Tower Travel Management Privacy Policy

Last Updated: 5/28/2020


PRIVACY STATEMENT

Tower Travel Management Corp. ("we" or "us") strives to be a leading provider of corporate travel

services and, as such, seeks to gain the full trust and confidence of our customers. We firmly believe in

protecting the privacy of personal information. This Privacy Policy explains our online information

practices regarding the collection, use, disclosure and protection of personal information when you use

our website and associated tools and services. It also explains the choices you can make about the way

your information is collected and used. This Privacy Policy applies to all information collected or

submitted on our site.

BY SUBMITTING YOUR INFORMATION TO US, CREATING AN ACCOUNT WITH US OR USING OUR WEBSITE

OR SERVICES, YOU ARE AGREEING TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY.


PERSONAL INFORMATION WE COLLECT

We collect personal information that you provide on our website, over the telephone, or through email,

chat or text communications. Personal information is information that identifies an individual or that

can be reasonably associated with a specific person or entity. When you use our website or associated

tools or services, we may collect the following types of personal information from you as needed:

  • Name, email address, and telephone numbers
  • Home, business, and billing addressees
  • Government issued identification required for travel reservations or identity verification, such as
  • passport, driver’s license, and tax identification numbers
  • Payment information such as payment card number, expiration date, and billing address
  • Rewards and air royalty programs and membership information
  • Birth date and gender
  • Data you give us about other people, such as your travel companions or others for whom you
  • are making travel reservations
  • Employment‐related information for corporate travelers
  • Travel history and travel‐related preferences such as favorite destinations and preferred
  • accommodation types


HOW WE USE PERSONAL INFORMATION

We use your personal information for the following purposes, depending upon the services you request

or the pages you visit on our website:

  • Book your travel reservations and provide assistance and services related to your travel
  • Create, maintain, and update user accounts on our website and authenticate you as a user
  • Enable and facilitate acceptance and processing of payments and other transactions
  • Respond to your questions, inquiries, and requests for information
  • Enable communication between you and the travel supplier, such as hotels and airlines
  • Contact you (such as by email, phone, chat or text message) to provide information that may
  • impact your travel, such as travel reservation confirmations and updates, travel alerts, travel
  • disruptions, weather information, newsletters, or for other purposes as described in this Privacy
  • Policy
  • Promote security, verify identity of our customers, prevent and investigate fraud and
  • unauthorized activities, defend against claims and other liabilities, and manage other risks
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  • Protect our and our users’ rights and interests, enforce our policies, defend ourselves, and take
  • action regarding illegal or suspected illegal activities
  • Respond to subpoenas, courts orders or other legal process, or to requests by law enforcement
  • other governmental agencies or authorities
  • Comply with applicable laws and regulations, including security and anti‐terrorism, customs and
  • immigration, and other such due diligence laws and requirements
  • Operate our business for lawful business purposes and as otherwise permitted by applicable law


SHARING OF PERSONAL INFORMATION

We share personal information with third parties who are performing functions related to the services

we offer and otherwise as described in this Privacy Policy. We never sell personal information to third

parties.


Third‐Party Service Providers

We share personal information with third‐parties we have contracted with to provide services in

connection with our provision of services to you and the operation of our business. For example, we use

third party service providers to provide credit card processing, book travel reservations, and distribute

email communications. We require these third parties to use such information only to complete such

tasks.


Travel Vendors

We share personal information with travel‐related vendors such as hotels, airlines, car‐rental

companies, insurance companies, and activity providers who fulfill your travel reservations. Airlines also

share your personal information with applicable government agencies pursuant to applicable laws and

regulations.


Legal Requirements

We may use or disclose your personal information when we believe it is appropriate to investigate,

prevent, or take action regarding illegal or suspected illegal activities; to enforce our policies and identify

parties in violation of our policies; to respond to any claims; to otherwise protect our rights or interests;

or to protect our users or other parties. We may also disclose your personal information pursuant to

the requirements of applicable laws and regulations; to respond to subpoenas, court orders or other

legal process; or to respond to requests of any law enforcement or governmental agency or authority.

In such cases we reserve the right, in our sole discretion, to raise or waive any legal objection or right

available to us.


Corporate Transactions

We may share your personal information in connection with a corporate transaction, such as a merger

or asset sale, or in the unlikely event of bankruptcy. In the case of any acquisition, we will inform the

buyer it must use your personal information only for the purposes disclosed in this Privacy Policy.


Other Disclosures

Although it is our policy not to use or share personal information except as described above, we reserve

the right, in our sole and absolute discretion, to disclose personal information if we believe such

disclosure is necessary or reasonable for any compelling reason, including but not limited to, the safety

or protection of our customers or any other party.


COOKIES AND SIMILAR TRACKING TECHNOLOGY

We currently do not use "cookies" or similar tracking technology to track or collect information on our

website. However, our website contains links to third party websites operated by third party service

providers that may also use cookies, web beacons and/or similar tracking technology. Such third party

operations are beyond our control. When you click on links to third party websites, you should review

the privacy policy of such third party to understand how they collect and use your personal information.

This Privacy Policy does not apply to such third party websites. You may disable or modify the use of

cookies within your web browser. However, such action may prevent you from maximizing utilization of

such third party websites.


Do‐Not‐Track Signals

“Do Not Track” signals are options that may be available on your browser to tell website operators that

you do not wish to have your online activity tracked. We do not currently take any action in response to

“Do Not Track” signals.


EXTERNAL LINKS AND THIRD PARTY WEBSITES

Due to the nature of our services, our website contains links from our site to third party websites. This

Privacy Policy does not apply to such third party websites. We strongly recommend that you review the

privacy policy posted on those other web sites to understand their procedures for collecting, using, and

disclosing personal information.


RETENTION OF INFORMATION

We may retain information, including personal information, for as long as necessary to comply with

applicable laws and in accordance with our internal business processes.


YOUR CHOICES

You can update the accuracy of your information at any time by logging into your account or by

contacting us. If you no longer wish to receive marketing and promotional emails, you may unsubscribe

by clicking the ‘unsubscribe’ link in the email or by contacting us. Please note that if you choose to

unsubscribe from or opt out of marketing emails, we may still send you important travel and account related messages from which you will not be able to unsubscribe.


OUR COMMITMENT TO DATA SECURITY

We want you to feel confident using our website and associated tools and services. While no company

can guarantee absolute security, we do maintain reasonable and appropriate electronic and physical

safeguards intended to protect the personal information we collect and process.


CONSENT TO ELECTRONIC COMMUNICATIONS

When you visit our website, use our chat feature, or send email or text messages to us, you are

communicating with us electronically. You consent to receive communications from us electronically

and agree that we may communicate with you by unencrypted email, text message or chat. You

acknowledge and agree that unencrypted email, text messages and chat conversations are not secure

and may be read by others, and you agree that when you request that we send you email, text messages

or chat messages you are authorizing us to transmit and disclose your information (including your

personal information) from time to time in an unencrypted manner. You further acknowledge that

emails, texts and chat conversations sent with this information are not stored in a secure manner.


CHANGES TO THIS POLICY

We reserve the right change this Privacy Policy at any time without advance notice. Whenever such a

change occurs, it will be clearly identified on our website. You can see when this Privacy Policy was last

updated by checking the “last updated” date displayed at the top of this Privacy Policy.


HOW TO CONTACT US

If you have any questions about our Privacy Policy or you believe we have not adhered to this Privacy

Policy, please contact:

Tower Travel Management

240 East Ogden Avenue, Suite 102

Hinsdale, IL 60521

Attn: John Smith

Telephone: (630) 928‐7100

Email: john.smith@towertravel.com

Our office hours are Monday – Friday 7am – 7pm Central standard time.