Privacy Notice
  1. Scope

All data subjects whose personal data is collected, in line with the requirements of the GDPR.

 

  1. Responsibilities
  • The GDPR Owner is responsible for ensuring that this notice is made available to data subjects prior to CTS Systems collecting/processing their personal data.
  • All Employees/Staff of CTS Systems who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.

 

  1. Privacy notice
  • Who are we?

CTS Systems is one of the leading automated commission collection and payment platforms within the travel industry. Our mission is to create the industry.  CTS Systems works with companies on all sides of the travel industry from small travel agents to large Travel Management Companies and venue-finding agencies.

Our GDPR Owner and data protection representatives can be contacted directly:

In the United States

 

In the United Kingdom

Third country (non-EU)/international organisation Safeguards in place to protect your personal data
Hotels, car rental agencies, rail lines, cruise lines, meeting and event planners All personal data is first obtained from agents and sent to hotels, rental agencies, rail and cruise lines, and planners and then sent back to them only to verify the appropriate billable attendee information
  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
  • Right of portability – you have the right to have the data we hold about you transferred to another organisation.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
  • Right to judicial review: in the event that CTS Systems refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.

All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data.

 

The details for each of these contacts are:

 

  Supervisory authority contact details GDPR Owner contact details
Contact Name: Information Commissioners Office Holly Mechsner
Address line 1: 11575 Great Oaks Way
Address line 2: Suite 130
Address line 3: Alpharetta, GA   30022
Email: privacyshield@ico.org.uk GDPR.US@CTSsystems.com
Telephone:

 

+44 1625 545 700 +1-678-503-4015

 

Read more about how and why we use your data here http://www.ctssystems.com/privacy-policy.

Personal data

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:

How we use your information

This privacy notice tells you how we, CTS Systems, will collect and use your personal data for services provided to our clients, including collecting commissions and processing payments.

 

Why does CTS Systems need to collect and store personal data?

In order for us to provide our clients with our services we need to collect personal data for commission collection and payment reconcilation. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

In terms of being contacted for marketing purposes CTS Systems would contact you for additional consent.

 

Will CTS Systems share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to CTS Systems in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to provide us accurate accounting and reporting. When they no longer need your data to fulfil this service, they will dispose of the details in line with CTS Systems’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

 

How will CTS Systems use the personal data it collects about me?

CTS Systems will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. CTS Systems is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

 

Under what circumstances will CTS Systems contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

 

Can I find out the personal data that the organisation holds about me?

CTS Systems at your request, can confirm what information we hold about you and how it is processed. If CTS Systems does hold personal data about you, you can request the following information:

  • Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
  • Contact details of the data protection officer, where applicable.
  • The purpose of the processing as well as the legal basis for processing.
  • If the processing is based on the legitimate interests of CTS Systems or a third party, information about those interests.
  • The categories of personal data collected, stored and processed.
  • Recipient(s) or categories of recipients that the data is/will be disclosed to.
  • If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
  • How long the data will be stored.
  • Details of your rights to correct, erase, restrict or object to such processing.
  • Information about your right to withdraw consent at any time.
  • How to lodge a complaint with the supervisory authority.
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if it wasn’t collected directly from you.
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

 

What forms of ID will I need to provide in order to access this?

CTS Systems accepts the following forms of ID when information on your personal data is requested: U.S. Driver’s License, government-issued passport (must be current), utility bill verifying name and address from last 3 months.

 

Contact details of the Data Protection Officer / GDPR Owner:

  GDPR Owner contact details
Contact Name: Holly Mechsner
Address line 1: 11575 Great Oaks Way
Address line 2: Suite 130
Address line 3: Alpharetta, GA   30022
Email: gdpr.us@ctssystems.com
Telephone: +1-678-503-4015

 

Document Owner and Approval

The GDPR Owner is the owner of this document and is responsible for ensuring that this record is reviewed in line with the review requirements of the GDPR.

A current version of this document is available to all members of staff in the staff handbook and on the Internet at http://www.ctssystems.com/privacy-notice.

Change History Record

 

Issue Description of Change Approval Date of Issue
1 Initial issue Mark Lewington 05/23/2018