Privacy Policy

Version 2.0

Effective Date: November 9th, 2016

Travelator, Inc., doing business as TravelBank, (“TravelBank”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect from users of our websites, located at TravelBank.com or Travelator.com, our mobile application (“Application(s)”) (collectively, the “Site”), and our online services (“Services”), who are using the Services as individual users or as part of a TravelBank Network.

  1. Definitions.

    Terms used in the Privacy Policy have the meaning set forth in this Privacy Policy or the TravelBank Terms of Use.

    1. “Company” means the legal entity that owns the rights to the domain included in the e-mail address that a user provides when he or she creates an Account with TravelBank. The Company will generally be a user’s employer. “Company” does not include a legal entity that operates an e-mail service (e.g. Hotmail, Yahoo, etc.) (an “E-Mail Service Entity”) unless one or more Managers employed by such E-Mail Service Entity have created a TravelBank Department Network(s) or TravelBank has an agreement with that E-mail Service Entity pursuant to which that entity has created a TravelBank Company Network.
    2. “Department” is a group, department or other unit of a Company.
    3. “Manager” is a user who identifies himself or herself as a Manager when the user creates an Account with TravelBank. A Manager may register himself or herself as an Employee within the same or another TravelBank Department Network, or within the TravelBank Company Network, to which the Manager belongs.
    4. “TravelBank Company Network” is a network which is created by a Manager on behalf of the entire Company when the Company enters into an agreement with TravelBank for such TravelBank Company Network. At such time as the Company elects to create a TravelBank Company Network, any then-existing TravelBank Department Network within that Company will automatically become a part of the TravelBank Company Network. The TravelBank Company Network will be overseen by an administrator named by the Company (“Company Administrator”) who shall be responsible for the use and sharing of all information, data, and other content posted to the TravelBank Company Network.
    5. “TravelBank Department Network” is a network for a Department which is created by a Manager. The Manager who creates the TravelBank Department Network shall be responsible for the use and sharing of all information, data, and other content posted to the TravelBank Company Network.
    6. “TravelBank Network” is either a TravelBank Department Network or a TravelBank Company Network.
    7. “Employee” is a user who identifies himself or herself as an Employee when the user creates an Account with TravelBank. An Employee may also register as a Manager within the same or another TravelBank Department Network, or within the TravelBank Company Network, to which the Employee belongs.
  2. Questions; Contacting TravelBank; Reporting Violations.

    If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at privacy@travelbank.com.

  3. User Consent.

    By submitting Personal Data through our Site or Services, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use and disclosure of your Personal Data in accordance with this Privacy Policy.

  4. A Note About Children.

    We do not intentionally gather Personal Data from visitors who are under the age of 13. If a child under 13 submits Personal Data to TravelBank and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a child under 13, please contact us at privacy@travelbank.com.

  5. A Note to Users Outside of the United States.

    If you are a non U.S. user of the Site, by visiting the Site and providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country. By providing your data, you consent to such transfer.

  6. Types of Data We Collect.

    “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.

    1. Information You Provide to Us.

      • We may collect Personal Data from you, such as your first and last name, gender, e-mail and mailing addresses, professional title, the name of your department or unit within your Company, the name of your Company, and your password when you create an account to log in to our network (“Account”). We may also collect reporting information such as the person you report to and your direct reports within the Company.
      • If you use our Services on your mobile device, including through our Application(s), we may collect your phone number and the unique device id number.
      • If you enable your mobile device to send us your location, we may store and use that information to provide you with location-based information and advertising. If you want to deactivate this feature, you can either uninstall the Application(s) or deactivate GPS on your mobile device.
      • If you use our Site or our Services to prepare budgets using our Travelator Budget Creator tool, we will collect information that you input into the tool as well as the email address of any individuals to whom you send such budgets.
      • If you use our Services, we will collect information about your travel itinerary, expenses and other information that you submit via the Application.
      • Our mobile homepage lets you store preferences like your location, safe search settings, and favorite widgets. We may associate these choices with your ID or the mobile device, and you can edit these preferences at any time on our mobile homepage.
      • When connecting to our Services via a service provider that uniquely identifies your mobile device, we may receive this identification and use it to offer extended services and/or functionality.
      • Certain Services may require our collection of your phone number. We may associate that phone number to your mobile device identification information.
      • We retain information on your behalf, such as files and messages that you store using your Account.
      • If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
      • When you post content (text, images, photographs, messages, comments or any other kind of content that is not your e-mail address) on our Site, the information contained in your posting will be stored in our servers and other users within your Company will be able to see it, along with your profile photo and any other information that you choose to make public on your profile page (“Profile”). The information that you provide in your Profile will be visible to others within the TravelBank Network(s) to which you belong.
      • When you participate in one of our surveys, we may collect additional profile information.
      • We also collect other types of Personal Data that you provide to us voluntarily, such as your operating system and version, product registration number, and other requested information if you contact us via e-mail regarding support for the Services.
      • If you participate in a sweepstakes, contest or giveaway on our Site, we may ask you for your e-mail address and/or home number (to notify you if you win or not). We may also ask for first and last names, and sometimes post office addresses to verify your identity. In some situations we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules for each sweepstakes and contest that you enter.
      • We may also collect Personal Data at other points in our Site that state that Personal Data is being collected.
    2. Financial Information

      We use Plaid Technologies, Inc. (“Plaid”) to gather your Personal Data from financial institutions. By using our Services, you grant TravelBank and Plaid the right, power and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored and processed by Plaid in accordance with the Plaid Privacy Policy. To see the Plaid Privacy Policy, please go to https://plaid.com/legal.

    3. Information You Provide to Facebook and other Social Networking Sites (SNS).

      The Services will allow users to access Facebook, Twitter, Linkedin and other SNS to interact with friends and to share on Facebook through Wall and friends’ News Feeds. In the future, the Services may allow you to merge your profiles if (i) you are already logged into the Services and Facebook or another SNS, by clicking on “Connect with Facebook,” or a similar connection on another SNS, and (ii) If you are already logged into the Services but not logged into Facebook or another SNS that we support, by clicking on “Connect with Facebook,” or a similar connection on another SNS, you will be prompted to enter your SNS credentials or to “Sign Up” for the SNS. By proceeding, you will allow the Services to access your information and you will be agreeing to the Facebook or other SNS’s Terms of Use in your use of the Services. Conversely, if you are not registered as a user of the Services at that time, and you click on “Sign in” using Facebook or another SNS that we support, you will first be asked to enter your Facebook or SNS credentials and then be given the option to register for the Services. In this case, we may receive information from Facebook or another SNS to make it easier for you to create an Account on the Site and show our relevant content from your Facebook or SNS friends. Once you register on the Site and connect with Facebook or another SNS, you will be able to automatically post recent activity back to Facebook or the other SNS. Any information that we collect from your Facebook or other SNS account may depend on the privacy settings you have with that SNS, so please consult the SNS’s privacy and data practices. You have the option to disable Facebook Connect at any time by logging into your Account through the Site and going to settings, “About Me,” “Linked Accounts,” and then unselecting “Facebook.” Further, you can disconnect your Services activity stream by visiting the Facebook Applications Settings page.

    4. Information Collected via Technology.

      • Information Collected by Our Servers. To make our Site and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
      • Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Site, track users’ movements around the Site, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Site or the Services again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests. Except as noted in this Privacy Policy, we do not link this automatically-collected data to Personal Data.
      • Cookies. Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your browser) and persistent Cookies (which stay on your computer/mobile phone until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs.
      • Pixel Tags. In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users’ Personal Data.
      • Mobile Services. We may also collect non-personal information from your mobile device if you have downloaded our Application(s). This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your geographic location, how you use the Application(s), and information about the type of device you use. In addition, in the event our Application(s) crash on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our Application(s). This information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual.
      • Analytics Services. We use third party analytics services, including but not limited to Google Analytics (“Analytics Services”), to help analyze how users use our Site and Services. We use the information we get from Analytics Services only to improve our Site and Services. The information generated by the Cookies or other technologies about your use of our Site and Services (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity. The Analytics Services may also transfer the Analytics Information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Service’s ability to use and share Analytics Information is restricted by such Analytics Service’s Terms of Use and Privacy Policy. By using our Site and Services, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above. For a full list of Analytics Services, please contact us at privacy@travelbank.com.
    5. Information Collected from You About Others.

      If you decide to invite a third party to review a budget you prepare using our Travelator Budget Creator tool, or to create an Account, we will collect your and the third party’s names and e-mail addresses in order to send an e-mail and follow up with the third party. We rely upon you to obtain whatever consents from the third party that may be required by law to allow us to access and upload the third party’s name and e-mail address as required above. You or the third party may contact us at privacy@travelbank.com to request the removal of this information from our database. The e-mail that is sent to the third party will come from your e-mail address so that the third party will know that you want to invite him or her to review your budget or create an Account on our Site.

    6. Information Collected from Your Company.

      In the event you are, or you become, part of a TravelBank Network, the Company Administrator for a TravelBank Company Network, or the Manager for a TravelBank Department Network, may provide us with your name, e-mail information, and other information related to your role within the Company or the TravelBank Network.

    7. Information Collected from Third Party Companies.

      We may receive Personal and/or Anonymous Data about you from companies that provide our Services by way of a co-branded or private-labeled website or companies that offer their products and/or services on our Site. These third party companies may supply us with Personal Data. We may add this information to the information we have already collected from you via our Site in order to improve the Services we provide.

    8. Location Information.

      If you have enabled location services on your phone, we collect your location information to make a map available to the recipients of your messages showing your location. If you do not want this information collected by us, you can disable location services on your phone.

    9. How We Respond to Do Not Track Signals.

      We do not currently respond to “do not track” signals or other mechanisms that might enable consumers to opt out of tracking on our Website.

  7. Use of Your Personal Data

    1. General Use.

      In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways, e.g.,

      • Prepare a budget using our Travelator Budget Creator tool and send the budget to a third party;
      • facilitate the creation of and secure your Account on our network;
      • identify you as a user in our system;
      • provide improved administration of our Site and Services;
      • provide the Services you request;
      • improve the quality of experience when you interact with our Site and Services;
      • send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
      • send you administrative e-mail notifications, such as budget and expense notifications, security, or support and maintenance advisories;
      • respond to your inquiries related to employment opportunities or other requests;
      • make telephone calls to you, from time to time, as a part of secondary fraud protection or to solicit your feedback; and
      • send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of TravelBank.
    2. User Testimonials and Feedback.

      We often receive testimonials and comments from users who have had positive experiences with our Services. We occasionally publish such content. When we publish this content, we may identify our users by their first and last name and may also indicate their home city. We obtain the user’s consent prior to posting his or her name along with the testimonial. We may post user feedback on the Site from time to time. We will share your feedback with your first name and last initial only. If we choose to post your first and last name along with your feedback, we will obtain your consent prior to posting your name with your feedback. If you make any comments on a blog or forum associated with our Site, you should be aware that any Personal Data you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these blogs and forums.

    3. Creation of Anonymous Data.

      We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.

  8. Disclosure of Your Personal Data.

    We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.

    1. Third Parties Designated by You.

      When you use the Services, the Personal Data you provide will be shared with the third parties that you designate to receive such information, including other websites, your friends, and business associates. Depending on the type of access you grant to such third parties, they may also be permitted to edit the information you have provided to us and to designate others to access and edit such information.

    2. Other Users in Your TravelBank Network(s).

      When you use the Services in your TravelBank Network(s), the Personal Data you provide may be shared with other users in those TravelBank Network(s) solely for the purpose of providing the Services.

    3. Third Party Service Providers.

      We may share your Personal Data with third party service providers to: provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to TravelBank. These third party service providers are required not to use your Personal Data other than to provide the services requested by TravelBank.

    4. Affiliates.

      We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.

    5. Corporate Restructuring.

      We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

    6. Social Networking Sites.

      Some of our Applications and Services may enable you to post content to SNSs (e.g., Facebook or Twitter). If you choose to do this, we will provide information to such SNSs in accordance with your elections. You acknowledge and agree that you are solely responsible for your use of those websites and that it is your responsibility to review the terms of use and privacy policy of the third party provider of such SNSs. We will not be responsible or liable for: (i) the availability or accuracy of such SNSs; (ii) the content, products or services on or availability of such SNSs; or (iii) your use of any such SNSs.

    7. Disclosure to Company and Managers.

      In the event that you are, or become, part of a TravelBank Company Network, we will share your Personal Data with the Company and the Company Administrator(s). In the event that you are, or become, part of a TravelBank Department Network, we will share your Personal Data with the Manager of that TravelBank Department Network.

    8. Other Disclosures.

      Regardless of any choices you make regarding your Personal Data (as described below), TravelBank may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on TravelBank; (c) to protect or defend the rights or property of TravelBank or users of the Site or Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.

  9. Third Party Websites.

    Our Site may contain links to third party websites. When you click on a link to any other website or location, you will leave our Site and go to another site, and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your Personal Data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.

  10. Your Choices Regarding Information.

    You have several choices regarding the use of information on our Services:

    1. Email Communications.

      We will periodically send you free newsletters and e-mails that directly promote the use of our Site or Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information above). Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our Terms of Use or Privacy Policy.

    2. Cookies.

      If you decide at any time that you no longer wish to accept Cookies from our Services for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Services or all functionality of the Services. If you have any questions about how to disable or modify Cookies, please let us know at the contact information provided above.

    3. De-Linking SNS.

      If you decide at any time that you no longer wish to have your SNS account (e.g., Facebook) linked to your Account, then you may de-link the SNS account in the “preferences” section in your account settings. You may also manage the sharing of certain Personal Data with us when you connect with us through an SNS, such as through Facebook Connect. Please refer to the privacy settings of the SNS to determine how you may adjust our permissions and manage the interactivity between the Services and your social media account or mobile device.

    4. Changing or Deleting Your Personal Data.

      You may change any of your Personal Data in your Account by editing your profile within your Account. You may request deletion of your Personal Data by us, and we will use commercially reasonable efforts to honor your request, but please note that (ii) we may be required by the Company by which you have been employed to keep any Personal Data that was provided to any TravelBank Company Network to which you belonged during the term of your employment by the Company as either a contractor or an employee; and (ii) we may be required by law to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives and the archives of the TravelBank Networks to which you belonged. We may also retain your information for fraud or similar purposes.

    5. Applications.

      You can stop all collection of information by the Application(s) by uninstalling the Application(s). You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

  11. Changes to This Privacy Policy.

    This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your Personal Data, we will notify you by sending you an e-mail to the last e-mail address you provided to us and/or by prominently posting notice of the changes on our Site. Any changes to this Privacy Policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of notice of the changes on our Site. These changes will be effective immediately for new users of our Services. Please note that at all times you are responsible for updating your Personal Data to provide us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice. If you do not wish to permit changes in our use of your Personal Data, you must notify us prior to the effective date of the changes that you wish to deactivate your Account with us. Continued use of our Site or Services, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

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