BCD Meetings & Events Global Privacy Policy (this “Policy”) Last Updated: April 16, 2020
BCD
Travel Services B.V., acts as controller of your personal data when
processed by BCD Meetings & Events entities and BCD Travel entities
that provide meetings & events services (“BCD M&E”, “we”, “our”,
or “us”), respects your privacy and is committed to complying with this
Policy, which describes how we, as a meetings and events management and
related services company, collect and use the personal data that you,
the company which you are an employee of or are otherwise attending
meetings and events on behalf of (“Company”), or third parties provide
to us.
This Policy describes what personal data we collect
about you, how we collect it, how we use it, with whom we may share it,
and what choices you have regarding our use of your personal data. We
also describe the measures we take to protect the security of your
personal data and how to contact us.
This Policy applies to BCD
M&E’s meetings and events and related services, e.g. incentive,
leisure and sport services that may be provided to you, including
related services on BCD M&E websites and applications that display
or link to this Policy (hereinafter collectively, the “Services”). If
you also receive our travel services provided by BCD Travel and/or our
business travel consulting services provided by Advito LLC, you may
review their policies on their websites, respectively
(www.bcdtravel.com, https://www.advito.com).
We encourage you
to read this Policy carefully and in its entirety as it relates to your
rights regarding the processing of your personal data. As a user of our
Services, you understand and agree that we collect, use, store, and
disclose your personal data in accordance with this Policy.
Our
privacy practices vary as they must amongst countries in which we
operate to reflect local legal requirements. BCD M&E complies with
applicable data protection laws in the jurisdictions in which it
operates in its handling of personal data.
Please note that this
Policy only applies where we process personal data about you as a
controller. We process personal data as controller when providing: (i)
services through BCD M&E applications, (ii) flight bookings and
associated services, and (iii) consulting services. It does not apply to
services where we process personal data as a processor on behalf of a
controller. When we are a processor, the privacy policy of the relevant
controller will apply.
What personal data does BCD M&E collect? In
the course of providing its Services, BCD M&E may collect, use,
store, and disclose personal data. Personal data is any information that
can be used to identify you or that we can link to you. You, as
attendee or user of the Services, may be asked to provide certain
personal data when you use our Services, such as: • Names and contact information (work and home/mobile phone, fax, email, address); • Event booker and emergency contact names and information; •
Attendee preferences and trip/meeting details (e.g. routings, class of
service, seat preferences, frequent flyer data, meal preferences,
hotel/rail/car and other ground transportation membership data and
preferences, special accommodation requests, other personal data
voluntarily supplied by you via your profiles, surveys, or other
requests); • Travel documentation (e.g. passport/visa/national
id/driver’s license number, TSA number, citizenship, date of birth,
gender); • Payment data (corporate/personal credit cards) and bank information; and • Login credentials, user IDs, employee IDs, IP addresses, and browsing information.
If
you submit any personal data relating to other people in connection
with the Services (e.g. if you make a reservation for another
individual, or provide an emergency contact), you represent that you
have the authority to do so and that you have informed them we will
collect, use, store and disclose such personal data in accordance with
this Policy.
How does BCD M&E collect personal data? BCD M&E collects personal data:
•
Directly from you when you access various parts of our Services,
including when you communicate with us via email or other channels; •
From other sources, for instance, including your Company and your
Company’s third parties who may send us your personal data on your or
your Company’s behalf; and • From the network of websites and
applications accessible through or utilized by our Services and our
company, including third party suppliers (e.g. airlines, hotels, payment
card providers) and our BCD M&E related companies, affiliates,
subsidiaries, joint ventures, partners, subcontractors, and agents. This
includes personal data we collect automatically through our websites
and applications, for instance by using cookies and similar
technologies.
How does BCD M&E use personal data and on which legal bases? BCD
M&E collects and uses your personal data for specified, explicit,
and legitimate purposes as described in this Policy and does not process
your personal data further in a manner that is incompatible with those
purposes.
BCD M&E uses personal data to: A. Provide its
Services and fulfill its obligations to your Company and attendees
(e.g. meeting & event management, complete and administer meeting
reservations, assist in managing the travel as well as the meeting,
provide reporting and analytics based on the Services, provide notices
about your account and the Services, inform you of updates to our
websites and applications and other changes to our products or
Services). B. Communicate with you via various multi-media
channels (for instance, by email, post, phone, or BCD M&E's websites
or applications) and to provide you with customer service. C.
Understand how our websites and applications are used and provide a
customized experience as you use our Services, such as by providing
interactive or personalized elements on our Services and providing you
with content based on your interests (for more information, see the
Section below titled “How does BCD M&E handle “do not track”
requests and use "Cookies" and other similar technologies?”). D.
Fulfill a request made by you or your Company (e.g. meeting/travel based
reporting, questions, booking requests, or other requests about your
personal data). Automated decision-making may be used to process some
requests to assist in delivering faster and more reliable Services to
you and/or your Company (e.g. rerouting your request to the appropriate
department, sending automatic replies). Important decisions will always
be reviewed by a BCD M&E employee. E. Send you newsletters,
marketing emails, and other information or materials that may interest
you or showing personalized advertisements. Where required, we will
obtain your consent before sending such marketing messages or showing
personalized advertisements. F. Conduct surveys (e.g. attendee,
client satisfaction) and review the quality and performance of our
services for customer satisfaction purposes. G. Carry out our
obligations and enforce your, our, or other’s rights as we believe
reasonably necessary (e.g. billing and collection, fraud prevention,
comply with legal obligations, and respond to legal proceedings or
requests from legal authorities and law enforcement or other third
parties).
To process your personal data as described above,
BCD M&E relies on the following legal bases. In view of purpose A,
we process your personal data where necessary for the performance of the
contract we have with your Company and/or you, which allows us to
deliver our Services to you. In view of purpose B to F, we rely on our
legitimate business interest to provide and improve our Services. For
purpose G, BCD M&E relies where applicable on compliance with legal
obligations. We rely on our legitimate business interest to prevent
fraud and to protect our rights. When using personal data to serve BCD
M&E's or a third party's legitimate interest, BCD M&E will
always balance your rights and interests in the protection of your
personal data against BCD M&E's rights and interests or those of the
third party.
Who does BCD M&E disclose personal data to and why? Personal data may be collected and shared with or disclosed as required for the provision of Services to: •
BCD M&E and its related companies, affiliates, subsidiaries, joint
ventures, partners, subcontractors, and agents as necessary to fulfill
and support the Services, including emergency bookings and assistance,
ticket issuance, responding to requests, and assessing or offering
promotions. • Other companies BCD M&E uses to support its
business who provide ancillary services (e.g. fulfillment, surveys,
storage, statistical analysis, technology, development, credit checks
(as applicable)). • Your Company for meeting and event-based
reporting, auditing, tracking and other purposes as necessary with your
Company, including those of its personnel they request we send or make
personal data available to. • Third party service providers you or
your Company request we send personal data to (e.g. App companies, that
provide an event app; congress registration providers; safety and
tracking information providers; other travel management companies or
event agencies; transfer/ground transportation companies; convention
bureaus, successor organizations). • Third party service providers
to complete travel and attendee arrangements and reservations and
fulfill the Services (e.g. Global Distribution Systems (GDSs); airlines,
trains, rental car and other ground transportation companies, hotels,
cruise lines, destination management companies, and other related
meeting and travel suppliers for booking/ticketing purposes; industry
reporting authorities; equipment and technology vendors, including,
without limitation, online booking tool providers, meeting registration
software providers (including onsite and mobile event management
solution providers), and audio visual companies; visa and passport
providers; credit card companies and payment collection and processing
companies). • Other third parties as we believe is reasonably
necessary in accordance with applicable laws, including laws outside
your country of residence to: (i) satisfy laws, regulations, or
governmental or legal requests and processes; (ii) identify, contact, or
bring legal action against someone who may be violating our terms of
use or policies or otherwise enforce our terms and policies; (iii)
operate the Services properly; or (iv) protect BCD M&E and those it
serves, including pursuing available remedies or to limit damages that
may be sustained (e.g. exchanging information with other companies and
organizations for the purposes of fraud protection and risk reduction).
Data
consolidation companies may also be used by BCD M&E or your Company
for the purpose of creating reports and related statistics for
benchmarking or other related purposes, including, without limitation,
utilizing cumulative statistical data, which may incorporate data
acquired from your Company for ordinary business purposes customary in
our industry and the Services we provide, but without identifying,
directly or indirectly, you or your Company.
BCD M&E may be
acquired, merge with another business, sell, or liquidate its assets,
acquire, or buy other businesses or assets. In such transactions,
personal data is generally one of the transferred business assets. In
the event of an acquisition, sale, liquidation, or merger, your personal
data and non-personal identifying information may be automatically
assigned by us in our sole discretion to a third party, in accordance
with applicable laws.
Does BCD M&E disclose personal data across borders? BCD
M&E is a global company that provides event management related
services and therefore, transferring your personal data internationally
is necessary for the provision of our Services. When sharing with or
disclosing personal data to other parties, including to BCD M&E’s
related companies, affiliates, subsidiaries, joint ventures, partners,
subcontractors, and agents who provide Services and maintain facilities,
your personal data may be transferred to countries with data protection
laws providing a lower standard of protection for your personal data
than your country.
We will transfer your personal data in
compliance with applicable data protection laws, including having
adequate mechanisms in place to protect your personal data when it is
transferred internationally (e.g. Model Clauses, data protection
agreements). If you have questions or wish to obtain more information
about the international transfer of your personal data or the
implemented safeguards, please contact us as provided in this Policy.
How does BCD M&E store and protect personal data? Typically,
BCD M&E stores personal data on its servers managed internally
(mainly in the European Economic Area and the United States) and with
third party storage providers. BCD M&E uses appropriate
technical and organizational security measures to protect the personal
data BCD M&E holds on its network and systems from unauthorized
access, disclosure, destruction, and alteration. We conduct periodic
reviews of our data collection, storage, processing, and security
measures to verify we are only collecting, storing, and processing
personal data that is required for our Services and to fulfill our
contractual obligations. While we make every effort to protect the
integrity and security of our network and systems, we cannot guarantee,
ensure, or warrant that our security measures will prevent illegal or
unauthorized activity related to your personal data. When using our
Services, you should be aware that no data transmission over the
Internet can be guaranteed as totally secure. Although we strive to
protect your personal data, we do not warrant the security of any data
and information that you transmit to us over the Internet and you do so
at your own risk.
In order to protect your personal data, we
kindly ask you to not send credit card information or other similar
sensitive personal data, including special categories of personal data,
to us via email. We also encourage you to keep your password
confidential and not disclose it to any other person. If you are sharing
a computer with anyone you should log out before leaving a website or
service to protect access to your password and personal data from
subsequent users. Please alert us immediately if you believe your
password or any of your personal data has been misused while using BCD
M&E Services and applications. Please note, we will never ask you to
disclose your password or credit card information in an unsolicited
phone call or email.
How long does BCD M&E keep my personal data? BCD
M&E retains personal data for the period necessary to fulfill the
purposes outlined in this Policy, unless a longer retention period is
required or permitted by applicable law. When determining how long to
retain personal data, we take into account the necessity of the personal
data for the provision of our Services, applicable laws and
regulations, including data protection laws, and our legal obligations.
We may retain records to investigate or defend against potential legal
claims. When retention of the personal data is no longer necessary, the
data will be deleted or aggregated for analytic purposes.
What about BCD M&E applications? BCD
M&E makes available its online applications (mobile and web based)
for download from various application marketplaces. BCD M&E collects
usage information for us to improve the application and to deliver a
better and more personalized experience. BCD M&E may follow
information on your use of our applications (e.g. anonymized statistics
on the daily number of visitors, the daily requests for specific usage
elements, tracking interest, who has posted content, the countries from
which applications and Services are accessed). We use these statistics
exclusively for measuring activities and for improvement or adaptation
of Services for your benefit. We may also use Google Analytics or other
analytics tools and methods to develop anonymized user statistics as
described in our Cookie Policy (https://www.bcdme.com/cookie-policy/).
BCD M&E uses such statistics for the analysis of activities, the
improvement of Services, communicating findings and product improvements
to your Company and other BCD M&E clients and prospective clients.
Such statistics do not contain personal data and cannot be used for the
collection of personal data. In accordance with the applications’ terms
of use, certain information about you (which may include your email
address, itinerary data, and other information you provide voluntarily)
may be shared with third parties as stated in this Policy. Please note
that once you leave BCD M&E websites and applications for others,
including, but not limited to, virtual assistants or other applications,
the privacy policies of the other websites or applications shall apply.
What about links to third party websites and services? Our
Services may contain links to third party websites. Some of these
websites may allow you to purchase products and services, register to
receive materials, or receive new product and service updates. In many
cases, you may be asked to provide contact information such as your
name, address, email address, phone number, and credit/debit card
information. If you use these third-party websites and/or provide your
personal data and information, the privacy policy and terms of service
on those websites are applicable. We encourage you to carefully read
such policies on third party websites before submitting your personal
data. BCD M&E is not responsible for and expressly disclaims any and
all liability related to the actions of such websites, their privacy
policies, or the terms and content of such websites.
How does BCD M&E handle “do not track” requests and use "Cookies" and other similar technologies? We
do not currently commit to responding to browsers “do not track”
signals with respect to BCD M&E websites and applications. We
process your personal data through our websites and applications in
accordance with this Policy, irrespective of your tracking settings.
We
may automatically collect information using “cookies”. You may choose
to refuse cookies in your browser (please refer to the “Cookies” link
below) however, that may limit your ability to receive some or all of
our Services and/or some features may not be available to you or may not
function properly as a result. Where required under applicable law, BCD
M&E will obtain your consent prior to collecting information by
using cookies. Additional information on “Cookies” and how the BCD
M&E website uses them can be found here
https://www.bcdme.com/cookie-policy/.
Does BCD M&E collect personal data of children? BCD
M&E does not knowingly collect personal data from children.
Individuals under 18 years of age should not use our Services to submit
any personal data about themselves.
What are my rights with respect to my personal data? You
may choose what personal data (if any) you wish to provide to us.
However, if you choose not to provide certain details, your experience
with some or all of our Services may be affected.
To the extent
required by applicable law, you have the ability to exercise various
rights with regard to your personal data (i.e. access, correction,
erasure, restriction, objection, portability, etc.). BCD M&E will
handle such requests in accordance with applicable law, including in the
time specified by applicable law and where permitted by applicable law,
may charge a reasonable administrative fee to cover the costs of
responding to any such request. Where processing is based on consent,
you have the right to withdraw consent at any time if required by
applicable law, without affecting the lawfulness of processing based on
your consent before your withdrawal.
In some jurisdictions, in
addition to you agreeing to this Policy, data privacy or protection laws
may require us to obtain a separate express consent for processing of
your personal data. Your consent may also be implied in some
circumstances, as permitted by applicable law, such as when
communications are required to fulfill your requests. How can I exercise my rights or make complaints? If
you wish to exercise any of your rights as described in this Policy,
you (or, in accordance with applicable law, someone on your behalf), can
submit your request by clicking here.
If you have any questions about this Policy, you can contact BCD M&E’s Data Protection Officer as follows:
Attn: BCD Travel Services B.V., Legal Department Address: Europalaan 300 City/State/Zip: 3526 KS Utrecht, The Netherlands Email: privacy@bcdtravel.com
BCD
M&E will respond to your request via the email address you use to
exercise your request, the phone number that you have registered with us
or we otherwise have on file for you, or any other suitable method.
Depending on your request, we may review the request with you and/or
your Company to assist in resolving and responding to the request.
We
are committed to working with you to obtain a fair resolution of any
complaint or concern you may have about our use of your personal data.
If, however, you believe that we have not been able to assist with your
complaint or concern, you may have the right to make a complaint to the
data protection authority in your country (if one exists in your
country).
How are changes to this Policy handled? BCD
M&E reserves the right to revise, amend, or modify this Policy at
any time and in any manner. When we post changes to this Policy, we will
update the "last updated" date at the top of this Policy and we
encourage you to regularly check this Policy for changes. |