Last Update: September 1st, 2009
1. Scope
This Privacy Notice applies
to easyTravel Web sites. Our strategy regarding privacy
and personal information is to protect the personally identifiable information
(PII) of its customers, business partners, and employees that is in
its possession at any given time within its organization. This protection
also applies to any PII collected, used or retained by easyTravel in
its dealings with third parties.
easyTravel has the responsibility
to ensure compliance with applicable privacy legislation when identifying
purposes, obtaining consent, providing notice, or responding to access
requests or complaints regarding the collection, use, or disclosure
of personal information.
easyTravel will act responsibly
while collecting, using, and disclosing personal information, as this
is a prerequisite to continued customer, partner, and employee confidence
and loyalty.
In accordance with the
Generally Accepted Privacy Principles (GAPP) derived from the Fair Information
Practices of the Organization for Economic Co-Operation and Development
(OECD), easyTravel will demonstrate compliance with its privacy policies
through the creation and enforcement of such policies and other supporting
documentation.
2. Collection and
Use of Personal Information
You may choose to provide
personal information through our web sites. Here are the ways in which
you may provide the information and the types of information you may
submit. We also provide below some information on how we may use the
information.
2.1 Contact Us
If you communicate with
us through the "Contact Us" link on our web sites, we may ask you
for information such as your name, email address and telephone number
so we can respond to your questions and comments. We also may use the
information you provide to evaluate the quality of our products.
2.2 Request a Quote
If you request a quote
from us, we ask you to provide details such as your name, email address,
telephone number and details of the relevant product. We use your details
to prepare and send you a quote. You may also choose to provide additional
comments and requests through our free text box.
2.3 Online Order,
Product Registration, Customer Account
If you submit an order
on-line with us, we will ask you for information necessary to complete
the transaction - such as your name, address, and credit card number,
and to allow you to purchase and download products, obtain access to
service and technical support, or otherwise utilize products or services
that you have selected, as well as technical data concerning your computer
or traffic data incidental to your Internet connection.
Additionally, you may
be asked in cases where software is sold pursuant to subscription, to
establish an account with us in order to obtain the software, and establish
entitlement to upgrades and updates required for the easyTravel software
to provide ongoing protection in accordance with its function.
This information will
be used by easyTravel to ensure your entitlement for renewal, support
and other services. The processing and transfer of the data are limited
to the following purposes: fulfillment of your order(s)/contract(s),
extension/delivering product updates/service-subscriptions or licenses,
product registration and activation, customer and technical support
as you may request it from time to time, processing license renewals
as you may request it from time to time, automatically processing license
renewals if you elect automatic renewal of your software license subscription
and internal (compliance) audits and fraud prevention.
2.4 Technical Support
If you request technical
support online, we will ask you for information necessary to complete
the transaction - such as your name, address and information about
your computer hardware, software and the nature of the problem you are
experiencing. Additionally, if required to facilitate support, we may
with your permission conduct an interactive session in which a easyTravel
technical support assumes control of your computer.
No information is retained
from such sessions beyond information to substantiate that such session(s)
took place. Information concerning technical issues may be retained
to provide you with continuing support; generally, the information and
knowledge obtained from such support, though not linked to you personally,
may be made available to technical and product specialists in order
to improve our products or provide similar solutions to similar technical
issues encountered by other easyTravel customers.
2.5
Web-site Forum or Networking Site
easyTravel operates forums,
web sites and related information services to better assist its customers
in using its products and services, discuss technical issues, and share
experience and knowledge. To permit you to obtain access to these information
services, to assist us in creating content that is relevant to you,
and to improve your experience on our Web site, including helping you
quickly find software, services or product information important to
you we collect information on your name and e-mail address, and keep
track of your preferences concerning the display or location of relevant
information. We utilize the information obtained from these sites to
improve our products and services.
2.6 Newsletter
or Alerts
You may wish to receive
information about product upgrades, new products, services, newsletters,
informative emails, and research on future product ideas or improvements.
If so, you will be asked to provide your name and e-mail address. If
there is any use beyond contacting you using such information, you will
be advised of the intended uses at the point that you are being asked
to provide such contact information.
2.7 Transactional
Emails
We may from time to time
send you transactional emails such as order confirmations or information
on service related issues. Because these emails are not promotional
in nature you are not able to unsubscribe from these transactional emails.
2.8 Product or
Service Information, Offers or Promotions
To provide you with promotions
or special offers that may be of interest to you, you may be asked to
provide us with your name, address and e-mail address information, as
well as to confirm that you are of the age of majority in the jurisdiction
in which you reside. You may be asked to provide additional information
to better understand you and possibly your organizations' needs and
experiences, opinions, as well as your experience or feedback in order
to qualify for such contests or promotions. We will also use your personal
information to award prizes if applicable. If there is any use beyond
contacting you with such information, you will be advised of the intended
uses at the point that you are being asked to provide such contact information.
2.9 Feedback or
Test Software
To assist us in creating
better products and services to meet your needs, we may solicit your
opinions and feedback concerning our software and services; you may
be asked to provide e-mail address information, as well as name, postal
address, occupation and the name of your organization, if you have not
already done so, as well as the opinions and feedback itself.
2.10 Careers
You may be able to submit
your resume and other information online to apply for a job with easyTravel.
The information you provide in connection with your job search will
be maintained in a database that is managed by a third party service
provider we have retained to help us conduct recruitment-related activities.
Our service provider
is authorized to use the information only in connection with hosting,
managing and maintaining our resume database. We use the information
you submit to evaluate your interest in employment and to contact you
regarding possible employment with the company.
2.11 Referral Service
If you choose to use
our referral service to tell a friend about our site, we will ask you
for your friends name and email address. We will automatically send
your friend a one-time email inviting him or her to visit the site.
easyTravel does not store your friends name and email address after
sending the one-time email. Note that this is not available in jurisdictions
where this method of referral is prohibited, such as the European Union.
You make the decision
whether to proceed with any activity that requests personal information.
If you do not wish to provide the requested information, however, you
may not be able to complete the transaction or functionality on the
site if the information is essential to complete the transaction or
functionality. .
2.12 Cookies
easyTravel may use cookies
from time to time. A cookie is a unique text file that a web site can
send to your browser software. Cookies enable a web site to tailor information
presented to you based on your browsing preferences. easyTravel may use
cookies to personalize web pages during your visit to our web sites,
and/or to remember you for easy navigation and access during your return
visits after registering for our products, services and other offers
including but not limited to White Papers, Webcasts, events, evaluation
software, e-books, etc. For these purposes, some cookies may be tied
to your e-mail address.
easyTravel may also use
cookies to track your visit to our web sites in order to collect aggregate
data. However, this information will only be used for analytical purposes
and will be limited to the minimum necessary to perform the analysis.
If you do not want easyTravel to deploy cookies in your browser, you
can set your browser to reject cookies or to notify you when a web site
tries to put a cookie in your browser software. Rejecting cookies may
affect your ability to use of some of the products and/or services at
our Web site.
2.13 Web Beacons
easyTravel may use Web
Beacons (also known as single pixel or clear GIFs) on its web sites
to analyze traffic patterns such as the frequency of use of particular
parts of the site. The data collected helps us learn what information
is of most interest to our customers and what offers our customers would
most like to see. If you do not want to assist easyTravel in improving
its Web sites, you can "opt-out" of this web sites analysis by disabling
JavaScript on your computer. If you disable JavaScript, some of the
features on our web sites will not work.
easyTravel may also use
web beacons in promotional email messages to determine whether the message
was opened and acted on. We may use this information on email response
to develop future promotions you may enjoy. For these purposes, some
of our Web beacons are tied to your e-mail address. Except for the email
address you have previously provided, the information we collect does
not identify you.
easyTravel may also use
third party scripts on our sites to optimize the effectiveness of easyTravel's
ads appearing on other parties' sites. The information collected is
not personally identifiable and is limited to the minimum information
necessary to optimize effectiveness.
3. Management of
Privacy
3.1 Opt-in and
Opt-out
In jurisdictions where
your consent is required at the point of collection before any sharing
of your information can take place, you will be given the option to
opt-in before such information is being shared, and to opt-in to the
transfer of your contact information to a third party.
In other jurisdictions,
we may offer you these choices at the time you give us your information,
or subsequently through "opt-out" mechanisms.
3.2 Other Privacy
Considerations
Please remember that
information you submit in a discussion groups or forums will be deemed
public information and will not be kept as confidential. There is a
risk in such communication venues that information can be collected
and used by others. Please be careful and responsible when you are participating
in such discussion groups or forums.
3.3 Update or Correction
of Personal Information
We make our best effort
to respond to your requests to update or correct your personal information.
If you believe that easyTravel does not have your most current personal
information, you can use one of the other communication channels at
the bottom of this notice. If requested, and to the extent permissible
by applicable law relating to the retention of records or otherwise
not required for valid business purposes (such as fulfillment of transactions),
you may request that we use our best efforts to remove such data from
easyTravel repositories.
4. Transfer and
Sharing of Information
4.1 Transfer of
Information
Since easyTravel is a
global company, we provide company information to our worldwide offices,
with information processing taking place in many countries. The personal
information that you have provided to us, for the purposes set out above,
will be transferred to servers in the United States, and there may be
further transfers to other countries in which easyTravel has operations
or to our outside contractors for the collection, transferring, storage
and processing of your information. Your consent is required for the
provision of the products and services set out above as well as for
the collection and transfer of your personal information for the purposes
identified above.
When you submit your
information via our web sites, you expressly consent to the collection
and transfer of your personal information for the purpose identified
above, and you understand, if you reside outside the United States,
that this information may be transferred to other companies of the easyTravel
group in the United States or to other countries that may have less
protective data protection standards than the region in which you are
situated (including the European Union), in which case easyTravel will
have taken steps to ensure that the collected information, if transferred,
receives an adequate level of protection.
4.2 Sharing of
Information
From time to time, and
in jurisdictions where it is permitted, we may provide your information
to easyTravel Partners to communicate to you information or offers
about products or services that they believe are important to you or
your business. If you prefer that we not provide your information to
our business partners, you may let us know using one of the methods
described in this policy, easyTravel provides a number of ways for you
to "opt-out" of receiving additional information from us or
having us provide your personal information to our partners by "opt-out"
options provided at the point of collection, through e-mail notices,
or through other preference management that may be available depending
on the service or web-site.
If you do not wish to
continue receiving our e-mail newsletters or bulletins you can opt-out
of receiving these communications by replying to the "unsubscribe"
address in the body of the email. In jurisdictions where sharing personal
information is prohibited without your "opt-in", no information
will be shared without your prior consent.
4.3 Third Parties
In addition, easyTravel
may retain the services of outside contractors to provide services for
us (e.g. ship products, provide technical support, or handle order processing).
If you elect to purchase
a software license through one of easyTravel' authorized online resellers,
your personal data will need to be shared between the easyTravel reseller
(as your vendor) and easyTravel (as the software manufacturer and licensor).
Furthermore, in order to manage purchases and license renewals by easyTravel
customers, easyTravel will need to share your personal information with
a billing system service provider.
Such service provider
will process data of easyTravel' customers only on behalf of easyTravel.
(These examples are not exhaustive, and may change from time to time).
We require that all such
contractors keep the personal information of our customers secure and
confidential. We have contractually bound third parties to such restrictions
and require that these contractors provide for appropriate technical
and organizational measures to secure the data, that they use personal
information only on behalf of easyTravel and that they do not share personal
information with others or use your personal information for their own
marketing purposes.
4.4 Legal Disclosures
Please be advised that
in certain instances, it may be necessary for easyTravel to disclose
your personal information to government officials or otherwise as required
by applicable law. No personally identifiable information will be disclosed
to any law enforcement agency or governmental agency except in response
to (i) a subpoena, warrant or other process issued by a court of competent
jurisdiction; or (ii) a legal process having the same consequence as
a court-issued request for information, in that easyTravel would be in
breach of local law were it to refuse to provide such information, and
it or its officers, executive or employees would be subject to liability
for failing to honor such legal process, or,
Where such disclosure
is necessary for easyTravel to enforce its legal rights pursuant to the
laws of the jurisdiction from which such information was gathered.
5. Security of
Personal Information
We have taken appropriate
security measures, consistent with international information practices,
to protect your personal information. These measures include, on our
web sites and Internet-enabled technologies, administrative, technical,
physical and procedural steps to protect your data from misuse, unauthorized
access or disclosure, loss, alteration, or destruction.
6. Collection and
Use of Non-Personal Information
We collect certain aggregate
and non-personal information when users visit our web sites. Aggregate
and non-personal information does not relate to a single, identifiable
visitor. It tells us information such as how many users visited our
sites and the pages accessed. By collecting this information, we learn
how to best tailor our web sites to our visitors. We collect this information
either through "cookie" technology or with "web beacons".
Additionally and through
our various tracking methods discussed above and using log files, we
may track domain names, IP addresses, and browser types from people
who visit our site. We use this information to track aggregate traffic
patterns throughout easyTravel' Web site. Such information is not correlated
with any personal information.
7. Links to
OTHER WEB SITES
At the easyTravel Web
sites, there are a number of links to companies with whom we have a
relationship.
easyTravel is not responsible
for the privacy practices of our business partners. We encourage you
to read their privacy statements, as they may differ from ours.
8. AMENDMENTS AND
CHANGES
In the event there is
a major change to easyTravel's privacy practices, a prominent notice
will be posted on our Web site. If the change involves the use of your
personally identifiable information, the notice will contain instructions
on how you can opt-out of such use.
9. Contact easyTravel
If you have any questions
or comments concerning this notice, or if you would like to change your
communication preferences, update or review the personal information
we have about you, or withdraw your consent for the collection, use
or disclosure of your personal information, please contact us: 
