To demonstrate our commitment to the privacy of your Personal Information, we have developed this policy, which discloses our privacy practices for the information we collect from you, as well as the collection, storage, use, or transfer of Personal Information to the United States.
It is CLS policy to notify individuals about the purposes for which we collect and use information we collect, how to contact us with inquiries or complaints, the types of third parties to which we disclose information, and the choices and means available for you to limit use and disclosure. This policy does not apply to websites run by independently-owned CLS franchises and affiliates, though those websites may link or redirect to CLS Web Site. Independent franchisees and affiliates may have developed their own standards and policies regarding privacy and security in connection with their web sites, subject to certain contractual obligations relating to their business relationship with CLS .
This policy informs you about:
1. What information we collect
2. Who collects and owns the information
3. How we use your Personal Information or disclose it to third parties
4. What choices you have regarding collection, use and distribution of your Personal Information
5. How to correct, update or delete your Personal Information
6. What kind of security procedures we use to protect the loss, misuse or alteration of information under our control
7. How to seek enforcement of your rights under this policy
8. How this policy may be amended
“Personal Information” is information that would allow someone to identify or contact you, including, for example, your full name, address, credit card number, and telephone number or email address. Personal Information excludes demographic or sensitive information that, by itself, does not identify any one individual.
1. What Information Is Collected.
CLS collects the Personal Information that you provide to us through our Web Site, Services, or Mobile App, our Worldwide Reservations Center, and directly through CLS sales employees. We may collect information in additional ways from Users of our Web Site, as explained in this Section and Sections 2 and 3.
Users may browse through the informational portion of our Web Site without providing us with any Personal Information. However, if you request information or materials from us, we may ask for your contact information, such as your name, email address, company name, address, and phone number. In addition, we may collect personal information from you when you send us emails or submit other forms of information directly to us. We may also collect personal information from you at other points on our Web Site that state that Personal Information is being collected.
To access and make reservations through the Services available at our Web Site and Mobile App, we will require you to complete a registration form. This registration form will request certain Personal Information about the Web Site or Mobile App user (“User”) and the traveler who will use our transportation services (“Client”) in the event the Client is different from the User. This information will be compiled into a profile. Such information may include at least the following: for the User, name, address, email address, company name, phone number and ARC or IATA number; and for the Client, name, email address, phone number, company name, work address, home address and billing address, pick-up and drop-off information, credit card information, corporate account information, and in-transit itineraries.
2. Who Collects Your Information.
CLS owns the Web Site, the Services, and the Mobile App and the Personal Information collected through the Web Site, the Services, and the Mobile App. We may outsource to a third party the hosting and operation of the Web Site. However, such third parties do not and will not have any ownership interest in the Personal Information collected or any right to use the Personal Information apart from the operation of our Web Site. For Personal Information we receive from third party reservations agents, systems or centers, CLS owns, jointly owns, or has the appropriate licenses to use such information. Because CLS is not responsible for the privacy practices of third parties, you should check with the third party who initiated your reservations to determine its respective privacy policies.
3. How We Use Your Information or Disclose It to Third Parties.
Delivery of Service – We use the personal information collected through our Web Site, Services, or Mobile App to administer and deliver our services. In connection with the delivery of our services, we may share the Personal Information with third-party partners or vendors who help deliver or administer the services, but they are only permitted to use the information in connection with the delivery or administration of our services. For example, we share a Client’s credit card information with a third-party credit card processing company, but that company is not permitted to use the credit card or Personal Information for any purpose other than to fulfill the specific purchase transaction. We may also share Personal Information with CLS subsidiaries, affiliates, licensees, and subcontracted service providers who need such information to provide the services that you have specifically requested.
CLS Sales Promotions – We may use the Personal Information collected through the Web Site, Services, or Mobile App to provide you with information or newsletters related to our services, and to promote our services to your company as listed in your profile. This may include information and promotions via email, postal mail, fax or telephone calls. However, for information that we have collected through your voluntary participation in an online customer survey to obtain your suggestions or comments about CLS International’s services, we use such information only for the purpose for which it was collected. We will not use such survey information for direct marketing or disclosure to other companies.
Transfer Due to Corporate Reorganization – We may share, sell or transfer the personal information you provide to us in the event of bankruptcy or the sale or transfer of a division or some or all of our corporate assets or capital stock.
Internal Marketing Research and Reporting – We use non-personal information on an aggregated basis for a variety of purposes, including operating and enhancing our Web Site, Services, or Mobile App and our service delivery, internal marketing research, and management reporting. We reserve the right to use and disclose this aggregated information to third parties for any purpose. Aggregate information will not identify any one specific individual.
Cookies – We also use pixels, or transparent GIF files, to help manage online advertising. These GIF files are provided by our advertisement management partners. These files enable our partners to recognize a unique cookie on your Web browser, which in turn enables us to learn which advertisements bring users to our website. The cookie was placed by us, or by another advertiser who works with our partners. The information that we collect and share is anonymous and not personally identifiable. It does not contain your name, address, telephone number, or email address.
Your California Privacy Rights – California Civil Code § 1798.83 (California’s “Shine the Light” Law) requires certain businesses to respond to requests from California customers who have an established relationship with the business about the business’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes.
Alternatively, such businesses may implement a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes unless the customer first affirmatively agrees to disclosure (Opt-In) or if the customer has exercised an option to opt-out of such disclosure (Opt-Out).
CLS does not disclose personal information of customers to third parties for third parties’ direct marketing purposes. In the event we do so in the future, we will not disclose any of your personal information to third parties for third parties’ direct marketing purposes unless you permit us to do so at the time you provide such information.
4. Controlling the Collection, Use and Onward Transfer of Your Information.
You can control the content of the Personal Information we have collected by following the instructions stated below in Section 5. In addition, if you do not want to receive marketing materials or communications from us or, subject to Section 5, do not want your contact information disclosed to third parties apart from the delivery or administration of our services, you can opt out.
We only share your Personal Information with third parties in limited circumstances where:
o Access, use, preservation, or disclosure of Personal Information is reasonably necessary for CLS to detect, prevent or remedy security or technical issues, or suspected or actual fraudulent or illegal activity; to satisfy any applicable law, regulation, ordinance, or legal process, including government investigation; or to protect the rights of CLS , our clients, or other individuals, as required or permitted by law.
Please note that if you provide any information on your own or directly to third parties who may be linked to, or otherwise connected with, our Web Site, different rules may apply to their use or disclosure of your personal information. We encourage you to investigate and ask questions before disclosing information to third parties.
5. Correcting, Updating and Deleting Your Personal Information.
You can access, update, or delete your personal information through CLS Web Site by logging into your CLS or Embarque account, by contacting us at email@example.com, through the Profile and Settings functions on the Mobile App, or by calling CLS Worldwide Reservations Center. However, for verification and security purposes, before we allow you to access, update, or delete your Personal Information through any means, you may be asked to provide us certain Personal Information. In addition, we may charge a reasonable fee and/or set a reasonable limit on the number of times within a given period that access requests will be considered. We may also restrict access to Personal Information in limited circumstances where the legitimate rights of persons other than the User or Client would be violated, or where the burden or expense of providing access would be disproportionate to the privacy risk to the individual.
We are not responsible for removing your Personal Information from the records of any third party who has previously been provided with your information in accordance with this policy. If you delete your Personal Information, it will not be used by us or disclosed to third parties in the future in the ordinary course of business. However, even if you delete or change some Personal Information in our registration database, it may still be stored on other databases (including those kept for archival purposes). Also, because we need to have certain of your Personal Information in order to deliver our services, you will not be able to receive such services if you delete such Personal Information.
6. Our Security Procedures.
We have established and currently maintain security procedures to protect the confidentiality, security and integrity of your Personal Information from loss, misuse, unauthorized access, and disclosure. We use encryption, tokenization, Secure Socket Layers, and firewalls, and we implement off-line efforts to further protect this information, including updating our security practices and privacy policies, and limiting employee, agent, and subcontractor access to Personal Information to those who need to know such information to deliver or administer services. In addition, both electronic and paper records containing Personal Information are maintained in access-controlled facilities.
Our Web Site, Services, and Mobile App are maintained in the United States of America. By using the Web Site, Services, or Mobile App, you authorize the exportation of your personal information to the U.S.A. and its storage and use as specified above when you provide such information to us.
Attn: Vice President, Chief Technology Officer [Data Controller]
PO Box 27661
Albuquerque, NM 87125
In the event of a formal complaint, it is CLS policy to contact the individual directly to resolve any concerns. If the complaint cannot be resolved through CLS internal processes. Such mediation will be held in New York, NY for complaints by individuals in the U.S.
8. Changes to this Policy.