Last Updated: May 25, 2018
Adelman Travel Group believes in protecting the privacy of individuals and making safe and ethical use of personal information that is provided to us via electronic channels.
This Site is not intended for anyone under the age of 18. If you are under the age of 18 and have reached this Site, please leave the Site. We do not knowingly collect personal information from children under 18, unless we have received consent from a parent or guardian.
If you believe that we might have any information from or about a child, please contact us at firstname.lastname@example.org. In the event that we learn that we have collected personal information from a child under the age of 13, without consent, we will delete that information and otherwise comply with the requirements of the Children’s Online Privacy Protection Act and other applicable laws such as the California Online Privacy Protection Act.
Security of your Information
We collect several types of information from and about users and Registered Users of this Site, including the information described below.
If you register for an account on the Site, you will become a “Registered User.” Most of the personally identifiable information we collect from you as a Registered User is voluntarily submitted by you, for example, first and last name, company name, email and postal address, etc. We consider your personally identifiable information and other information we collect about your travel arrangements (your “Personal Information”) confidential. If you become a Registered User, you may be issued a username and password, which you should keep confidential. We have implemented security mechanisms designed to protect your information from loss, misuse and unauthorized access, disclosure, alteration and destruction.
“Given the nature of the travel industry, some third parties we do not control may have access to your Personal Information in order to complete the reservation and fulfillment of travel services. The primary third parties accessing your Personal Information are Sabre and Concur. Pursuant to our policies, Sabre and Travelport will not sell or give your Personal Information to any unaffiliated party, other than those involved in providing the requested transportation or service, without the your permission, except when required by law or when data is requested by government or law enforcement authorities or in the unlikely event of a sale of the business or transfer of assets.
Our employees who have access to your Personal Information have signed confidentiality agreements for data made available to them during their course of employment at the Agency.
Non-Personally Identifiable Information
Although we largely only collect personally identifiable information from Registered Users, we may collect non-personally identifiable information from everyone that accesses the Site. We use this information to help make the Site more useful to you and to better understand our users and Registered Users.
We may collect non-personally identifiable information about you through a variety of technical methods, including the following:
- Collection of Usage Details and IP Address. As you navigate through this Site, we may collect details of your visits to this Site, including, but not limited to, traffic data, location data, logs, the resources that you access, and information about your computer and internet connection, including your IP address, operating system and browser type. We may also collect the webpage from which you came immediately before reaching the Site and the webpage to which you went immediately after leaving the Site. We may use this information for system administration and to report aggregate information to our advertisers and business partners.
- Collection with Cookies. “Cookies” are pieces of information that a website sends to your computer while you are viewing a website. We may place and access cookies on your computer and/or mobile device to track and store preferential information about you. You consent to our placement of cookies on your computer and/or mobile device. Please note that most internet browsers will allow you to stop some cookies from being stored on your computer and/or mobile device and to delete some cookies stored on your computer and/or mobile device. If you choose to do so, however, your use of certain aspects of this Site may be inaccessible, or not function as expected.
- Collection with Web beacons. “Web beacons” are electronic images, tags or scripts that allow a website to access cookies and help track general usage patterns of visitors to a website. Web beacons can recognize certain types of information, such as cookies, time and date of a page view, and a description of the page where the Web beacon is placed. We may use Web beacons to compile information regarding use of this Site.
- Collection with Mobile Device GPS. If you are using a mobile device application to access or use the Site, we may use the GPS of the mobile device to identify your location. Any such identification is used only in connection with the functionality of the Site or Service and will not be otherwise used, except in the aggregate with the location information from other users.
The information collected through these technical methods, standing alone, cannot be used to determine your identity. If such information is combined in a way that makes it become personally identifiable information, we will treat the combined information as personally identifiable information as described above.
We do not collect any financial information on this Site. If you make a debit or credit card payment online, you will be taken to a secure payment service provider who will take your payment on our behalf and return you to this Site when your order has been completed. You should not communicate credit card or other payment information via email, as it is not secure.
Limited Use of your Personal Information
Adelman Travel Group will not divulge the statistical information we compile for your company except for the express purpose of generating reports which have been authorized by you or otherwise agreed to by you in the normal course of our assisting you in managing your travel spending, or unless acting under a good faith belief that such action is necessary to: (1) conform to legal requirements or comply with legal process; (2) protect and defend the rights or property of Adelman Travel Group; (3) enforce our agreements with customers; or for any other reason that we may, at our sole discretion, feel is necessary or proper under the circumstances. We may also compile statistics from IP addresses accessing our website. Adelman Travel Group will not sell any customer specific information to any third party.
We may take your personally identifiable information and make it non-personally identifiable, either by combining it with information about other individuals (aggregating your information with information about other individuals), or by removing characteristics (such as your name) that make the information personally identifiable to you (de-personalizing your information). We may use and/or disclose to third parties such aggregate or de-personalized information in any manner and without notice or compensation to you.
International Data Transfers and Contractual Terms
Adelman Travel, its authorized partners, or affiliates will not store or transmit any personal data to third parties without your consent or agreement to use such services as incorporated, such as travel related third-party vendors. Adelman Travel only collects the minimum amount of data necessary to provide you with account servicing and functionality of our Site and Services. As an EU Customer, you have rights associated to our current sub-processor list as well as notification of any changes. For more information or an additional Data Protection Addendum (DPA) please contact email@example.com.
Identifying the Controller and Processor
Adelman Travel serves as a both a controller and processor of Customer personal data. Adelman Travel may need to process additional personal data if we provide ancillary services such as customer service through a direct business relationship with an applicable partner. Whenever you purchase or obtain services or products from Adelman Travel directly, Adelman Travel will serve as the controller for that data, meaning that Adelman Travel will serve to store, protect and make decisions surrounding the use of your data. Whenever you purchase or use Adelman Travel Services on behalf of third party users, Adelman Travel will be the processor of that data while you remain the controller.
Adelman Travel will:
- Take all reasonable measures to ensure that the Personal Information can be accessed only by authorized personnel;
- Take all reasonable measures to prevent unauthorized access to the Personal Information through the use of appropriate physical and logical (passwords) entry controls, securing areas for data processing, and implementing procedures for monitoring the use of data processing facilities;
- Build in system and audit trails;
- Use secure passwords, network intrusion detection technology, encryption and authentication technology, secure logon procedures and virus;
- Account for the risks that are presented by Processing, for example, from accidental or unlawful destruction, loss, alteration, unauthorized or unlawful storage, processing, access or disclosure of Personal Information;
- Ensure pseudonymization and/or encryption of Personal Information, where appropriate;
- Maintain ongoing confidentiality, integrity, availability and resilience of processing systems and services;
- Maintain the ability to restore the availability and access to Personal Information in a timely manner in the event of an outage;
- Implement a process for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures for maintaining the security of the Personal Information;
- Monitor compliance on an ongoing basis;
- Implement measures to identify vulnerabilities with regard to the processing of Personal Information in systems used to provide Travel Services to the Data Controller;
- Provide employee and contractor training to ensure ongoing capabilities to carry out the security measures established in the policy.
Your Rights, Consent, and Opt-Out
Consent by Site Visitors
Consent by Site Customers
For features on the Site that allow online transactions, Site Customers may knowingly submit contact information, and other information.
Changing or Removing Information; Opting Out; Discretionary Account Information
To allow appropriate control or deletion of your Personally Identifiable Information or to get immediate access to our sub-processor list, or information you have provided to us via the Site, and/or to change or update discretionary information that you have previously submitted, please contact firstname.lastname@example.org
If Adelman Travel chooses to send to you bulletins, updates, or other unsolicited communications that are marketing-related materials, Adelman Travel will provide you with the ability to decline - or "opt-out of" - receiving such communications. Instructions for opting-out will be provided if and when Adelman Travel determines to send you such a communication. Please understand that you will not be allowed to "opt-out" of formal notices concerning operation of this Site, and other legal notices.
Finally, in accordance with an Opt-Out, if you also request an account deletion with your Opt-Out, Adelman Travel will remove your name and all other Personally Identifiable Information from our databases compiled from the Site or Services. You may request account deletion or request your privacy preferences with us by emailing us at email@example.com.
Please understand, however that, if you request deletion or limitation of your information, you most likely will be unable to utilize associated features and any associated services that Adelman Travel provides. You may not remove de-identified or Aggregate Information from our databases. At times, we may not accommodate a request to change or delete information if we reasonably believe the change would violate applicable conflicting law (e.g. what is required by a specific EU member state) or cause the information to be incorrect. For more information about GDPR related rights, your right to deletion and the right to be forgotten, email us at firstname.lastname@example.org for any assistance.
Disclosure of Traveler Specific Data
We will not divulge traveler specific information to any third party other than in the ordinary course of conducting business for the benefit of customers which may include confirming reservations, upgrades, frequent flyer status or for purposes of accommodating a change in travel plans.
Collection of Travel Data
The collection of travel data for reporting purposes and customer billing is an industry standard, and many travel management companies use this information to provide useful features for their customers including web access to reporting and ability to modify traveler profiles online. This data may also be provided to suppliers with your consent to benchmark market share and revenue production for the sole purpose of analyzing spending patterns in accordance with your pre-existing or pending contracts.
Before a traveler takes their first trip we will request specific personal information to ensure a high service level for each trip. Such personal information may include but is not limited to telephone numbers, credit card numbers, passport and visa information, birth dates, frequent flyer information, hotel and rental car id numbers, office address and phone numbers. In addition we ask for email addresses and fax numbers to facilitate delivery of travel information including invoices, trip itineraries and trip specific updates.
When you submit comments and questions on our services via our website, we also ask for your e-mail address. This is to allow us to contact you with questions about your feedback.
In addition to the uses for the information you submit to us, we may use personally identifiable information about you to:
*Contact you when necessary for additional information necessary to process or fulfill your travel request; determine if you are satisfied with our service; inform you that an upgrade is available; send travel warnings and updates; verify the status of a non-refundable booking; inform you of the status of your trip.
*Send or contact you with information or special offers available from Adelman Travel Group
Adelman Travel Group takes steps to protect the confidentiality, privacy and security of personal information that is communicated to us. Like many companies that accept payment by credit card, Adelman Travel Group may share customers’ personal information with qualified third parties in order to process your order.
Circumvention of Security Measures
Data Retention and Removal
All data and personal information is the property of our customers, as such, customers may request transfer of this data to them if they are no longer contracting to use Adelman Travel Group services. Adelman Travel Group may charge a reasonable fee to assist in such data transfers.
Do Not Track Requests
This Site does not respond to “do not track” requests. All traffic is treated as equal and processed the same in that we will track users and Registered Users use of the Site as well as the webpage that the user or Registered Users came from before reaching the Site and the webpage to which he or she went after leaving the Site. If you desire to have your browsing be private, we suggest that you use your web browser’s private, incognito or other similar options.
Operation of this Site in the United States
This Site is operated in the United States. If you are located in the European Union, Canada or elsewhere outside of the United States, any information you provide to us will be transferred to the United States. By using this Site or providing us with your information, you consent to this transfer and to the applicable laws of the United States.
Data Protection Officer
SPECIAL NOTIFICATION FOR CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS
Individuals who are residents of California and have provided their personally identifiable information to us may request information regarding our disclosures, if any, of their personally identifiable information to third parties for direct marketing purposes. Such requests must be submitted to us at email@example.com or in writing at:
- Adelman Travel Group
6980 N Port Washington Road
Milwaukee, WI 53217
California privacy rights requests must include the reference “Request for California Privacy Information” on the subject line and in the body of the message and must include the e-mail address or mailing address, as applicable, for us to send our response. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted other than to the address specified in this paragraph.