Omega World Travel, Inc. ("Omega") and its group of companies, respects individual privacy and values the confidence of its customers, employees, consumers, vendors and business partners. Omega World Travel, Inc. collects, uses and discloses personal information only for the benefit of our customers and at all times the collection and retention of personal information is compliant with the laws of the countries in which it does business. Omega has a tradition of upholding the highest ethical standards in its business practices. This EU-US Privacy Shield (the "Policy") sets forth the privacy principles Omega follows with respect to the collection, retention and transmission of personal information from the European Union (EU) to the United States.
Omega World Travel may be required to disclose personal information in response to a lawful request made by public authorities, including to meet national security or law enforcement requirements.
Omega World Travel, Inc. complies with the EU-US Privacy Shield Framework and requirements as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Omega World Travel is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). Omega World Travel, Inc. has certified that it adheres to the EU-US Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access and Recourse, and Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view Omega World Travel's certification, please visit https://www.privacyshield.gov.
For purposes of this Policy, the following definitions shall apply:
"Agent" means any third party (GDS, industry reporting authorities, internet booking engines, and other travel related suppliers that are deemed necessary to fulfill travel obligations) that collects or uses personal information under the instructions of, and solely for, Omega or to which Omega discloses personal information for use on Omega's behalf.
"Omega" means Omega World Travel, Inc., its predecessors, successors, subsidiaries, divisions, affiliates and groups in the United States.
"Personal information" means any information or set of information that identifies or could be used by or on behalf of Omega to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.
"Sensitive personal information" means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. In addition, Omega will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.
This EU-US Privacy Shield Policy (the "Policy") applies to all personal information received by Omega in the United States from the EU in any format, including electronic, paper or verbal.
When Omega collects personal information directly from individuals in the EU, it will inform them about the purposes for which it collects and uses their personal information, the types of non-agent third parties, if any, to which Omega discloses that information, and the choices and means, if any, that Omega offers individuals for limiting the use and disclosure of their personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Omega, or as soon as practicable thereafter, and in any event before Omega uses the information for a purpose other than that for which it was originally collected.
If Omega receives personal information from its subsidiaries, affiliates or other entities in the EU, it will use such information in accordance with the notices such entities provided and the choices made by the individuals to whom such personal information relates.
Omega World Travel may collect information from individuals who utilize our services. Omega primarily utilizes this information to provide travel arrangement services and duty of care reporting. Omega will only disclose this information if it is necessary to provide such services, we have received your permission prior to disclosure, or if Omega believes that it is required by law. The information you may be asked to provide includes, but is not limited to, name, address, telephone number, billing information (including credit card data), and travel information. Unless stated otherwise, this collected data and information is used for the provision of our travel services and may be shared with our affiliates, subsidiaries, Global Distribution Systems, Industry Reporting Authorities, and other travel supplies that are deemed necessary to fulfill travel arrangements.
Omega will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
For sensitive personal information, Omega will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. An individual wishing to limit the use or sharing of their data should contact Goran Gligorovic (Please refer to the Dispute Resolution section for contact information).
Omega will provide individuals with reasonable mechanisms to exercise their choices.
Omega will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Omega will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.
Omega will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. These agents may use this information to fulfill travel arrangements and other duty of care obligations. If Omega has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Omega will take reasonable steps to prevent, stop the use, or remediate the unauthorized processing of data. In addition, Omega will attempt to limit the purposes for which the data may be processed and ensure the Agent will provide a similar level of privacy protection. Upon request, Omega will provide a summary or copy of privacy provisions of its contract with the Agent to the Department of Commerce. In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, Omega World Travel is potentially liable. Pursuant to the Privacy Shield, Omega World Travel remains liable for the transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.
Omega acknowledges the right of individuals to access their personal information. Upon request, Omega will grant individuals reasonable access to personal information that it holds about them. In addition, Omega will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. An individual who seeks access or who seeks to correct, amend, or delete inaccurate data should direct his query to the contact listed below under the Dispute Resolution.
Omega will take reasonable and appropriate precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
Omega will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Omega determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.
In compliance with the EU-US Privacy Shield Principles, Omega World Travel, Inc. commits to resolve complaints about your privacy and our collection or use of your personal information. European Union Individuals with inquiries or complaints regarding this privacy policy should first contact Omega World Travel by mail or email as follows:
Omega World Travel-Privacy Shield Disputes
ATTN: Goran Gligorovic
3102 Omega Office Park
Fairfax, VA 22031
ggligorovic@owt.net
Omega will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy.
Omega World Travel, Inc. has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU Privacy Shield, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit EU-US Privacy Shield for more information and to file a complaint. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
This Policy may be amended from time to time, consistent with the requirements of the Privacy Shield Principles. Omega will provide appropriate public notice about such amendments.
March 1, 2019
