Privacy Policy


Effective Date:  November 5, 2019

Virtuoso, Ltd. (“Virtuoso”) is a network of independent luxury travel agencies (“Member Agencies”), with more than 17,500 travel advisors worldwide. We represent the best of the best in travel, with a portfolio of nearly 1,700 preferred travel suppliers - top hotels, cruise lines, tour operators, and more (“Preferred Suppliers”).

Virtuoso respects your concerns about privacy. This Privacy Policy describes the types of personal information we collect about individuals (including customers,  Member Agency travel advisors, Preferred Supplier representatives, vendor and consultant representatives, and job applicants), how we may use the information, with whom we may share it, and the choices available to individuals regarding our use of the information. The Privacy Policy also describes the measures we take to safeguard the personal information, how long we retain the information, and how individuals can contact us about our privacy practices and to exercise their rights.

Our privacy practices may vary in the countries in which we operate to reflect local practices and legal requirements.

Click on one of the links below to jump to the listed section:
•    Information We Obtain
•    How We Use The Information We Obtain
•    Online Tracking
•    Information We Share
•    Data Transfers
•    Your Rights and Choices
•    Notice to California Residents
•    Other Online Services and Third-Party Features
•    How We Protect Personal Information
•    Retention of Personal Information
•    Updates To Our Privacy Policy
•    How To Contact Us

 

Information We Obtain


We obtain certain personal information in connection with the services we provide. The types of personal information we obtain include:

•     Contact information, such as name, postal address, email address and telephone number;
•    online password and other log-in details;
•    payment information, such as name, billing address and payment card details (including card number, expiration date and security code);
•    booking information;
•    information about travel plans, interests, preferences and Member Agency and advisor affiliation;
•    demographic information we acquire from third parties;
•    information you submit in connection with applying for a job with Virtuoso, such as information in your resume and details about your employment and education; and
•    other personal information in content you provide to us on our websites, such as photos and videos, dates of birth, passport information, and personal information provided in response to surveys and contests, in comments to our blog posts, and in feedback.

You are not required to provide this information, but if you choose not to do so, we may not be able to offer you certain of our services and features of our websites.

From our travel advisors, we collect information such as name, contact information, photos, Member Agency affiliations, travel specialties, city and country information, languages spoken, attendance at Virtuoso-hosted events, reviews and recommendations.

From our Preferred Supplier representatives, we collect information such as name, contact information, event attendance, and online chat details if you choose to communicate with us this way.

From our vendor representatives, we collect information such as name, contact information, job title, and employer details.

In addition, when you visit our websites, we obtain certain information by automated means, such as through the use of cookies, web server logs and web beacons. The information collected in this manner includes IP addresses, operating systems type, browser type, domain and other system settings. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. Through these automated collection methods, we collect “clickstream data,” which is a log of content on which a visitor clicks while browsing a website. As the visitor clicks through the website, a record of the action may be collected and stored.

To the extent required by applicable law, we will obtain your consent before placing cookies or similar technologies on your device. To find out more about the way we use cookies, web beacons and similar technologies and how to manage your settings and preferences at any time, please visit our Cookie Policy which can be found in the footer.

 

How We Use The Consumer Information We Obtain


We may use the consumer information we obtain to:

•    Create and manage your profile and account;
•   Suggest potential travel advisors to our customers;
•    offer and provide products and services to you, such as hotel bookings and marketing materials;
•    communicate with you about, and administer your participation in, surveys, events, programs, contests, promotions and other offers;
•    communicate with you on behalf of our Member Agencies and preferred suppliers;
•    display content on our websites, such as our travel advisors’ accounts and profiles;
•    respond to and communicate with you about your inquiries and requests, and provide information you request;
•    process claims we receive in connection with our products and services;
•    Manage our career opportunities, including for recruitment purposes, candidate screening and evaluation, and employee onboarding; and
•    Establish and manage our relationships with our vendors and consultants.
•    operate, evaluate and improve our business (including developing new products and services; enhancing and improving our services; managing our communications; analyzing our products; and performing accounting, auditing, billing reconciliation and collection activities and other internal functions);
•    perform data analyses (including market and consumer research, trend analysis, financial analysis, and anonymization of personal information);
•    protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and
•    comply with and enforce applicable legal requirements, relevant industry standards and our policies.

As required by applicable law, we use the personal information we obtain to comply with applicable legal requirements, carry out our contractual obligations and, as permitted by law, pursue our legitimate interests as described above (such as managing our website, performing data analyses, and operating, evaluating and improving our business). Otherwise, we obtain consent to process personal information. We may combine information we obtain about you (such as through our website or from third parties such as our Member Agencies, analytics vendors or Preferred Suppliers) for the purposes described above. We also may use the information we obtain in other ways for which we provide specific notice at the time of collection or otherwise with your consent.

In addition, we use information collected online through cookies, web beacons and other automated means for purposes such as (i) customizing our users’ visits to our websites and (ii) managing our business. We also use this information to help diagnose technical and service problems, administer our websites, identify users of our websites, and gather demographic information about our users. We use clickstream data to determine how much time users spend on web pages of our websites, how users navigate through our websites, and how we may tailor our websites to better meet the needs of our users.

We also use third party web analytics services on the websites, such as those of Google Analytics and, Hotjar. The service providers that administer these services use technologies such as cookies, web server logs and web beacons to help us analyze how visitors use the websites. The information collected through these means (including IP address) is disclosed to these service providers, who use the information to evaluate use of the websites. More information is available in our Cookie Policy [https://www.virtuoso.com/Cookie-Policy].  To learn more about Google Analytics and, Hotjar and how to opt out, please visit www.google.com/analytics/learn/privacy.html, or https://www.hotjar.com/opt-out
 

Online Tracking

 

On our websites, we collect information about your online activities to provide you with advertising about products and services tailored to your individual interests. This section of our Privacy Policy provides details and explains how to exercise your choices.

You may see certain ads on other websites based on your visits to our websites because we participate in advertising networks administered by third-party vendors. Ad networks allow us to target our messaging to users considering demographic data, users’ inferred interests and browsing context. These networks track your online activities over time by collecting information through automated means, including through the use of cookies, web server logs and web beacons. The networks use this information to show you advertisements that are tailored to your individual interests, to track your browser across multiple websites, and to build a profile of your web browsing. The information our ad network vendors collect includes information about your visits to websites that participate in the vendors’ advertising networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our websites and on third-party websites that participate in the ad networks.  This process also helps us track the effectiveness of our marketing efforts. Our websites are not designed to respond to “do not track” signals received from browsers.  To learn how to opt out of ad network interest-based advertising in the U.S., please visit www.aboutads.info/choices, http://www.networkadvertising.org/choices/, and http://preferences-mgr.truste.com/
 

Information We Share


We do not sell or otherwise share personal information about you, except as described in this Privacy Policy. We share the personal information we obtain with third parties who perform services on our behalf, such as ad network vendors, data analytics vendors, survey platforms, cruise lines (in connection with Virtuoso Voyages registration), and email and print marketing vendors. These third parties are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. In addition, we share consumer personal information with Member Agencies and their travel advisors (if you select or already have a relationship with an advisor) to provide the services you request and with Preferred Suppliers to collaborate on special offers for Member Agency clients.

We may share the accounts and profiles of travel advisors on our websites so consumers can identify those advisors whose services they would like to engage.

We also may disclose information about you (i) if we are required to do so by law, regulation or legal process (such as a court order or subpoena), (ii) in response to requests by government agencies, such as law enforcement authorities, (iii) for the purpose of or in connection with legal proceedings, or otherwise for the purpose of establishing, exercising or defending our legal rights, or (iv) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity. We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).
 

 

Data Transfers

 

We may transfer the personal information we collect about you to recipients (including third party service providers) in countries other than the country in which the information originally was collected.  Those countries may not have the same data protection laws as the country in which you initially provided the information.  When we transfer your information to recipients in other countries (such as the U.S.), we will protect that information as described in this Privacy Policy and will comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries other than the one in which you provided the information.

If you are located in the European Economic Area (“EEA”) or Switzerland, with respect to transfers of personal information to the U.S., Virtuoso is certified under the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield frameworks developed by the U.S. Department of Commerce and the European Commission and Swiss Federal Data Protection and Information Commissioner, respectively, regarding the transfer of personal information from the EEA or Switzerland to the U.S.  Click here to view our EU/Swiss-U.S. Privacy Shield Privacy Policy at https://www.virtuoso.com/Footer/Privacy-Policy-EU-US
 

Your Rights and Choices


We offer you certain choices in connection with the personal information we obtain from you, such as how we use the information and how we communicate with you. To update your preferences, ask us to remove your information from our mailing lists or submit a request, please contact us as specified in the How to Contact Us section of this Privacy Policy.  You may unsubscribe from receiving future marketing and promotional emails by clicking on the unsubscribe link provided in our emails.  We may still contact you to respond to an inquiry and for certain account-related or transactional purposes.

To the extent provided by applicable law, you may (1) request access to the personal information we maintain about you; (2) request that we update, correct, amend, erase or restrict the information; or (3) exercise your right to data portability, by contacting us as specified in the How to Contact Us section of this Privacy Policy. Depending on your location, you may have the right to file a complaint with a government regulator if you are not satisfied with our response. Where provided by law, you may withdraw any consent you previously provided to us or object at any time to the processing of your personal information on legitimate grounds relating to your particular situation, and we will apply your preferences going forward. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to your information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain.
 

Notice to California Residents

 

Subject to certain limits under California law, California residents may ask us to provide them with (i) a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (ii) the identity of those third parties. To make this request, California residents may contact Virtuoso as specified in the How to Contact Us section below.
 

Other Online Services and Third-Party Features


For your convenience and information, our websites may contain links to other online services, and may include third-party features such as apps, tools, widgets and plug-ins. These online services and third-party features may operate independently of Virtuoso. The privacy practices of these third parties, including details on the information they may collect about you, is subject to their own privacy policies or notices, which we strongly suggest you review. We are not responsible for the content of any online services that are not affiliated with Virtuoso, any use of those services, or the privacy practices of those services.
 

How We Protect Personal Information

 

We maintain administrative, technical and physical safeguards designed to protect personal information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
 

Retention of Personal Information

 

To the extent permitted by applicable law, we retain personal information we obtain about you as long as (1) it is needed for the purposes for which we obtained it, in accordance with the provisions of this Privacy Policy, or (2) we have another lawful basis for retaining the data beyond the period for which it is necessary to serve the original purpose for collecting the data.
 

Updates To Our Privacy Policy


This Privacy Policy may be updated periodically to reflect changes in our personal information practices. We will post a notice on our websites and/or send you an email to notify you of any significant changes to our Privacy Policy and indicate at the top of the notice when it was most recently updated.
 

How To Contact Us


If you have any questions about this Privacy Policy, or if you would like us to update information we have about you, change your preferences or exercise other applicable data protection rights, please contact us by e-mail at help@virtuoso.com, by phone at 1-855-570-3827, or write to us at:

Virtuoso, Ltd.
777 Main Street, Suite 900
Fort Worth, TX 76102

For residents of the EEA, Virtuoso, Ltd.  is responsible for the processing of your personal information.  Residents of the EEA may contact us using this web form. [https://privacyportal-cdn.onetrust.com/dsarwebform/0b815c70-8d73-4627-b3c1-c5e60f2a2a84/38e59ad3-3030-43df-8d8b-99bb109f03ed.html]