Privacy Statement for Business Partners

This Privacy Statement explains how the Allbookers.com group of companies processes personal data concerning individuals, employees, owners, or representatives acting on behalf of our (existing, former, or potential) Business Partners

In this document, Allbookers.com group companies may be referred to as "we," "us," "our," or "Allbookers.com." Individuals, employees, owners, or representatives acting on behalf of our Business Partners may be referred to together or separately as "you," "your," or "Business Partners."

Within the context of this Privacy Statement, the term "Business Partners" may refer to:

• Trip providers,
• Travel agencies,
• Third party vendors,
• Ground transportation companies,
• Payment service providers,
• Other business partners enabling Trip reservations through their websites and/or apps (or other means),
• And natural or legal persons maintaining a business relationship with a Allbookers.com group company.

This Privacy Statement applies to any Allbookers.com group company responsible for the processing of personal data concerning a Business Partner. Depending on the nature of the business relationship, different Allbookers.com group companies may be responsible for the processing of that personal data

To find out if and to what extent other Allbookers.com group companies are responsible for the processing of your personal data, please review the information provided below. Information is also provided in your agreement with Allbookers.com and made available on our online platforms (such as sign up pages or procurement management platforms). Alternatively, you can contact us at[email protected]

Terms We Use in This Privacy Statement

"Trip" refers to the various travel products and services that can be ordered, acquired, purchased, bought, paid for, rented, provided to, reserved by, combined by, or consumed by end users, from the Trip Provider.

"Trip Provider" means the provider of accommodation (e.g., hotel, motel, apartment, bed & breakfast, landlord, and generically referred to as "accommodation partner"), attractions (e.g., (theme) parks, museums, sightseeing tours), transportation provider (e.g., car rentals, cruises, rail, taxi, airport rides, coach tours, transfers), tour operators, travel insurances, and any other travel or related product or service as from time to time available for Trip Reservation on our platforms.

"Trip Service" means the online purchase, order, (facilitated) payment or reservation service as offered or enabled by Allbookers.com in respect of various products and services as from time to time made available by Trip Providers on the platform.

"Trip Reservation" means the order, purchase, payment, booking, or reservation of a Trip.

Data Collection

The personal data Allbookers.com collects in regards to Business Partners depends on the context of the business relationship and their interaction with Allbookers.com, the choices made by the Business Partner and the products, services, and features they use.

Please note that the data items in the sections below are only considered "personal data" when concerning a natural person (meaning an individual human being). These data items are not considered "personal data" when concerning a legal person or entity.

The personal data Allbookers.com collects about our Business Partners can include the following:

Personal data you give to us

• Contact details

  We collect contact data from our Business Partners, such as first and last name, date of birth (as required), addresses, business email addresses, telephone, and fax numbers.

• Financial data

  We collect data necessary for payment and invoicing purposes (including your bank details, bank account number, and VAT number) and data otherwise necessary for the processing of credit slips

• Verification details

  Allbookers.com can ask (representatives of) Business Partners to provide a copy of company registration documents, their ID card or passport, a photo, a video, or other relevant information to verify the authenticity of the Business Partner. This may also include proof-of-licenses or tax information.

• Other data

  When a Business Partner communicates with Allbookers.com, we collect and process information about these communications. During calls with our support center, live listening may be conducted and calls may be recorded for quality control and training purposes. These recordings may also be used for the handling of claims and fraud detection purposes.

  Recordings are kept for a limited amount of time before being automatically deleted, unless Allbookers.com has a legitimate interest to keep the recording for longer. This only happens in exceptional cases, such as for fraud investigation, compliance, and legal purposes.

Information we collect automatically

Depending on the business relationship, Allbookers.com may also collect information automatically- some of which may be personal data. This data is collected when a Business Partner uses online services such as a registration form, a user account (e.g., for the Extranet or partner center), a vendor management platform, or a Allbookers.com app, like Pulse.

The data collected may include:

• Language settings,
• IP address,
• Location,
• Device settings,
• Device operating system,
• Log information,
• Time of usage,
• URL requested,
• Status report,
• User agent (information about the browser version),
• Result (viewer or booker),
• Browsing history,
• User Allbookers ID,
• Device identifiers such as Android ID, MAC Address, IMEI,
• And the type of data viewed.

Personal data you give to us about others

By sharing other individuals' personal data for business purposes-such as data belonging to your staff members-you confirm that these individuals have been informed about the use of their personal data by Allbookers.com in accordance with this privacy statement. You also confirm that you have obtained all necessary consent, as required by the laws and regulations applicable to you.

Other information we receive from other sources

• Information on insolvencies

  In insolvency matters, Allbookers.com can receive information relating to Business Partners from insolvency administrators, courts, or other public authorities.

• Data related to law enforcement and tax authority requests

  Law enforcement or tax authorities can contact Allbookers.com with additional information about Business Partners in the event that they are affected by an investigation.

• Fraud detection and prevention, risk management, and compliance

  In certain instances, and as permitted by applicable law, Allbookers.com may need to collect data through third-party sources for fraud detection and prevention, risk management, and compliance purposes.

Processing Purposes

Allbookers.com uses the previously described Business Partner information, some of which may be personal data, as relevant, for the following purposess:

A. Registration and administration

Allbookers.com uses account details, contact details, and financial data to manage the business relationship with the Business Partner. This includes for registration and verification purposes.

Certain information, including a Business Partner's name and address, can be used for other purposes in accordance with the agreement entered into between the Business Partner and Allbookers.com. An example of this would be using an accommodation partner's contact details to enable Trip Reservations at their property through a third-party website.

B. Customer service

Allbookers.com uses the information provided by Business Partners (which may include personal data) to provide support services-for example, to respond to requests, questions, or concerns from Business Partners or customers.

C. Other activities, including marketing

If a potential Business Partner has not finalized online registration, Allbookers.com may send a reminder to complete the registration process. We believe that this additional service is useful to our (future) Business Partners because it allows them to complete the registration without having to fill out all registration details again.

Allbookers.com may invite Business Partners to attend and host events that we think might be relevant or of interest to them. We may also use personal data to offer and host online forums that enable Business Partners to find answers to frequently asked questions about the offering and usage of Allbookers.com products and services.

As relevant to the business relationship, Allbookers.com uses personal data for communications, including providing information about system or product updates, sending the Allbookers.com newsletter, inviting Business Partners to participate in referral programs or competitions or for other marketing communications. When we use personal data to send direct marketing messages electronically, we will offer appropriate opt-out options.

D. Messaging tools

Allbookers.com may offer Business Partners different means to communicate with (prospective or existing) guests before or after a reservation.

Business Partners can also contact Allbookers.com to forward reservation information or questions to guests, or communicate with guests using alias emails, which always include Allbookers.com as a recipient.

Allbookers.com may access communications between Business Partners and guests. We also use automated systems to review, scan, and analyze communications for the following purposes:

• Security,
• Fraud prevention,
• Compliance with legal and regulatory requirements,
• Investigations of potential misconduct,
• Product development and improvement,
• Research,
• Customer engagement (including to provide guests with information or offers we believe may be of interest to them),
• And customer or technical support.

Communications sent or received using Allbookers.com communication tools will be received and stored by Allbookers.com.

E. Analytics, improvement, and research:

Allbookers.com uses information provided to us, which may include personal data, for analytical purposes. This is part of our drive to improve Allbookers.com products and services and enhance user experience.

This data can also be used for testing purposes, troubleshooting, and to improve the functionality and quality of Allbookers.com's online services. We also invite Business Partners to participate in surveys and conduct other market research from time to time.

Certain Business Partners may be invited to join a dedicated online platform to interact with Allbookers.com and/or exchange experiences with other Business Partners.

Please consult the information Allbookers.com provides when you are invited to participate in a survey, market research or to join an online platform, to understand how your personal data may be treated differently than described in this Privacy Statement.

F. Security, fraud detection, and prevention

We process the information provided to us, which may include personal data, in order to investigate, prevent, and detect fraud and other illegal acts. This may be personal data a Business Partner has provided to Allbookers.com, for example, for verification purposes as part of the registration process, personal data collected automatically, or personal data obtained from third-party sources (including from guests).

Allbookers.com may also use personal data to facilitate investigation and enforcement by competent authorities, where necessary. For these purposes, personal data may be shared with law enforcement authorities.

Allbookers.com can also use personal data for risk assessment and security purposes, including the authentication of users, and we use third-party service providers for third-party risk management. These providers help us to assess the business risk profile of our Business Partners. They may also provide us with third-party due diligence reports, which, as permitted by applicable law, may include possible information about criminal convictions and offenses of owners or Business Partners.

G. Legal and compliance

In certain cases, Allbookers.com needs to use the information provided (which may include personal data) to handle and resolve legal disputes or for regulatory investigations, risk management, and compliance. We may also use it to enforce our agreement(s) with Business Partners or solve a complaint or claim involving a guest, as reasonably expected, and in accordance with internal policies and procedures.

In addition, we may need to share information about Business Partners (including personal data) where required by law or strictly necessary to respond to requests from competent authorities. This includes tax authorities, courts, other governmental, and public authorities or local municipalities (e.g., in relation to short-term rental laws).

If we use automated means to process personal data, which produces legal effects or significantly affects you or other natural persons, we will implement suitable measures to safeguard yours or the other person's rights and freedoms. This includes the right to obtain human intervention.

Legal Bases

As applicable for purposes A and B, Allbookers.com relies on the legal basis that the processing of the personal data is necessary for the performance of the agreement between the Business Partner and Allbookers.com. If the required information is not provided, Allbookers.com cannot register a Trip Provider or otherwise work with a Business Partner, nor can we provide customer service.

In view of purposes C to G, Allbookers.com relies on its legitimate interest to provide its services or obtain services from Business Partners, to prevent fraud and to improve its services. When using personal data to serve Allbookers.com's or a third party's legitimate interest, we will always balance the impacted individual's rights and the protection of their information against Allbookers.com's and/or the third party's rights and interests.

For purposes F and G, Allbookers.com also relies, where applicable, on compliance with legal obligations (such as lawful law-enforcement requests). Finally, where needed under applicable law, Allbookers.com will obtain your consent prior to processing personal data, including for marketing purposes or as otherwise required by law.

If you wish to object to the processing set out under C to E and are unable to find a way to opt out directly (for example, in your account settings), please contact [email protected]

Data Sharing

• Sharing with affiliates

  In order to support the use of the Allbookers.com services, your information (which may include personal data) may be shared with members of the Allbookers.com corporate group.

• Sharing with third parties

  We share Business Partners' information (which may include personal data) with third parties, as permitted by law and as described below:

  • Service providers (incl. suppliers). We share personal data with selected third-party service providers to provide our products and services, prevent and detect fraud, store data, and otherwise support our business processes, or so they can conduct business on our behalf.
  • Payment Providers and other financial institutions. To process payments between a Business Partner and Allbookers.com or a guest and a Business Partner, relevant personal data is shared with payment providers and other financial institutions.
  • Sanction list screening or risk management as required by applicable law.

• Sharing and disclosure of aggregated data

  We may share information with third parties in an aggregate form and/or another form that does not allow the recipient to identify you, for example, for industry analysis or demographic profiling.

International Data Transfers

The transmission of Business Partners' personal data, as described in this Privacy Statement, may include overseas transfer of this data. This may be to countries whose data protection laws are not as comprehensive as those of the country or countries in which you initially provided the information, including within the European Union. In such cases, we will protect your personal data as described in this Privacy Statement.

Where required by European law, we will put appropriate safeguards in place to ensure that such transfers comply with European privacy law. In particular, when personal data is transferred to third-party service providers, we establish and implement appropriate contractual, organizational, and technical measures with such providers.

These measures can be established using "Standard Contractual Clauses," approved by the European Commission, by examining the countries data may be transferred to and imposing specific technical and organizational security measures. Where applicable, you can ask us for a copy of these contractual agreements using the contact details provided below.

Security

We have procedures in place to prevent unauthorized access to and misuse of personal data.

We use appropriate business systems and procedures to protect and safeguard information, including personal data. We also use security procedures and technical and physical restrictions for accessing and using the personal data on our servers. Only authorized personnel are permitted to access personal data in the course of their work.

Data Retention

We will retain personal data for as long as deemed necessary to manage the business relationship with a Business Partner, to provide Allbookers.com services to a Business Partner and to comply with applicable laws (including those regarding document retention), resolve disputes or claims with any parties, and as otherwise necessary to allow us to conduct our business.

All personal data we retain about you as a Business Partner is subject to this Privacy Statement and our internal retention guidelines.

Your Choices and Rights

Depending on where you are located or the Allbookers.com entity processing your personal data, different rights may apply to the processing of that data, as set out in this privacy statement. As applicable:

• You can ask us for a copy of the personal data we hold about you,
• You can inform us of any changes to your personal data, or you can ask us to correct any of the personal data we hold about you,
• In certain situations, you can ask us to erase, block, or restrict the personal data we hold about you, or object to particular ways in which we are using your personal data,
• In certain situations, you can also ask us to send the personal data you have given us to a third party.

Where we are using your personal data on the basis of your consent, you are entitled to withdraw that consent at any time, subject to applicable law. Where we process your personal data based on legitimate interest or public interest, you also have the right to object at any time, subject to applicable law.

Regardless of your location or the Allbookers.com entity with which you are contracted, we rely on our Business Partners to ensure that the personal data we hold is complete, accurate, and current. Please always inform us promptly of any changes to or inaccuracies in your personal data.

Contact Us

If you have questions, requests, or concerns about how we process your personal data, or would like to exercise any of the rights you have under this Privacy Statement, contact our data protection officer at [email protected].You can also contact your local data protection authority.

We address privacy specific questions, requests, and concerns that are reported to us using internal policies and procedures based on applicable privacy laws, regulations, and guidance. We revisit and enhance these policies and procedures regularly, also taking into account Business Partner feedback.

Changes to This Privacy Statement

Just as our business is always changing, this Privacy Statement also changes from time to time. If we plan to make material changes or changes that have an impact on you, we will always contact you in advance. An example of this kind of change would be if we were to start processing your personal data for purposes that aren't detailed above.