CWT Global Privacy Policy and Notice

The Global Privacy Policy is available in English and in the following languages. Please note that some of these pages are currently being translated.

Last updated November 2019

 

Your privacy matters

CWT Global B.V. and affiliate entities (together CWT) specialize in managing business travel, meetings and events and related products and services around the world for companies of all sizes as well as government institutions and non-governmental organizations.

CWT is committed to respecting your privacy through appropriate protection and management of the personal information collected from our corporate clients and their employees, contractors or guests.

This Global Privacy Policy and Notice describes the personal information we collect, how we use it and share it, in the context of the provision of our services.

Why do we collect personal information?

CWT collects personal information from its corporate clients, their employees, contractors or guests (“travelers and attendees”) for the performance of its commercial agreements and to facilitate travel, hospitality, meetings and events for:

  • the management of travel, transportation and hospitality reservations and bookings;
  • the provision of visa application assistance;
  • the management of meetings and events reservations and bookings;
  • the provision of meeting badges, stationary, catering and audio-visual services;
  • the reporting of corporate client’s travel policy compliance and travel expenses;
  • the provision of corporate client’s travel spend and budget analysis;
  • quality assurance and training purposes;
  • the prevention and detection of fraud;
  • the performance of sanctions screening in order to comply with  international regulations;
  • the management of corporate client relationships, account administration and reconciliation, and corporate client invoicing;
  • the communication of travel information including itineraries, safety alerts and fare optimization, and related help desk support;
  • the communication of satisfaction surveys.

We may also collect contact information to communicate information on CWT products and services as well as process information for internal aggregated statistics on market and corporate client account analysis and business forecasting, on the basis of our legitimate interests.

What personal information do we collect?

We may collect your name, surname, phone number, email and address, country of residence, company name, job title, employee identification number, Internet Protocol address, gender, date and place of birth, payment card information, travel preferences where expressed such as seat, meal, smoking, special assistance services (which may reveal religious beliefs and data concerning health, known as special categories of personal data under European data protection laws), government-issued photo identification documents (passport and identity card), visa details, emergency contact information, ticket number and itinerary details, fare information, frequent flyer information, loyalty card information, information related to traveler requests, audio recordings, to fulfil the purposes listed above in the context of the performance of our business activities.

How do we collect your personal information?

Upon the conclusion of commercial terms of agreement, CWT will collect personal information from our corporate clients about the travelers they wish us to service. Online ‘Traveler Profiles’ will be populated with such information using a CWT’s proprietary tool (called Portrait) where further personal information (such as preferences  described above) may be entered upon account activation by the travelers themselves or their travel arranger using either our online tools or other communication channels. In cases where special categories of personal data is collected, processing is performed upon prior consent notice. Traveler Profile information may also be received from an online booking tool service provider (OBT) if requested by a corporate client.  

When organizing meetings and events, CWT may receive personal information (name, surname, contact details and country of residence) about attendees from our corporate clients. CWT may also receive such personal information through online booking service providers contracted by CWT.

With whom do we share your personal information?

In order to fulfil our business purposes i.e. arrange and manage your travel and hospitality bookings, and in line with travel industry practices, CWT may need to share your personal information with third-party service providers listed below:

  • Travel vendors (airlines, hotels, car rental companies, transportation companies);
  • General Distribution Systems (GDS), which are computerized reservation systems holding real-time inventory (on airlines, hotels, car rental companies, etc…) to enable reservation transactions between travel management companies and travel vendors;
  • Online Booking Tools (OBT), which are online portals displaying airlines and hotels to enable bookings;
  • Safety and security service providers;
  • Card payment companies;
  • From time to time, governmental bodies in accordance with applicable laws.

In order to fulfil our business purposes i.e. arrange and manage your meetings and events bookings, and in line with industry practices, CWT needs to share your personal information with third-party service providers listed below:

  • Travel vendors (airlines, hotels, car rental companies, transportation companies);
  • Providers of conference badges and stationary;
  • Providers of catering services;
  • Providers of audio-visual services.

Our corporate clients also may request us to share traveler or attendee information with designated third-parties of their choice, in connection with the products and services we provide.

Furthermore, CWT uses third-party sub-contractors for the management of its information technology tools and platforms. Such subcontractors may access your personal data but only for, on behalf of, and under the instructions of CWT, and are required to adhere to CWT policies, procedures and processes and to comply with applicable privacy laws.

CWT also reserves the right to disclose your personal data if required to do so by law or in the good faith belief that such action is reasonably necessary to comply with applicable law.

In accordance with the California Consumer Privacy Act, the preceding twelve (12) months, CWT has not sold any personal information.

Do we transfer your personal data outside of your country of residence?

Given the international nature of CWT services, personal data transfers need to be made both internally within the CWT group, its affiliates and joint-ventures, and externally to its global partner network, and other third-party providers (described above).

Where your personal data is transferred to a country which is not governed by a data protection law affording a similar level of data protection than that in force in your country of residence, or to which no adequacy decision has been issued by the relevant European Commission, CWT has taken steps to ensure an adequate level of protection of the transferred data in the country of transfer by entering into appropriate data transfer agreements based on the European Standard Contractual Clauses (also known as European Model Clauses) issued by the European Commission. This enables the safeguarding of your information in the overseas country, and in accordance with applicable laws.

Where do we store your personal data?

Given the international nature of CWT group, we use several locations across the globe for our data storage requirements.

Based on the residency of the traveler, CWT will store Traveler Profile information in CWT’s profile management database either in a data center located in Spain (for European resident data) or in a data center located in the U.S.(for all other resident data). European resident data are then internally transferred to our U.S.-based data center to enable mid and back-office management services including travel reservation consolidation and client reporting.

Storage of financial data is performed on a regional basis on CWT servers hosted in data centers in the U.S., data centers in Spain and data centers in Singapore.

For personal information collected in the People’s Republic of China (PRC), resident data will be stored in the PRC.

How do we ensure your personal data is safe?

We continuously implement and maintain administrative, organizational, technical and physical security measures to ensure the confidentiality, integrity, availability and resilience of our systems that process your personal data.

How long do we retain your personal data?

We will retain your personal data for a period not exceeding that required for the purposes for which they were collected, notably to fulfil our commercial agreements, provide our services, respond to inquiries on travel history and other business activities, comply with our legal obligations such as financial reporting and with limits prescribed by applicable regulations, and to preserve evidence for the management of disputes, claims or litigation.

Compliance with this Policy and data protection laws

CWT is committed to complying with both this Global Privacy Policy and Notice and applicable data protection and privacy laws including but not limited to:

  • The European General Data Protection Regulation (EU) 2016/679 (‘GDPR’);
  • The California Consumer Privacy Act or 2018 (‘CCPA’ taking effect on 1 January 2020);
  • The Brazilian Law No 13.709 of 14 August 2018 Which Provides for the Protection of personal Data and Amends the Federal Law No 12.965 of 23 April 2014 (‘LGPD’ taking effect in early 2020);
  • The Australian Privacy Act 1988 (No. 119, 1988 as amended);
  • The Singaporean Personal Data Protection Act of 2012 (No. 26 of 2012); and
  • The Chinese Cybersecurity Law of 2016, effective 2017 ('the Cybersecurity Law').

Direct-Marketing Data Protection Notice

We may use your personal contact information (name, surname, email, company name, job title, country of residence) to send you direct-marketing communications.

Where you receive a direct-marketing communication from us, it is either because you or your company on your behalf have requested such communication, or because we believe the communication is of interest to you or your company based on the services we provide to you and your company.

In some cases, we will have collected your contact details from publicly available sources or through a third-party with whom you or your company on your behalf have agreed onward sharing.

When you visit CWT websites, you can always elect not to provide us with your contact information. You can still visit most of CWT’s web pages but may be unable to receive our newsletters, to download white papers or be sent information on specific products and services or invitations to events, which necessarily require us to interact with you.

We rely on our legitimate interests to keep you informed on our products and services. However if you no longer wish to receive direct-marketing communications, you can click on the ‘unsubscribe’ link at the bottom of the communication. In this cases, your contact details will no longer be used in that regard.

Where we engage third-party sub-contractors to manage our marketing campaigns, they do so on our behalf and under our instructions, and we ensure they commit to complying with our policies and applicable privacy laws and do not use your data for any other purposes.

CWT shall retain your information so long as you wish to keep receiving our direct-marketing communications and/or to comply with legal obligations, a Court order or regulatory requirements, and to fulfil your request to ‘unsubscribe’ from marketing communications.

Your Rights

You are entitled to several rights in relation to your personal data under application data protection laws. Please note these may vary depending on your country of residence.

You have a right to access and rectify the personal data CWT processes about you. Where pertinent and upon legitimate grounds, you also have a right to erasure (right to be forgotten) of your personal information.

Depending on your country of residence, where relevant and upon legitimate grounds, you may also have a right to restrict, and object to, the processing of your personal information, and also a right to data portability.  

If you wish to exercise your rights, please complete our SAR Form.

Contact Information

To contact CWT with questions or issues about this Global Privacy Policy and Notice, please use globalprivacy@g11h.cn. Depending on your country of residence, you may also have a right to lodge a complaint with your local supervisory data protection authority.

For CWT Employees

In the course of your employment at CWT, we may process your personal information as described above for the purposes of your CWT business travel and meetings & events. For other purposes and processing that relate to your employment, please refer to relevant company policies and notices.

List of CWT Entities

 

This policy is subject to change. The changes will be posted from time to time on CWT websites, so please ensure you check this policy regularly.

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