If you have any questions regarding our authority to collect and/or process Personal Data or any other terms of the Contract, please contact your manager.
What Personal Data Do We Collect Or Receive?
In order to provide the Service and other services required by your Company, we may require various categories of Personal Data from time to time. This Personal Data may be collected from you or be provided on your behalf by your Company and may include:
- your name, title, gender and date of birth;
- your company name and employee ID number;
- your contact information, including your telephone number and email address;
- your credit card details;
- your passport details; and
- your travel itinerary and special travel requirements.
Your provision of your Personal Data to us is voluntary. However, if you elect not to provide certain Personal Data, you may be unable to use the Service and we may be unable to provide the information or services that you have requested.
How Do We Collect Or Receive Personal Data?
What We Do With Personal Data And On What Basis Do We Use It
We (and those acting on our behalf) may collect, store, use and process Personal Data both inside and outside the Countries:
- in accordance with your Company's written instructions;
- as required to provide the Service and/or fulfil our obligations under the Contract;
- in accordance with any terms set out at the point at which Personal Data is collected; and
- as necessary to comply with legal, regulatory, immigration or customs requirements,
in each case in the capacity as data processor under applicable data protection legislation.
More specifically, this may include:
- the creation, storage and administration of your traveller (if applicable) and expense administration profiles
- the transfer and disclosure of Personal Data to service providers which the Company requires or requests us to provide as part of our provision of services under the Contract
- the transfer and disclosure of Personal Data to service providers, in and to the Countries, that are relevant to the provision of the Service to you (for example, the provision of IT infrastructure for the logging and management of support queries and for the purpose of optical character recognition associated with the technology we use)
- responding to you or your Company's requests for information concerning your expense transactions or to respond to questions you or your Company might have
- the transfer, disclosure and storage of Personal Data of your Company's registered administrators to enable us to contact them about the Services we provide to you (for example, to keep them informed about future releases of our technology, the status of support queries that have been logged, advising of upcoming maintenance windows and other issues that may affect the Service)
- addressing questions relating to our services from you or your Company and pursuant to the Contract
- the transfer and disclosure of Personal Data to the Fraedom Group in any of the Countries
- the provision to your Company of management information, data aggregation (including aggregation using data provided to us by third parties at your Company's request), quality assurance surveys and any other services required from time to time by your Company
- the transfer and disclosure of Personal Data to your Company as required by your Company from time to time, including as part of its management information, expense management and travel monitoring requirements
- the transfer of data to third parties at your Company's request
- responding to an audit of the Service under the Contract by your Company
As explained above, there may be limited circumstances where we have to use your Personal Data to satisfy our own legal or regulatory requirements, or otherwise to defend or establish legal claims, in which we case we will be the data controller for the purposes of applicable data protection legislation.
- our use of your Personal Data is in our legitimate interest as a commercial organisation (for example, in order to establish or defend legal claims or other queries or complaints about our Services). In these cases we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained in the Your Legal Rights section below; or
- our use of your Personal Data is necessary to comply with a relevant legal or regulatory obligation that we have, for example to make disclosures required by tax authorities, law enforcement and/or our regulatory bodies.
We use information collected from cookies and other technologies to improve your user experience and the overall quality of our services. We do this by setting our own cookies but also through certain third party products we use including Google Analytics, Fraedom Session Cookie and Fraedom Language preferences cookie. These third party cookies allow us to improve your experience of this application and to improve the Service we provide through this application. The cookies that we use on this application do not collect information that identifies individual users.
Additional information about the use of Google Analytics can be found at www.google.com/policies/privacy/partners.
Location Based Services
Certain Services require details of your location (for example, in order to provide you with local weather information). Depending on your browser and mobile device settings, we may receive this information automatically or following a request which you accept. We may share this data with certain third parties in order to provide these location based services. If you elect to disable location based services, you may not be able to use some or all of the features of the relevant Service.
Accessing the Application using our App
If you are a user of the Service pursuant to a Contract you may use our app to access the application and the Service. By registering a mobile device in order to access the application and the Service via our app, we will collect information about your device's Operating System (OS) version, manufacturer, model, and carrier. This information is used for the duration of your session and is not stored by us.
Please provide accurate Personal Data and update it as necessary in the manner specified below. In the absence of any updates, we will assume that the Personal Data submitted is correct.
How We Protect And Store Your Information
We recognise the need and take reasonable steps to ensure that Personal Data we have collected remains secure. While we have security measures in place as required by the Contract and at law in order to protect against the loss, misuse, alteration of and unauthorised access to Personal Data under our control, you acknowledge that there remains a risk that Personal Data transmitted over the internet and stored by computer may be intercepted or accessed by an unauthorised third party.
Storing your Personal Data
In specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.
Your rights in relation to your Personal Information
If you wish to exercise your rights in relation to our use of your Personal Data where we are the data controller, you can do so by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to address your request promptly or inform you if we require further information in order to fulfil your request.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Right of access to Personal Data - you have a right to request that we provide you with a copy of your Personal Data that we hold and you have the right to be informed of; (a) the source of your Personal Data; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your Personal Data may be transferred
Right to rectify or erase Personal Data - if you wish to delete, deactivate or amend the Personal Data, you have a right to request that we rectify inaccurate Personal Data. We may seek to verify the accuracy of the Personal Data before rectifying it.
Data portability - where we are relying upon your consent or the fact that the processing is necessary for the performance of a contract to which you are party as the legal basis for processing, and that Personal Data is processed by automatic means, you have the right to receive all such Personal Data which you have provided to us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.
Right to restriction of processing - you have the right to restrict our processing of your Personal Data where: (i) you contest the accuracy of the Personal Data until we have taken sufficient steps to correct or verify its accuracy; (ii) where the processing is unlawful but you do not want us to erase the data; (iii) where we no longer need the Personal Data for the purposes of the processing, but you require it for the establishment, exercise or defence of legal claims; or (iv) where you have objected to processing justified on legitimate interest grounds (see below) pending verification as to whether we have compelling legitimate grounds to continue processing. Where Personal Data is subjected to restriction in this way we will only process it with your consent or for the establishment, exercise or defence of legal claims.
Right to withdraw consent to marketing activity - As described above, we will not send you marketing material unless you or your Company has requested it, but you have the right to withdraw from such activity at any time. In the case of any email marketing communications, you can do this by following the unsubscribe link in the email.
Right to object to processing justified on legitimate interest grounds - where we are relying upon legitimate interest to process Personal Data, then you have the right to object to that processing. If you object, we must stop that processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims. Where we rely upon legitimate interest as a basis for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.
You also have the right to lodge a complaint with a supervisory authority, in particular in your country of residence, if you consider that the processing of your Personal Data infringes applicable law.
If you wish to exercise any of your rights as described above, please contact us at the address given below.
Queries and Complaints
You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your Personal Data.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
You can contact us by writing to us at:
38 Chancery Lane
FAO: Legal Department
This page was last updated on 15 October 2018