Effective as of: 8/24/2018
Travel Benefits Card, its affiliates and subsidiaries ("Company," "We," “Us,” and “Our”) respects your privacy and are committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you or that you may provide when you visit the website (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect when you participate in any of our programs:
Information We Collect About You and How We Collect It
We collect several types of information from and about users of our Website, including the following categories of information:
We collect this information:
Information You Provide to Us. The information we collect on or through our Website may include:
You also may provide information, or comments, or photographs to be published or displayed (hereinafter, "posted") on public areas of the Website or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages/you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
The information we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
The technologies we use for this automatic data collection may include:
We may tie information gathered above to personal information you provide to us.
We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
How We Use Your Information and Legal Bases for Processing
We only process your information where it is necessary for:
There may be occasions where we request your consent to process your Personal Information. Where applicable, you may withdraw consent subsequently at any time by contacting us as detailed under Contact Information, below, without affecting the lawfulness of processing based on consent before its withdrawal. For example, we may use your information to contact you about our own and third-parties' goods and services that may be of interest to you. We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria. Information on how to opt-out of interest-based advertising can be found under the section titled Choices on How We Use and Disclose Your Information or by contacting us as detailed under Contact Information.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose personal information that we collect or you provide as described above (How We Use Your Information and Legal bases for Processing) to the following:
To our subsidiaries and affiliates including but not limited to: International Cruise & Excursion Gallery, Inc; ICE Europe, Ltd; Gallery Lifestyles and Cruises S. De R.L. De C.V.; Gallery Intertel Services S. De. R.L. De C.V.; I.C.E. Vacations Asia-Pacific Pty Ltd; ICE Travel Portugal, LDA; and ICE Vacation Center India Private Limited.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. Below are some of the mechanisms available to change control over your information automatically provided when visiting the Website:
We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Digital Advertising Alliance or the Network Advertising Initiative ("NAI") on the NAI's website or by visiting www.AboutAds.info .
Information Sent Abroad
ICE is a global organization and provides global services. In certain circumstances, sharing data cross-border is essential to the services you receive from Us.
I. Special Requirements under EU Data Protection Laws (GDPR):
In order to complete your booking, complete analysis, or for other legitimate purposes we transfer, process and store information about you outside of the EEA on servers located in the United States by Travel Benefits Card and its affiliates located at 2173 Salk Ave, Suite 300, Carlsbad, California 92008. Therefore, your information may be transferred to, stored, or processed in the United States. We will ensure that in terms of Data Security Standards, our systems in the US will have the same level of data protection that is required of our EU affiliate. If we transfer your Personal Information to agencies or third parties outside the EEA, we require similar, binding EU Standard Contractual Clauses, and we monitor compliance with such. Our affiliated or related entities, associates and partners have also agreed to adopt equivalent measures. Copies of these measures can be obtained by contacting Us as detailed under Contact Information below. You may lodge a complaint with the UK Information Commissioner’s Office if you consider that our processing of your Personal Information infringes applicable law.
II. Special Requirements under Mexican Data Protection Laws
In accordance with the requirements of the Mexican Federal Law on the Protection of Personal Information Held by Private Parties (Ley Federal de Protección de Datos Personales en Posesión de los Particulares) (the “Mexican DP Law”), We inform our users and subscribers located in Mexico of Our compliance with the Mexican DP Law. Under Mexican DP Law, We do not need to obtain your consent for the processing of your Personal Information for the purposes that give rise and are necessary for the fulfillment of our relationship (e.g. personal information required in order for you to subscribe to our vacation programs). In case you do not agree with the processing of your personal information for such purposes and as described in this policy, please abstain from acquiring or using our services.
Our Website users and subscribers located in Mexico should note that:
Your Rights to Accessing and Correcting Your Information
You can review and change your personal information by logging into the Website and visiting your account profile page. You have the right to ask ICE not to process your Personal Information for marketing purposes. You also have the right to access Personal Information about you by ICE and to correct inaccurate Personal Information. Please ensure that we have an up-to-date active and deliverable email address for you. In accordance with applicable law, you may also have the right to object to or request restriction of the processing of your Personal Information and to request erasure and to port Personal Information about you.
Access to your Personal Information will be granted in accordance with the requirements of applicable national legislation. The information will be forwarded to you within an appropriate period of time in accordance with applicable law, and where any discrepancies are discovered following your enquiry, we will take immediate steps to validate and, where appropriate, correct our records.
Retention of Data
We will retain your personal information during the term of the provision of the services availed by You only for so long as reasonably necessary for the purposes set out herein, in accordance with applicable laws.
Children Under the Age of 18
Our Website is not intended for children under 18 years of age. No one under age 18 may provide any personal information to Company or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us as detailed under Contact Information, below.
Data Security and Retention
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions provided therewith will be encrypted.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Your Personal Information will be retained only for so long as reasonably necessary for the purposes set out above, in accordance with applicable laws.
Your California Privacy Rights
California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us as detailed under Contact Information.