CAREY INTERNATIONAL’S COMMITMENT TO PROTECTING YOUR PRIVACY
For purposes of the EU’s General Data Protection Regulation 2016 (the “GDPR”), the data controller is Carey International, Inc., with offices at 7445 New Technology Way, Frederick, MD 21703.
• What information we collect;
• Who collects and owns the information;
• How we use your Personal Information or disclose it to third parties;
• What choices you have regarding collection, use and distribution of your Personal Information;
• How to access, request, correct, update or erase your Personal Information;
• What kind of security procedures we use to protect the loss, misuse or alteration of information under our control;
• How this policy may be amended.
“Personal Information” is information that would allow someone to identify or contact you, including, for example, your full name, address, credit card number, and telephone number(s) or email address. Personal Information excludes aggregated or anonymized demographic or sensitive information that, by itself, does not identify any one individual.
1. What Information Is Collected.
Carey collects the Personal Information that you provide to us through our Web Site, Services, or Mobile App, our Worldwide Reservations Center, and directly through Carey sales employees. We may collect information in additional ways from Users of our Web Site, as explained in this Section and Sections 2 and 3.
Users may browse through the informational portion of our Web Site without providing us with any Personal Information. However, if you request information or materials from us, we may ask for your contact information, such as your name, email address, company name, postal address, and phone number(s). In addition, we may collect personal information from you when you send us emails or submit other forms of information directly to us. We may also collect personal information from you at other points on our Web Site that state that Personal Information is being collected.
We do not respond to web browser “do not track” signals. If you arrive at our Web Site by way of a link from a third party web site that does respond to “do not track” requests, the recognition of any “do not track” request you have initiated will end as soon as you reach our Web Site.
2. Who Collects Your Information.
Carey owns the Web Site, the Services, and the Mobile App and the Personal Information collected through the Web Site, the Services, and the Mobile App. We may outsource to a third party the hosting and operation of the Web Site. However, such third parties do not and will not have any ownership interest in the Personal Information collected or any right to use the Personal Information apart from the operation of our Web Site. For Personal Information we receive from third party reservations agents, systems or centers, Carey owns, jointly owns, or has the appropriate licenses to use such information. Because Carey is not responsible for the privacy practices of third parties, you should check with the third party who initiated your reservations to determine its respective privacy policies.
3. How We Use Your Information or Disclose It to Third Parties.
Delivery of Service - We use the Personal Information collected through our Web Site, Services, or Mobile App to administer and deliver our services. In connection with the delivery of our services, we may share the Personal Information with third-party partners or vendors who help deliver or administer the services, but they are only permitted to use the information in connection with the delivery or administration of our services. For example, we share a Client's credit card information with third-party credit card processing and fraud detection companies, but those companies are not permitted to use the credit card or Personal Information for any purpose other than to assist us to safely and securely fulfill the specific purchase transaction. We may also share Personal Information with Carey subsidiaries, affiliates, licensees, and subcontracted service providers who need that information to provide the services that you have requested. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of EEA Personal Data that we transfer to them.
Carey Sales Promotions and Marketing - We may use the Personal Information collected through the Web Site, Services, or Mobile App to provide you with information or newsletters related to our services, and to promote our services to your company as listed in your profile, where you have provided your consent if required under the applicable law. This may include information and promotions and marketing via email, the Mobile App, postal mail, fax or telephone calls. However, for information that we have collected through your voluntary participation in an online customer survey to obtain your suggestions or comments about Carey International's services, we use such information only for the purpose for which it was collected. We will not use such survey information for direct marketing or disclosure to other companies.
Internal Marketing Research and Reporting - We use non-personal information on an anonymized, aggregated basis for a variety of purposes, including operating and enhancing our Web Site, Services, or Mobile App and our service delivery, internal marketing research, and management reporting. We reserve the right to use and disclose this aggregated information to third parties for any purpose. Aggregate information will not identify any one specific individual.
Cookies - We also use pixels, or transparent GIF files, to help manage online advertising. These GIF files are provided by our advertisement management partners. These files enable our partners to recognize a unique cookie on your Web browser, which in turn enables us to learn which advertisements bring users to our website. The cookie was placed by us, or by another advertiser who works with our partners. The information that we collect and share is anonymous and not personally identifiable. It does not contain your name, postal address(es), telephone number, or email address.
Transfer Due to Corporate Reorganization - We may share, sell or transfer the Personal Information you provide to us in the event of bankruptcy, other reorganization, or the sale or transfer of a division or some or all of our corporate assets or capital stock.
Your California Privacy Rights - California Civil Code § 1798.83 (California’s “Shine the Light” Law) requires certain businesses to respond to requests from California customers who have an established relationship with the business about the business’ practices related to disclosing certain personal information to third parties for the third parties’ direct marketing purposes.
Alternatively, such businesses may implement a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes unless the customer first affirmatively agrees to disclosure (Opt-In).
Carey does not disclose Personal Information of customers to third parties for third parties’ direct marketing purposes. In the event we do so in the future, we will not disclose any of your Personal Information to third parties for third parties’ direct marketing purposes unless you consent in advance
4. Controlling the Collection, Use and Onward Transfer of Your Information.
You can control the content of the Personal Information we have collected by following the instructions stated below in Section 5. In addition, if you do not want to receive marketing materials or communications from us or, subject to Section 5, do not want your contact information disclosed to third parties apart from the delivery or administration of our services, you can Opt-Out. You may withdraw or Opt-Out at of allowing us to share your Personal Information for marketing materials or communications at any time during your business relationship with Carey. You begin the process to Opt-Out of receiving marketing materials or communications from us at Opt-out@Carey.com.
In any event, we only share your Personal Information with third parties in limited circumstances where:
• Access, use, preservation, or disclosure of Personal Information is reasonably necessary for Carey to detect, prevent or remedy security or technical issues, or suspected or actual fraudulent or illegal activity; to satisfy any applicable law, regulation, public authorities, ordinance, matters related to national security, or legal process, including government investigation; or to protect the rights of Carey, our clients, or other individuals, as required or permitted by law.
Please note that if you provide any information on your own or directly to third parties who may be linked to, or otherwise connected with, our Web Site, different rules may apply to their use or disclosure of your Personal Information. We encourage you to investigate and ask questions before disclosing information to third parties.
5. Accessing, Requesting, Correcting, Updating and Erasing (‘Right to be Forgotten’) Your Personal Information.
You can access, update, restrict, erase or transfer your Personal Information through Carey’s Web Site by logging into your Carey or Embarque account through the Profile and Settings functions on the Mobile App, by contacting us at Privacyinfo@Carey.com, or by calling Carey’s Worldwide Reservations Center. However, for verification and security purposes, before we allow you to access, update, restrict, erase or transfer, you may be asked to provide us certain Personal Information. You may also request that we provide to you certain information related to your business relationship with Carey by contacting us at Privacyinfo@Carey.com or by calling Carey’s Worldwide Reservations Center.
6. Our Security Procedures.
We have established and currently maintain security procedures to protect the confidentiality, security and integrity of your Personal Information from loss, misuse, unauthorized access, and disclosure. We use encryption, tokenization, Secure Socket Layers, and firewalls, and we implement off-line efforts to further protect this information, including updating our security practices and privacy policies, privacy and security related training, and limiting employee, agent, and subcontractor access to Personal Information to those who need to know such information to deliver or administer services. In addition, both electronic and paper records containing Personal Information are maintained in access-controlled facilities and access to the information within our secured facilities is limited to only those Carey associates with a legitimate need to access the information in furtherance of providing the services requested by you.
Our Web Site, Services, and Mobile App are maintained in the United States of America. By using the Web Site, Services, or Mobile App, you authorize the exportation/transfer of your Personal Information to the U.S.A. and its storage and use as specified above when you provide such information to us.
We will store your Personal Information, in a form that permits us to identify you, for no longer than is necessary for the purpose for which the Personal Information is processed. We store your Personal Information as necessary to comply with our record retention policy, any legal obligations (which may include the duration of a pending suit, allegation, investigation or claim), resolve disputes, and enforce our agreements and rights, or if it is not technically and reasonably feasible to remove it. Otherwise, we will seek to delete your Personal Information within a reasonable timeframe upon request.
For residents of the European Union:
Carey England Limited
Attn: Data Representative
Manderson House, Commerce Rd,
Brentford, Middlesex, TW8 8LH, United Kingdom
For residents outside of the European Union:
Carey International, Inc.
Attn: Data Representative
7445 New Technology Way
Frederick, MD 21703
8. Dispute Resolution and Enforcement.
Carey has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to JAMS, a non-profit alternative dispute resolution provider located in the United States. In the event of a formal complaint, it is Carey’s policy to contact the individual directly to resolve any concerns. Carey will cooperate with JAMS, free of charge to you, pursuant to the JAMS International Mediation Rules, which are accessible on the JAMS website at https://www.jamsadr.com/eu-us-privacy-shield, if the complaint cannot be resolved through Carey’s internal processes. If you do not receive timely acknowledgment of your complaint, or if we have not addressed your complaint to your satisfaction, please contact or visit www.jamsard.com for more information or to file a complaint. Such JAMS mediation will be held in New York, NY for complaints by individuals in the U.S. and in London, UK for complaints by individuals outside of the U.S.
You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your complaint directly with Carey and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you.
9. Changes to this Policy.