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ATPCO Privacy Policy

EFFECTIVE DATE: 17 October 2016

The privacy of your personal information is important to ATPCO. This Privacy Policy describes how ATPCO collects and uses a customer’s personal information.

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 Network and Security Services
Privacy and Compliance
Airline Tariff Publishing Company
Washington Dulles International Airport
45005 Aviation Drive, Dulles, VA 20166
Tel: 703-661-7889
Email: privacy@atpco.net

ATPCO PRIVACY PRINCIPLES

Introduction

ATPCO is committed to protecting our users’ privacy. The ATPCO Privacy Policy is designed to inform our users about the manner in which ATPCO collects and uses personal information provided to ATPCO. By using our site, systems, or services, you agree that ATPCO can collect, use, and disclose such personal information in accordance with our Privacy Policy.  For the purposes of this policy, “personal information” has the same meaning as Personal Data as in the “Provisions Specific to European Users,” except the data applies to individuals outside the EU as well.

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
  • Organization
  • 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)
  • Phone
  • 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. 

As is true of most websites, we also gather certain information automatically and store it in log files.  This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data.  We use this information to analyze trends, administer our site, track users’ movements around our site, gather demographic information about our user base as a whole, and better tailor our services to our users’ needs.  Except as noted in this Privacy Policy, we do not link this automatically-collected data to personal information.

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.

In addition to the tracking technologies we place, other companies may set their own Cookies or similar tools when you visit our site.  This includes third party analytics services, including but not limited to Google Analytics (“Analytics Services”), that we engage to help analyze how users use our site, as well as third parties that deliver content or offers.  We may receive reports based on these parties’ use of these tools on an individual or aggregate basis.  We use the information we get from Analytics Services only to improve our site and services.  The information generated by the Cookies or other technologies about your use of our site and Services (the “Analytics Information”) is transmitted to the Analytics Services.  The Analytics Services use Analytics Information to compile reports on user activity.  The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ Terms of Use and Privacy Policy.  By using our site and services, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above.  For a full list of Analytics Services, please contact us at privacy@atpco.net.

Use of Personal Information

In general, personal information you submit to us is used either to respond to requests that you make, aid us in serving you better, and administer and improve our site, systems, and services; prevent potentially prohibited or illegal activities, comply with applicable law and enforce our terms of use; and for any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

For the avoidance of doubt, any business, transaction or related data disclosed pursuant to a customer agreement between ATPCO and a customer is governed solely by the terms of the applicable customer agreement(s) and is not subject to this Privacy Policy.

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.

We may share some or all of your personal information with our parent company, subsidiaries, joint ventures, or other companies under common control with ATPCO (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.

We may share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving the sale, transfer, or divestiture of all or a portion of our business or assets.  In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Privacy Policy.

Regardless of any choices you make regarding your personal information, ATPCO may disclose personal information if it believes in good faith that such disclosure is appropriate (a) in connection with any legal investigation or proceeding; (b) to comply with relevant laws or to respond to subpoenas or warrants served on ATPCO; (c) to protect or defend the rights or property of ATPCO, its affiliates or its users; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, our terms of use, or any other contractual arrangement.

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.

CHANGES TO THIS PRIVACY POLICY

ATPCO may update its Privacy Policy from time to time. When we amend the policy in a material way, a notice will be posted on the ATPCO Web sites at http://www.atpco.net/atpco-privacy-policy.

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?

"Personal Data" means any data relating to EU-based individuals by which they can actually be identified or could be identifiable, whether simply from that information alone, or in combination with any other information which is in our control (including any “personal data”, as defined in the EU Directive). Where it meets the definition outlined above, each reference to personal information or collected information in this Privacy Policy, for users based in the European Economic Area (the "EEA"), shall be read as references to 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 

Use of ATPCO’s site, systems and services confirms your consent to and acknowledgement of the ATPCO Privacy Policy.  In addition, you accede to the collection and use of the information as outlined in the Privacy Policy.  This includes your agreement that your Personal Data may be stored at locations outside the EEA.  Wherever it is stored or processed, ATPCO will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy

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.

Use of Cookies

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.

Visitors to our site will typically be able to remove and reject Cookies from our website by changing their browser settings. Many browsers and devices are set to accept Cookies until you change your settings. Please note that if you do choose to remove or reject our Cookies, it will affect your usage of our site and applications.  Our applications require the use of Cookies.

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 privacy@atpco.net with any questions or concerns.