1. INTRODUCTION

The privacy of our clients and travelers is of the utmost importance to Ovation Travel Group, Inc. dba Lawyers Travel (“Lawyers Travel”, “we”, “us”). This Privacy Policy applies to all travel services provided by Lawyers Travel for its clients as well as to the website https://www.lawyerstravel.com (the “Website”) and explains the policies adopted and implemented by us for purposes of protecting personally identifiable information (“PII”) we receive from our clients (“Clients”), travelers and Website visitors. In this Privacy Policy, the term PII means information that can be used to identify a natural person.

We know that you are concerned about how we use and disclose PII, and we are committed to complying with laws applicable to the collection and processing of PII. We wish to remind you that this Privacy Policy applies to PII that we process when you use our services and if you otherwise communicate with us, for example by requesting information related to our services. It does not apply to any links to third parties’ websites and/or services, such as third-party applications, that you may encounter when you use our services. We encourage you to carefully familiarize yourself with privacy policies applicable to any websites and/or services operated by third parties. Please be aware that we are not responsible for the privacy practices of any third parties.

2. PII WE COLLECT

While providing travel services, Lawyers Travel collects PII that is necessary to complete a reservation with an airline carrier, hotel, car rental agency, or other supplier named on a traveler’s itinerary (a “Travel Supplier”). Upon a Client’s request, Lawyers Travel may also collect employment-related PII such as an employee identification number, department or department number. The specific elements of PII that Lawyers Travel may process in connection with providing travel services include, but are not limited to:

  • Passenger First Name;
  • Passenger Last Name;
  • Passenger Middle Initial;
  • Passenger Salutation;
  • Date of Birth;
  • Gender;
  • Employee Identification Number/Employee ID;
  • Ticket/Document Number;
  • Original Issue Ticket/Document Number;
  • Passport Number;
  • TSA Known Redress Number;
  • Airline Frequent Flyer Number;
  • Credit Card Information; and
  • Passenger Name Record (PNR) Reference

On the Website, we may collect the following information from you that may constitute PII:

  • Name;
  • Job title;
  • Company name;
  • Phone number;
  • Email address; and
  • Information included in your job application including, but not limited to, information included in your resume.

The software used on the Website automatically collects the following information that may constitute PII:

  • Website use event data such as which links or buttons you have clicked and the pages you have viewed;
  • The type of device you are using to access the Website;
  • The IP address from which you access the Website; and
  • The name and version of the device operating system.

The logging technology used on the Website automatically collects the URL of the site from which you came and the site to which you are going when you leave the Website. 

We may place a "cookie" on the hard drive of the device that you use to access the Website. Cookies are text files that are saved on the hard drive of your device by means of your browser, enabling us to recognize your browser for purposes such as saving your preferences and directing relevant content to you. Most of the currently available browsers give you the option of managing cookies by, for example, disabling them entirely, accepting them individually, and deleting saved cookies from your hard drive. We would like to remind you that if you completely disable cookies on your browser, you might not be able to use some features of the Website.

Google Analytics is an element of the Website. By using cookies, Google Analytics collects and stores data such as time of visit, pages visited, time spent on each page of the website, the IP address, and the type of operating system used in the devices used to access the Website. By using a browser plugin provided by Google, you can opt out of Google Analytics.  We also use other services that analyze, track, and distribute information collected on the Website for analysis and marketing purposes.

Finally, we may periodically conduct surveys.  Participation in any Lawyers Travel survey is completely voluntary.  Lawyers Travel takes the information received from individuals responding to surveys and combines (or aggregates) it with the responses of other Clients to create broader, generic responses to the survey questions (such as gender, age, residence, hobbies, education, employment, industry sector, or other demographic information).

We generally process PII on the basis of (i) consent; (ii) a contract, such as a travel management agreement; (iii) a legal obligation imposed on us; or (iv) our legitimate interest to process PII.  Such legitimate interests include our ability to provide our travel products and services to our clients and travelers that use our services.

3. THE PURPOSES FOR WHICH WE USE PII

We use the PII for the following purposes:

  • To provide, operate, develop, and improve our travel products and services;
  • To improve Client and traveler customer service;
  • To communicate with you;
  • To operate, develop, improve, and protect the Website;
  • To market research and electronic direct marketing, in accordance with applicable law;
  • To audit and analyze the Website;
  • For recruiting purposes;
  • To ensure the technical functionality and security of the Website.
  • To prevent and investigate fraud and other misuses;
  • To comply with laws, regulations, or legal requests for the PII;
  • To protect Lawyers Travel, its employees, affiliates and other clients;
  • To protect our rights and/or our property;
  • To personalize user experience; and
  • To ensure the technical functionality and security of the Website.

4. HOW WE DISCLOSE PII

We may disclose the PII we collect to the following categories of third parties:

  • The global distribution systems (“GDS”), a software-based service for making travel reservations;
  • Service providers such as Travel Suppliers or other third party services providers necessary to the operation of our business, Our clients that request the data relating to travel services utilized by their employees;
  • Subcontractors such as travel support service providers;
  • Industry reporting authorities and other entities necessary in providing travel services;
  • To public authorities, such as law enforcement, if we are legally required to do so or if we need to protect our rights or the rights of third parties.

Moreover, we may disclose information to third parties in an aggregate format that does not constitute PII and does not allow for the direct identification of individual users of the Website or individual travelers.

5. YOUR RIGHTS

You have the following rights with respect to the PII we hold about you:

The right to access PII we hold about you: if you would like to access PII we hold about you, please contact your employer (i.e. our client) or submit a request to privacy@ovationtravel.com. Lawyers Travel will respond to inquiries directed to privacy@ovationtravel.com within forty-five (45) calendar days.

The right to have incomplete, incorrect, outdated, or unnecessary PII corrected, deleted, or updated. If you have questions regarding the correction, deletion, or updating of the PII we hold about you, please contact your employer (i.e. our client) or contact us at privacy@ovationtravel.com.

The right to opt out of receiving electronic direct marketing communications from us: All electronic direct marketing communications that you may receive from us, such as e-mail messages and SMS-messages, gives you an option of not receiving such communications from us in the future. If you have any additional questions about electronic direct marketing received from us, please contact us at     privacy@ovationtravel.com.

If you wish to limit the use or disclosure of PII about you to a third party, including requests to “opt out,” you must contact your employer (i.e., Lawyers Travel’s client) or submit a request to privacy@ovationtravel.com.

6. DATA RETENTION

Records of new reservations and past reservations (collectively “Reservations”) are kept for six (6) years from the date of booking. If you are no longer employed by a Client, with the exception of Reservations, we will delete PII included in your personal profile immediately following the termination of your employment, provided that such termination has been communicated by the Client to us. If your employer discontinues the use of our travel services, with the exception of Reservations, we shall remove all profile information associated with your employer as soon as reasonably practicable upon discontinuing providing travel services to your employer.

7. SECURITY

Lawyers Travel maintains a data security program to protect PII, which includes commercially reasonable administrative, technical and physical safeguards designed to (i) protect the security and confidentiality of such PII; (ii) identify, assess and protect against any reasonably foreseeable internal and external threats, risks or hazards to the security or integrity of such PII; and (iii) protect against unauthorized access to or use of such PII.

Lawyers Travel currently utilizes the Secure Sockets Layers (SSL) protocol and firewalls to safeguard PII. In addition, access to PII is restricted to employees who have a “need to know,” and those employees must use passwords to access the PII.  For a more detailed description, please see Lawyers Travel’s Security Policy (available to Lawyers Travel’s Clients upon request). Although Lawyers Travel makes every effort to ensure the protection, integrity and security of Lawyers Travel’s network and systems, Lawyers Travel cannot guarantee or warrant that the security measures will protect PII that we process.

8. PRIVACY SHIELD

Lawyers Travel complies with the EU-US and Swiss-US Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use, and retention of PII from the EU and/or Switzerland. To review our Privacy Shield Privacy Policy, please click https://www.lawyerstravel.com/privacy-shield-policy.  

9. PII ABOUT CHILDREN

We do not knowingly collect information from children under the age of 13 on the Website. If you are under the age of 13, please do not provide any PII to us on the Website. Parents of children under the age of 13 may provide PII about a child in connection with our provision of travel services, and we process such PII in accordance with this Privacy Policy.

10. YOUR CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83 permits users that are residents of California to request certain information regarding Lawyers Travel’s disclosures of PII to third parties for such third parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please email us at privacy@ovationtravel.com.

The California Online Privacy Protection Act (“CalOPPA”) requires Lawyers Travel to disclose how it responds to Do Not Track Signals in your web browser. Lawyers Travel does not interpret or respond to Do Not Track Signals. You may set your web browser to not accept new cookies or web beacons or disable cookies altogether. Please note that doing so may hinder your experience on the Website. Please see the Help section of your browser for instructions on managing security preferences.

11. CHANGES TO THE PRIVACY POLICY

Lawyers Travel reserves the right to revise, amend, or modify this Privacy Policy at any time and in any manner. You can tell when changes have been made to the Privacy Policy by referring to the “Last Updated” legend on top of this page.

12. QUESTIONS

Should you have any questions regarding this Privacy Policy, your privacy as it relates to the use of the Website or the travel services we provide, or the protection of the PII we hold about you, please contact us at privacy@ovationtravel.com. We seek to promptly resolve any concerns you may have.

Effective date: December 13, 2017