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Privacy Policy

 

 

Privacy Policy effective 01.03.2019

 


1. Changes to This Policy We may update this Policy from time to time. If we do, we will let you know about any material changed, either by notifying you on this site or by sending you an email. New versions of this policy will never apply retroactively — we will tell you the exact date they go into effect. If you keep using TSI USA after a change, that means you accept this Policy.

 

2. Who we are TSI USA, LLC is a global travel management company that focuses on guaranteed savings, advanced technology, and superior service all supported with a guaranteed ROI. Most important, we have adopted an employee culture, creating an environment where we put our employees first, with the intended result that our employees put our customers first. While TSI USA and partners operate throughout 100 offices in over 60 countries, including a wholly-owned technology center located in Mumbai, we have the ability to provide local service, savings, and value around the globe.

 

3. Information Collected Non-Personal Information Non-personal information is information that cannot be used to directly or indirectly identify a person. TSI USA automatically collects and stores non-personally identifiable information about you to TSI USA’s Web sites by tracking the name of the domain and host from which you access the Internet; the Internet protocol (IP) address of the computer you are using; the browsing software you use and your operating systems; the date and time you access our Web sites; and the Internet address of the site from which you linked directly to our Web sites. We use this information only as anonymous aggregate data to determine the number of visitors to different sections of our Web sites, to ensure our Web sites are working properly, and to help us make our Web sites more useful. TSI USA does not collect any other non-personally identifiable information.

 

4. Personal Information Personal identifiable information (PII) is information that can be used to directly or indirectly identify a person. Some examples of personal information are: name, home or email address, home telephone number, identification number (e.g., social security number or social insurance number), financial information and physical characteristics. TSI USA may collect personal information from you through TSI USA’s Web sites to respond to information requests from you about TSI USA’s products and services, and for investor relations material. For example, customers that contact us are asked for their name, address, telephone number, store name/concept, number of stores and email address. Investors are asked for name, company, address, telephone number, email address and what type of investor relations material they are requesting. TSI USA also collects personal information from customers and business partners for general business purposes (specifically, reviewing customer credit and/or financial history, entering into contracts for products and services, processing orders and payments for products and services and providing support services to customer, all at customer’s request).

 

5. Use of Information TSI USA will only use the information you provide to us for the following reasons:
• Responding to your requests, inquiries, and/or questions;
• Enable you to use our travel services;
• Contact you regarding your purchase;
• Collect payments;
• Provide purchased services through our website, over the phone, and/or through client portals;
• Send invoices;
• Send specifically requested email notifications;
• Send TSI USA emails and newsletters containing company news, product, or service information;
• Send marketing communications.


The personal information you elect to provide to us may include:
• Your name;
• Contact information (including but not limited to, email address, mailing address, phone number, and fax number);
• Work information (such as your job title, position, and information about your company);
• Payment information (credit card data including number, expiration and cvv).


Personal data may be provided to TSI USA when you:
• Make a purchase from us;
• Submit an acknowledgement, a complaint or dispute;
• Complete a survey or questionnaire that is sent or that you have been invited to take;
• Submit a contact form through our website and/or portal;
• Subscribe to our email notifications or newsletters;
• Register a user profile on our website;
• Contact us by phone, website, portal and/or email.


Information collected and stored automatically: If you do nothing during your visit but browse through the Web site, read pages, or download information, we will gather and store certain information about your visit automatically. This information does not identify you personally. We automatically collect and store information like the following concerning your visit:
• The Internet domain (for example, “xcompany.com” if you use a private Internet access account or “yourschool.edu” if you connect from a university’s domain);
• Your IP address (an IP address is a number that is automatically assigned to your computer whenever you are surfing the Web) from which you access our Web site;
• The type of browser and operating system used to access our site;
• The date and time you access our site;
• The pages you visit; and
• If you linked to our Web site from another Web site, the address of that Web site.
We use this information to help us make our site more useful to visitors, to learn about the number of visitors to our site, and the types of technology our visitors use. We do not track or record information about individuals and their visits.


TSI USA will process your personally identifiable information (PII) based on your consent and according to our privacy policy and the guidelines of the EU-U.S. Privacy Shield.

 

6. Transfer of your Information


TSI USA may use third-party suppliers to perform services on our behalf that may involve accessing your personal information. We require that our third-party vendors maintain and protect your personal information in accordance with the standards outlined in this notice. Please note, that some of our vendors may process your data outside of the United States.
We reserve the right to use, transfer, sell, and share aggregated anonymous data, which does not include any PII, about our website’s users as a group for any legal business purposes, i.e. analyzing usage trends of our customers.


We do not provide your PII to any parties unconnected with the services TSI USA provides, except for what is disclosed in this privacy notice regarding third-parties.
TSI USA remains liable and responsible for the data processing operations undertaken by those third-parties, acting as our subcontractors to process data on our behalf.
If you do not want TSI USA to provide your contact information to a third-party in order to offer you products and services related to the products and services that you purchased from us, you may elect to opt-out by contacting TSI USA’s Privacy Officer as instructed in Section 10 below.

 


7. Use of Cookies
When you access our website, we automatically collect certain data about your use of our website. We gather this information by using “cookies” and/or other technologies to collect non-personally identifiable information from your visits to our website and your browser sessions to enhance your overall site experience and for statistical purposes. Cookies allow Web site operators to better customize visits to the site based on each of your preferences. These cookies are used as a convenience to the customer to help them keep track of login information, recent reports viewed and other information in connection with their visit to TSI USA website.
We may collect, process or transfer the following information about you: the name of the domain from which you access the Internet; the date and time you access our site; and the Internet address of the website from which you linked directly to our site. We use the information we collect to measure the number of visitors to the different sections of our site, and to help us make our site more useful to visitors. We may transfer the information we collect to our corporate affiliates. You can set your browser to turn off “cookies” or to warn you when a website attempts to place a “cookie” on your computer. However, if you turn off the “cookies,” our and other websites may not work as intended.

 


8. Security
TSI USA Web sites follow industry-standard practices to protect the data we collect and maintain, including using Transport Layer Security (TLS) to encrypt information as it travels over the internet. Your account information is protected by a password, which you should choose carefully and keep secure. We have an Incident Response Team and protocol in place in the event of a data breach. We encourage the responsible disclosure of vulnerabilities of our services by emailing DataProtectionOfficer@tsiusa.com.
Storage, Retention, and Accuracy of Personal Information TSI USA takes reasonable precautions to protect personal information from loss, misuse, or unauthorized access, disclosure, alteration or destruction. Personal information is maintained in secure electronic and manual files at TSI USA, and access to these files is limited to TSI USA employees for whom access is necessary to properly process the personal information consistent with the stated purposes. TSI USA will retain your personal information only for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws. We will retain and use this information as necessary for the purposed set out in this policy and to the extent necessary to comply with our legal obligations, resolve disputes, enforce our agreements and protect TSI USA’s legal rights. We take all reasonable steps to ensure that your personal information is accurate, up-to-date, complete, and reliable for TSI USA intended use.

 


9. Links
to Non-TSI USA Web Sites TSI USA’s Web sites contain links to other Web sites for your convenience and information. TSI USA is not responsible for the privacy practices, privacy statements, or the content of any Web sites linked to TSI USA’s Web sites. TSI USA also has no control over whether the Web sites linked to TSI USA’s Web sites use cookies to track information about visitors to their Web sites.

 


10. Global Organization
TSI USA is a global organization, with business processes, management structures, and technical systems that cross borders. Our privacy practices are designed to provide protection for your personal information provided to us all over the world. We may share your personal information within TSI USA and transfer it to countries in the world where we do business. Some countries may provide less legal protection for your information. In such countries, we will still handle your information in the manner described in this policy.
EU-U.S. Privacy Shield Compliance


TSI USA and its closely held technology partner, Internet Travel Services, LLC, is in compliance with the Privacy Shield program, which is administered by the International Trade Administration (ITA) within the U.S. Department of Commerce. The EU-U.S. Privacy Shield Framework was designed to provide companies on both sides of the Atlantic with a mechanism to comply with EU data protection requirements when transferring personal data from the European Union to the United States in support of transatlantic commerce. TSI USA has been Self-Certified in accordance with the EU Directive on Personal Data Protection. The principles of EU-US Privacy Shield Program are notice, choice, onward transfer, security, data integrity, access and enforcement. Additional information about Privacy Shield principles and to view TSI USA’s certification, please visit https://www.privacyshield.gov.


Members of the European Union If you are a resident of a Member State of the European Union and have any concerns or complaints, please first address these issues to the Privacy Officer, privacyofficer@tsiusa.com. TSI USA is located in the United States, as are the servers that make our websites available. All matters relating to privacy issues and websites are governed by the laws of the United State and the State of Texas. If the Privacy Officer does not satisfactorily address a complaint within thirty (30) days, any dispute, controversy or claim shall be settled by an arbitration administered by an arbitration agency.


TSI USA has further committed to refer unresolved Privacy Shield complaints to American Arbitration Association, an alternative dispute resolution provider located in the United States or the United States Council for International Business (USCIB) via the EU DPAs, serving as an independent resource mechanism (IRM) for dispute resolution (i.e., have agreed to participate in the dispute resolution procedures of the panel established by the EU DPAs to resolve disputes pursuant to the Privacy Shield Principles). If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit AAA for more information or to file a complaint. The services of American Arbitration Association are provided at no cost to you. All arbitrations will be conducted in English. Judgment rendered by the arbitrator may be entered in any court having jurisdiction. Texas, U.S.A. shall be the site of all hearings, and such hearings shall be before a single arbitrator. You may also submit complaints to the Federal Trade Commission at https://www.ftccomplaintassistant.gov or via telephone at (202) 382-4537.


Binding Arbitration
If your dispute or compliant can’t be resolved by TSI USA, nor by the panel established by the EU Data Protection authorities or through the Department of Commerce, you may have the right to require that TSI USA enter into binding arbitration with you pursuant to the Privacy Shield’s Recourse, Enforcement and Liability Principle and Annex I of the Privacy Shield.

 


11. Disclosures Required by Law
In certain circumstances, it is possible that your personal information may be subject to disclosure by us pursuant to judicial or other government subpoenas, warrants or orders.

 


12. Mergers or Acquisitions
TSI USA may decide to sell, buy, merge or otherwise reorganize businesses, whether for strategic or other business reasons. These business transactions may involve the disclosure of personal information to prospective or actual purchasers or the receipt of personal information from sellers. TSI USA shall seek appropriate protection for your personal information in these types of transactions.

 


13. Your Rights
Users residing in certain countries, including the EU, are afforded certain rights regarding their personal information. Except where an exception or exemption applies, these rights include the ability to access, correct, and request deletion of your personal information.


You have the following data protection rights, which we will always work to uphold:
1. The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using these details at privacy@tsiusa.com.
2. The right to access the personal data we hold about you. Part 14 will tell you how to do this.
3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.
5. The right to restrict (i.e. prevent) the processing of your personal data.
6. The right to object to us using your personal data for a particular purpose or purposes.
7. The right to data portability. This means that you can ask us for a copy of your personal data held by us to re-use with another service or business in many cases.

Users can manage their personal information, in their profile settings.

 


14. How Can I Access My Personal Data?
If you want to know what personal data, we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.


All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible. To access the form, click here.


There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.


We will respond to your subject access request within 30 days. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

 


15. Contact Information
You may contact TSI USA’s Data Protection Officer to access, correct or delete your personal information. In compliance with the Privacy Shield Principles, TSI USA commits to resolve complaints about our collection or use of your personal information. Individuals in the European Union with inquiries or complaints regarding our Private Shield policy should first contact TSI USA at:
Data Protection Officer
by Phone (214) 915-9000 or 1-877-915-9009 FREE; by facsimile at: (214) 915-9080;
by email at: dataprotectionofficer@tsiusa.com; or
by mail at TSI USA , 8111 LBJ Freeway Suite 900, Dallas, Texas, 75251 USA, Attention: Data Protection Officer
We will respond to your inquiries within 30 days of receipt.
This Web site is maintained by TSI USA, 8111 LBJ Freeway Suite 900, Dallas, Texas, 75251USA, or one of its subsidiaries around the world.