PRIVACY STATEMENT FOR CALIFORNIA RESIDENTS
This PRIVACY STATEMENT FOR CALIFORNIA RESIDENTS (this “Statement”) supplements the information contained in the Privacy Policy (“Privacy Policy”) of COLLETTE TRAVEL SERVICE, INC and its affiliates and subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to consumers, employees, job applicants, independent contractors, visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this Statement to comply with the California Consumer Privacy Act of 2018 as amended and supplemented by the California Privacy Rights Act (“CCPA”) and other applicable California privacy laws. Unless specifically defined in this Statement, any terms defined in the CCPA shall have the same meaning when used in this Statement.
INFORMATION WE COLLECT
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device (“Personal Information”). Personal Information that we collect includes, but is not limited to, Sensitive Personal Information. In particular, we have collected the following categories of Personal Information from consumers within the last twelve (12) months: Note that the categories listed below are defined by CCPA. Inclusion of a category in the list below indicates only that, depending on the services and products we provide you, we may collect some information within that category. It does not necessarily mean that we collect all information listed in a particular category for all of our customers.
| Category | Examples | Collected |
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. | YES |
| B. Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories. | YES |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | YES |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. | YES |
| G. Geolocation data. | Physical location or movements. | YES |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | NO |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
| K. Inferences drawn from other Personal Information. | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
| L. Sensitive Personal Information | A category of Personal Information that includes: (a) government-issued identifying numbers (such as social security, driver's license, state identification and passport numbers); (b) financial account details (such as credit card numbers and access codes); and (c) race or ethnicity information. | YES |
Personal Information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA's scope, such as:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; or
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
We obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from you or our clients or their travel professionals. For example, from information that you provide to us related to the services for which you engage us or in the employment application, interview or hiring as well as the continuing employment process.
- Indirectly from you or our clients or their agents. For example, through information we collect from you in the course of providing services to you.
- Directly and indirectly from activity on our website (www.gocollette.com). For example, from submissions through our website portal or website usage details collected automatically.
- From third-parties that interact with us in connection with the services we perform or in connection with the job application, interview, or hiring process as well as the continuing employment process.
- For job applicants and employees, from you, prior employers, references, recruiters, job-related social media platforms, third-party sources of demographic information, third-party companies such as background check companies and drug testing facilities, claim administrators and investigators.
USE OF PERSONAL INFORMATION
We may use or disclose the Personal Information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided. For example, if you provide us with Personal Information in order for us to reserve travel accommodations for you, we will use that information to make and change reservations as needed and submit it to the applicable authorities.
- In connection with the employment application, interview or hiring process as well as the continuing employment process.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, reservation updates and other notices concerning our products or services that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our website and present its contents to you.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.
We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
SHARING PERSONAL INFORMATION
We may sell or share your Personal Information to a third party for a business purpose. When we sell or share Personal Information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have sold or shared the following categories of Personal Information of consumers for a business purpose:
Category A: Identifiers.
Category B: California Customer Records Personal Information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category L: Sensitive Personal Information
We sell or share your Personal Information for a business purpose to the following categories of third parties:
- Our affiliates.
- Service providers.
- Third parties to whom you or your travel professional authorize us to disclose your Personal Information in connection with products or services we provide to you.
- Third parties to whom you authorize us to disclose your Personal Information in connection with the employment application, interview, or hiring process as well as the continuing employment process.
In the preceding twelve (12) months, we have sold or shared Personal Information.
RETENTION OF PERSONAL INFORMATION
We will retain your Personal Information in accordance with our record retention requirements and policies which reflect business and legal considerations. We will retain your Personal Information for the time period reasonably necessary to achieve the business and commercial purposes described in this Statement and/or our Privacy Policy or any other notice provided at the time of collection. Your Personal Information may be retained longer if required or permitted by applicable law.
YOUR RIGHTS AND CHOICES
The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
- Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting or selling or sharing that Personal Information.
- The categories of third parties with whom we sell or share that Personal Information.
- The specific pieces of Personal Information we collected about you (also called a data portability request).
- If we sold or shared your Personal Information for a business purpose, two separate lists disclosing:
- sales, identifying the Personal Information categories that were sold, shared or disclosed to each category of recipient; and
- sharing for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
- Deletion Request Rights
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Maintain such information in connection with your current or past employment by us.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
- Personal Information Correction Rights
You (or a person authorized by you) have the right to correct any inaccuracies in your Personal Information. You can exercise this right by following the process set forth below. If you exercise this right, we will make commercially reasonable efforts to correct any inaccuracies within 45 days after our receipt of your request.
- Opt Out Rights
You (or a person authorized by you) have the right to opt out of the sale or sharing of your Personal Information by us through a link entitled “Do Not Sell or Share My Personal Information.” You can access the opt out link on our home page (www.collette.com) as well as within the following section of this Statement.
Right to Limit the Use of Sensitive Personal Information
You (or a person authorized by you) have the right to limit our use of Sensitive Personal Information through a link entitled “Limit the Use of My Sensitive Personal Information.” You can access this link on our home page (www.collette.com) as well as within the following section of this Statement. If you choose to exercise this right, we may use your Sensitive Personal Information only to perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services.
- Exercising Access, Data Portability, Deletion, Opt Out, Sensitive Personal Information Use Limiting, and Personal Information Correction Rights
To exercise the access, data portability, deletion, opt out, Sensitive Personal Information use limiting, and Personal Information correction rights described above, please submit a verifiable consumer request to us by either:
- Calling us at 855.821.8147
- Emailing us at privacyinquiries@collette.com
- Visiting here
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
NON-DISCRIMINATION
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
- Retaliate against any employee, job applicant, or independent contractor for exercising their rights under CCPA.
CHANGES TO OUR PRIVACY STATEMENT
We reserve the right to amend this Statement at our discretion and at any time. When we make changes to this Statement, we will notify you by email or through a notice on our website homepage.
CONTACT INFORMATION
If you have any questions or comments about this Statement, our Privacy Policy, the ways in which we collect and use your Personal Information, or your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Email: privacyinquiries@collette.com
Call: 855-821-8147
Write: Marketing Department
Privacy Inquiries
Collette
180 Middle Street
Pawtucket, RI 02860
