ELITE TRAVEL

Fortis Global Services Privacy Notice

Last updated: 11/26/2019

Fortis Global, LLC (“Fortis Global”, “we”, “us” and “our”) takes the issue of safeguarding your privacy seriously. Our Privacy Notice describes what information we collect from our Members as well as visitors to the Fortis Global website and mobile App, and the way in which Fortis Global uses this information to better serve your needs.

This Privacy Notice has been adopted by all of the distinct legal entities that manage and operate Fortis Global Services. References to “we”, “us”, “our” and “Fortis Global” throughout this Privacy Notice, depending on the context, refer collectively to those separate and distinct legal entities.

What is Personal Information?

Personal information is any information about you as an identifiable individual. The personal information that we process includes:

Basic information – such as name, age, gender, passport information and publicly available photograph;
Contact information – such as your home address, zip/postal code, email address and phone number;
Financial information – such as your credit card details, itemized spending and transaction history;
Health information where disclosed and relevant to the provision of services;
Preferences – such as special requests, service issues and other preferences for your travel;
Technical information – such as information about the device you use to interact with us (including the unique device identifier, hardware model, operating system and version, and mobile network information, in the case of our mobile App); and
Correspondence – when you contact us, such as to send an inquiry or make a request, any correspondence or application may be kept and added to your personal information.

How do we use your personal information?

We use your personal information for the following purposes:

to enable you to use our website and our mobile App;
to help us identify you and any accounts you hold with us;
to provide superior customer service to you;
to process transactions through our website and to assist in any inquiries about your transaction;

to contact you in relation to matters that arise from the services we provide;
if you become a Member, to create an owner profile that is stored in our internal Member portal;
to operate our business, including for internal purposes such as auditing, data analysis, statistical and research purposes and troubleshooting to help us improve our services.

Occasionally we will combine information from a number of Members to better understand trends and your expectations. When this occurs, all identifiers are removed and the aggregate, anonymized information cannot be linked to any specific individual.

On what basis do we use your personal information?

We use your personal information on the following basis:

to comply with legal and regulatory obligations, including financial reporting requirements imposed by government regulators and our auditors;
to enter into agreements with you, and to perform our agreement to provide services to you;
for legitimate business purposes – using your personal information helps us to operate and improve our business and minimize any disruption to the services that we may offer to you. It also allows us to make our communications with you more relevant and personalized to you, and to make your experience of our services more efficient and effective;
because you have given your consent – at times we may ask for your consent to allow us to use your personal information for one or more purposes or;
for the establishment, exercise or defense of legal claims or proceedings.

How is personal information collected?

We collect your personal information while monitoring our technology tools and services, including email communications sent to and from Fortis Global.

Otherwise, we gather information when you provide it to us, or interact with us directly, for example:

when you create a profile or sign in to access an existing profile on our website or App;
during your use of services through our internal Member portal; and
during your use of services with third-parties.

We also receive information about you from other sources, such as our business partners and publicly available sources. We combine information that we have about you from various sources, including the information that you have provided to us.

Finally, we may collect your photograph from publically available sources so that we can recognize you in order to provide you with superior customer service.

How do we protect personal information?

We use a variety of security measures and technologies to help protect your personal information from unauthorized access, use, disclosure, alteration or destruction, consistent with applicable data protection and privacy laws. For example, we allow only encrypted communications from all of our web forms, including when you provide your credit card information through our internal Member portal.

Fortis Global stores personal information in a secure location and we take steps to ensure that only designated individuals have access to this information.

What information is not secure?

We endeavor to protect the privacy of your account and other personal information that we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information. Also, while we endeavor to put adequate contractual protections in place, we cannot guarantee the security of any personal information in databases hosted by third parties.

It is important to note that any e-mail communication is not secure. This is a risk inherent in the use of e-mail. Please be aware of this when requesting information or sending forms to us by e- mail (for example, from the “Contact Us” section of our website). We recommend that you do not include any confidential information (i.e., credit card information) when using e-mail. For your protection, our e-mail responses to you will not include any confidential information.

Finally, to be prudent, please be sure to always close your browsers when you are done using the site. Although the session will terminate after a short period of inactivity, it is best to close your browsers immediately upon completion, especially when using a public computer.

What personal information may be provided to third parties?

We may share certain of your personal information with:

Service providers (including medical, security, legal and concierge services designed to ensure Member’s needs are taken care of in advance of and, as necessary, during travel);
Fortis Global Sales Specialists;
agents, contractors or third party service providers of Fortis Global who provide services to Fortis Global to better serve your needs as a Member;
escrow agents, third party lenders and loan-servicing agents;
a prospective buyer or investor in the event that we sell any business or assets;
analytics and search engine providers that assist Fortis Global in the improvement and optimization of the website and our mobile App;

our professional advisors and auditors; and
local or foreign regulators, governments, courts, law enforcement and national security authorities.

You may advise Fortis Global if you do not want personal preferences shared.

Where a third party is engaged by Fortis Global to provide services on our behalf, Fortis Global ensures these parties protect your Personal Information in a manner consistent with the principles articulated in this Privacy Notice.

If Fortis Global suspects any unlawful activity is taking place, it may investigate and/or report its findings or suspicions to the police or other relevant law enforcement agency.

Transfers of your personal information outside your home country

Your personal information may be processed by Fortis Global and its trusted third party suppliers anywhere in the world, including in countries where data privacy laws may not be equivalent to, or as protective as, the laws in your home country.

In particular, your personal information will be stored in your Member profile on our internal Member portal located in Chicago, Illinois.

We will implement appropriate measures to ensure that your personal information remains protected and secure when it is transferred outside of your home country.

Your rights

Accessing your personal information

We understand that you may like to know what personal information we hold about you. We are happy to assist you with your request. To protect your personal information, however, we require that you prove your identity to us at the time your request is made.

When you make a request in person, we will require you to produce some form of photo identification such as a passport or a driver’s license and you will be asked to sign a request form.

Where you make a request by other means, we request you contact us in writing via email, fax or letter including a copy of a government issued identification and signature. We require home and business addresses and phone numbers so we can check them with our files and satisfy ourselves as to your identity.

The above information is required to create an audit trail of how the request has been handled.

Fortis Global reserves the right to decline access to your personal information under certain circumstances as permitted by law. If your personal information is not disclosed to you, you will be provided with the reasons for this non-disclosure.

Other rights

You may also be entitled to:

request the correction and/or deletion of your personal information;
request the restriction of the processing of your personal information, or object to that processing;
opt out from processing of your personal information for direct marketing purposes;
withdraw your consent to the processing of your personal information (where Fortis Global is processing your personal information based on your consent); and
request the receipt or transmission to another organization, in machine-readable form, of the personal information you have provided to Fortis Global.

Where you are given the option to share personal information with Fortis Global, you can always choose not to do so.

If you do not wish to receive marketing information from Fortis Global, you may notify our Legal Department. You will always have the ability to accept or decline any form of communication from Fortis Global. You may unsubscribe from electronic marketing communications at any time by selecting the “unsubscribe” link included in such communications.

If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.

This could mean that we are unable to perform the actions necessary to achieve the purposes of processing described above or that you are unable to make use of the services offered by us.

After you have chosen to withdraw your consent, Fortis Global may be able to continue to process your personal information to the extent required or otherwise permitted by law.

If at any time you wish to exercise any of these rights, you can do so by contacting our Legal Department at:

Fortis Global, LLC
Legal Department
1360 N. Milwaukee Ave., 3rd Floor Chicago, IL 60622

How long is my Personal Information retained?

We will delete your personal information once it is no longer required for any of the purposes described above. We will also keep your personal information where we need to do so in connection with a legal action or an investigation involving Fortis Global.

Any financial information Fortis Global retains will be protected under the terms of this Privacy Notice and, where financing is arranged in the United States, under the Financial Services Modernization Act.

How is personal information affected by business transactions and/or transfers?

Fortis Global engages with Independent Contractors to coordinate your services. Fortis Global may disclose to Service providers certain Member information as required to implement business transactions between the Service provider and a particular Member. All other personal information is considered to be proprietary to Fortis Global, and is not shared with the Service provider. All other personal information remains with Fortis Global.

What laws apply to this notice?

Fortis Global, LLC does business worldwide as Fortis Global and is an Illinois limited liability company organized under the laws of the State of Illinois. We apply the requirements of Illinois Law (and any other applicable laws) to how we handle all personal information wherever received, and each Service provided by Fortis Global also complies with the local privacy laws of the jurisdiction where it is provided. All transfers of personal information between countries will be subject to the terms of this Privacy Notice and in compliance with these laws.

If you have additional questions regarding the law or if you feel we have not treated your personal information appropriately, you may contact our Legal Department via letter:

Fortis Global, LLC
Legal Department
1360 N. Milwaukee Ave., 3rd Floor Chicago, IL 60622

You may also have the right to complain to the local data privacy supervisory authority in your home country.

Contact Us

If you have any questions or concerns regarding this Privacy Notice, please contact our Legal Department:

Fortis Global, LLC
Legal Department
1360 N. Milwaukee Ave., 3rd Floor Chicago, IL 60622

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