EU-US/Swiss-US Privacy Shield
Last Modified: January 1, 2020
PURPOSE AND SCOPE
In compliance with the Privacy Shield Principles, Creative Group commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact:
Darryl Hoover, Chief Technology Officer
7430 E. Caley Avenue, Suite 320
Centennial, CO 80111
(201) 847-2233
Creative Group has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU and Switzerland.
Creative Group complies with the EU-US Privacy Shield Framework, and the Swiss-US Privacy Shield Framework, as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively.
Creative Group has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and view our certification, please visit https://www.privacyshield.gov.
The legal entities included in this registration are:
Direct Travel, Inc. of which Creative Group is a company
Creative Group commits to all personal data transferred from the EU and Switzerland to the US to be subject to the principles of the Shield. Creative Group only receives personal data for the purpose of arranging travel-related services and will not use this data for any other purpose. The types of personal data collected may include mandatory items such as passport data, contact information, and methods of payment. This list is not exhaustive. That personal data will at all times be kept secure, and Creative Group will take responsibility and appropriate measures to protect it from loss, misuse and unauthorized access, disclosure, alteration, and destruction.
Any contact with Creative Group regarding matters relating to the processing of personal data under the Shield must be directed in writing to:
Darryl Hoover, Chief Technology Officer
7430 E. Caley Avenue, Suite 320
Centennial, CO 80111
(201) 847-2233
Personal data will only be onward transferred to 3rd parties who are directly involved in fulfillment of program and travel arrangements for our attendees, and for that specific purpose only. These will include (but are not limited to) airlines, hotels, and global distribution systems. This data will be kept securely by the 3rd party. Creative Group commits to fully comply and be liable with the ‘Accountability for Onward Transfer’ Principal in the Shield in as far as the personal data transfer applies.
Individuals have the right to access their own personal data with the ability to have that data corrected or deleted, or limiting its use or its disclosure. An individual may also elect not to have their personal data transferred to one or more 3rd parties, or processed for a specific purpose, but it may severely limit or prevent travel arrangements being made on their behalf in such circumstance. That application must be made in writing to the address above.
Creative Group acknowledges the investigatory and enforcement powers of the Department of Transportation, or any other US authorized statutory body in relation to the Shield, and the requirements to disclose personal data in response to a lawful request by any public authority, or to meet national security or law enforcement requirements in the United States. Creative Group commits to making public any order from the DoT or a court relating to any non-conformance to the principles of the Shield.
Creative Group will utilize the external services of the UK Information Commissioner’s Office or Swiss Federal Data Protection and Information Commissioner’s Office, for free dispute resolution arising from the processing of personal data under the Shield. It may be possible for an individual to invoke binding arbitration in certain circumstances if agreed with the Commissioner’s Office.
Creative Group will conduct internal audits to ensure that the policy statements made above remain true and accurate, and that they have been implemented in accordance to the Privacy Shield Principles.
Darryl Hoover
