Last updated July 2019
Why do we collect personal data
(CWT Global B.V. and its affiliates, together CWT) uses personal information. CWT is a travel management company
with operations in many countries around the world and provides business travel services and meetings
and events services to its corporate clients. CWT collects personal information from the Clients'
travelers, from participants at Client meetings & events organized by CWT, and from the users of CWT
websites. The purpose of this information collection is for CWT to provide these services.
What information do we collect
When servicing a given corporate Client, an electronic
'Traveler Profile' is created in CWT's proprietary tool, CWT Portrait, for each traveler. The
personal information is entered through feeds from the corporate clients or by the traveler
(or the authorized CWT Travel Advisor).
- The personal information that we collect for each traveler may include: name, gender, date of birth, address, phone numbers, email addresses, credit card references/numbers, travel destinations, travel schedules, travel preferences (seat, meal, smoking, etc.), passport and visa details, as well as next of kin information. If a 'master profile' is created by an online booking tool service provider (OBT), CWT receives the profile information from the OBT and a profile is automatically created in CWT Portrait to enable the counselor to fulfill traveler's requests.
- When organizing a meeting or event for a corporate Client, CWT collects personal information to register the participants to the meeting or event through tools that may be selected by the Client or receives lists of participants from the Client.
- CWT collects personal information from users to its websites through the use of online forms and when the user emails CWT his/her details.
- CWT forwards these user requests to the appropriate CWT team to respond to the user.
How we process personal information
In addition to creating Traveler Profiles and 'passenger
name records' (PNRs), CWT uses the personal information (usually the PNR) of the traveler for the
following travel and other travel-related purposes.
The Traveler Profiles are stored in a database as a reference document to
be consulted each time a reservation is to be made. When a reservation is made, CWT creates a PNR that contains
all of the personal information along with the reservation information that is needed to fulfill the travel
request of a traveler and to fulfill regulatory requirements for travel to certain destinations such as the Secure
Flight program in the United States and the Advanced Passenger Information System in several countries such as the
UK and China. To make reservations, CWT needs to transfer personal information to various third party travel
suppliers (such as airlines, hotels, car rental companies, online booking tool companies and safety and security
tracking providers, as well as computer reservation systems) within the traveler's home country or in another
country where the traveler may be traveling and often also to government bodies for certain destinations such as
DHS in the US. Without this information travel will not be possible.
Consolidation of Travel Data
At the request of the Client (the paying party for the travel), CWT or a
third party may prepare information reports that summarize and analyze the travel expenditures per destination,
per travel supplier, etc. Such reports may include certain personal information from the traveler's profile.
Transfers to Third Parties at Corporate Client's Request
CWT may transfer personal information to third parties at the request of the
Client, for example for information consolidation or emergency traveler tracking services. These transfers could
involve transfers of personal information to other countries.
Transfers within the CWT group
Transfers are made throughout CWT, its subsidiaries, joint ventures and
international partners to support travel-related services such as emergency online booking services, airline ticket
issuance and technical help-desk requests, and for screening where required for compliance with the law.
Transfers to CWT service providers
Transfers are for CWT to obtain support services in connection with the
travel and meetings & events services to its clients (such as administrative, information technology and
technology platforms for CWT tools, telecommunications, payment services).
CWT may be required by law to transfer information to governments and
law enforcement agencies where required.
Compliance with Travel Policy
At the request of the Client, CWT may report on the compliance of the
travelers with the travel policy of the Client and identify any exceptions to the compliance.
Collecting Travel Payments
CWT may transfer personal information to third parties in the traveler's
home country or to another country for the purpose of collecting payments related to travel reservations.
The electronic Traveler Profiles that CWT maintains are stored in a
central database at a CWT location in the United States. For clients using an OBT provider, the personal
information may be stored by these third-parties.
New Products and Services
With the goal of improving service and based on the information given
to CWT, CWT may send additional information to the traveler if it applies to his/her trip or in advance of
future trips. An example might be a list of restaurants near a specific hotel in the destination city or
parking at the departure airport.
Application of the Policy
Transfer to Third Parties: CWT requires third parties processing EU
travelers personal information to meet the standards of data privacy laws in the EU.
Security: CWT has implemented appropriate technical and organizational measures to protect the personal
information obtained from our Clients' travelers against accidental or unlawful disclosure or destruction.
Retention and Deletion: CWT keeps personal information only as long as required to fulfill the services
requested by its Clients. CWT may need to keep certain information to comply with financial reporting laws
or to inquiries from Clients on past travel activities
Travelers' Rights of Access
The traveler has a right of access to his/her personal data. The
traveler can update his/her Traveler Profile directly in CWT Portrait. To contact CWT with questions or
issues about CWT's information processing, the traveler may contact firstname.lastname@example.org.
Dispute resolution: Any questions or concerns regarding the use of disclosure of personal information may
be directed to email@example.com. CWT will investigate and attempt to resolve complaints and
disputes regarding use and disclosure of your personal information.