T. Global Partners, Inc. Privacy Policy

Effective date: April 1, 2019

T. Global Partners, Inc. (“us”, “we”, “our” or “T. Global Partners”) respects your privacy and is committed to maintaining your trust and confidence. We believe that you should know how your information is used and collected, and we appreciate that you trust us to do so carefully and sensibly.

This Privacy Policy sets forth our current privacy practices and explains the information we collect when you visit the online website operated by us, http://www.tglobalpartners.com, when you utilize content and functionality incorporating the subdomain “tglobalpartners” (including our email or associated mobile applications), when you operate any other tool whereby personal data or other information is collected by, or on behalf of us, or when you employ our related professional expertise (hereinafter collectively referred to as the “Service”). This page informs you of our policies regarding the collection, use and disclosure of certain personal, proprietary and confidential information when you use our Service and the choices you have associated with such information. By using any of our Service, you unconditionally agree that you have read and understood our Privacy Policy and consent to the collection and use of all information in accordance with this Privacy Policy. This Privacy Policy does not apply to the practices of companies that T. Global Partners does not own or control, or to individuals that T. Global Partners does not employ or manage.

Definitions

Service
Service means all content and functionality utilizing the subdomain “tglobalpartners” (including the https://www.tglobalpartners.com website, any email or associated mobile applications), all direct submissions of Confidential Information to us including your communications with us by telephone or in person for reasons including, but not limited, to making inquiries, your use of any other tool whereby personal data or other Confidential Information is collected by, or on behalf of us, or any other use or reliance on our professional expertise.

Confidential Information
Confidential Information means (a) name, gender, personal and work contact details, business title, date and place of birth, image, nationality, and passport and visa information, biometric information, voice recognition (e.g., Alexa), and facial recognition information; (b) information relative to guest restaurant, hotel or travel information, including, without limitation, preferences, special requests, and any information necessary to fulfil special requests (e.g., health conditions or dietary preferences that require specific accommodation or services); (c) contact and other relevant details concerning the employees of corporate client accounts and vendors and other individuals with whom we do business (e.g., destination management companies, travel agents or hotel sales agents); (d) business records, financial information and other non-public information that our clients or vendors reasonably expect us to safeguard from disclosure to the public, including without limitation, credit card details, payment method details, credit details, and account details and credentials for frequent guest, frequent flyer or travel partner programs; (e) proprietary client information or technology; (f) other critical business assets that could be compromised if not managed properly; or (g) additional information we are required or authorized by applicable laws to collect and process in order to authenticate or identify you or the information you have provided.

Usage Data
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies
Cookies are small text files which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device (computer, tablet or mobile) when you are on the Internet, including on our website.

Data Controller
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Confidential Information is, or is to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Confidential Information and we are subject to the European Union General Data Protection Act (the “GDPR”) in so far as your data was provided to us while you were located in the European Union. For more information on whether the GDPR applies to your personal data, please see https://www.eugdpr.org/.

Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User)
Data Subject is any living individual who is using our Service and is the subject of Confidential Information.

Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Confidential Information
While using our Service, we may ask you to provide us with certain Confidential Information. This information could be used to contact or identify you. Such information may include, but is not limited to:

  • Name, gender, personal and work contact details, business title, date and place of birth, image, nationality, and passport and visa information, biometric information, voice recognition (e.g., Alexa), and facial recognition information;
  • Information relative to guest restaurant, hotel or travel information, including, without limitation, preferences, special requests, and any information necessary to fulfil special requests (e.g., health conditions or dietary preferences that require specific accommodation or services);
  • Contact and other relevant details concerning the employees of corporate accounts and vendors and other individuals with whom we do business (e.g., destination management companies, travel agents or hotel sales agents);
  • Business records, financial information and other non-public information that our clients or vendors reasonably expect us to safeguard from disclosure to the public, including without limitation, credit card details, payment method details, credit details, and account details and credentials for frequent guest, frequent flyer or travel partner programs;
  • Proprietary client information or technology; or
  • Other critical business assets that could be compromised if not managed properly.
  • Additional information we are required or authorized by applicable laws to collect and process in order to authenticate or identify you or the information you have provided

Usage Data
We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device (“Usage Data”).

This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Tracking Cookies
We may collect and use Cookies and similar tracking technologies such as beacons, tags and scripts to track the activities of our Service and to improve and analyze our Service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we may use:

  • Session Cookies. We may use Session Cookies to operate our Service.
  • Preference Cookies. We may use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We may use Security Cookies for security purposes.

Use of Confidential Information, Usage Data and Tracking Cookies
T. Global Partners, Inc. uses the collected data for various purposes:

  • To provide and maintain our Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues

Legal Basis for Processing Confidential Information under the General Data Protection Regulation (GDPR)
If you are from the European Economic Area (EEA), T. Global Partners, Inc.’s legal basis for collecting and using the Confidential Information described in this Privacy Policy depends on the Confidential Information we collect and the specific context in which we collect it.

T. Global Partners, Inc. may process your Confidential Information because:

  • We need to fulfil a contractual obligation with you or to prepare a contract on your behalf
  • To assist in event registrations
  • To provide and charge for goods and services or facilitate services on your behalf, including hotel, restaurant and transportation transactions
  • To deal with any concerns or feedback you may have
  • To inform you of needed information
  • To provide services to you, send you correspondence, and provide notice on important dates
  • You have given us permission to do so
  • The processing is in our legitimate interests and it is not overridden by your rights
  • To comply with the law, including, without limitation, the provision of needed accommodations under the Americans with Disabilities Act (“ADA”)
  • To assist in recovering money you owe to us

Retention of Data
T. Global Partners, Inc. will retain your Confidential Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Confidential Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws, such as information needed for income tax and audit purposes), to resolve disputes and to enforce our legal agreements and policies.

T. Global Partners, Inc. will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

Transfer of Data
Your information, including Confidential Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Confidential Information, to the United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

T. Global Partners, Inc. will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Confidential Information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other Confidential Information.

Disclosure of Data

Disclosure for Law Enforcement
Under certain circumstances, T. Global Partners, Inc. may be required to disclose your Confidential Information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements
T. Global Partners, Inc. may disclose your Confidential Information in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of T. Global Partners, Inc.
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability
  • To assist in the prevention or detection of a serious crime.

Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Confidential Information, we cannot guarantee its absolute security.

Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Data Protection Rights under the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. T. Global Partners, Inc. aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Confidential Information. If you wish to be informed about what Confidential Information we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

  • The right to access. You have the right to request a copy of the Confidential Information that we hold about you.
  • The right of rectification. You have the right to have your Confidential Information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Confidential Information and in certain circumstances, you can ask for the Confidential Information we hold about you to be erased from our records.
  • The right of restriction. You have the right to request that we restrict the processing of your Confidential Information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where T. Global Partners, Inc. relied on your consent to process your Confidential Information.

Please note that we may ask you to verify your identity before responding to such requests.

All of the above requests will be forwarded should there be a third party involved in the processing of your Confidential Information. These rights differ depending upon the location within the world where information was created or shared. The erasure of your information may also be subject to T. Global Partners Inc.’s record retention schedule. Should the data fall within one of the areas where we are under a legal requirement to retain such data for a certain period of time, T. Global Partners, Inc. will retain that data in accordance with its legal obligations. Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply. Should we determine that you are not entitled to exercise that right, we will provide you with the reason(s) for the denial. You may have the right to complain to a Data Protection Authority about our collection and use of your Confidential Information.

Service Providers
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analyzing how our Service is used. These third parties have access to your Confidential Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. For example, we occasionally hire other companies to register for events. We will provide these companies only with the information they need to deliver the services, and they are contractually prohibited from using that information for any other purpose.

Analytics
We may use third-party Service Providers to monitor and analyze the use of our Service. For example, Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of activities such as our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en.

Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services. Similarly, we may offer opportunities to engage in blogs, and social networks, such as Facebook and Twitter that are designed to be visible to other users, including any comments and postings that you make. You should be aware that any personally identifiable information you choose to submit via those media can be read, collected, and used by other participants and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit when you engage in such activities.

Children’s Privacy
Our Service does not address anyone under the age of 18 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Confidential Information, please contact us. If we become aware that we have collected Confidential Information from children without verification of parental consent, we take steps to remove that information from our servers.

Changes to This Privacy Policy
We may update or amend our Privacy Policy from time to time to reflect new or different privacy practices, without notice to you. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “effective date” at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Privacy Shield
T. Global Partners complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. T. Global Partners has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.

T. Global Partners is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). We sometimes provide personal information to third parties to perform services on our behalf. If we transfer personal information received under the Privacy Shield to a third party, the third party’s access, use, and disclosure of the personal data must also be in compliance with our Privacy Shield obligations. We will remain liable under the Privacy Shield for any failure to do so by the third party unless we prove we are not responsible for the event giving rise to the damage.

Individuals with inquiries or complaints regarding our Privacy Policy should first contact us at Privacy@tglobalpartners.com. If an individual has an unresolved complaint or concern that is not addressed satisfactorily by us, that individual may contact our U.S. based third party dispute resolution provider (free of charge), the International Centre for Dispute Resolution/American Arbitration Association (“ICDR/AAA”). Please contact or visit http://go.adr.org/privacyshield for more information or to file a complaint. Individuals may have the option to select binding arbitration under the Privacy Shield Panel for the resolution of a complaint under certain circumstances. For further information, please see the Privacy Shield website at https://www.privacyshield.gov.

Contact Us
If you have any questions about this Privacy Policy, please contact us by email at: Privacy@tglobalpartners.com.