This privacy policy aims to give you information on how ITN collects and processes your personal data, including any data you may provide through the Platforms when you purchase a product or service or sign up to our newsletter.
The Platforms are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.This privacy policy supplements other notices and privacy policies and is not intended to override them.

ITN is the controller and responsible for your personal data.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, please contact the DPO using the details set out below.

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: International Travel Network, LLC
Email address: privacy@asaptickets.co.uk

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes [first name, maiden name, last name, username or similar identifier, title, date of birth and gender].
• Contact Data includes [billing address, delivery address, email address and telephone numbers].
• Financial Data includes [bank account and payment card details].
• Transaction Data includes [details about payments to and from you and other details of products and services you have purchased from us].
• Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website].
• Profile Data includes [your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses].
• Usage Data includes [information about how you use our website, products and services].
• Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

When you give us personal information, you are telling us that the information is true, accurate, complete and current. You are also telling us that you have the authorization to provide it to us.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

We will use your personal information in the following ways:

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message

Marketing email has an opt-out URL and you can unsubscribe from such communication at any time. You cannot unsubscribe from servicing emails and administrative messages.

Our servers and data centers are located in the U.S and our service providers may be located there and in other countries. By providing us personal information, you agree that your personal information may be transferred to and stored in these countries. These countries may have different and/or less stringent privacy/data protection and data security rules than those of your own country. As a result, your personal information may be subject to access requests from governments, courts, or law enforcement in those countries according to laws in those countries. Subject to the applicable laws in such other countries, we will provide the necessary safeguards to maintain protections of your personal information, e.g. by obtaining from the data recipients contractual commitments based on the EU model clauses.

ITN has a security program intended to keep the personal information stored in our systems protected from unauthorized access and misuse. Our systems are configured with data encryption, or scrambling technologies and firewalls constructed to industry standards. We also use Secure Socket Layer (SSL) technology that protects the data you send over the Internet. Personal information may only be accessed by persons within our organizations, or our third parties to carry out the uses indicated in this Privacy Policy.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

If you click through to third party websites or other platforms, ITN’s privacy policy does not apply.

ITN does not knowingly collect personal information from minors. If we become aware that a minor is attempting to submit personal information, we will remove this information from our records. If you are the parent/legal guardian of a minor who has given us personal information, please contact us so we can delete it.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by contacting us at any time.

We may modify this Privacy Policy at any time and without prior notice. We will notify you of material changes to how we use your personal information prior to implementing them. We may notify you about such a material change by email or prominent notice on our website. By using our services and Platforms after we post these changes, you indicate you accept them.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

We (or our suppliers) use several common tracking tools. We use these tools to collect usage and demographic information about you over time and across different Web sites when you use our Platforms. We also have third parties (e.g. advertisers) that collect personal information this way. Tools we use may include browser cookies. Your browser will store these cookies on your computer in a small file.

We and our advertising partners may also use web beacons (single pixel GIF images). These web beacons are placed in the code of a Web page or an email newsletter. When you access a partner site within our mobile applications, we may track your activity on that site.

By using the Platforms, you give us your free, unambiguous and informed consent to the use of any of the cookies and tracking tools mentioned in this policy.

ITN uses tracking tools for following purposes

• To track new visitors to the Platforms.
• To help us recognize your browser as a previous visitor. This includes saving and remembering any preferences that may have been set while your browser was visiting the Platforms, such as language.
• To make use of cross-device tracking in order to optimize our advertising activities. As part of cross-device tracking, ITN may combine information collected from a particular browser or mobile device with another computer or device linked to the computer or device from which the information was collected. By changing your cookie settings on your device you can change your cross-device tracking settings for advertising purposes.
• To work with online advertising companies to display targeted advertising on our Platforms and third party platforms that you visit. This targeting may be based on information you submit on our Platforms or third party platforms. This targeting may also be based on your activities or behaviors on our Platforms or those of third parties. We may also obtain information about your browsing history from our business partners.
• To track when you book on partner websites.
• To help improve our website offering and for capacity planning purposes. We or our third party service providers may set analytics cookies. These allow us to gather aggregated or segmented information about the types of visitors that access our Platforms and the pages and advertisements that they view. In order to better understand your use of our Platforms, we or our third party service providers may collect information on such use, including pages visited, links clicked and mouse movements. We do not use this information to personally identify you.

Your browser may give you the ability to control cookies. How to do this varies from browser to browser. You should view the Help menu on the browser you use for further information. Your opt out choice is stored in opt out cookies only in that browser, so you should separately set your preferences for other browsers, computers, or devices you may use. If your browser blocks cookies, your opt out preferences may not be effective. Deleting browser cookies can remove your opt out preferences, so you should visit this page periodically to review your preferences. If you block or delete cookies or opt out of online behavioral advertising, not all of the tracking that we have described in this policy will stop.

Please also note that opting out of a third party cookie does not mean that you will no longer receive or be subject to online advertising or marketing. It means that the third party service from which you opted out will no longer deliver ads tailored to your web preferences and online behavioral.

We may also use Google Analytics to collect demographic and interest data about you (such as age, gender, and interests), including through Google Analytics Demographics and Interest Reporting. We may use the information collected about you through Google Analytics for Google services such as Remarketing with Google Analytics and Google Display Network Impression Reporting. Choices you make are browser and device specific. Some aspects of our site use cookies to function. You may not be able to use these features if you set your device to block cookies.

Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. These features are not yet uniform, so we are not currently set up to respond to those signals.