1. Scope

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

2. 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.
  • 3. 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 European Union

In the United Kingdom

The personal data we collect from third parties is only what is necessary to provide proof of travel provided by our clients in order to process commission collections and payments:

Personal Data Types:

  • First and last name
  • Arrival and departure dates for travel
  • Hotel where travel occurred

The personal data we collect will be used for the following purposes:

  • Processing payments
  • Collecting commissions

Our legal basis for processing for the personal data:

  • Is for CTS Systems to fulfill contractual obligations to clients

Any legitimate interests pursued by us, or third parties we use, are as follows:

  • Personal data is only collected when it is necessary for CTS to use it to reconcile client accounts, collect commissions owed, and provide reporting for clients

There are no special categories of data collected by CTS Systems.

  • Consent

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.

Consent is required for CTS Systems to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

You may withdraw consent at any time by contacting us at the email addresses or phone numbers above. You will be sent a consent form to be completed at that time.

  • Disclosure

CTS Systems will pass on your personal data to third parties that already have it without first obtaining your consent. The following third parties will receive your personal data for the following purpose(s) as part of the processing activities:

Third country (non-EU)/international organisationSafeguards in place to protect your personal data
Hotels, car rental agencies, rail lines, cruise lines, meeting and event plannersAll 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.
  • Retention period

CTS Systems will process personal data for only as long as required to collect commissions and will store the personal data that is associated with a payment electronically for up to seven years in order to comply with the auditing guidelines of the U.S. Internal Revenue Service.

  • Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  • 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.

  • Complaints

In the event that you wish to make a complaint about how your personal data is being processed by CTS Systems (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and CTS Systems’ data protection representatives GDPR Owner.

The details for each of these contacts are:

 Supervisory authority contact detailsGDPR Owner contact details
Contact Name:Information Commissioners OfficeHolly Mechsner
Address line 1: 4400 Northpoint Pkwy.
Address line 2: Suite 160
Address line 3: Alpharetta, GA  30022
Email:privacyshield@ico.org.ukGDPR.US@CTSsystems.com
Telephone:  +44 1625 545 700+1-678-503-4015

4. Online privacy statement

Personal data

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

“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

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 1:4400 Northpoint Pkwy.
Address line 2:Suite 160
Address line 3:Alpharetta, GA  30022
Email:gdpr.us@ctssystems.com
Telephone:+1-678-503-4015

Change History Record

IssueDescription of ChangeApprovalDate of Issue
1Initial issueMark Lewington05/23/2018
2Review – No ChangeMark Lewington05/19/2019
3Review – No ChangeMark Lewington05/18/2020
4Review – UK AdditionMark Lewington05/19/2021