Galileo Canada Distribution Systems, Inc. (hereinafter “Galileo Canada”) is a proud member of Galileo International, Inc. Galileo International, Inc., is one of the world’s leading providers of electronic global distribution services and transaction processing to the travel industry utilizing a computerized reservations system (hereinafter, the “Galileo system”). Travel agencies and other subscribers to the Galileo system make reservations on over 400 airlines, 20 car rental companies, 65,000 hotel locations, and other travel-related suppliers worldwide. The processing services provided by the Galileo system link together these travel suppliers, subscribers, and consumers to facilitate and confirm travel reservations.
Some of the data processed by Galileo Canada and/or the Galileo system includes personally identifiable information (“PII”).
PII includes personal information normally provided by or on behalf of a prospective traveler to a travel agent, both about that particular traveler as well as other parties traveling with that traveler, in order to make a reservation. Such information usually includes the traveler’s name and phone number. It can also contain any other data entered into the Galileo system by the agency or travel supplier including but not limited to address, frequent flier number, dietary preferences, special needs, etc.
In addition, PII may include personal information provided by or on behalf of a travel agent in Canada who chooses to supply his/her PII to Galileo Canada in order to participate in any product, service, program, contest, sweepstake, bonus, award or similar incentive program offered by Galileo Canada to travel agents in Canada. Such information usually includes the travel agent’s name, address and phone number, but it may also include other data provided by the travel agent, including, but not limited to, email address, FAX number, etc.
Purpose. Galileo Canada collects, processes and discloses PII to facilitate reservation transactions, to meet legal and regulatory requirements, to develop products and services, and to better manage and/or promote Galileo Canada’s business and operations.
Scope. This Policy applies to PII that is collected through Galileo Canada and/or the Galileo system. Galileo Canada does not assume any responsibility for unauthorized use or disclosure by the agency or travel supplier who originally provided the information. In other words, the Policy is only intended to apply to Galileo Canada and not to the travel agency or supplier that provided or utilized the information. This Policy does not apply to information in an aggregated form that can no longer be connected with a specific person.
Collection, Use and Disclosure of Traveler PII:
Collection. Galileo Canada collects and processes PII and other data provided primarily by travel agents who subscribe to the Galileo system. Galileo Canada may also collect PII from others such as travel suppliers that have access to the Galileo system. Galileo Canada generally does not conduct business directly with individual travelers and therefore does not generally collect PII directly from individual travelers.
Use. Galileo Canada generally obtains and processes PII for the purpose of facilitating the reservation process as requested by a traveler. For example, when a prospective traveler discloses air travel plans to a travel agent, the agent enters the data into the Galileo system in order to make a reservation. The Galileo system electronically contacts the airline in question to ascertain whether the flight is available. If an appropriate flight is available, the travel agent completes the reservation in the Galileo system. Galileo Canada transmits the reservation data to the travel suppliers involved in the booking. This would include the primary data such as passenger name, flight details and relevant telephone contacts, and can include optional information as directed by the travel agent. The data is stored in the Galileo system to allow for travel changes by the travel agent or travel suppliers. It is possible that PII will be disclosed to alternative travel suppliers or travel agents to facilitate changes to a travel itinerary. Galileo Canada may use PII data in any other manner upon the consent of the consumer involved.
Disclosure. Galileo Canada discloses PII to the extent necessary or related to successfully completing the reservation. Thus, PII is disclosed to the travel agency and travel suppliers selected by the traveler and others involved in the transaction, such as the traveler’s credit card company, insurance company, and otherwise as necessary on important public interest grounds or as required by law, court order, or as requested by a governmental or law enforcement authority or in the good faith belief that disclosure is otherwise necessary or advisable. Ticketing information is provided to the local bank settlement plan (“BSP”) in the course of the BSP allocating funds to the airlines involved in the transaction. Certain ticketing information in the Galileo system is optionally available to the airlines. PII may also be disclosed in any other manner upon the consent of the traveler involved or to anyone who Galileo Canada reasonably believes is seeking the information as the agent of the traveler. Galileo Canada reserves the right to disclose PII in connection with the sale or transfer of all or substantially all of the assets of Galileo Canada or Galileo International, Inc. to a third party.
Collection, Use and Disclosure of Travel Agent PII. Galileo Canada may collect, use, and disclose PII information as is reasonably necessary to implement and support any product, service, program, contest, sweepstake, bonus, award or similar incentive program directed at those travel agents in Canada who have chosen to participate in such product, service, program, contest, sweepstake, bonus, award or similar incentive program.
Third Party Processing and Disclosure. Galileo Canada may utilize (and disclose PII to) affiliates or third party suppliers to perform certain outsourced services including but not limited to data center management, software development, etc. Such entities may have access to PII. In such circumstances, appropriate means shall be employed to help ensure such third parties maintain the requisite level of data security as required by law.
Retention. The Galileo system archives PII offline within 72 hours of the completion of travel. Subject to applicable law, all PII data is destroyed within three years of the completion of travel.
Security Safeguards. Galileo Canada shall protect PII by security safeguards appropriate to the sensitivity of the PII against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction. To protect PII sent to Galileo Canada, Galileo Canada uses a security system that includes advanced technologies, intrusion detection systems, logical network segmentation, and security restrictions. If Galileo Canada transmits PII over the Internet as part of the reservation process, Galileo Canada uses industry-standard, secure-socket-layer (SSL) technology, which is utilized by most browsers to encrypt PII before it is transferred across the Internet. To further safeguard PII, Galileo Canada frequently uses direct communication links to travel suppliers and travel agents rather than the Internet to transfer information. If PII is transferred using the Internet, such information is sent in encrypted format and ultimately stored in Galileo Canada secure database. All of Galileo Canada’s employees and contractors with access to PII are and shall be contractually required to respect the confidentiality of the PII.
Accuracy. Galileo Canada primarily relies upon travel agents and travel suppliers to provide accurate information. The data is then processed through a series of quality control measures. Galileo Canada strives to promptly correct any PII found to be inaccurate, and where appropriate, Galileo Canada transmits the updated data to appropriate personnel.
Access. As a processor of data, Galileo Canada does not conduct business directly with individual travelers. Upon request, individual travelers may have access to their own data held by the Galileo system by contacting the travel agent involved in the booking. Upon request, travel agents in Canada may have access to their own data held by Galileo Canada.
Consent. Galileo Canada does not have a direct relationship with the individual travelers for which it collects, processes and discloses PII. Each travel agent and travel supplier that primarily supplies PII to Galileo Canada is responsible for ensuring that it has obtained the appropriate consents required to permit Galileo Canada to collect, process and disclose individual traveler PII covered by this Policy. In obtaining such consent, such business associate should use reasonable efforts to ensure that the individual traveler (or his or her agent) is advised of the identified purposes for which PII will be used or disclosed. Such business associate should ideally seek such consent at the time the PII is collected. However, such business associate or Galileo Canada may seek consent to use and disclose PII after it has been collected but before it is used or disclosed for a new purpose. In determining the appropriate form of consent, the sensitivity of the PII and reasonable expectation of the data subject should be considered. An individual traveler may withdraw his or her consent at any time, subject to legal or contractual restrictions and reasonable notice. By supplying his/her own PII, a travel agent in Canada consents to reasonable use of his/her PII for purposes of the product, service, program, contest, sweepstake, bonus, award or similar incentive program in which the travel agent has chosen to participate.
Publication. Galileo Canada makes its policies and practices regarding the management of PII readily available. This Policy is available on the Galileo Canada web site at www.galileo.com/galileo/en-ca/. All employees of Galileo Canada are required to read this Policy on an annual basis.
Compliance. The Chief Privacy Officer for Galileo Canada is Thomas J. DeMay, Esq. Any questions regarding this Policy may be addressed to him c/o Galileo Canada, 2 Bloor Street West, Suite 1006, Toronto, Ontario, Canada M4W 3E2.
Changes. Galileo Canada reserves the right to modify or amend this Policy at any time and for any reason. If there are material changes to this Policy or in how Galileo Canada will use PII, Galileo Canada will prominently post such changes prior to implementing such change.
Effective: 04/25/07