Updated:  August 2021

Vai Travel Privacy Notice

Vai Travel LLC (Vai Travel or Vai) respects your privacy and is committed to being transparent about how we collect, use, and share the information we hold about you. This Privacy Notice is intended to help you understand how we handle data that can be used to directly or indirectly identify an individual (“Personal Data”).

Who We Are

Vai Travel is a travel services company that serves corporate and individual clients. Our headquarters is located at 13 Bow Circle, Hilton Head Island, SC 29928 USA

Personal Data We Collect

We may collect your data: directly from you, through electronic means, such as our website, traveler profile or online booking tool, or by your employer (for corporate travelers).

Travel Services

We collect your data to arrange travel on your behalf. The most common data that we collect includes, but may not be limited to:

  • Full Legal Name
  • Date of Birth
  • Gender
  • Known Traveler/Redress Numbers
  • Frequent Flyer Numbers
  • Phone Numbers
  • Email address
  • Dietary Requests
  • Disability Details to Facilitate Travel
  • Credit card number or other payment information

Website Data Collection

Our Website contains forms that may be completed by you or your designated agent, such as a traveler profile, credit card details, or information requests. The personal data that we collect may include:

Traveler Profile Form
  • Full Legal Name
  • Date of Birth
  • Gender
  • Known Traveler/Redress Numbers
  • Frequent Flyer Numbers
  • Phone Numbers
  • Email Address
  • Dietary Requests
  • Disability Details to Facilitate Travel
  • Emergency Contact Details
  • Travel Preferences
Credit Card Form
  • Credit Card Number
  • Expiration Date
  • Security Code
  • Billing Address]
  • Phone Number
  • Email Address
Travel Request / Information Form
  • Name
  • Email Address
  • Travel Interests

Information We Collect Through Automatic Data Collection Technologies

Whenever you visit our Site, use our services, or view our online advertisements, the website software automatically collects the following information, some of which may be considered Personal Data:

  • Website use event data, such as: which links or buttons you have clicked, search terms and the pages you have viewed
  • Travel and Social preferences, interests and activities
  • The type of device you are using to access the Website
  • The IP address from which you access the Website
  • 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
  • Cookie Data: A “cookie” is data that a website server stores on your computer. Cookies enable websites to recognize your computer and to “remember” your entries as you move from page to page, or even when you revisit the site from time to time using the same computer
  • Google Analytics: 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

You can learn more about how we use cookie data by reviewing our Cookie Policy which can be found in the “Cookie Policy” section of this document.

We use Personal Data for the Following Purposes

  • Travel Services & Products: To provide, operate, develop, and improve our travel products and services
  • Processing of Payment for Travel or travel related services
  • Customer Service: To operate and improve Client and traveler customer service
  • Engagement: To communicate with you, including responding to your comments or requests for information
  • Corporate Travel: Establishing, managing and terminating business relations with Client
  • Website Management to:
    • Operate, develop, improve, and protect the Website
    • Audit and analyze the Website
    • Content Management and Personalize user experience
    • Ensure the technical functionality and security of the Website
  • For market research and electronic direct marketing, in accordance with applicable law;
  • For recruiting and hiring purposes
  • To prevent and investigate fraud and other misuses
  • Legal Compliance: Enabling Vai Travel to comply with laws, regulations, or legal requests for the Personal Data
  • To protect Vai Travel, its employees, affiliates and other clients against error, fraud, theft, and damage to our goods and property
  • To protect our rights and/or our property
  • For any other reasonable business purposes about which we notify you and to which you consent

Legal Basis for Personal Data

We will only collect and use your Personal Data, if at least one of the following conditions applies:

  • We have your consent. When you give us your consent, you will be given details on how to change your mind or visit the ‘Your rights’section of this policy for more information.
  • contract is in place with you, such as for travel management services.
  • Compliance with a mandatory legal obligation, for example, sharing Personal Data with regulatory authorities so you can travel.
  • It is necessary to protect your vital interests.
  • There is a need to protect a public interest.
  • Vai Travel has legitimate business interests, for example: fraud prevention, maintaining the security of our network and services, and the improvement of our services. For more information, visit the ‘Your rights’section of this policy

How We Share Personal Data

We may disclose the Personal Data we collect to the following:

  • The global distribution systems (“GDS”), a software-based service for making travel arrangements.
  • Service providers, when necessary, to fulfill your travel request.
  • Other third parties, or with employees, agents, consultants and others who may require the information to fulfill our contractual or other obligations to you.
  • Our corporate clients that request data concerning travel services utilized by their employees or those traveling on our clients’ behalf.
  • Our corporate clients as part of their operational and financial corporate travel management
  • 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 need to protect our rights or the rights of third parties.
  • Affiliates or Acquired Companies: As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or we acquire another company, the information we have about you will be transferred to and used by the acquiring entity.
  • We may disclose information to third parties in an aggregate format that does not constitute Personal Data and does not allow for the direct identification of individual users of the Website or individual travelers.

We do not sell your data nor do we share information with third parties for sole purpose of marketing to you.

Sharing Personal Data with Travel Suppliers

Our Privacy Notice applies to services offered by Vai Travel but excludes Travel Suppliers that have separate privacy notices. We may share the minimum Personal Data necessary with other companies affiliated with Vai Travel, for example, to provide the products and services you request; to manage and improve our products, services and day-to-day operations; where appropriate, to make contact and interact with you; and, if allowed and appropriate, for marketing or market research purposes.

Linked Sites

This Policy does not apply to your use of unaffiliated websites to which our Site is linked. Vai Travel is not responsible for the privacy practices or the content on linked sites. We recommend that you carefully read the privacy policies of each site you visit.

Social Media Features

Our website may contain social media features such as Facebook, Instagram, and LinkedIn that have their own privacy notices. Please be sure to read their terms and conditions and privacy notices carefully before providing any Personal Data as we do not accept any responsibility or liability for these features. When we use social plug-ins on our website from social networks such as Facebook, Instagram, and LinkedIn, we integrate them as follows:

  • When you visit our website, the social plug-ins are deactivated, i.e. no data is transmitted to the operators of these networks. If you want to use one of the networks, click on the respective social plug-in to establish a direct connection to the server of the respective network
  • When you activate a social plug-in, the network transfers the content that becomes available directly to your browser, which integrates it into our websites. In this situation, data transmissions can also take place that are initiated and controlled by the respective social network. Your connection to a social network, the data transfers taking place between the network and your system, and your interactions on that platform are governed solely by the privacy policies of that network.
  • The social plug-in remains active until you deactivate it or delete your cookies.

Safeguarding Personal Data

We have implemented technical and organizational security measures to protect your Personal Data that is managed by us against manipulation, loss, destruction and against access by unauthorized persons. We are constantly reviewing and improving our security measures. Although Vai Travel makes every effort to ensure the protection, integrity and security of Vai Travel’s network and systems, Vai cannot guarantee or warrant that the security measures will protect all Personal Data.

The security of your data also depends on you. For example, where you have chosen a password for access to certain services, you are responsible for keeping this password confidential.

Data Retention

We will retain your Personal Data for only as long as it is necessary for the uses set out in this Privacy Notice and/or to meet legal and regulatory requirements. After this period, we will securely erase Personal Data. If data is needed after this period for analytical, historical or other legitimate business purposes, we will take appropriate measures to anonymize or destroy this data.

Marketing Communications

If you receive marketing emails from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving commercial email from us, and any other promotional communications that we may send to you from time to time, by sending your request by email to info@VaiTravel.com.

Please be aware that if you opt-out of receiving commercial emails from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may receive promotional communications from us that you have opted-out from during that period. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages regarding travel services.

Information Collected by Automated Means

Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of our Site.

Please note that there is currently no uniform way in which to respond to Do Not Track signals, and at this time we do not respond to such signals.

Your European Privacy Rights and Choices

If you are a resident of the EU or Switzerland, you have specific rights for your Personal Data under the European General Data Protection Regulation (GDPR).

Vai Travel LLC is the Data Processor within the meaning of the General Data Protection Regulation (“GDPR”) for global Corporate Travel Management services on behalf of its clients, as well as some Leisure Travel related travel services.

Vai Travel LLC is the Data Controller within the meaning of the General Data Protection Regulation (“GDPR”) for VaiTravel.com and some Leisure related travel services.

At Vai Travel we address your rights for:
  • Data Access: You have a right to ask for a copy of the Personal Data we hold about you. You can write to us asking for a copy of other Personal Data we hold about you. Please include any details to help us identify and locate your Personal Data. Where we can provide data access, we will do so free of charge except where further copies are requested, in which case we may charge a reasonable fee based on administrative costs.
  • Data Correction and Deletion: We want to make sure that the Personal Data we hold about you is accurate and up to date. If any of the details we hold appear to be incorrect, please let us know. We will update or erase your data, unless we have to keep it for legitimate business or legal purposes.
  • Data portability: You have the right to be able to take with you the Personal Data you provided to us in certain circumstances.
  • Right to object to use of Personal Data: You have the right, in certain circumstances, to object to Vai Travel processing your Personal Data.
  • To opt out of marketing messages: If you no longer want to receive marketing messages from Vai Travel, you can choose to opt out at any time. If you’ve previously opted in to receive personalized content based on how and where you use our network, you can also opt out at any time.

Vai Travel will offer EU and Swiss individuals whose personal information has been transferred to us the opportunity to choose whether the personal information it has received is to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. An individual may opt-out of such uses of their personal information by contacting us at Info@VaiTravel.com.

If we intend to disclose it to a third party acting as a controller not previously identified, we will offer you the opportunity to opt-out of such uses and/or disclosures where it involves non-sensitive data or opt-in where Sensitive Personal Data a is involved.

If we intend to use your Personal Data for a purpose that is materially different from the purposes listed in this Notice, or if we intend to disclose it to a third party acting as a controller not previously identified, we will offer you the opportunity to opt-out of such uses and/or disclosures where it involves non-sensitive data or opt-in where Sensitive Personal Data a is involved.

Please note:

  • We will not be able to delete information that is required to maintain our business purpose or that is required to facilitate your contract with us or to perform the services you have otherwise requested from us.
  • We may ask you to verify your identitybefore we can act on your request or complaint. We may also ask you for more information to help ensure that you are authorized to make such a request or complaint when you contact us on behalf of someone else.

For more information or to exercise your rights, please submit a request via post or email to Vai Travel LLC. We will respond to inquiries directed to us within thirty (30) calendar days. If the request pertains to data that was provided to us by your employer, please contact your employer (i.e. our client).

By mail:

Vai Travel LLC

Attn: Data Protection Officer

13 Bow Circle

Hilton Head Island, SC 29928 USA

By email: Info@VaiTravel.com

You can also contact us if you have a complaint about how we collect, store or use your Personal Data. Please submit any complaints in writing to the Data Protection Officer at the address/email noted above.

If you would like more information about data protection and your Personal Data rights in general, please visit the European Data Protection Supervisor’s site at https://edps.europa.eu/data-protection/

If you are not happy with our response to your requests, you may lodge a complaint with the data protection authority in your country.

Your California Privacy Rights

If you are a resident of California, you have specific rights for your Personal Data under the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice. This section describes your CCPA rights and explains how to exercise those rights.

  • The right to notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
  • The right to access / the right to request. The CCPA permits you to request and obtain from information regarding the disclosure of your Personal Data that has been collected in the past 12 months by Vai Travel or its subsidiaries to a third-party for the third party’s direct marketing purposes.
  • The right to say no to the sale of Personal Data. You also have the right to ask Vai Travel not to sell your Personal Data to third parties. You can submit such a request in writing to Info@VaiTravel.com.
  • The right to know about Your Personal Data. You have the right to request and obtain from Vai Travel information regarding the disclosure of the following:
    • The categories of Personal Data collected
    • The sources from which the Personal Data was collected
    • The business or commercial purpose for collecting or selling the Personal Data
    • Categories of third parties with whom we share Personal Data
    • The specific pieces of Personal Data we collected about You
  • The right to delete Personal Data. You also have the right to request the deletion of your Personal Data that have been collected in the past 12 months.
  • The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your Consumer’s rights, including by:
  • Denying goods or services to You
  • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
  • Providing a different level or quality of goods or services to You
  • Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.
Exercising Your CCPA Data Protection Rights

In order to exercise any of your rights under the CCPA, and if you are a California resident, you can email us at Info@VaiTravel.com. We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Do Not Sell My Personal Information

We do not sell personal information. However, the Service Providers we partner with (for example, our advertising partners) may use technology on our website and social media channels that “sell” personal information as defined by the CCPA law. If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by opting out or not consenting to the use of cookies. Please note that any opt out is specific to the browser you use, so you may need to opt out on every browser that you use.

Website

You can opt out of receiving ads that are personalized by following instructions presented on the “Cookie Consent” notice banner. The opt out will place a cookie on your computer that is unique to the browser you use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.

Mobile Devices

Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:

  • “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
  • “Limit Ad Tracking” on iOS devices

You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals. However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

Policy Changes

This Notice replaces all previous versions. We may change the Notice at any time, so please check it regularly on our website for any updates. You can tell when changes have been made to the Privacy Policy by referring to the “Last Updated” legend on top of this page.  Any changes will be effective on the effective date stated in the revised Privacy Policy. Your continued use of the Site after we have posted a revised Privacy Policy indicates your agreement to the revisions.

Definitions

For purposes of this Policy, the following definitions shall apply:

“Agent” or “Processor” means any third party that collects or uses Personal Data under the instructions of, and solely for, Vai Travel LLC or to which Vai Travel discloses Personal Data for use on Vai Travel’s behalf.

“CCPA“ or “California Consumer Privacy Act” also known as AB-375, is a bill intended to enhance privacy rights and consumer protection for residents of California, United States.

“Vai Travel” or “Vai” means Vai Travel LLC, its affiliates under common control, predecessors, successors, subsidiaries, divisions and groups in the United States.

“GDPR” or “General Data Protection Regulation”, also known as Regulation (EU) 2016/679, is a European Union law drafted on April 27, 2016 and instituted on May 25, 2018 on data protection and privacy for all individual citizens of the European Union and the European Economic Area.

“Personal Data” means any information or set of information that identifies or could be used by or on behalf of Vai Travel to identify an individual. Personal Data does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public Personal Data.

“Sensitive Personal Data” or “Special Categories of Personal Data” This are categories of personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data, biometric data for the purpose of uniquely identifying a natural person; health data; and data concerning a natural person’s sex life or sexual orientation. In addition, Vai Travel will treat as sensitive Personal Data any information received from a third party where that third party treats and identifies the information as sensitive.

“Data Controller”: The data controller determines the purpose and manner in which personal data is used.

“Data Processor”: Processes Personal Data as instructed on behalf of a data controller

“European Economic Area (EEA)” consist of EU Member States plus Norway, Iceland and Lichtenstein.

“Online advertising” refer to Marketing messages that you may see on the internet.

“US Secure Flight Data”: The Transportation Security Administration (TSA) requires you to provide your full name, date of birth and gender for the purpose of watch list screening. You may also provide your Redress Number, if available. Failure to provide details may result in denial of transport or denial of authority to enter the boarding area. TSA may share information you provide with law enforcement or intelligence agencies or others under its published system of records notice. Please see the TSA website for more details.

Cookie Policy

We use or may use the data collected through cookies, log files, device identifiers, and clear GIFs to (a) remember information so in subsequent visits a user will not have to re-enter it; (b) provide custom, personalized content, and information; (c) monitor the effectiveness of our Services; (d) monitor aggregate metrics such as total number of visitors, traffic, and usage on our website and our Services; (e) diagnose or fix technology problems; and (f) help users efficiently access information after signing in.

Clear GIFs, pixel tags, and other technologies: Clear GIFs (also known as web beacons, web bugs or pixel tags) are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs, in connection with Services to, among other things, track the activities of visitors, help us manage content, and compile statistics about site usage. We and our third-party service providers also use clear GIFs in HTML emails to our customers to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

Third-Party Analytics: We use automated devices, applications, and other means, such as Google Analytics to evaluate usage of our Vai Travel websites and Services. We use these tools to help us improve our Services, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. Third-party advertising networks are never allowed to collect information about the users of our websites or Services