Trans-Europe Express LLC.
(Effective June 2018)
Our Privacy Commitment:
Summary of Material Provisions:
Collection of Data:
We collect Personal Data about you and travelers on whose behalf you are booking Services. This Personal Data is either obtained from data you provide to us directly or that we obtain in connection with your use of our Services.
Use of Collected Data:
We use the Personal Data we have collected to provide our Services to you, to upgrade and enhance our Services to you and others, to communicate with you about the Services you have elected to receive, and to market our Services by sending and placing advertisements, marketing material and additional offers that we believe may be of interest to you.
Sharing of Data:
In order to provide our Services, we share Personal Data with third party service providers, such as hotels, tour and excursion providers, rail and cruise operators, and visa procurement facilitation providers, among others, all as necessary to ensure that you receive the Services you have requested.
For all Personal Data we collect, we have deployed reasonable and current safeguards, using technical, administrative and physical means, to prevent unauthorized access, ensure that Personal Data is only used for its intended purposes, and to prevent unauthorized access to such data.
You may control how we use Personal Data collected from you for purposes of marketing to you, whether online or via email or otherwise.
As a data subject, we understand you may want to access, modify and/or delete some or all of the Personal Data we have collected about you. You may do so by contacting us at email@example.com.
We take the privacy of children very seriously. None of our Services are directed to anyone under the age of 18 and access and use of our Services by individuals under the age of 18 is strictly prohibited.
Information We Collect:
Personal Data We Collect
We collect Personal Data in connection with your use of our Services, both directly through your own input and indirectly through your use of our Services. We may also obtain Personal Data about you whenever you purchase services from third parties with which we have a relationship to provide some or all of our Services, such as Booking.com, Expedia.com, and Agoda.com (collectively, our “Third Party Partners”). The Personal Data we may have access to, obtain, retain and use may include your name, address, telephone number, email address, passport number, credit card number, age, date of birth, gender, username and password for our Website, other banking information, accommodation details, including accommodation name, location and length of stay, as well as all other Personal Data necessary or useful in connection with any reservations and requests made through our Services. We collect this Personal Data primarily to provide our Services to you, such as booking reservations for hotels, tours, excursions, river cruises, and rail tickets through our Websites and the provision of our Visa Facilitation Services, but also to show you additional advertisements and offers we think will be of interest to you, and as necessary to detect and prevent fraud, to ensure the safety and security of our Services, to protect and defend our rights and the rights of others, and to comply with all applicable laws and regulatory requirements, as well as court orders, and legal process.
Non-Personal Data We Collect
How we use your information:
We use Personal Data and Non-Personal Data, including using and sharing such data (1) to deliver our Services to you, to contact you about such Services, or to assist our Third Party Partners with the delivery of their products and services to customers, potential customers and other individuals, such as you; (2) to enable third party service providers to assist or facilitate the Services we provide our clients, including specifically reservation booking services and visa facilitation services; (3) to comply with applicable laws and regulations; (4) to respond to a subpoena, search warrant, or other lawful request for information that we may receive from time to time, regardless of whether such a response is required by applicable law; (5) to enforce our terms of service or to otherwise protect our rights; (6) with vendors, technology providers, administrative service providers, and third party partners we have selected for purposes of validating data, enhancing data, verifying information, and suppressing information in some circumstances, such as credit card processing partners; (7) with other Trans-Europe Express entities, affiliates, and third party marketing partners for marketing purposes; (8) to protect the safety of the public and other users of our Services; (9) to transfer the Collected Information (or any portion of the Collected Information) to a third party in connection with a business transition or combination, such as a merger, acquisition, or asset sale involving Trans-Europe Express or any of our Services; (10) to advertise and market our Services; (11) to improve our Services; and/or (12) for any other purposes for which you provide consent. We also may share Collected Information with other third parties for purposes of marketing. Generally, we will retain your Personal Data for no more than two (2) years following the date of completion and fulfillment of a transaction booked through our Website, though typically such Personal Data is retained for no longer than it is needed, which is usually about nine (9) months.
Our Data Sharing Practices:
Our Third Party Partners
By using our Services to book hotels, tours, excursions, cruises, rail passage and visa facilitation services, we may provide your Personal Data to the applicable Third Party Partner providing such service. Please refer to the websites of such Third Party Partners to review their respective privacy policies with respect to their use of your Personal Data and other information about such Third Party Partners.
Third Party Agents
Future Business Transfers
Compliance with Law and Other Disclosures
Trans-Europe Express reserves the right to release Personal Data in order to comply with applicable law and when we believe that disclosure is necessary to comply with a judicial proceeding, court order, or legal process served on us. We may also release Personal Data to enforce or apply the terms and conditions applicable to our Services, protect us or others against fraudulent or inappropriate activities, or otherwise protect the rights, property or safety of Trans-Europe Express, our affiliated companies, our customers, or others.
How we store and protect the information we receive:
Trans-Europe Express stores Personal Data and non-Personal Data in a database on computers owned, leased or licensed by us, including from Digital Management Partners, LLC (Gigenet) and OOO Express, which are located within the United States and Russia, respectively. All Collected Information is maintained and stored on our servers in encrypted form and has industry accepted security measures, such as a server firewall, to protect against the loss, misuse, and alteration of the information under our control. We also maintain physical and procedural safeguards to protect Personal Data and non-Personal Data. Notwithstanding the foregoing, we cannot guarantee that our security measures will ensure that Collected Information is not illegally accessed, stolen or altered. As such, your use of our Services if at your own risk. Trans-Europe Express uses 3D Secure for purposes of processing credit card transactions, which uses a Secure Socket Layer (SSL) encryption for transactions processed.
Cookies and Other Tracking Technologies:
There are two classes of Cookies based on how long they remain on your system, including “Session Cookies” which are used only during your visit to the Services and are erased once you close your browser and “Persistent Cookies” which can remain on your browser for up to two (2) years from your last visit to our Services and allow us to remember you on any subsequent visits to our Services and thereby provide you with more relevant content to you via our Services, including remembering your Website preferences, such as language and areas of interest.
The cookies contain no Personal Data. To learn more about Cookies, you can click here or here. To learn about how you can opt out of the receipt of cookies, please click here. To learn about how you can remove cookies placed on your device or prevent the placement of cookies on your device, please see the “Your Choices” section below.
“Device Information” is information we automatically collect and store related to the device you used when you accessed our Services, such as the type of device you are using (e.g., lap top or iPhone), certain device identifiers that are unique to the device you are using, and your internet service provider (ISP).
“Location Information” is information obtained from your device’s global positioning system (GPS) signal, WiFi networks proximately accessible to your device, nearby cell towers, and other available information about your location. When you use location enabled services in connection with our Services, this type of information may be made available to us. However, we do not use Location Information to determine your precise location, but only for general location identification limited to a particular city or zip code.
“Other Technologies Information” refers to information that is now or that may sometime in the future become accessible to us through new technologies and the non-Personal Data you share or otherwise make available to us.
“Pixels” or “Tracking Pixels” are graphic images (usually 1 pixel x 1 pixel) that are placed on a web page and allows for the collection of information regarding the use of the web page where such pixel is placed. Trans-Europe Express uses third party ad servers to support tracking pixels and cookies.
“Beacons” is programming code used to display an image on a web page and can also transfer an individual’s user identification to a database and associate the individual with previously acquired information about the information. Web beacons enable Trans-Europe Express and its Third Party Partners to track certain websites you visit or advertisements you view online across different websites over time. Web beacons help determine products or services in which you may be interested and help track online behaviors for marketing purposes. You can learn more about web beacons here.
We work with third-parties that place cookies on our Websites to provide their services, including:
- Data Providers: We also allow data providers to collect web log data from you (including IP address and information about your browser or operating system), when you visit our Websites, or place or recognize a unique cookie on your browser to enable you to receive customized ads or content. These cookies contain no personally identifiable information. The cookies may reflect de-identified demographic or other data linked to data you voluntarily have submitted to us, e.g., your email address, that we may share with data providers solely in hashed, non-human readable form.
- Analytics/Measurement: We also use third-party analytics cookies to gain insight into how our visitors use the Website, to find out what works and what does not, to optimize and improve our Websites and to ensure we continue to be interesting and relevant. The data we gather includes which web pages you have viewed, which referring/exit pages you have entered and left from, which platform type you have used, date and time stamp information, and details such as the number of clicks you make on a given page, your mouse movements and scrolling activity, the search words you use and the text you type while using our Websites. We also make use of analytics cookies as part of our online advertising campaigns to learn how users interact with our website after they have been shown an online advertisement, which may include advertisements on third-party websites.
- Remarketing Pixel Tags and other technologies: In addition, we may share usage information about visitors to our Websites with third-party advertising companies for the purpose of managing and targeting advertisements and for market research analysis on our Websites and other sites. For these purposes, we and our third-party advertising companies may place or recognize a cookie on your computer, device or directly in our emails/communications or may place pixel tags (also called clear gifs) on some of the pages you visit on our Websites. We will then use the non-personally identifiable information that is collected using these pixel tags to serve you relevant advertisements when you are visiting other sites on the Internet. These advertisements may be targeted to specific searches you conducted on Trans-Europe Express during earlier browsing sessions.
- Flash Cookies: Our partners, who provide certain features on our site or display advertising based on your browsing activity, also use Local Shared Objects such as Flash cookies, and Local Storage such as HTML5, to collect and store content information and preferences. Various browsers may offer their own management tools for removing HTML5 local storage. To manage Flash cookies, please click here.
The chart below provides opt out options with respect to third party cookies and targeting based on the data collected by such cookies.
|Served by:||Opt-Out Options|
While you can opt out of receiving advertisements based on the information collected by such third party cookies, as specified and/or by the relevant third party with respect to third party cookies, you cannot opt out of or otherwise block the placement of advertisements based on the choices you make with respect to cookies.
To opt out of all online behavioral advertising, please visit the YourOnlineChoices website.
Please note, however, that this may make it impossible for Trans-Europe Express to include you in some of its advertising campaigns. Trans-Europe Express’ cookies will be known as third party cookies. If you have multiple internet browsers or users on the same computer or device, you will need to select an option which stops cookie-based targeting and repeat this for each browser, device and/or user. Please note that your cookie preferences are stored in a cookie, and deletion of your cookies may override this.
To disable the collection of usage information on your mobile devices you will need to change your device settings - “Opt-out of Interest-Based Ads” on Android devices and “Limit Ad Tracking” on iOS devices.
You have control regarding our use of your Personal Data for direct marketing. Specifically, and where required by law with your prior consent, we may contact you to advertise our Services or solicit feedback regarding our Services. If you would like to prevent Trans-Europe Express from using your Personal Data for these purposes, you will be able to do so when placing an order on our Website.
However, if you are unwilling to provide us with the ability to collect, use, process, and share your Personal Data and non-Personal Data your ability to use our Services will be severely limited and, in some cases, you may not be able to use our Services at all.
Trans-Europe Express Email Choices: With respect to any Trans-Europe Express email lists you have subscribed to, whether directly through the Services or on the websites or mobile applications of our partners, including our Third Party Partners, you can opt-out of future emails by clicking the link included in the footer of any message you receive or otherwise follow the instructions provided. Even after you have unsubscribed, we may continue to use Personal Data collected prior to your opt out.
Third Party Cookie Choices: With respect to cookies, your web browser should provide you with information on how to prevent the placement of, or how to remove, cookies placed on your computer by Trans-Europe Express. Trans-Europe Express also works with its partners to serve cookies. The chart below provides your opt out options with respect to those third party partner cookies and the advertising targeted via those cookies:
|Third Party Partner||Opt-Out Options|
While you can opt out of receiving advertisements based on the information collected by such cookies, you cannot opt out of or otherwise block the placement of advertisements.
You can also visit youradchoices.com to review your opt out choices with respect to many of these third party partners.
Please note that if you have multiple internet browsers on the same computer or device, you may need to undertake the opt out operation for each browser, device and/or user. If you or your privacy / security software deletes the opt-out cookie from your computer, browser or device, you will need to undertake the process noted above again.
Trans-Europe Express Mobile Application Choices: You can choose to opt out of the collection and usage of data from mobile applications using the settings within such mobile applications. You can also generally opt out using your device settings by selecting “Opt Out of Interest-Based Ads” on Android devices and “Limit Ad Tracking” on iOS devices.
Trans-Europe Express Location Tracking Choices: You can update your location preferences on your device generally, or you can block the collection of location data altogether by updating the settings for individual applications.
Trans-Europe Express Multiple Device and Browser Choices: To the extent we use cross-device mapping services in order to link devices that belong to the same user or household, users can opt out of the collection of information for each device by taking the steps set forth above. For clarity, an opt out for one device is not an opt out for all devices, even if those devices are linked for advertising purposes. As such, you may need to opt-out of multiple devices and browsers.
Accessing and Controlling Your Personal Data
If you would like to change, access or delete your Personal Data. You may do so by accessing your profile on our Websites or by contacting us at firstname.lastname@example.org. In most cases we will need to validate your identify before providing you access to your Personal Data, allowing changes to such Personal Data or honoring any request to delete such Personal Data. Once validated, Trans-Europe Express will respond to your requests within thirty (30) days of receipt. To the extent your use of our Services is through a username and password protected login on our Websites, you will need such username and password to access your information.
Depending on the jurisdiction in which you reside, you may have specific rights under local legislation to: (i) request access to your Personal Data; (ii) request modification of your Personal Data; (iii) request deletion of your Personal Data; (iv) request restriction of processing of your Personal Data; (v) request data portability; and/or (vi) object to the processing of your Personal Data. Contact us at email@example.com if you have questions or would like to exercise such rights.
We will retain your information for as long as your account is active or as needed to provide you Services. In addition, we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Cross-Border Data Transfer:
Information collected by third parties:
We are not responsible for the actions or omissions of third parties in any way, including with respect to any information they receive directly or indirectly from you or from us. If you believe that any party who claims association with Trans-Europe Express is improperly collecting or using information about you, you should contact them directly. You may also notify us by emailing us at firstname.lastname@example.org, though we maintain no responsibility to reply to such correspondence or to take any action in connection with such correspondence. Our Services may also link to third party websites and offerings, including plugins appearing on our Websites, over which we exercise no control. Under no circumstances is Trans-Europe Express responsible for the privacy practices or the content of such third-party websites and offerings, including their information collection, storage, usage and sharing practices. Please contact such third parties in connection with any issues you may have with respect to those third-party websites and offerings.
Your representations to us:
Trans-Europe Express is very sensitive to the issue of the privacy rights for children. We comply with the Children’s Online Privacy Protection Act (COPPA). For more information about COPPA and children’s privacy, please click here. When we use the term “parent” below, we mean to include legal guardians. Our Services generally are neither developed for, nor directed at, children. Trans-Europe Express does not knowingly collect, use or disclose Personal Data from children under the age of 13 without prior parental consent or in accordance with applicable law. Our Websites are not intended for use by anyone under the age of 18 and any such use is prohibited.
California Privacy Rights Under California Civil Code Section 1798.83
California Civil Code Section 1798.83, known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us a list of what Personal Data (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. To make such a request, please contact us at email@example.com. For all requests, you must put the statement "Your California Privacy Rights" in the body of your request, as well as your name, street address, city, state and zip code. In the body of your request, please provide enough information for us to determine if this applies to you. You need to attest to the fact that you are a California resident and provide a current California address for our response. Please note that we will not accept requests via the telephone, mail or by facsimile, and we are not responsible for notices that are not labeled or sent properly or that do not have complete information.
Effective Date: June 2018