Global Crew Logistics / CTC2 Privacy Policy

Effective Date: June 3,  2024

This Privacy Policy describes how Global Crew Logistics / CTC2 ("we," "us," or "our") collects, uses, and shares the personal information of corporate travelers when managing and facilitating travel services for our corporate clients ("Clients").

1. Our Role in Data Processing

For the personal data of travelers, we act primarily as a Service Provider (or "Processor") on behalf of our corporate Clients, who are the Data Controllers (or "Businesses"). The Client determines what data is collected and why, and we process it to fulfill our contractual obligation to manage their travel program.

A key component of our service involves the use of Global Distribution Systems (GDS), such as Sabre, which store the majority of transaction data required for booking.

2. Information We Collect and Retain

We receive and process information required to book and manage travel. However, much of the detailed, sensitive information is housed within the GDS platforms.

Information Retained by Global Crew Logistics / CTC2 for Direct Use and Corporate Reporting:

• Traveler Identification: Name of the corporate traveler.
• Trip Details: Booking reference, travel dates, and destination(s).
• Corporate Reportable Fields (Report Data): Employee ID, Department, Cost Center, Reason for Travel, and other fields defined by the Client's managed travel program.
• Contact Information: Business email and business phone number.
• Communication Data: Records of interactions, including emails and call logs related to support and booking changes.

Data Processed via GDS (Sabre):

In the course of making a booking, additional detailed personal and sensitive information is required and processed through the GDS (e.g., Sabre) and shared with suppliers, including passport details, date of birth, payment details, and sensitive preference data.

3. How We Use and Process Your Information

We use and process the data primarily to fulfill our agreement with the Client and specifically leverage the GDS to manage the booking lifecycle.

Purpose	Description
Facilitating Travel Services	We input and retrieve data from the GDS (Sabre) to process, confirm, and manage travel services with suppliers, and to issue travel documents.
Managing Corporate Programs	We use the traveler's name, trip details, and Report Data to ensure compliance with the Client's corporate travel policy and to charge the appropriate Client accounts.
Corporate Reporting	We use the retained Report Data (Employee ID, Department, etc.) in combination with transaction data pulled from the GDS to generate mandatory financial and compliance reports for the Client.
Duty of Care and Security	We access traveler location data housed in the GDS to provide the Client with traveler tracking capabilities to fulfill their duty of care obligations.

4. Disclosure and Sharing of Your Information

We share your personal data with third parties to successfully provide the contracted corporate travel services.

• Global Distribution Systems (GDS): All booking data is entered into and processed by a GDS, such as Sabre.
• Travel Suppliers: Your detailed travel data (from the GDS) is shared with airlines, hotels, car rental agencies, and other travel service providers.
• Client (Employer/Sponsor): We provide the Client and their authorized travel administrators or finance teams with Report Data and comprehensive travel expenditure reports.
• International Data Transfers: As travel management is global, your data may be transferred to suppliers and processors worldwide. We ensure appropriate safeguards are in place when required by law.

5. Data Security

We maintain appropriate security measures to protect the personal data we retain (primarily the Name, Trip Details, and Report Data) and rely on the security protocols of our **GDS partner (Sabre)** and other travel suppliers to protect the detailed transaction data housed in their systems.

6. Cookies and Tracking Technologies

We and our service providers use "cookies" and similar tracking technologies (such as web beacons and pixels) on our website and online booking tools to enhance user experience, analyze usage, and for marketing purposes.

• What are Cookies? Cookies are small files stored on your device that uniquely identify your browser and remember information about your visit.
• How We Use Them:
  • Essential Cookies: Necessary for the operation of our online booking tools and website (e.g., maintaining your session or remembering your login state).
  • Analytical/Performance Cookies: Help us understand how the website and booking tools are used, which pages are most popular, and identify errors to improve performance.
  • Functionality Cookies: Allow us to remember choices you make (such as language preferences) and provide enhanced, more personal features.
  • Advertising/Targeting Cookies: Used by third parties to build a profile of your interests and show you relevant advertisements on other sites.
• Your Choices: You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service or booking tools.

7. Your Rights

Your data privacy rights are primarily governed by the privacy policy of our Client, who is the Data Controller. You should direct any requests (e.g., access, correction, or deletion) to your employer (our Client) in the first instance.

8. Data Retention

We retain the traveler's name, trip details, and corporate Report Data for the duration required to satisfy our contractual obligations to the Client and any legal, accounting, or reporting requirements. After this period, we securely dispose of or anonymize the retained data.

9. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our data practices or relevant laws. We will notify our Clients of any material changes and update the "Effective Date" at the top of this policy.

10. Contact Information

If you have questions about this Privacy Policy or the personal data we process on your behalf, please contact:

Global Crew Logistics / CTC2
Attention: Privacy/Data Protection Officer
Address: 2699 Collins Ave. / Miami Beach, FL 33140
Email: privacy@ctc2.com
Phone: 305-576-3200