Effective March 10th, 2020
VAX is an award winning travel platform specifically designed for Travel Agencies and Travel Agents. VAX VacationAccess Worldwide, LLC. works with contractors to provide you with access to a variety of benefits described herein as “VAX Content” which includes but is not limited to VAX applications, products and services. VAX VacationAccess is powered by Trisept, an Apple Leisure Group (“ALG”) company.
We want you to know VAX VacationAccess will never sell, lease or rent your Personal Information to ensure your privacy is protected. We will always endeavor to take steps to assure that any personal information you provide to us will remain private and secure.
We encourage you to read this Privacy Notice carefully, and to regularly check this page to review any changes we might make
The VAX family of platforms and services is managed by Trisept Solutions which is part of Apple Leisure Group (“ALG”) and operates under the policies of ALG. Trisept processes customer travel data from its data centers in the USA. Trisept is not responsible for the content of the information it processes or responsible for the way its clients treat personal information they collect or control.
Accordingly, neither VAX VacationAccess nor Trisept directly interfaces with the traveling public (with the exception of “VAX Web” which allows travelers to interact with the platform services directly) and does not collect Personally Identifiable Information (“PII” under the General Data Protection Regulation (GDPR) of the European Union) or Personal Information (“PI” under the California Consumer Protection Act (CCPA)) from consumers. However, limited PII/PI is collected from representatives of its clients such as Travel Agents or Travel Merchandisers. This policy describes what information is collected directly as well as protections that are incorporated in the products and services Trisept/VAX VacationAccess provides to its clients that protect the information of their customers.
In no case is PII/PI sold by Trisept or VAX VacationAccess. However, either may disclose your personal information as required by law, such as to comply with a subpoena, or similar legal process, when it believes in good faith that disclosure is necessary to protect their rights, protect individuals safety or the safety of others, investigate fraud, or respond to a government request.
Trisept is an approved organization under the US – EU and Switzerland Privacy Shield administered by the International Trade Association of the US Dept. of Commerce (see: https://www.privacyshield.gov/list.)
“Client” – means any Travel Agency or Travel Agent that contracts for or agrees to use the VAX VacationAccess platform(s).
“Contractor” – means an independent provider of goods or services on behalf of VAX VacationAccess Worldwide, LLC.
“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
“Customer” – means an individual for whom the Travel Agency undertakes researching, shopping, booking, or purchasing of products and services on the VAX VacationAccess web sites.
“Personal Information” means information from which any individual is directly or indirectly identifiable.
“Process”, “Processing” or “Processed” means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.
“Third Party” – means a company other than VAX VacationAccess Worldwide, LLC or a domain name other than www.vaxvacationaccess.com.
“Trisept” – means the company that is part of Apple Leisure Group that provides solutions and services to travel agents and agencies and in some cases to the traveling public directly.
"VAX" – means the VAX VacationAccess technology owned by VAX that enables the Travel Agency to access the VAX Content, various customer’s inventories (all of which are maintained separately and are not owned or controlled by VAX) and make purchases on behalf of their agency and/or customers.
We may Process the following categories of Personal Information about you:
We may also collect:
Children. The services are not intended for use by children, especially those under 13. No one under the age of 13 should provide any Personal Information or use our public discussion areas, forums or chats. Minors under the age of 18 are not permitted to make purchases through the services or to obtain coupons or codes from the services to purchase goods or services on third party websites. If, notwithstanding these prohibitions, your children or your customer’s children disclose information about themselves in our public discussion areas, consequences may occur that are not intended for children (for example, they may receive unsolicited messages from other parties). If it is discovered that we have collected Personal Information from someone under 13, we will delete that information immediately.
The PII/PI is collected and used for processing transactions through the platform to provide services to your customers. The agreement between VAX VacationAccess and our clients ensures the information will be used for the purpose it was intended.
We may have to share your personal data with the parties set out below for the purposes set out above.
We require all service providers and third parties to respect the security of your personal data and to treat it in accordance with the law.
We do not allow our third parties and service providers to use your personal data for their own purposes without your consent and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Certain parts of the platform (specifically VAX Pro (UK) although parts of other transactions may also be covered) provide transactions that are between providers in the EU and UK and entities in the US. These processing transactions are frequently subject to the Principles of the Privacy Shield between the EU and the US.
As part of the Trisept Solutions platforms, the VAX platforms and services are, in some cases, used for covered transactions between parties in the EU and the US. To that extent, the transactions are covered by the certification attained by Trisept Solutions as a certified organization under the voluntary Privacy Shield guidelines. The following principles apply to Trisept and to certain of the VAX VacationAccess transactions:
This principle states that any person for whom PII/PI is collected must be able to choose whether to continue receiving information from Trisept/VAX VacationAccess once the initial selection has been made. Subscribers to newsletters or mailings regarding travel specials or similar marketing materials may choose to stop receiving these emailed notices at any time by using the “unsubscribe” tab on the website. Alternatively, send an email to email@example.com with the request to be unsubscribed.
Subscribers to any of VAX VacationAccess’s clients marketing messages must go to those websites directly and request to unsubscribe or follow the instructions provided on the website in order to choose to change status regarding receiving marketing emails.
On rare occasions, VAX VacationAccess may need to communicate service related announcements via email, in which case, such communication will be made to the registered email address on the client account.
Accountability for Onward Transfer:
In some cases VAX VacationAccess uses third parties to assist in the provisison of its services. Third parties may be service providers such as banks that process payments, firms that provide analytics of aggregated information that report on types of services and purchases made to assist in making the platforms more efficient or effective in supplying services and the like. Any third party is required by contract or similar written agreement to have in place a firm commitment to the security and privacy of any data it handles under the direction of VAX VacationAccess. Further it must have, and provide evidence upon request, suitable security solutions in place to ensure the safety and security of any PII/PI it processes or manages on behalf of VAX VacationAccess. In the event a third party determines it is no longer able to meet the requirements or Trisept or VAX VacationAccess determines a third party is not meeting the requirements for protecting the PII/PI per the contract, Trisept or VAX VacationAccess will notify its impacted clients of this fact and the steps taken to remediate the situation.
Trisept and VAX VacationAccess take reasonable precautions to ensure the security and safety of data including loss, misuse, unauthorized access, disclosure, alteration and destruction of any PII/PI it collects directly or processes on behalf of a controller or other responsible party. Please note that transmitting any information involves the inherent risk of theft and unauthorized use. No method of transmission over the Internet, or method of electronic storage, is 100% secure, therefore, Trisept and VAX VacationAccess cannot guarantee its absolute security. Using the Hosting Platform for the transmission of customer information is encrypted using secure socket layer technology (SSL).
Data Integrity and Purpose Limitation:
It is critical to note that Trisept and/or VAX VacationAccess are NOT responsible for data collected and onward submitted for processing by clients and their customers that are the actual purchasers of the travel services. Trisept and/or VAX VacationAccess take reasonable steps to ensure services are provided with the proper and sufficient protections to meet the Privacy Shield principles for processing PII/PI.
Persons from whom VAX VacationAccess collects PII/PI have the right to access that information and may submit a request to see or have that data to firstname.lastname@example.org at any time. A request may be made to review the information in order to make a correction or a change to the information held. Requests will be responded to within 30 business days of receipt of the request.
Please note, information will be maintained for as long as an account is active or as needed to provide the services and per the ALG information retention policy. Data must be maintained and used to comply with legal obligations, resolve disputes and enforce agreements. A request to delete an account and/or any information held is subject to these circumstances.
In the unlikely event of a dispute or an unresolved privacy issue, please contact the U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request with the details of the issue.
Recourse, Enforcement and Liability
The last of the seven (7) principles required to comply with the agreements of the US-EU Privacy Shield requires notification of the individual’s rights regarding recourse, enforcement and liability. With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Trisept is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Trisept may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, a requestor may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
VAX VacationAccess partners with a third party to either display advertising on the website or to manage advertising on other sites. The third party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising click here [or if located in the European Union click here]. Please note this does not opt you out of being served ads. You will continue to receive generic ads.
As is true of most web sites, VAX VacationAccess gathers certain information automatically and stores it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. This automatically collected data is not linked to other information we collect about you.
VAX VacationAccess acknowledges that persons have the right to access their personal information. For the most part, VAX VacationAccess has no direct relationship with the individuals whose personal data is processed (the only persons for whom we have access are our employees and the PII/PI of travel agents or authorized representatives of our clients). An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his/her query to the specific client (the data controller) that collected it. If the client requests us to remove the data, we will respond to that request within 30 business days.
Questions, comments or complaints regarding the company’s policy or data collection and processing practices can be emailed to: VAXdatarequest@triseptsolutions.com