for instance, if necessary to meet our legal obligations, including retaining the information for tax and accounting purposes. We will de-identify, aggregate, or otherwise anonymize your personal information if we intend to use it for analytical purposes or trend analysis over longer periods of time.
The criteria we use to determine our retention periods include:
- The duration of our relationship with you, including any open accounts you may have with Egencia, or recent bookings or other transactions you have made on our site
- Whether we have a legal obligation related to your personal information, such as an obligation to keep records of your transactions with us
- Whether there are any current and relevant legal obligations affecting how long we will keep your personal information, including contractual obligations, litigation holds, statutes of limitations, and regulatory investigations
CHANGES TO THIS PRIVACY STATEMENT
Egencia may update this Privacy Statement in the future. We will notify you about material changes to this Privacy Statement by sending a notice to the e-mail address you provided to us or by placing a notice on our Web site. You can see when this Privacy Statement was last updated by checking the “last updated” date displayed at the top of this Statement.
HOW TO CONTACT US
If you have questions about either this Privacy Statement or our privacy practices generally, please contact us at:
- Email us via our customer service and feedback form. We will do our best to respond to your request within 24 hours.
- Call us. If you need more immediate assistance, please call us directly at 09 975 7930.
- Write to us. Our address is Global Privacy Director, Expedia Legal & Corporate Affairs, Expedia, Inc., 1111 Expedia Group Way West, Seattle, WA 98119, USA.
For more information about the data controller and/or representative for personal information we process, please click here.