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Privacy

GDPR PRIVACY NOTICE

Last updated: 05/01/2026

1. Introduction

Travelnet Solutions, LLC along with its affiliates listed in Section 9 of this GDPR Privacy Notice (defined below), collectively, “TNS,” “Track,” “we,” or “us”) recognizes the importance of, and is committed to, maintaining the privacy of personal information that it receives relating to individuals. This supplemental privacy notice (“GDPR Privacy Notice”), which is provided in addition to the Privacy Notice, governs how TNS collects, processes, and uses Personal Information (as defined below) relating to residents of the European Union (“EU”) and the United Kingdom (“UK”) (collectively, “you”) covered by the EU General Data Protection Regulation (“EU GDPR”) and the UK General Data Protection Regulation (“UK GDPR” and together with the EU GDPR, “GDPR”) and provides information regarding how such EU and UK residents can exercise their rights under the GDPR. In case of conflict between the Privacy Notice and this GDPR Privacy Notice, this GDPR Privacy Notice will control with respect to EU and UK residents covered by this GDPR Privacy Notice. This GDPR Privacy Notice is only relevant to you if you are a resident of EU or the UK and we are a data controller of your Personal Information and subject to the GDPR in respect of our processing of your Personal Information. By using the Services, you confirm that you understand and acknowledge the provisions of the Privacy Notice and this GDPR Privacy Notice. If you are a TNS employee in the EU or UK, you will have separately received our GDPR Employee Privacy Notice.

2. Definitions

Capitalized terms used herein but not otherwise defined shall have the meaning assigned to it in the Privacy Notice.

3. How we collect your Personal Information

We collect Personal Information about you directly from you, for example, when you request to receive Services from us or, where you are our customer, you are using our website. If you fail to provide certain Personal Information when requested, we may not be able to perform the contract we have entered into with you to provide you services, or we may be prevented from complying with our legal obligations.

4. Purposes and Lawful Basis of Processing

The GDPR requires that we only process your Personal Information for purposes that we tell you about and only where we have a lawful basis to do so. The table below sets out our purposes of processing (as set out in Section 4 of the Privacy Notice) and the lawful basis of processing we rely on. For additional information on the Personal Information we collect, please refer to Section 3 of the Privacy Notice.
Purpose of processing Lawful basis for processing Personal Information
  • Provide, operate, and maintain our Services
 This processing is necessary to take steps to enter, or perform, a contract for services with you, and our legitimate interest of managing our customer relationships and providing our services Communications Data, Registration and Profile Information, Payment Information
  • Improve, personalize, and expand our Services (including customizing our web page content based on browser type and/or other information)
 This processing is necessary for our legitimate interest of improving our Services and providing you with a smooth, efficient and customized experience on our website Communications Data, Registration and Profile Information, Information Collected by Cookies, Technical Information
  • Understand and analyze how you use our Services (including analyzing trends, administering the site, tracking users’ movement on the website, and gathering demographic information)
 This processing is necessary for our legitimate interest of running our Site and to evaluate, develop and improve our services Information Collected by Cookies, Technical Information
  • Develop new products, services, features, and functionality of our Services
 This processing is necessary for our legitimate interest of developing our business and service offerings Communications Data, Registration and Profile Information, Information Collected by Cookies, Technical Information
  • Communicate with you, including by email, either directly or through one of our partners, including for customer service
 This processing is necessary to perform the contract between you and us, and for our legitimate interest in properly managing our customer relationships and operating our business Communications Data, Registration and Profile Information
  • Marketing purposes, including to provide you with updates and other information relating to the website, and for marketing and promotional purposes
 You have consented to this processing or, where permitted by law, this processing is necessary for our legitimate interest of promoting our business and providing you with information that we think you may be interested in Communications Data, Registration and Profile Information
  • For ongoing review and improvement of the information, content and Services provided to ensure it is user friendly
 This processing is necessary for our legitimate interest of improving our Services Communications Data, Registration and Profile Information, Information Collected by Cookies, Technical Information
  • Conduct analysis required to detect malicious data and understand how this may affect your IT system
 This processing is necessary for TNS’ legitimate interest of ensuring that its systems, and the data contained therein, are protected Technical Information
  • For in-depth threat analysis, prevent any potential disruptions such as cyber-attacks, and for statistical monitoring and analysis of current attacks on devices and systems for the ongoing adaptation of the solutions provided to secure systems and devices against current attacks
 This processing is necessary for TNS’ legitimate interest of ensuring that its systems, and the data contained therein, are protected Technical Information
  • Find and prevent fraud and other crimes or malpractice, and to improve fraud detection and information security
 This processing is necessary for our legitimate interest in preventing and protecting ourselves against fraud Communications Data, Registration and Profile Information, Payment Information, Technical Information
  • For the purpose of, or in connection with, any legal proceedings (including prospective legal proceedings), and obtain legal advice or to establish, exercise or defend our legal rights, including to enforce our agreements, policies and terms of use
 This processing is necessary to obtain legal advice or to establish, exercise or defend legal rights. It is also necessary for our legitimate interest in protecting ourselves and defending ourselves against litigation. Communications Data, Registration and Profile Information, Payment Information
  • Complying with legal obligations
 This processing is necessary for the compliance with legal obligations to which we are subject Communications Data, Registration and Profile Information, Payment Information
  • Confirm and verify your identity and to conduct due diligence
 This processing is necessary for the compliance with legal obligations to which we are subject and our legitimate interest in ensuring that we contract with who you say you are Communications Data, Registration and Profile Information
  • For the management and administration of our business, and comply with our contractual obligations
 This processing is necessary to take steps to any contract for services we have with you, and our legitimate interest of managing our business Communications Data, Registration and Profile Information, Payment Information
  • In connection with a corporate transaction, such as a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of any or all of our assets or liabilities in corporate control or a restructuring event
 This processing is necessary for our, and any potential counterparties’, legitimate interest of assessing any potential transaction Communications Data, Registration and Profile Information

5. International Transfers

We may transfer your Personal Information to a recipient based in a country outside of the European Economic Area and the UK. Where we do so, we will ensure that such transfer is in accordance with our obligations under the GDPR. For example, this may involve transferring your Personal Information to a jurisdiction deemed to provide an adequate level of protection of your Personal Information under the GDPR. Other times, the recipient may be in a jurisdiction that has less stringent laws relating to Personal Information. In these circumstances, we will put in place appropriate safeguards to ensure that your Personal Information remains adequately protected, which may include entering into European Commission or UK Information Commissioner’s Office approved standard contractual clauses with the recipient of your Personal Information. If you would like more details about the safeguards we rely on, please contact us using the details set out in Section 8 of this GDPR Privacy Notice. For additional information on how we store your Personal Information, please refer to Section 8 of the Privacy Notice.

6. Your GDPR Rights

You have certain choices regarding your Personal Information, as described below.
  1. Access. You have the right to obtain a copy of the Personal Information we hold about you and other supplementary information from us.
  2. Deletion. You have the right to request that we delete certain Personal Information we have collected from you and to tell our service providers to do the same.
  3. Correction. You have the right to request that we correct or complete certain Personal Information we maintain about you if it is inaccurate or incomplete.
  4. Transfer. You have the right to ask us to transfer your Personal Information to a different data controller.
  5. Restriction. You have the right to request that we limit the use and disclosure of your Personal Information in certain circumstances.
  6. Objection. You have the right to object to our processing of your Personal Information where we are processing it on the legitimate interests lawful basis, including where we are using it for direct marketing purposes.
  7. Withdraw consent. While we do not typically rely on consent to process your Personal Information, where we do so you have the right at any time to withdraw your consent.
However, please note that some of these rights may not always apply, as there are sometimes requirements and exemptions, which may mean we need to keep processing the Personal Information or not disclose it, or other times when the rights may not apply at all. We will always tell you if we think we do not have to comply. To exercise any of these rights, please visit the TNS Privacy Request Center or contact us using the details set out in Section 8 of this GDPR Privacy Notice. You also have the right to complain to your local data protection regulator about our processing of your Personal Information, although we would always ask you to speak to us or, if you are resident in the EU, our EU representative or, if you are resident in the UK, our UK representative first if possible on the contact details set out in the ‘Contact Us’ section below. In the UK, the data protection regulator is the ICO and their contact details are available here: https://ico.org.uk/make-a-complaint/. If you live in an EU member state, you can find your local data protection regulator here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

7. Other GDPR Disclosures

  1. No Automatic Decision-making. We may process some of your Personal Information automatically, but we do not use computer algorithms to make automated decisions based on your Personal Information.
  2. Retention of Personal Information. We retain Personal Information for as long as is reasonably necessary in connection with the purposes for which the Personal Information was collected. For additional information on how we store your Personal Information, please refer to Section 7 of the Privacy Notice.

8. Contact Us

If you have any questions about this Privacy Notice or our processing of your Personal Information, or to exercise any of your rights, then please contact [email protected].

9. TNS Data Controllers

Entity Address
Travelnet Solutions, LLC 9900 Hemingway Avenue, South Cottage Grove, Minnesota 55016, United States