Legal

Last update 03/03/2023

Privacy Policy (September 2022 - February 2023)

TRAVELPERK is committed to protecting your privacy, which includes the security of your personal data.

This Privacy Policy is only applicable to the processing of personal data that TRAVELPERK carries out as Data Controller. That is, applicable to the following categories of data (as defined below):

  • Visitors
  • Prospects
  • Admins
  • Event attendees

Please note that the personal data of travelers (as defined below) will be processed according to (i) the Data Processing Agreement applicable to TRAVELPERK as data processor and the Customer as data controller and (ii) the Customer’s privacy policies implemented to regulate data processing of their employers and/or contractors. Please refer to our Data Processing Agreement for further information. By contracting the Services, the Customer accepts and agrees to be bound by such Data Processing Agreement.

For clarification purposes, the following definitions apply:

  • Affiliates means any entity that directly or indirectly controls, is controlled by, or is under common control - where control means the ownership of a majority share of the stock, equity or voting interests of such entity- with Customer, or any party with a direct or indirect shareholding or equity interest in Customer.
  • Customer are the companies, entities, and/or organizations who retain TRAVELPERK’s services.
  • Event attendees are individuals who attend presential or virtual events organized by TRAVELPERK.
  • Travelers are the Customer’s employees, directors and, exceptionally, contractors who have a traveler account on TRAVELPERK’s platform linked to a Customer account.
  • TravelPerk means TRAVELPERK, S.L.U.

    In relation to Admin Data, TravelPerk means the TravelPerk group company responsible for the Platform and for providing the Services in Customer’s country/region. Except as otherwise agreed with the Customer in a separate agreement or otherwise:

    For Customers who are located in the United States of America or Canada (including related Affiliates registered in the Platform under the Customer account, regardless of where those entities are located), the contracting entity is TRAVELPERK AMERICA, INC;

    For Customers who are located in the United Kingdom (including related Affiliates registered in the Platform under the Customer account, regardless of where those entities are located), the contracting entity is TRAVELPERK UK IRL LIMITED;

    For any other Customer (including related Affiliates registered in the Platform under the Customer account regardless of where those entities are located) Customer is contracting with TRAVELPERK, S.L.U.
  • Visitors are individuals who merely navigate through TRAVELPERK’s publicly accessible website.
  • Prospects are employees or representatives of a Customer to whom TravelPerk contracts to offer its services and/or who are interested in receiving more information and/or retaining TRAVELPERK’s services on behalf of such company, entity, and/or organization.
  • Admin are the Customers’ employees who act in representation of the Customer and whom have administration rights on TRAVELPERK’s platform. Admins can hire TravelPerk services on behalf of a Customer, upgrade new services, upload Customer travel policies, provide approvals etc.
  • Users are Admins, Prospects and Visitors as well as any other category of data subject to this privacy policy from time to time.

Any other term not expressly defined in this Privacy Policy shall have the same meaning as in the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/ECGDPR (“GDPR”).

TRAVELEPERK is a software as a service (“SaaS”) addressed to companies, entities, and/or organizations seeking to book business travel services and related services always in the context of business travel (hereinafter, referred to as the “Services”).

Minors under 18 years of age shall therefore not be authorized to use the Services or provide any personal data.

Users:

  • warrant that they are of legal age and that all the personal data that provide to TravelPerk is correct, accurate, complete, and updated;
  • warrant that they hold all necessary powers and authorizations to, on behalf of the Customer, provide TravelPerk with personal data for its processing and acknowledge that they shall be liable for any damage that may arise from non-compliance of this obligation;
  • acknowledge that TRAVELPERK’s application is not intended to store or process special categories of data or sensitive personal data (and, therefore, TravelPerk will not ask Users to disclose personal data concerning health, sex life or orientation, racial or ethnic origin, political views, religious or philosophical beliefs and trade union membership, as well as biometric and genetic data). Users shall only disclose special categories of data to TravelPerk when is strictly necessarily for TravelPerk to render the Services.

Users shall be solely liable when including personal data belonging to a third party.

In compliance with GDPR and data protection appliable laws TRAVELPERK informs you of the following:

DATA CONTROLLER
TRAVELPERK, S.L.U., a company duly incorporated pursuant to the laws of Spain, with registered office at Avinguda Catedral 6-8 1ª Planta, 08002 Barcelona (Spain), with Spanish Tax Identification Code (CIF) B-66-484.577, and registered with number B-467263 in the Registry of Commerce of Barcelona, is the entity acting as data controller of your personal data, for the purposes specified below.

Notwithstanding the foregoing, in relation to Admin Data:

For Customers who are located in the United States of America or Canada (including related Affiliates registered in the Platform under the Customer account, regardless of where those entities are located), the entity acting as a data controller of your personal data for the purposes identified in the section "If you are an Admin" is TRAVELPERK AMERICA, INC, with registered office at 3415 S Sepulveda Blvd, Suite 1100, Los Angeles, CA 90034 and company number 46-1832033.

For Customers who are located in the United Kingdom (including related Affiliates registered in the Platform under the Customer account, regardless of where those entities are located), the entity acting as a data controller of your personal data for the purposes identified in the section "If you are an Admin" is TRAVELPERK UK IRL LIMITED, with registered office at Alpha Tower, Suffolk Street Queensway, Birmingham, West Midlands, B1 1TT and company number 03770815.

For any other Customer (including related Affiliates registered in the Platform under the Customer account regardless of where those entities are located) the entity acting as a data processor is TRAVELPERK, S.L.U, with registered office at Avinguda Catedral 6-8 1ª Planta, 08002 Barcelona (Spain), with Spanish Tax Identification Code (CIF) B-66-484.577, and registered with number B-467263 in the Registry of Commerce of Barcelona.

DATA PROTECTION OFFICER
You may contact our Data Protection Officer at TRAVELPERK’s postal address or at the following e-mail address: dpo@travelperk.com.

HOW WE OBTAIN YOUR PERSONAL DATA
We will process the personal data that Users voluntarily provide to us when Users contact us, register on our platform, visit our website, and/or use our Services, as well as the data which is generated in the course of the relationship between the Customer and TRAVELPERK.

We may also obtain your contact and professional information from our partners when you have shown an interest in TRAVELPERK’s products or services, or from websites where you have made available such information publicly.

WHAT TYPE OF PERSONAL DATA WE PROCESS, FOR WHAT PURPOSES, AND ON WHICH LEGAL GROUNDS
The types of personal data that we process, for what purposes, and on which legal grounds depends on whether you are a Prospect, an Admin or a Visitor. The details are outlined below:

IF YOU ARE A PROSPECT

PROSPECTIVE CONTRACTUAL RELATIONSHIP WITH YOUR COMPANY, ENTITY, OR ORGANISATION

TYPE OF DATA:
TRAVELPERK processes the following personal data:

  • Identification Data (first and last name, professional email address)
  • Professional or corporate contact details regarding the company, entity, or organization you work for, collaborate with, or represent
  • Any additional information that you provide in your requests for information
  • Lead in case a Prospect has shown interest on TravelPerk services in a third website

PURPOSES:
We will process your personal data in order to:

  1. manage and process your requests for information relating to our company or our services, or your requests to obtain the services offered by TRAVELPERK on behalf of your company, entity, or organization; and
  2. manage the prospective contractual relationship between TRAVELPERK and your company, entity, or organization.

LEGAL GROUNDS:
The processing of your personal data for this purpose is necessary to take the necessary steps to enter into a contract in relation with such requests and a legitimate interest of our company, expressly acknowledged by applicable data protection legislation.

COMMERCIAL COMMUNICATIONS ON SIMILAR PRODUCTS OR SERVICES

TYPE OF DATA:
TRAVELPERK processes the following personal data:

  • Identification Data (first and last name, professional email address)
  • Professional or corporate contact details regarding the company, entity, or organization you work for, collaborate with, or represent

PURPOSES:
We will process your personal data in order to send commercial and promotional communications your company, entity, or organization – including by electronic means or telephone – regarding TRAVELPERK’S services or products that are similar in nature to those included in your requests, or on which you have requested information or shown an interest. Where applicable regulations allow so, we will send you commercial communications regarding products or services in which your company could be interested.

You may object to receive this type of communications, now or at any time, by clicking the unsubscribe section or by sending a message to personaldata@travelperk.com

LEGAL GROUNDS:
The processing of your personal data for this purpose is necessary to fulfill a legitimate interest of our company, expressly acknowledged by applicable e- commerce and data protection legislation.

TYPE OF DATA:
TRAVELPERK processes the personal data that you voluntarily provide or that is generated in the course of the relationship between your company, organization, or entity with TRAVELPERK.

PURPOSES:
We will process your personal data in order to comply with our legal obligations.

LEGAL GROUNDS:
The processing of your personal data for this purpose is necessary to comply with our legal obligations.

IF YOU ARE AN ADMIN

CONTRACTUAL RELATIONSHIP WITH YOUR COMPANY, ENTITY, OR ORGANISATION

TYPE OF DATA:
TRAVELPERK processes the following personal data:

  • Identification Data (first and last name, professional email address)
  • Professional or corporate contact details regarding the company, entity, or organization you work for, collaborate with, or represent
  • Any other information that is generated in the course of the relationship between your company, organization, or entity with TRAVELPERK

PURPOSES:
We will process your personal data in order to manage the commercial or contractual relationship. This includes:

  • processing your personal data when you hire services on behalf of the Customer
  • answering and process your requests and queries
  • controlling compliance with the terms and conditions of use of the Services) between TRAVELPERK and the company, entity, or organization you work for, collaborate with, or represent.

LEGAL GROUNDS:
The processing of your personal data for those purposes is necessary for the performance of a contract between the Customer and TRAVELPERK.

COMMERCIAL COMMUNICATIONS ON SIMILAR PRODUCTS OR SERVICES AND COMMUNICATIONS REGARDING SERVICES HIRED

TYPE OF DATA:
TRAVELPERK processes the following personal data:

  • Identification Data (first and last name, professional email address)
  • Professional or corporate contact details regarding the company, entity, or organization you work for, collaborate with, or represent

PURPOSES:
We will process your personal data in order to send commercial and promotional communications to your company, entity, or organization – including by electronic means – regarding TRAVELPERK’S services or products that are similar in nature to those retained by the Customer, as well as those included in your requests, or on which you have requested information or shown an interest.

You may object to receive this type of communications, now or at any time, by clicking the unsubscribe section or by sending a message to personaldata@travelperk.com

We will process your personal data in order to send communications to the Customer – including by electronic means – regarding updates, changes and new features on the services retained by the Customer, as well as those included in your requests, or on which you have requested information or shown an interest

LEGAL GROUNDS:
The processing of your personal data for this purpose is necessary to fulfill a legitimate interest of our company, expressly acknowledged by applicable e- commerce and data protection legislation.

The processing of your personal data for those purposes is necessary for the performance of a contract between the Customer and TRAVELPERK.

TYPE OF DATA:
TRAVELPERK processes the following personal data:

  • Identification Data (first and last name, professional email address)
  • Professional or corporate contact details regarding the company, entity, or organization you work for, collaborate with, or represent
  • Interactions held with our customer service (that is, requests made, and your voice in the event that calls are recorded)

PURPOSES:
We will process your personal data in order to monitor the quality of our services.

LEGAL GROUNDS:
The processing of your personal data for this purpose is necessary to fulfill a legitimate interest of our company, expressly acknowledged by applicable e- commerce and data protection legislation.

If calls are recorded, the processing of personal data is also based on your express consent which you grant when you call our customer service.

PARTNERSHIPS

TYPE OF DATA:
TRAVELPERK processes the following personal data:

  • Identification Data (first and last name, professional email address)
  • Professional or corporate contact details regarding the company, entity, or organization you work for, collaborate with, or represent

PURPOSES:
We will process your personal data in order to share it with potential partners if you give your consent.

LEGAL GROUNDS:
The processing of your personal data for this purpose is based on your consent.

IF YOU ARE A SIGNATORY OF A CONTRACT

CONTRACTUAL RELATIONSHIP WITH YOUR COMPANY, ENTITY, OR ORGANISATION

TYPE OF DATA:
TRAVELPERK processes the following personal data:

  • Identification Data (first last name, ID number), signature, professional email address
  • Professional or corporate contact details regarding the company, entity, or organization you work for, collaborate with, or represent

PURPOSES:
We will process your personal data in order to manage the commercial or contractual relationship. This includes:

  • processing your personal data when you hire services on behalf of the Customer
  • answering and process your requests and queries
  • -controlling compliance with the terms and conditions of use of the Services) between TRAVELPERK and the company, entity, or organization you work for, collaborate with, or represent

LEGAL GROUNDS:
The processing of your personal data for those purposes is necessary for the performance of a contract between the Customer and TRAVELPERK.

IF YOU ARE AN EVENT ATTENDEE

MANAGING YOUR REGISTRATION AND PARTICIPATION IN THE EVENT

TYPE OF DATA:
TRAVELPERK processes the following personal data:

  • Identification Data: first and last name.
  • Professional data: job title, work email address.
  • Corporate details regarding the company, entity, or organization you work for, collaborate with, or represent.

PURPOSES:
We will process your personal data in order to manage your participation in the event.

LEGAL GROUNDS:
The processing of your personal data for those purposes is based on your consent.

COMMERCIAL COMMUNICATIONS

TYPE OF DATA:
TRAVELPERK processes the following personal data:

  • Identification Data: first and last name.
  • Professional data: job title, work email address.
  • Corporate details regarding the company, entity, or organization you work for, collaborate with, or represent.

PURPOSES:
We will process your personal data in order to send you information about the products and services offered by TravelPerk and its partners.

LEGAL GROUNDS:
The processing of your personal data for those purposes is based on your consent.

BLOG POSTS ABOUT THE EVENT

TYPE OF DATA:
TRAVELPERK processes the following personal data:

  • Image

PURPOSES:
We will process your personal data in order to publish blog posts about in-person events on the TravelPerk website.

LEGAL GROUNDS:
The processing of your personal data for those purposes is necessary in order to fulfill a legitimate interest of our company.

IF YOU ARE A VISITOR

COOKIES AND SIMILAR TECHNOLOGIES

TYPE OF DATA:
When you interact with our platform or request a demo personal data will be collected by means of cookies and similar technologies. Any personal data generated in relation with the use of cookies (and similar technologies) and information from the log file, including the IP address, the kind of browser, the URLS, the number of clicks and the way in which you interact with links, domain names, landing pages and pages visited.

PURPOSES:
Please consult our Cookies Policy

LEGAL GROUNDS:
Please consult our Cookies Policy

TYPE OF DATA:
TRAVELPERK processes the personal data that you voluntarily provide or that is generated in the course of your with TRAVELPERK.

PURPOSES:
We will process your personal data in order to comply with our legal obligations.

LEGAL GROUNDS:
The processing of your personal data for this purpose is necessary to comply with our legal obligations.

IF YOU ARE A TRAVELER, TRAVELPERK DOES NOT ACT AS DATA CONTROLLER, BUT RATHER AS A DATA PROCESSOR OF THE CUSTOMER (NORMALLY, YOUR EMPLOYER). Your personal data will be processed according to the Data Processing Agreement entered into between TRAVELPERK and the Customer.

SERVICES HIRED BY DIFFEERENT COMPANIES OF A SAME GROUP
When a Customer hires TravelPerk services, it may hire such services on behalf of his company and also on behalf of certain Affiliates.

When doing so, the Customer confirms to be authorized by Affiliates to hire the services and to provide TravelPerk with access to personal data for such purpose. The Customer acknowledges that Affiliates shall in all cases be subject to TravelPerk’s privacy policy and Data Processing Agreement as amended from time to time. The Customer commits to inform Affiliates accordingly.

AUTOMATED DECISION MAKNG
TRAVELPERK does not adopt any decisions that could affect you in a significant manner based solely on automated processing of your data. All decision-making processes of our company related to your requests are conducted with human intervention.

RECIPIENTS
Your data may be disclosed to the following third parties, for the following reasons:

  • Our Partners: insofar as you have shown an interest in one of our Partners’ products or services. This disclosure is necessary in order to fulfill your request;
  • Public Administrations: for compliance with legal obligations to which TRAVELPERK is bound due to its activity, only if requested;
  • Accounting audit companies: for compliance with legal obligations to which TRAVELPERK is bound due to its activity;
  • Interested third parties and their advisors in the context of any corporate operation of TRAVELPERK, or the contribution or transmission of any business or part of business activity, as well as transmitting the same to said third party in the case of execution of the operation. Said data disclosure will be carried out under the legitimate interest of TRAVELPERK consisting in the correct governance of the same;
  • Law Enforcement Agencies: when our company is required to provide information in compliance with a legal obligation;
  • Courts and Tribunals: In the cases provided by Law;
  • Data Processors that need access to your data in order to provide the services that TRAVELPERK has engaged to those providers. The type of providers are the followings: prospective tools, surveying tools, customer care suppliers, acquisition suppliers, hosting suppliers, digital marketing suppliers and TravelPerk affiliates. The required confidentiality and data processing contracts are signed between these providers and TRAVELPERK in order to protect your privacy.

Should TRAVELPERK disclose your personal data to other third parties in the future, it will duly inform you.

INTERNATIONAL DATA TRANSFERS
TRAVELPERK has engaged the services of providers located outside of the European Economic Area (“Third Countries”). These providers have signed the confidentiality and data processing contracts required by the regulations for providers located in Third Countries, applying the guarantees and safeguards necessary to preserve your privacy. Such guarantees and safeguards consist of adequacy decisions of the European Commission, standard contractual clauses approved by the European Commission or other legal mechanisms allowed by GDPR.

In the event that the disclosure to interested third parties and their advisors in the context of any corporate operation of TRAVELPERK involves a data transfer outside of the European Economic Area, this international data transfer will be carried out applying the guarantees and safeguards necessary to preserve your privacy.

For more information on the guarantees of your privacy, please refer to the postal and electronic addresses included in the sections “DATA CONTROLLER” and “DATA PROTECTION OFFICER” of this Privacy Policy.

RETENTION PERIODS
Your personal data will be kept for as long as the relationship with TRAVELPERK continues. Upon termination of such relationship, for any cause, TRAVELPERK will keep your personal data for the entire duration of any and all statutory limitation periods that are applicable to the processing, and for the purpose of proving compliance with our legal and contractual obligations. Once said periods have come to term, your personal data will be deleted or, alternatively, anonymized.

CONFIDENTIALITY
TRAVELPERK is committed to maintain confidential the information that Customers provides while the latter test out our services.

YOUR RIGHTS
You may exercise your rights of access, rectification, erasure and portability, restriction, right to withdraw consent, and/or right to object to the processing, by contacting TRAVELPERK’s at the following email address personaldata@travelperk.com.

Further, should you consider that the processing infringes the data protection regulation or your rights, you may submit a complaint to:

  • Our Data Protection Officer at the postal and electronic addressed (dpo@travelperk.com), or
  • The Spanish Data Protection Authority (Agencia Española de Protección de Datos) via its website or postal address.

CALIFORNIA CONSUMER PRIVACY ACT SECTION
This section supplements this Privacy Policy and applies to California residents only to the extent the California Consumer Privacy Act (CCPA) is applicable to TravelPerk from time to time. For the sake of clarity, the entire TravelPerk Privacy Policy (and not only this section) applies to Californian residents.

California residents may exercise the following rights:

  • Right to request a copy of the personal information we have collected about you or disclosed in the last 12 months (including categories of personal information that we have disclosed about you to third parties for a business purpose and categories of recipients of such personal information). TravelPerk will first verify your identity for such purpose.
  • Right to request deletion: you have the right to request the deletion of personal information we have collected from you (subject to some exceptions).
  • Right to Opt Out to the sale of personal information: you have the right to instruct us not to sell personal information we have collected about you to third parties now or in the future.

For the sake of clarity, TravelPerk does not sell personal data to third parties (as this term is defined in the California Consumer Privacy Act).

You have the right not to receive discriminatory treatment when exercising the rights described above. To exercise those rights please send an email to personaldata@travelperk.com with the subject “California Rights Request”.

As stated in this Privacy Policy, TravelPerk discloses your personal data to third party suppliers hired by TravelPerk who process your personal data following instructions from TravelPerk and for the purposes TravelPerk indicates from time to time.

CHANGES TO THIS PRIVACY POLICY AND THE CALIFORNIA CONSUMER PRIVACY ACT SECTION
We may update this Privacy Policy from time to time and will notify you of said changes and updates as required by law. We will indicate the date that revisions were last made to this Privacy Policy at the bottom of the Privacy Policy. You can always ask TravelPerk for a copy of the previous versions of Privacy Policy.

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