Privacy Policy
Effective March 2, 2019
The Luxury Travel Agency respects the privacy of our clients and website visitors. This Privacy Policy explains what personal information we collect, why we collect it, how we use and share it, how long we keep it, and the choices and rights available to you.
This policy is intended to cover our operations and clients in the United States and Canada. Additional rights may apply if you live in another jurisdiction.
Who We Are
The Luxury Travel Agency operates through affiliated companies in the United States and Canada:
The Luxury Travel Agency, LLC
4117 Hillsboro Pike, Suite 103-174
Nashville, Tennessee 37215
United States
The Luxury Travel Agency, NAS Inc.
120-56 Aberfoyle Crescent
Toronto, Ontario M8X 2W4
Canada
TICO Registration #50024754
Depending on the services provided, one or both companies may collect, use or hold your personal information. Information may be shared between our Nashville and Toronto offices where necessary to arrange travel, service reservations and manage our relationship with you.
We have designated a Privacy Officer who is responsible for our privacy practices and for responding to questions, requests and complaints. Contact information appears at the end of this policy.
Information We Collect
The information we collect depends on how you interact with us and the travel services you ask us to provide.
Information you provide when you contact us
This may include your:
- name;
- email address;
- telephone number;
- home or mailing address;
- city, state, province or country;
- preferred method of communication; and
- information you provide about the travel you are considering.
Information needed to arrange travel
Depending on the journey, we may collect:
- full legal names as shown on passports;
- dates of birth;
- nationality and citizenship information;
- passport numbers, issuing countries and expiration dates;
- copies or images of passports or other travel documents where provided;
- visa and immigration information;
- home and billing addresses;
- emergency contacts;
- airline, hotel and other loyalty program numbers;
- known traveler, trusted traveler or redress numbers;
- flight, accommodation and transportation details; and
- information about other people traveling with you.
Travel preferences and history
We may maintain information that allows us to provide a more personalized and informed service, including:
- preferred airlines, hotels, cruise lines and travel brands;
- room and bed preferences;
- seating preferences;
- food and beverage preferences;
- preferred destinations and styles of travel;
- past journeys and reservations;
- anniversaries, birthdays and other special occasions;
- interests and activities; and
- notes from previous journeys.
Our objective is to avoid making you repeat the same preferences every time you travel and to allow future journeys to benefit from what we learned from previous ones.
Sensitive information
Travel sometimes requires information that is more sensitive.
You may choose to tell us about allergies, dietary requirements, mobility or accessibility needs, pregnancy, medications, or medical or health information where it affects transportation, accommodation, activities or your ability to travel safely.
We collect this information only where it is relevant to your travel.
Where express consent is required, including for sensitive information under applicable Canadian privacy law, we will ask for that consent when the information is collected or before it is disclosed for the relevant purpose.
You may withdraw your consent, subject to legal or contractual restrictions. If you do, we will explain any effect that may have on our ability to arrange or service your travel.
Payment and billing information
We may collect payment card information, bank transfer information, billing addresses, transaction details and other information needed to collect payment or make reservations on your behalf.
Payment card information is handled as described under Payments below.
Communications
We may retain emails, messages, completed forms, call notes and other communications between you and The Luxury Travel Agency where reasonably necessary to provide services, maintain an accurate record of your instructions or manage our relationship with you.
Website and device information
When you use our website, we and our service providers may collect information such as:
- IP address;
- approximate geographic location;
- browser and device type;
- operating system;
- referring website;
- pages viewed;
- links clicked; and
- information collected through cookies, pixels and similar technologies.
More information appears under Cookies, Analytics and Advertising below.
How We Collect Information
Most personal information comes directly from you through email, telephone, messaging, our website, client forms, meetings and conversations with our team.
We may also receive information from:
- another person traveling with you;
- a family member, assistant or other person authorized to arrange travel for you;
- hotels, airlines, cruise lines and other travel suppliers;
- destination management companies, guides and local partners;
- loyalty and preferred-partner programs;
- booking and reservation systems; and
- service providers used in connection with your travel.
If you provide personal information about another adult traveler, you confirm that you are authorized to provide it for the purpose of arranging their travel. Please make this Privacy Policy available to them.
Information about children should be provided by a parent, guardian or other person authorized to arrange their travel.
Why We Use Personal Information
We use personal information where reasonably necessary to:
- respond to inquiries;
- understand your travel requirements;
- recommend destinations, accommodations and experiences;
- design itineraries;
- make and service reservations;
- issue and service airline tickets;
- arrange hotels, villas, cruises, yachts, transportation, guides and experiences;
- communicate your preferences and requirements to travel suppliers;
- obtain preferred-partner benefits and recognition;
- manage payments, invoices and accounting;
- maintain your travel profile and history;
- assist when travel plans change or problems arise;
- communicate with you before, during and after travel;
- verify instructions and prevent fraud or misuse;
- maintain appropriate business and transaction records;
- comply with tax, accounting, legal, regulatory, immigration and security requirements;
- protect our clients, employees and business;
- resolve disputes and respond to claims; and
- send marketing communications where you have consented or where otherwise permitted by applicable law.
We limit our collection and use of personal information to purposes that are reasonably connected to our services and business.
Consent and Your Choices
When you ask us to arrange travel, you understand that we must use and disclose certain information in order to provide the services you have requested.
For example, we cannot make an airline reservation without providing the passenger’s name and other required information to the airline.
We will seek additional or express consent where appropriate because of the sensitivity of the information, because the use is outside what you would reasonably expect, or because applicable law requires it.
For Canadian clients, we follow the principles of meaningful consent under applicable Canadian privacy law. We aim to explain what information is being collected, why we need it, who may receive it and any meaningful consequences of providing or withholding it.
You may withdraw consent to optional uses of your information at any time. Withdrawal of consent does not affect uses or disclosures already lawfully made and may not apply where we must retain or use information for legal, contractual or regulatory reasons.
Who We Share Information With
Travel cannot usually be arranged without sharing information with other companies.
Depending on your journey, we may share appropriate information with:
Travel suppliers
Hotels, resorts, lodges, villa companies, airlines, cruise and yacht operators, rail companies, private aviation providers, ground transportation companies, guides, naturalists, destination management companies and local operators.
We provide the information reasonably necessary to arrange and service your travel.
Our Nashville and Toronto offices
Information may be shared between The Luxury Travel Agency, LLC and The Luxury Travel Agency, NAS Inc. where necessary to provide or administer your travel services.
Travel consortia and preferred-partner programs
This may include Virtuoso and hotel or travel preferred-partner programs where information is required to register a reservation, provide recognition or obtain benefits.
Booking and reservation systems
We use airline ticketing systems, global distribution systems, reservation systems and other travel-industry platforms to arrange and service travel.
Business service providers
We may use companies that provide services such as:
- payment and secure card authorization;
- customer relationship management;
- itinerary management;
- email;
- cloud storage;
- document management;
- accounting;
- website hosting;
- analytics;
- cybersecurity; and
- advertising and marketing.
Where a service provider processes personal information on our behalf, we require appropriate confidentiality and privacy safeguards consistent with the nature of the information and the services being provided.
Professional advisers
We may disclose information to lawyers, accountants, auditors, insurers and other professional advisers where reasonably necessary.
Governments and authorities
We may provide information to customs, immigration, border, security, law-enforcement, tax or other authorities where required by law or reasonably necessary to comply with the requirements of a destination or transportation provider.
Independent Travel Suppliers
Hotels, airlines, cruise lines, tour operators and certain other travel suppliers are independent businesses.
Once information is provided to them to fulfill a reservation or service, they may have their own legal obligations and may use information for their own legitimate business purposes. Their own privacy policies and practices may therefore apply.
The Luxury Travel Agency does not control the privacy practices of independent travel suppliers.
International and Cross-Border Processing
Travel is international by nature.
Your information may be transferred to or accessed from the United States, Canada and the countries involved in your travel. It may also be processed in countries where our technology and service providers operate.
Information held outside your home country or province may be subject to the laws of that jurisdiction and may be accessible to courts, law-enforcement or government authorities in accordance with those laws.
For personal information transferred by our Canadian operations to a service provider for processing, we use contractual, organizational or other appropriate measures designed to provide a level of protection appropriate to the sensitivity of the information.
When you ask us to arrange international travel, necessary information will also need to be disclosed to the airlines, hotels, operators and other suppliers involved in delivering that travel.
Payments
We use third-party payment and card-authorization services to help handle payment information securely.
Where we need payment card information to make a reservation on your behalf, we collect and use it only with your authorization and only for legitimate travel or payment purposes.
Access to payment card information is restricted to people who need it for their work. We do not retain full card numbers longer than reasonably necessary for the transaction, reservation or authorized travel purpose.
Where possible, payment information should be submitted through the secure payment or credit-card authorization method we provide.
Please do not send full payment card numbers through ordinary email, SMS or other unsecured messaging methods.
Bank transfer information and payment records may be retained in our accounting and transaction records as required for legitimate business, tax and legal purposes.
How Long We Keep Personal Information
We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including:
- arranging and servicing travel;
- maintaining an ongoing client relationship;
- responding to questions or disputes;
- maintaining transaction and accounting records;
- complying with tax, legal and regulatory requirements; and
- protecting our legitimate business interests.
Different categories of information may therefore be retained for different periods.
Passport and identity-document information may be retained for an ongoing client so that it does not need to be provided again for every journey. We generally delete expired documents and information that is no longer reasonably required.
You may ask us to delete passport or identity-document information sooner, subject to any legal or operational requirement to retain it.
Marketing contact information is retained until you unsubscribe, withdraw consent where applicable, or ask us to remove it, subject to limited records we may retain to ensure that your preference continues to be respected.
Security
We use administrative, technical and physical safeguards appropriate to the nature and sensitivity of the personal information we hold.
These may include:
- access restrictions;
- password and authentication controls;
- secure business systems;
- limited access to sensitive and payment information;
- staff privacy and security practices;
- secure storage and transmission methods where appropriate; and
- procedures for responding to suspected privacy or security incidents.
No method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.
Privacy and Security Breaches
We maintain procedures for responding to suspected loss, unauthorized access, use or disclosure of personal information.
Where applicable law requires us to notify affected individuals, a privacy regulator or another authority of a breach, we will do so in accordance with those requirements.
We also maintain records of privacy breaches where required by applicable law.
Cookies, Website Analytics and Advertising
Our website uses cookies and similar technologies, including pixels and tags.
Necessary technologies
Some technologies are required for website operation, security and basic functionality.
Analytics
We use services including Google Analytics and Clicky to help us understand how visitors find and use our website and how individual pages perform.
Advertising
We use the Meta pixel and may use similar advertising technologies to measure advertising effectiveness and, where permitted, help deliver advertising to audiences likely to be interested in our services.
Email analytics
Our email platform may tell us whether a marketing email was opened or whether a link was clicked. We use this information to understand whether our communications are useful and to improve them.
You can control or delete cookies through your browser settings. Where applicable law requires consent or provides a right to opt out of particular analytics, advertising or tracking activities, we will provide and honor the applicable choice.
Some U.S. state privacy laws use terms such as “sale,” “sharing” or “targeted advertising” more broadly than their everyday meaning. We do not sell personal information for money.
Where an applicable U.S. law gives you the right to opt out of advertising-related sharing or targeted advertising, you may contact our Privacy Officer using the information below.
Marketing Communications
We may send newsletters, destination information, offers and other travel-related communications where you have requested them, where we have the consent required by applicable law, or where another legal permission applies.
Every marketing email we send provides a way to unsubscribe.
For Canadian recipients, commercial electronic messages are sent in accordance with Canada’s anti-spam requirements, including applicable consent, identification and unsubscribe requirements.
Unsubscribing from marketing does not prevent us from contacting you about an active reservation, payment, travel disruption or other service-related matter.
Your Privacy Rights — Canada
If you are in Canada, applicable federal or provincial privacy law may give you rights concerning your personal information.
Subject to lawful exceptions, you may ask us to:
- tell you whether we hold personal information about you;
- provide access to personal information we hold about you;
- explain how it has been used or disclosed;
- correct information that is inaccurate or incomplete;
- withdraw consent to uses or disclosures that depend on consent; and
- address a concern or complaint about our privacy practices.
Requests and complaints should first be directed to our Privacy Officer.
We may need to verify your identity before providing access to personal information or acting on a request.
If you are not satisfied with our response, you may also have the right to complain to the Office of the Privacy Commissioner of Canada or an applicable provincial privacy regulator.
Your Privacy Rights — United States
Privacy rights differ by state, and not every state privacy law applies to every business or every category of information.
Where an applicable U.S. privacy law gives you the right to do so, you may be able to request that we:
- confirm whether we process your personal information;
- provide access to certain personal information;
- correct inaccurate personal information;
- delete certain personal information;
- provide a portable copy of certain information;
- opt you out of certain sales, sharing or targeted advertising;
- limit certain uses of sensitive information; or
- review or appeal a decision concerning a privacy request.
We will not discriminate against you for exercising a privacy right provided by applicable law.
We may need to verify your identity before completing a request. Where permitted by law, an authorized agent may submit a request for you, but we may require evidence of the agent’s authority and may verify the request directly with you.
Sensitive Information
We do not use sensitive information such as passport, health or accessibility information for advertising or unrelated marketing purposes.
Sensitive information is used only for purposes reasonably connected with providing travel services, complying with legal requirements, protecting safety, preventing fraud or another purpose for which you have specifically authorized its use.
Automated Decision-Making
We do not use personal information to make solely automated decisions that produce legal or similarly significant effects concerning our clients.
Children
Our travel-advisory services and website are directed to adults.
We collect personal information about children only where it is provided by a parent, guardian or another person authorized to arrange travel on the child’s behalf.
We do not knowingly use children’s personal information for behavioral advertising.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our services, technology, practices or legal obligations.
The effective date at the top identifies the current version.
If we make a material change that significantly affects how we use personal information already in our possession, we will provide additional notice or obtain consent where required by applicable law.
Contact Us
Questions, access requests, corrections, privacy-rights requests and complaints may be directed to:
Privacy Officer
The Luxury Travel Agency
andrew@theluxurytravelagency.com
United States
The Luxury Travel Agency, LLC
4117 Hillsboro Pike, Suite 103-174
Nashville, Tennessee 37215
United States
Canada
The Luxury Travel Agency, NAS Inc.
120-56 Aberfoyle Crescent
Toronto, Ontario M8X 2W4
Canada
TICO Registration #50024754
