Privacy statement
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Partnership Travel Consulting, Inc.:  Privacy Policy
Version 2.0  February 2014

Introduction
Partnership Travel Consulting, LLC. (“Partnership Travel Consulting”) is committed to protecting the privacy and confidentiality of personal data.  Partnership Travel Consulting has made a decision to voluntarily participate in the safe harbor available to U.S. organizations under the European Commission’s directive on data protection.  This privacy policy explains how Partnership Travel Consulting collects data from its customers, how that data is protected and how Partnership Travel Consulting complies with the requirements of the safe harbor.

Privacy Generally
Partnership Travel Consulting provides data consolidation and analysis services for its corporate customers throughout the world, including some EU countries.  Partnership Travel Consulting enters into written agreements with its corporate customers whereby it provides consulting services regarding corporate travel departments and/or acts as their agent for data management which allows them to evaluate spending history and patterns.  The use of that data is governed by the written contract, and data is not used by Partnership Travel Consulting for any purpose not specified in the contract.  Specifically, Partnership Travel Consulting consolidates expense and purchasing data on behalf of its corporate customers.  Such data is collected from customers or transferred from third parties such as travel agencies, credit card companies and other data consolidators and then transferred only to Partnership Travel Consulting customers’ information systems for their use.  In the event Partnership Travel Consulting contracts with a third party to collect such data, that third party is obligated to subscribes to the safe harbor principles, be subject to the European directive or other adequacy finding, or enter into a written agreement to provide at least the same level of privacy protection as is required by the safe harbor principles.

Website User Privacy
Partnership Travel Consulting currently maintains a publicly accessible website (the "website").  The website does not collect any personal data.  Website users do not receive any unsolicited communications from Partnership Travel Consulting regarding any commercial offers or advertisements at any time.

The website service does not use cookies (small text files a website can use to track the activities of users over time and across different websites).

Users of the website should be aware that links to other Internet sites may be available on the website.  If a user leaves the website and goes to another site, users should be aware that those sites may follow privacy policies that differ from the policies of Partnership Travel Consulting.  Partnership Travel Consulting is not responsible for, and expressly disclaims any and all liability related to, actions of such linked sites, their privacy policies or the content of such sites.

If Partnership Travel Consulting decides to update or modify its website privacy policy, it will post the changes on the website so that users will always have the ability to know what information Partnership Travel Consulting collects, how it uses the information, and under what circumstances it delivers the information.  Continued use of the website after any such changes constitutes acceptance of the new terms.

How Collected Data is Protected
At no point during the data consolidation process does any third party have access to a customer’s data without that customer’s written consent.  In providing data management services, Partnership Travel Consulting affirms that the customer data is the exclusive property of the customer and that Partnership Travel Consulting will abide by the customer’s directions in the treatment of its data.  Partnership Travel Consulting will not use customer data for any unauthorized purpose, including but not limited to reselling the data to any third party.  Notwithstanding the foregoing, Partnership Travel Consulting may transfer data to an entity which acquires all or substantially all of the assets of Partnership Travel Consulting or to an entity providing services to Partnership Travel Consulting and which subscribes to the safe harbor principles, is subject to the European directive or other adequacy finding, or enters into a written agreement to provide at least the same level of privacy protection as is required by the safe harbor principles.

Partnership Travel Consulting has enacted and follows reasonable precautions to safeguard the privacy of customer data, including requiring all employees to sign confidentiality agreements and conducting background checks on new employees.

How Partnership Travel Consulting Complies With the U.S. Safe Harbor
Partnership Travel Consulting complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Partnership Travel Consulting has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Partnership Travel Consulting’s certification, please visit http://www.export.gov/safeharbor/

The European Commission’s directive on data protection, which became effective in October 1998, would prohibit the transfer of personal data to non-European Union nations that do not meet the European “adequacy” standard for privacy protection.  One way U.S. organizations may meet that adequacy standard is by certifying that they adhere to safe harbor principles developed by the U.S. Department of Commerce.  Partnership Travel Consulting is committed to full compliance with the safe harbor privacy principles, as follows:

Notice.  Where Partnership Travel Consulting acts only as an agent for the collection of corporate data, all data transfers occur only upon written direction of the owner of the data, Partnership Travel Consulting’ corporate customer.

Choice.  Acting only as an agent for its corporate customers, Partnership Travel Consulting is not required to provide data subjects an opportunity to choose or opt-out whether the personal information will be disclosed.  However, Partnership Travel Consulting does not use customer data for any purpose incompatible with those authorized in its customer agreements.

Sensitive Information.  Sensitive information, including credit card numbers, is not stored except as directed by the Partnership Travel Consulting customer who owns the data, and is not transferred to third parties except as authorized by corporate customers.

Onward Transfer.  Partnership Travel Consulting will not transfer personal data of its customers except with the written authorization of the company that owns the data, except that Partnership Travel Consulting may transfer personal data to an entity which acquires all or substantially all of the assets of Partnership Travel Consulting or to an entity providing services to Partnership Travel Consulting, but only if such entity subscribes to the safe harbor principles, or is subject to the European directive or other adequacy finding or enters into a written agreement to provide at least the same level of privacy protection as is required by the safe harbor principles.

Security.  Partnership Travel Consulting maintains reasonable precautions to protect personal data from loss, misuse and unauthorized disclosure, alteration or destruction.  Only authorized users, bound by employee confidentiality agreements, have access to such stored data.

Data Integrity.  Partnership Travel Consulting collects only that data authorized by the corporate customer.  Where Partnership Travel Consulting is directed by its customer to transfer data to a third party, Partnership Travel Consulting follows the data masking and confidentiality provisions agreed to by the customer and third party.

Access.  Partnership Travel Consulting will correct, amend or delete any erroneous data if instructed to do so by its customers, subject to the principles of proportionality and reasonableness.

Enforcement.  Partnership Travel Consulting will allow its customers reasonable access, to verify Partnership Travel Consulting’ commitment to adhere to the safe harbor principles, including transferring a sample of data stored on its systems to the customer.  Partnership Travel Consulting will cooperate with the EU Data Protection Authorities and the Department of Commerce to resolve any complaints and disputes arising in connection with its privacy policy.  All Partnership Travel Consulting employees will be required to be familiar with and adhere to this privacy policy.  Partnership Travel Consulting will investigate any reported complaints of violations of its privacy policy and will take prompt remedial action where violations are found.  Dispute resolution provisions in Partnership Travel Consulting’ customer contracts will be followed.

Anti-Corruption PolicyPartnership Travel Consulting has reviewed and supports the United States Resource Guide to the Foreign Corrupt Practices Act (FPCA), and we regularly review the guide and principles of the Act, a copy of which may be found by clicking here

Contacting Partnership Travel Consulting
In order to inquire or complain about Partnership Travel Consulting’ privacy policies or anything related to the privacy of personal information handled by Partnership Travel Consulting, please contact the following individual:  Andrew Menkes, Chief Executive Officer, Partnership Travel Consulting, LLC. (609) 443-8460, email: This e-mail address is being protected from spambots. You need JavaScript enabled to view it