Effective Date: April 17, 2018
- What Information Is Collected
- Who Collects the Information
- How the Information Is Used
- Information We Collect on Behalf of Our Clients
- With Whom the Information May be Shared
- Privacy Protections for Children
- The Choices Available to Users Regarding Collection, Use And Distribution of Personal Information and Other Information
- What Kind of Security Procedures We Use to Protect the Loss, Misuse, or Alteration of the Information Under Our Control
- Information for European Union Users
- International Transfer
- Contact Information for Questions, Comments or Complaints
- Dispute Resolution
WorldAware Commercial Services
WorldAware collects both Personal Information and Other Information when you register for or use the Services. “Personal Information” is any information or set of information relating to an identified person or an identifiable person who can be identified, directly or indirectly, by reference to an identifier such as an identification number, location data, an online identifier or one or more factors specific to physical, physiological, genetic, mental, economic, cultural, or social identity. For example, Personal Information includes name, address, email address, employer’s company name, job title, phone or fax number, employee ID, travel itineraries, including emergency contact information and, if requested by a client, passport numbers. “Sensitive Personal Information” means Personal Information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, or trade union membership, that concerns an individual’s health or sex life, criminal proceedings, or that is designated in writing by a third party as Sensitive Personal Information.
- For individuals residing in the European Union, where WorldAware collects Personal Information directly from you, we will inform you about the type of Personal Information collected, the purposes for which we collect and use the Personal Information, and the types of non-agent third parties to which WorldAware discloses or may disclose that information, and the choices and means, if any, WorldAware offer individuals for limiting the use and disclosure of their Personal Information. Under these circumstances, notice will be provided in clear and conspicuous language when you are first asked to provide Personal Information to WorldAware, or as soon as practicable thereafter, and in any event before WorldAware uses or discloses the information for a purpose other than that for which it was originally collected or discloses it for the first time to a third party.
We collect Personal Information for the WorldAware Commercial Services in the following circumstances:
- You provide certain Personal Information to us when you: (a) register to use the Services, (b) order products and services from us, and (c) send email messages, submit forms, or send other information to us.
- WorldAware may obtain Personal Information about you from third parties. For example, we may receive data feeds, including your past, current, or future travel plans, from a travel agency, Global Distribution System (GDS) such as Sabre, or a data aggregator, such as itinerary aggregators in order to provide risk management services.
- When you complete a profile form to obtain personalized Worldcue® TRAVELER reports, you are required to give your contact information (such as name and email address). This information is used to contact you about WorldAware services about which you have expressed interest. It is optional for you to provide additional Personal Information (such as health and activity information) and unique identifiers (in the case of employees), but doing so permits WorldAware to provide a more personalized Worldcue® TRAVELER report.
- If you use our Apps, WorldAware may request to collect information about the precise location of your device using GPS, WiFi, or cellular network signals. In particular, our Worldcue® Mobile App collect precise location when you use the “Crisis” or “Check In” buttons or when you use the App to learn about information that is relevant to your current location. Our ExploreSafe™ app collects precise location from your device on a real-time, continuous basis to inform you, and allow your organization to inform you, of incidents and threats near your current location. In addition, our WorldAware Critical Trac® app collects precise location from your device on a real-time, continuous basis for tracking purposes and when you use the “Panic” and “Check In” buttons. If you would like WorldAware to stop collecting precise location from your device, please follow the instructions in the section below titled “The Choices Available to Users Regarding Collection, Use, Sharing, and Correction of Personal Information.”
- In the event of a complaint, we may receive Personal Information about you from other users or third parties who may communicate information to us about you in relation to that complaint.
- We may collect Personal Information from you at other points on our Services that state that Personal Information is being collected.
We and our service providers may also collect Other Information when you use the Services. This may include your computer or device operating system and browser type, your Internet service provider, your domain name, your general geographic location, the website that you visited before the Site, the webpage visited, the content accessed, the time spent on the webpage and the link you used to leave the Site.
WorldAware collects both Personal Information and Other Information for Marketing purposes when you register for access to content in any form or you contact us. Personal Information collected for Marketing purposes includes name, address, email address, employer's company name, job title, phone or fax number. We do not request any "Sensitive Personal Information" for Marketing purposes.
We collect Personal Information for Marketing purposes in a variety of ways including:
- Offline: When you attend one of our events, during phone calls with sales representatives, or when you contact customer service.
- Through You: Information that you voluntarily provide through forms or access requests. Note that there is no legal obligation for you to provide us with Personal Information and any information collected by us will be provided by you at your own will and with your consent. We may also collect Personal Information from you at other points on our Services that state that Personal Information is being collected. You always have the ability to modify or remove information you provide WorldAware either in the form or through an email to firstname.lastname@example.org.
- Information From Other Sources: In order to enhance our ability to provide relevant marketing, offers and services to you, we may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms, as well as from other third parties.
We and our service providers may collect Other Information for Marketing purposes in the following ways, including:
- Through Your Browser or Device: Certain information is collected by most browsers or automatically through your device, such as computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Sites (such as the Apps) you are using.
WorldAware collects both Personal Information and Other Information when you apply through our careers portal or some other method and when you are employed by WorldAware. Personal Information collected may include name, address, bank information for payroll purposes, email address, job title, phone or fax number, emergency contact information, and where appropriate, passport numbers and/or national registration numbers. "Sensitive Personal Information" means Personal Information that reveals race, criminal proceedings as part of routing background checks, and work performance information.
On our career portal, we use Google Analytics in the manner described above.
WorldAware, Inc., which owns and operates the WorldAware Services, is the company that collects Personal Information and Other Information through our Services. Our mailing address is:
185 Admiral Cochrane Drive
Annapolis, Maryland 21401 USA
And our customer service email address is email@example.com.
For individuals residing in the European Union, WorldAware will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual or directed by an employer that has purchased WorldAware products or services on behalf of its employees. WorldAware will take reasonable steps to ensure that Personal Information is reliable for its intended use, accurate, complete and current.
We use Personal Information and Other Information as part of our Commercial Services to:
- Provide you with content, products, and services that you request, fulfill the terms of any agreement you have with us, and operate our business.
- Register you for the Services and tailor the Services specifically to the profile you provide.
- Send administrative communications about the Services, provide relevant alerts and information related to your travel, respond to your requests, request feedback or handle customer service questions or issues, or to notify you of important changes or updates to the Services.
- Provide location-based services to you. For example, our Apps may enable you to opt-in to check-in with your current location, send a signal with your current location during a crisis, receive content including incident and threat information that is tailored to your precise location, and, in some cases, allow your precise location to be monitored on areal-time, continuous basis.
- Operate our Services, enhance our Services, and deliver messages.
- Provide certain information to potential customers on an aggregated basis. For example, we may report that we have a certain number of travelers or that we have processed a certain number of trips in a potential customer's jurisdiction.
We use Personal Information and Other Information collected for Marketing purposes to:
- Respond to any requests for information you submit.
- If you elect to use our referral service for informing a friend about our Services, we ask you for the friend’s name and email address. Where permitted by law, WorldAware will automatically send the friend a one-time email inviting them to visit the Services. WorldAware stores this information for the sole purpose of sending this one-time email. The friend may contact WorldAware at firstname.lastname@example.org to request the removal of this information from our database.
- Send newsletters and promotional communications (which we send on an opt-in basis where required by law) regarding our current products, Services, and features; our new or improved products, services, or features; and other information that we believe may interest you. Although we hope that you will find our promotional communications useful, you may opt out of receiving them by following the “unsubscribe” instructions included at the bottom of each email message.
- We use your information to do such things as understand and analyze how the Services are being used, create new products and services, and deliver messages.
- We may provide lists of prospects from tradeshows with partners (on an opt-in basis where required by law).
- We may provide certain information to potential customers on an aggregated basis. For example, we may report that we have a certain number of travelers or that we have processed a certain number of trips in a potential customer’s jurisdiction.
We use Personal Information and Other Information collected for Employment Purposes to:
- Fulfill our legal obligations as your employer including performance evaluation, tax reporting, payroll data and employee benefit services.
The use of information collected through our service shall be limited to the purpose of providing the service for which the Client has engaged WorldAware.
WorldAware collects information under the direction of its Clients and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.
If your employer (our Clients) has purchased WorldAware products or services on your behalf, WorldAware may receive Personal Information about you directly from your employer. For individuals residing in the European Union, if your employer has given WorldAware any Personal Information about you in connection with its purchase of a WorldAware product or service for your benefit, your employer and not WorldAware will be responsible for determining the method and means by which you will receive notice and the ability to consent to WorldAware’s receipt and use of such information.
An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the WorldAware’s Client (the data controller). If requested to remove data, we will respond within a reasonable timeframe.
We will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. WorldAware will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We disclose information to third parties in the following circumstances:
- WorldAware may share Personal Information and Other Information we collect with our contractors and third-party service providers, including companies that send email and other messages on our behalf to you, to companies that store such information for these uses, and companies that perform analytics services for us, on a need-to-know basis in order to provide and maintain our Services. These companies are authorized to use your personal information only as necessary to provide these services to us. For consumers residing in the European Union, WorldAware will obligate such service providers to safeguard such information in a manner consistent with this Policy and the consent provided by you and to provide the same level of protection as the Privacy Shield Principles. WorldAware will remain liable under the Privacy Shield Principles if the service provider processes information in a manner inconsistent with the Principles, unless WorldAware proves that it is not responsible for the event giving rise to the damage, if any.
- We share information we collect with red24 Limited, red24 PTE Ltd and Red24 Operations Ltd., our corporate subsidiaries, who must also adhere to the Privacy Shield Principles.
- Our Site and Apps may allow third parties (such as Google) to collect information through cookies, pixel tags, and mobile advertising identifiers, such as Apple’s IDFA or Android’s Advertising ID, for use in online interest-based advertising. For more information about behavioral advertising practices, visit the Network Advertising Initiative, the Digital Advertising Alliance or the European Digital Advertising Alliance. You may opt out of our third-party service providers’ interest-based advertising practices in web browsers and mobile apps by clicking http://preferences-mgr.truste.com or if located in the European Union click http://www.youronlinechoices.eu. Please note you will continue to receive generic ads. Although our Sites currently do not respond to "do not track" browser headers, you can limit tracking by taking the steps discussed above. Please note that the use of online tracking mechanisms by third parties is subject to those third parties' own privacy policies and not this Policy.
- If a WorldAware product or service is purchased by an individual’s employer on behalf of the individual, WorldAware may transfer Personal Information and Other Information, including precise location, to the employer for its legitimate business purposes, including, without limitation, for purposes of risk management and/or crisis response.
- When you contribute to a public area or feature of our Site, the information that you submit will be made available to other users, and sometimes to the general public. For this reason, we recommend that you do not submit any Personal Information, including your full name, home address, phone number, other information that would enable other users to locate you, or financial or medical information on these areas of our Site. If you are a California resident under the age of 18 and a registered user of our Services, you may request that we remove content that information that you post on our Services that personally identifies you. To obtain removal of such content or information, please send an email with a detailed description of the specific content or information you would like removed to email@example.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted, since the content or information may remain in our database, may remain visible in a manner that does not identify you, or may have been re-posted by another user. There may be other circumstances in which applicable laws do not require or allow removal even if requested.
- In addition, WorldAware may use and disclose Personal Information and Other Information as it believes reasonably necessary: to comply with applicable law or respond to legal process (for example, a court order, search warrant or subpoena); in response to lawful requests by public authorities (such as to meet national security or law enforcement requirements); to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our Terms and Conditions, or in other circumstances in which WorldAware has a good faith belief that its products or Services are being used in the commission of a crime or that there is an emergency that poses a threat to the safety of you or another person; or to protect our rights and property.
- WorldAware may disclose Personal Information and Other Information to facilitate the financing, securitization, insuring, merger, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.
- We may also disclose aggregated, de-identified information about users of the Services for any purpose, such as by publishing a report on trends in the usage of the WorldAware Services.
This Site and the WorldAware Services are provided for adults only. The Site and the Services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under the age of 13 through the Site or Services.
The Choices Available to Users Regarding Collection, Use And Distribution of Personal Information and Other Information
You can control the collection, use, and sharing of your information by following the instructions stated below. Please note that if you provide any information to parties who provide services to our Site or Apps or to any other sites or apps you encounter on the Internet or otherwise (even if these sites are branded with our branding), different rules may apply to their use or disclosure of the Personal Information you disclose to them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties.
- You have the right to access, amend or delete Personal Information we hold about you, and in some cases to object to the processing of your Personal Information or request your Personal Information to be provided to you in a portable form. For example, if your Personal Information changes, you would like to review or correct your Personal Information, or if you no longer desire our Services, you may correct, update, or remove your Personal Information at the member information page or by emailing our Customer Support at firstname.lastname@example.org. Upon request WorldAware will provide you with information about whether we hold any of your personal information. We will respond to your request within a reasonable timeframe.
- You are given the opportunity to ‘opt in’ to having your Personal Information used for purposes not directly related to our Services at the point where we ask for the information. For example, WorldAware might want to use your information as part of future marketing campaigns.
- You may also ‘opt out’ of receiving non-essential or promotional communications directly from WorldAware. If you no longer wish to receive our non-service-related mailings, you may opt out of receiving these communications by following unsubscribe instructions at the bottom of each communication, replying to the email and placing “unsubscribe” in the subject line of the email, or emailing us at email@example.com.
- WorldAware may collect location information if you use an WorldAware application on your mobile device. The iOS and Android (OS 6.0+) platforms will alert you the first time a WorldAware app wants permission to access certain types of data and will let you consent (or not consent) to that request. You may subsequently manage your location sharing preferences at any time with the iOS and Android (OS 6.0+) platforms by changing the Location Services settings on the device. Android (OS 5.1.1 and earlier) devices will notify you of the permissions that a WorldAware app seeks before you first use the app, and your use of the app constitutes your consent. Some applications, such as ExploreSafe™ may also permit you to modify location reporting (the transmission of your location information to our servers) from within the application Settings. Please note that the Services require your precise location for certain features to work properly.
What Kind of Security Procedures We Use to Protect the Loss, Misuse, or Alteration of the Information Under Our Control
WorldAware takes commercially reasonable administrative, technical, and physical precautions to protect our users’ information against loss, misuse and unauthorized access, disclosure, alteration, and destruction. However, no system is 100% secure, and therefore we cannot guarantee the absolute security of the information that we collect.
We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements, consistent with applicable law.
WorldAware participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. WorldAware is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov/list.
WorldAware is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. WorldAware complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, WorldAware is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, WorldAware may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
WorldAware provides services globally so it may be necessary to transfer your Personal Information internationally. In particular, your Personal Information will be transferred to and processed in the United States and wherever you access WorldAware provided services while you travel. By using this Service, you acknowledge that the data protection and other laws of other countries may provide a less comprehensive or protective standard of protection than those in your country or the country you are in while using our services.
Users are encouraged to contact WorldAware if they have a Privacy Shield-related complaint. Questions, comments, or complaints regarding the use or disclosure of Personal Information and this Policy should be sent by email to firstname.lastname@example.org or submitted to the following person by mail as follows:
Attn: Ellen Ryan
185 Admiral Cochrane Drive
Annapolis, MD 21401 USA
Our data protection officer can be contacted as follows:
155 Commercial St.
London E1 6BJ
WorldAware will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the Privacy Shield principles contained in this Policy. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.