Privacy Policy
Why do we collect personal data?
This Privacy Policy explains how In2Scotland [TTCE] uses personal information. TTCE is a travel and destination management company which provides travel services, meetings and events services to corporate and private clients. TTCE collects personal information from the Clients’ travellers, from participants at Client meetings & events organised by TTCE, and from the users of TTCE websites. The purpose of this information collection is for TTCE to provide these services.
What information do we collect?
When servicing a given Client, an electronic ‘Traveller Profile’ is created in TTCE’s proprietary tool for each traveller. The personal information is entered through feeds from the clients or by the traveller (or the authorised travel arranger). The personal information that we collect for each traveller may include: name, gender, date of birth, address, phone numbers, email addresses, travel destinations, travel schedules, travel preferences (seat, meal, smoking, etc.), passport and visa details. If a ‘master profile’ is
created by an online booking tool service provider (OBT), TTCE receives the profile information from the OBT and a profile is automatically created in our tool to enable the consultant to fulfil traveller’s requests. When organising a meeting or event for a Client, TTCE collects personal information to register the participants to the meeting or event through tools that may be selected by the Client or receives lists of participants from the Client. TTCE collects personal information from users to its websites through the use of online forms and when the user emails TTCE his/her details. TTCE forwards these user requests to the appropriate TTCE team member to respond to the user.
How we process personal information
In addition to creating Traveller Profiles and ‘passenger name records’ (PNRs), TTCE uses the personal information (usually the PNR) of the traveller for the following travel and other travel-related purposes. Reservations: The Traveller Profiles are stored in a database as a reference document to be consulted each time a reservation is to be made. When a reservation is made, TTCE creates a PNR that contains all of the personal information along with the reservation information that is needed to fulfil the travel request of a traveller and to fulfil regulatory requirements for travel to certain destinations such as the Secure Flight program in the
United States and the Advanced Passenger Information System in several countries such as the UK and China. To make reservations, TTCE needs to transfer personal information to various third party travel suppliers (such as airlines, hotels, car rental companies, online booking tool companies and safety and security tracking providers, as well as computer reservation systems) within the traveller’s home country or in another country where the traveller may be traveling and often also to government bodies for certain destinations such as DHS in the US. Without this information travel will not be possible.
Consolidation of Travel Data: At the request of the Client (the paying party for the travel), TTCE or a third party may prepare information reports that summarise and analyse the travel expenditures per destination, per travel supplier, etc. Such reports may include certain personal information from the traveller’s profile.
Transfers to Third Parties at Corporate Client’s Request: TTCE may transfer personal information to third parties at the request of the Client, for example for information consolidation or emergency traveller tracking services. These transfers could involve transfers of personal information to other countries.
Transfers within the TTCE group: Transfers are made throughout TTCE, joint ventures and international partners to support travel-related services such as emergency online booking services, airline ticket issuance and technical help-desk requests, and for screening where required for compliance with the law.
Transfers to TTCE service providers: Transfers are for TTCE to obtain support services in connection with the travel and meetings & events services to its clients (such as administrative, information technology and technology platforms for TTCE tools, telecommunications, payment services).
Regulatory transfers: TTCE may be required by law to transfer information to governments and law enforcement agencies where required.
Compliance with Travel Policy: At the request of the Client, TTCE may report on the compliance of the travellers with the travel policy of the Client and identify any exceptions to the compliance.
Collecting Travel Payments: TTCE may transfer personal information to third parties in the traveller’s home country or to another country for the purpose of collecting payments related to travel reservations.
TTCE Databases: The electronic Traveller Profiles that TTCE maintains are stored in a central database. For clients using an OBT provider, the personal information may be stored by these third-parties.
New Products and Services: With the goal of improving service and based on the information given to TTCE, the company may send additional information to the traveller if it applies to his/her trip or in advance of future trips. An example might be a list of restaurants near a specific hotel in the destination city or parking at the departure airport.
Application of the Policy
Transfer to Third Parties: TTCE requires third parties processing EU traveller’s personal information to meet the standards of data privacy laws in the EU.
Security: TTCE has implemented appropriate technical and organisational measures to protect the personal information obtained from our Clients’ travellers against accidental or unlawful disclosure or destruction.
Retention and Deletion: TTCE keeps personal information only as long as required to fulfil the services requested by its Clients. TTCE may need to keep certain information to comply with financial reporting laws or to inquiries from Clients on past travel activities.
Travellers’ Rights of Access
The traveller has a right of access to his/her personal data. The traveller can update his/her Traveller Profile. To contact TTCE with questions or issues about TTCE’s information processing, the traveller may contact angelina.fairgrieve@ttce.com.
Dispute resolution: Any questions or concerns regarding the use of disclosure of personal information may be directed to angelina.fairgrieve@ttce.com. TTCE will investigate and attempt to resolve complaints and disputes regarding use and disclosure of your personal information.
This policy is subject to change. The changes will be posted on our website.
