EFFECTIVE DATE: 17 October 2016
Should you have any questions about this policy, our data collection process, or the usage of the collected data, please contact us at:
Manager of Enterprise Security Services
Privacy and Compliance
Airline Tariff Publishing Company
Washington Dulles International Airport
45005 Aviation Drive, Dulles, VA 20166
ATPCO PRIVACY PRINCIPLES
We may create anonymous data records from personal information by excluding information (such as your name) that makes the data personally identifiable to you. We reserve the right to use anonymous data for any purpose and disclose anonymous data to third parties in our sole discretion. “Anonymous data” means data that does not, by itself, permit the identification of individual persons and that is not associated with or linked to personal information. For the avoidance of doubt, we may take airline pricing information that users provide, anonymize it, aggregate it with the anonymized data of other users, and then make such aggregated, anonymous data available to other users of our services.
Information We Collect
ATPCO collects and stores the following information to facilitate business communications and to aid problem resolution:
- First and last name
- Employment category (employee or contractor)
- Access authorizer name (the name of the person who last requested access on behalf of the recipient)
- Address information (street, city/province, country, postal code)
- E-mail address
This information is required when access is requested to ATPCO systems; subsequent updates are provided by either your organization’s access authorizer or you, the individual user.
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 your e-mail to us, in order to send you a reply.
We may also collect personal information at other points in our site, systems, or services that state that personal information is being collected.
Information Collected via Technology
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.
We also collect information through the use of technology such as Cookies, as further described in the section below entitled “Provisions Specific to European Users” except the data collection applies to individuals outside the EU as well.
Use of Personal Information
Disclosure of Your Personal Information
We share anonymous data, including airline pricing information, with other users of our services as described in the Introduction section above.
We may share your personal information with third-party service providers that conduct quality assurance testing, facilitate creation of accounts, provide technical support, and/or provide other services to ATPCO.
Access and Correction
ATPCO will provide users reasonable access to the information collected from them and take reasonable steps to allow any inaccurate or incomplete information to be corrected, amended, or deleted. Users with ATPCO accounts will receive periodic requests to review and update their data. Users also have the option to review and update their data at will by logging into FareManager and clicking on the “Update User Information” link.
PROVISIONS SPECIFIC TO EUROPEAN USERS
ATPCO’s role as data processor in performing services for users
Where we process Personal Data (as defined below) that is controlled by our users in the performance of our services for them, for the purposes of Directive 95/46/EC of the European Parliament (the "EU Directive"), ATPCO is a data processor. ATPCO agrees that it will treat Personal Data processed by it on behalf of its users in accordance with applicable provisions of the EU Directive, this Policy, and our agreements with our users.
ATPCO’s role as a data controller
For the purposes of the EU Directive, ATPCO will be a data controller in respect of Personal Data (as defined below) it receives from its users directly (for example, information received directly via this website or that is linked to a user’s account on this site) which it controls and can determine the purposes for which, and the manner in which, that Personal Data is, or is to be, processed – i.e., it is not collecting and processing that Personal Data simply for and on behalf of its users.
What is Personal Data?
We may store and process your data outside the EEA. The Personal Data that we collect and process may be transferred to, and stored at, a destination outside the EEA. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in the provision of support services to you or subcontractors who help us process the Personal Data we process on your behalf.
Consent to storage and processing of your data outside the EEA
Links to other sites
Our websites may contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these websites.
Cookies are small data files stored sent from a website and stored within a user’s web browser/hard drive. Cookies may contain session information or settings to enhance a user’s experience or may be necessary to utilize a website’s applications. ATPCO uses both session Cookies (which expire once Users close their web browser) and persistent Cookies (which stay on Users’ computers or devices until they delete them) to provide you with a more personal and interactive experience on our websites. This type of information is collected to distinguish different users.
ATPCO does not collect or maintain personally identifiable information within Cookies created or used by our websites.
Access to your personal data
Where we act as a data controller of any Personal Data (see above), the EU Directive gives you the right to access information we hold about you.
Most data we house originates via an access request from your employer or data partner. Once your access is established, you have the ability to view or modify the data provided by your employer or data partner. If you do not want us to house this information, you will need to relinquish your access to ATPCO’s systems where a login is required. Much of this data is available to view or update on https://faremanager.atpco.net via the “Update User Information” link.
If you wish to formally request access to Personal Data we hold about you, entered by you on various internet forms within our systems, you may do so in accordance with your rights under the EU Directive. Any such request may be subject to a fee of US $10 to meet reasonable costs in providing you with details of the information we hold about you. If you wish to make such a request, please contact firstname.lastname@example.org with any questions or concerns.