Privacy Policy


	Privacy Policy: Galileo USA

Privacy Policy: Galileo Canada

Galileo Canada Distribution Systems, Inc. (hereinafter "Galileo Canada") is a proud member of Galileo International, Inc., a Cendant company. Galileo International, Inc., is one of the world's leading providers of electronic global distribution services and transaction processing to the travel industry utilizing a computerized reservations system (hereinafter, the "Galileo system"). Travel agencies and other subscribers to the Galileo system make reservations on over 500 airlines, approximately 30 car rental companies, more than 52,000 hotel locations, and other travel-related suppliers worldwide. The processing services provided by the Galileo system link together these travel suppliers, subscribers, and consumers to facilitate and confirm travel reservations.

Some of the data processed by the Galileo system in the normal course of the reservation procedure includes personally identifiable information ("PII"). PII includes personal information normally provided by or on behalf of a prospective traveler to a travel agent, both about that particular traveler as well as other parties traveling with that traveler, in order to make a reservation. Such information usually includes the traveler's name and phone number. It can also contain any other data entered into the Galileo system by the agency or travel supplier including but not limited to address, frequent flier number, dietary preferences, special needs, etc.

Purpose.

Galileo Canada collects, processes and discloses PII to facilitate reservation transactions, to meet legal and regulatory requirements, to develop products and services, and to better manage Galileo Canada's business and operations.

Scope.

This Policy applies to PII that is collected in Canada through the Galileo system. Galileo Canada does not assume any responsibility for unauthorized use or disclosure by the agency or travel supplier who originally provided the information. In other words, the Policy is only intended to apply to Galileo Canada and not to the travel agency or supplier that provided or utilized the information. This Policy does not apply to information in an aggregated form that can no longer be connected with a specific person.

Collection, Use and Disclosure

Collection.

Galileo Canada collects and processes PII and other data provided primarily by travel agents who subscribe to the Galileo system. Galileo Canada may also collect PII from others such as travel suppliers that have access to the Galileo system. Galileo Canada generally does not conduct business directly with individual travelers and therefore does not generally collect PII directly from individual travelers.

Use.

Galileo Canada generally obtains and processes PII for the purpose of facilitating the reservation process as requested by a traveler. For example, when a prospective traveler discloses air travel plans to a travel agent, the agent enters the data into the Galileo system in order to make a reservation. The Galileo system electronically contacts the airline in question to ascertain whether the flight is available. If an appropriate flight is available, the travel agent completes the reservation in the Galileo system. Galileo Canada transmits the reservation data to the travel suppliers involved in the booking. This would include the primary data such as passenger name, flight details and relevant telephone contacts, and can include optional information as directed by the travel agent. The data is stored in the Galileo system to allow for travel changes by the travel agent or travel suppliers. It is possible that PII will be disclosed to alternative travel suppliers or travel agents to facilitate changes to a travel itinerary. Galileo Canada may use PII data in any other manner upon the consent of the consumer involved.

Disclosure.

Galileo Canada discloses PII to the extent necessary or related to successfully completing the reservation. Thus, PII is disclosed to the travel agency and travel suppliers selected by the traveler and others involved in the transaction, such as the traveler's credit card company, insurance company, and otherwise as necessary on important public interest grounds or as required by law, court order, or as requested by a governmental or law enforcement authority or in the good faith belief that disclosure is otherwise necessary or advisable. Ticketing information is provided to the local bank settlement plan ("BSP") in the course of the BSP allocating funds to the airlines involved in the transaction. Certain ticketing information in the Galileo system is optionally available to the airlines. PII may also be disclosed in any other manner upon the consent of the traveler involved or to anyone who Galileo Canada reasonably believes is seeking the information as the agent of the traveler. Galileo Canada reserves the right to disclose PII in connection with the sale or transfer of all or substantially all of the assets of Galileo Canada or Galileo International, Inc. to a third party.

Third Party Processing and Disclosure.

Galileo Canada and the Galileo system may utilize (and disclose PII to) affiliates or third party suppliers to perform certain outsourced services including but not limited to data center management, software development, etc. Such entities may have access to PII. In such circumstances, appropriate means shall be employed to help ensure such third parties maintain the requisite level of data security as required by law.

Retention.

The Galileo system archives PII offline within 72 hours of the completion of travel and destroys the data within three years of the completion of travel.

Security Safeguards.

Galileo Canada shall protect PII by security safeguards appropriate to the sensitivity of the PII against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction. To protect PII sent to us, we use a security system that includes advanced technologies, intrusion detection systems, logical network segmentation, and security restrictions. If we transmit PII over the Internet as part of the reservation process we use industry-standard, secure-socket-layer (SSL) technology, which is utilized by most browsers to encrypt PII before it is transferred across the Internet. To further safeguard PII, we frequently use direct communication links to travel suppliers and travel agents rather than the Internet to transfer information. If PII is transferred using the Internet, such information is sent in encrypted format and ultimately stored in our secure database. All of Galileo Canada's employees and contractors with access to PII are and shall be contractually required to respect the confidentiality of the PII.

Accuracy.

Galileo Canada primarily relies upon travel agents and travel suppliers to provide accurate information. The data is then processed through a series of quality control measures. Galileo Canada strives to promptly correct any PII found to be inaccurate, and where appropriate, Galileo Canada transmits the updated data to appropriate personnel.

Access.

As a processor of data, Galileo Canada does not conduct business directly with individual travelers. Upon request, individual travelers may have access to their own data held by the Galileo system by contacting the travel agent involved in the booking.

Consent.

Galileo Canada does not have a direct relationship with the individual travelers for which it collects, processes and discloses PII. Each travel agent and travel supplier that primarily supplies PII to Galileo Canada is responsible for ensuring that it has obtained the appropriate consents required to permit Galileo Canada to collect, process and disclose the PII covered by this Policy. In obtaining such consent, such business associate should use reasonable efforts to ensure that the individual traveler (or his or her agent) is advised of the identified purposes for which PII will be used or disclosed. Such business associate should ideally seek such consent at the time the PII is collected. However, such business associate or Galileo Canada may seek consent to use and disclose PII after it has been collected but before it is used or disclosed for a new purpose. In determining the appropriate form of consent, the sensitivity of the PII and reasonable expectation of the data subject should be considered. An individual traveler may withdraw his or her consent at any time, subject to legal or contractual restrictions and reasonable notice.

Publication.

Galileo Canada makes its policies and practices regarding the management of PII readily available. This Policy is available on the Galileo Canada web site at Galileocanada.ca. All employees of Galileo Canada are required to read this Policy on an annual basis.

Compliance.

The Chief Privacy Officer for Galileo Canada is Thomas J. DeMay, Esq. Any questions regarding this Policy may be addressed to him at Galileo Canada, 9700 W. Higgins Road, Rosemont, IL 60018. USA.

Changes.

Galileo Canada reserves the right to modify or amend this Policy at any time and for any reason. If there are material changes to this Policy or in how Galileo Canada will use PII, Galileo Canada will prominently post such changes prior to implementing such change.

Effective 6/1/04

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