This Privacy Statement explains how Clevenard Limited and Clevenard Global International Limited processes personal data concerning individuals, employees, owners, or representatives acting on behalf of our (existing, former, or potential) Business Partners.
In this document, Clevenard Limited and Clevenard Global International Limited may be referred to as “we,” “us,” Clevenard, “our,” or “Clevenard Booking & Tourism Services.” 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 Clevenard Limited or Clevenard Global International Limited.
Note that companies using our “Clevenard Booking & Tourism Services for Business” services to facilitate Trip reservations for their staff are instead subject to our Privacy and Cookie Notice for customers.
This Privacy Statement applies to any Clevenard Limited or Clevenard Global International Limited responsible for the processing of personal data concerning a Business Partner. Depending on the nature of the business relationship, different Clevenard Limited may be responsible for the processing of that personal data.
For example, Clevenard Limited, located in London, United Kingdom, is responsible for the processing of Trip Provider data. This Privacy Statement also applies to Booking Spain Services Hotel Reservation Services Ltd, located in London when processing the personal data of accommodation partners in the United Kingdom.
To find out if and to what extent other Clevenard Limited processes your personal data, please review the information provided below. Information is also provided in your agreement with Clevenard Limited and made available on our online platforms (such as sign-up pages or procurement management platforms). Alternatively, you can contact us at firstname.lastname@example.org.
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 Clevenard Limited and Clevenard Global International Limited 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.
The personal data Clevenard Booking & Tourism Services collects in regards to Business Partners depends on the context of the business relationship and their interaction with Clevenard Booking & Tourism Services, 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.
If you’re a Business Partner in the state of California, in addition to the information here you have certain additional rights outlined in the section of our privacy statement applicable to California.
The personal data Clevenard Booking & Tourism Services collects about our Business Partners can include the following:
Personal data you give to us
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.
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.
Clevenard Booking & Tourism Services 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.
When a Business Partner communicates with Clevenard Booking & Tourism Services, 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 Clevenard Booking & Tourism Services 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, Clevenard Booking & Tourism Services 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 Clevenard Booking & Tourism Services app, like Pulse.
- The data collected may include:
- Language settings,
- IP address,
- 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 Booking 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 Clevenard Booking & Tourism Services 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, Clevenard Booking & Tourism Services 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 Clevenard Booking & Tourism Services 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, Clevenard Booking & Tourism Services may need to collect data through third-party sources for fraud detection and prevention, risk management, and compliance purposes.
Clevenard Booking & Tourism Services uses the previously described Business Partner information, some of which may be personal data, as relevant, for the following purposes:
A. Registration and administration
Clevenard Booking & Tourism Services 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 Clevenard Booking & Tourism Services. 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
Clevenard Booking & Tourism Services 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, Clevenard Booking & Tourism Services 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.
Clevenard Booking & Tourism Services 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 Clevenard Booking & Tourism Services products and services.
As relevant to the business relationship, Clevenard Booking & Tourism Services uses personal data for communications, including providing information about system or product updates, sending the Clevenard Booking & Tourism Services newsletter, inviting Business Partners to participate in referral programs or competitions (such as Booking Hero) 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
Clevenard Booking & Tourism Services may offer Business Partners different means to communicate with (prospective or existing) guests before or after a reservation.
Business Partners can also contact Clevenard Booking & Tourism Services to forward reservation information or questions to guests, or communicate with guests using alias emails, which always include Clevenard Booking & Tourism Services as a recipient.
Clevenard Booking & Tourism Services may access communications between Business Partners and guests. We also use automated systems to review, scan, and analyze communications for the following purposes:
- Fraud prevention,
- Compliance with legal and regulatory requirements,
- Investigations of potential misconduct,
- Product development and improvement,
- 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 Clevenard Booking & Tourism Services communication tools will be received and stored by Clevenard Booking & Tourism Services.
E. Analytics, improvement, and research:
Clevenard Booking & Tourism Services uses information provided to us, which may include personal data, for analytical purposes. This is part of our drive to improve Clevenard Booking & Tourism Services 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 Clevenard Booking & Tourism Services’ 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 Clevenard Booking & Tourism Services and/or exchange experiences with other Business Partners.
Please consult the information Clevenard Booking & Tourism Services 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 Clevenard Booking & Tourism Services , 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).
Clevenard Booking & Tourism Services 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.
Clevenard Booking & Tourism Services 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, Clevenard Booking & Tourism Services 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.
As applicable for purposes A and B, Clevenard Booking & Tourism Services 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 Clevenard Booking & Tourism Services. If the required information is not provided, Clevenard Booking & Tourism Services 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, Clevenard Booking & Tourism Services 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 Clevenard Booking & Tourism Services or a third party’s legitimate interest, we will always balance the impacted individual’s rights and the protection of their information against Clevenard Booking & Tourism Services and/or the third party’s rights and interests.
For purposes F and G, Clevenard Booking & Tourism Services also relies, where applicable, on compliance with legal obligations (such as lawful law-enforcement requests). Finally, where needed under applicable law, Clevenard Booking & Tourism Services 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@example.com.
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.
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.
We will retain personal data for as long as deemed necessary to manage the business relationship with a Business Partner, to provide Clevenard Booking & Tourism 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. If you have questions about the specific retention periods for the various types of personal data we process, please get in touch using the contact details below.
Your choices and rights
Depending on where you are located or the Clevenard Booking & Tourism Services 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 Clevenard Booking & Tourism Services 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.
If your business has agreements with a different entity to Clevenard Limited. If you would like further information about the relationship between that entity and Clevenard Limited, you can contact us at any time. You should also do so if you would like to exercise your rights regarding the personal data processed about you as part of that business relationship.
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 firstname.lastname@example.org. 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.