Our Commitment to Your Privacy
We Will Not Share Your Personal Information
We value your business and respect your privacy. We operate a strict opt-in only policy. We will not send you any information unless you have requested it, or unless someone, who we will identify, has requested that we pass that information on to you. At no time will we share, sell, rent or make available in any other way any information you have provided to us or we have collected by tracking your usage of our website.
If you wish to be removed from our list (opt-out), you can do so by clicking on the link at the bottom of each email communication you receive from us.
General Data Policy
Repose, LLC collects, stores and processes data, including Personally Identifiable Information (PII) through various tools and software, for the sole purpose of doing business. Data is only shared in a secure format with employees, contractors, suppliers and suppliers’ subcontractors for the purpose of securing or arranging or offering a travel experience. Repose, LLC is careful to only divulge the information specific to provide the service or offer and never shares data unnecessarily. Data is never shared with any person or entity without a specific operational purpose and data is never sold. You have the right to retrieve your data and have your data erased from our systems at any time by contacting email@example.com.
GDPR Privacy Notice
This notice applies only to persons in the European Economic Area, which includes the European Union.
1. The Purpose of this Notice
This Privacy Notice provides mandatory information as required under Articles 13 and 14 of the European General Data Protection Regulation (GDPR) regarding the transparency of personal data processing. Definitions of certain terms are found in the GDPR.
2. The Data Controller for Personal Data
The Data Controller for the personal data processed by us is the Client Company of CADENCE TRAVEL (the employer of the natural person whose data is collected, hereafter referred to as the Data Subject). The Data Controller will pass personal data of their employees to CADENCE TRAVEL to manage travel on behalf of those employees in connection with their business.
CADENCE TRAVEL, as Data Processor acting on the instructions of the Data Controller under a written contract with them, will subsequently use that personal data to facilitate travel arrangements for the Data Subject. It is this contract which forms the ‘Legal Basis’ for the processing of personal data carried out by CADENCE TRAVEL in these circumstances.
CADENCE TRAVEL will also become a Data Controller if it collects additional personal data directly from a Data Subject. In these circumstances CADENCE TRAVEL will be acting under a ‘Legitimate Interest’ to legally process the data for the management of travel for the Data Subject and to fulfil the contractual requirements for its Client.
3. Your Rights
As a Data Subject you have the following rights under the GDPR:
* The right to be informed; This means anyone processing your personal data must make clear what they are processing, why, and who else the data may be passed to.
* The right of access; this is your right to see what data is held about you by a Data Controller.
* The right to rectification; the right to have your data corrected or amended if what is held is incorrect in some way.
* The right to erasure; under certain circumstances you can ask for your personal data to be deleted. This would apply if the personal data is no longer required for the purposes it was collected for, or your consent for the processing of that data has been withdrawn, or the personal data has been unlawfully processed.
* The right to restrict processing; this gives the Data Subject the right to ask for a temporary halt to processing of personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.
* The right to data portability; a Data Subject has the right to ask for any data supplied directly to the Data Controller by him or her, to be provided in a structured, commonly used, and machine-readable format.
* The right to object; the Data Subject has the right to object to further processing of their data which is inconsistent with the primary purpose for which it was collected, including profiling, automation, and CADENCE marketing.
* The right not to be subject to a decision based solely on automated processing.
* The right to make a complaint directly to a supervisory authority within the Data Subject’s country.
4. Contact Details
The identity and contact detail for the Data Protection Officer within CADENCE TRAVEL is:
Chief Privacy Officer
5. Data Protection Principles
CADENCE TRAVEL has adopted the following principles to govern its collection and processing of Personal Data:
* Personal Data shall be processed lawfully, fairly, and in a transparent manner.
* The Personal Data collected will only be those specifically required to fulfill travel, accommodation, or other travel-related requirements.
Such data may be collected directly from the Data Subject or provided to CADENCE TRAVEL via his /her employer. Such data will only be processed for that purpose.
* Personal Data shall only be retained for as long as it is required to fulfill contractual requirements, or to provide statistics to our Client Company.
* Personal Data shall be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are collected and/or processed. Personal Data shall be accurate and, where necessary, kept up to date.
* CADENCE TRAVEL will not use personal data for any monitoring or profiling activity or process, and will not adopt any automated decision making processes.
6. Transfers to Third Parties
To fulfill the travel arrangements for a Data Subject it will in most cases be necessary to process personal data via a third party (these will include but are not limited to airlines, hotels, car rental companies, and Visa or Passport companies). Personal Data shall only be transferred to, or processed by, third party companies where such companies are necessary for the fulfillment of the travel arrangements.
Personal Data shall not be transferred to a country or territory outside the European Economic Area (EEA) unless the transfer is made to a country or territory recognized by the EU as having an adequate level of Data Security, or is made with the consent of the Data Subject, or is made to satisfy the Legitimate Interest of Repose, LLC in regard to its contractual arrangements with its clients