1. Accountability

Expo Egypt is responsible for personal information in its custody or under its control, including any personal information transferred to a third party for processing. Expo Egypt requires a comparable level of protection for personal information handled by its third-party contractors.

Each Expo Egypt office is responsible for maintaining and protecting the personal information of Travellers under its control. In fulfilling this mandate, each Expo Egypt office has designated an individual or individuals who are accountable for compliance with this Privacy Policy.

In addition, Expo Egypt has designated a corporate Privacy Manager to facilitate Expo Egypt’ privacy compliance, in conjunction with senior leadership - who has overall responsibility for Expo Egypt’ privacy compliance.

2. Identifying Purposes

Expo Egypt shall identify the purposes for which personal information is collected, at or before the time the information is collected. When personal information that has been collected is to be used for a purpose not previously identified, the new purpose will be identified prior to use.

The primary purposes for which Expo Egypt collects personal information include:

• to establish and maintain responsive relationships with Clients and Travellers;
• to provide travel tour operator services to its Clients including, without limitation, making travel arrangements on behalf of Travellers, providing travel policy compliance services, and collecting and reporting on Client travel data;
• to understand Client and Traveler needs and preferences, including special requirements;
• to obtain payment for services;
• to develop, enhance, market or provide products and services, including, without limitation, to market or provide products and services through Expo Egypt and affiliated partners of Expo Egypt;
• to manage and develop Expo Egypt’ business and operations;
• to conduct surveys and promotions; and
• to meet legal and regulatory requirements.

3. Consent

The knowledge and consent of the individual are required for the collection, use or disclosure of personal information, except where required or permitted by law.

Expo Egypt provides travel tour operator services to clients. In order to complete these services, Expo Egypt requires personal information for authorized Travellers. The personal information collected by Expo Egypt may include, but is not limited to, name, address, age, marital status, passport and visa information, emergency contact, email, phone number, financial information and corporate data.

Expo Egypt may also collect sensitive personal information related to a Traveler’s travel arrangements (such as the Traveler’s disabilities, allergies and other medical information and special needs) to help the Traveller obtain special accommodations for travel arranged by or through Expo Egypt, but only if the Traveller submits such sensitive personal information to us. If a Traveller does not want us to collect and use such sensitive personal information, then the Traveller should not submit this information to us. Expo Egypt will not share a Traveller’s sensitive personal information with a third party unless authorized to do so by the Traveller.

In order to complete the travel arrangements requested by the Traveler, Expo Egypt may input the Traveler’s personal information into a Tour Management Tech operating system or provide the Traveller’s personal information to one of the global distribution systems or an internet booking engine (“GDS”) or other travel supplier. The GDS uses such personal information to aid in fulfilling the travel arrangements requested by a Traveller through specific travel suppliers, such as airlines, hotels and rental car agencies. Expo Egypt receives confirmation of the travel arrangements requested by a Traveller.

Upon completion, Expo Egypt provides information to the Client on travel arrangements made for a Traveler. This information may include, but is not limited to, information regarding the dates and times of travel, locations travelled to and from, classes of service provided, the names and locations of any hotels or other lodging arranged for the Traveller by Expo Egypt, the names of other travel suppliers providing services to the Traveller, and the costs incurred for all travel services selected by the Traveller. A Traveler’s personal information may also be shared with the Client for which a Traveller is making travel arrangements.

Expo Egypt does not exercise any control over personal information that has been transmitted to the GDS or other travel suppliers. By submitting personal information to Expo Egypt, the Traveler authorizes the use and disclosure of such personal information to complete the travel arrangements requested by the Traveller. Personal information transferred to a travel supplier will be used by such supplier in accordance with their privacy policies, many of which contain provisions similar to the provisions contained in this Privacy Policy. Personal information transferred to a supplier may be subject to the Privacy Laws of a foreign jurisdiction. In addition, United States or other government and law enforcement authorities may have access to a Traveller’s personal information under certain security screening protocols.

A Traveler may choose not to have any of his or her personal information disclosed or transferred to third parties in accordance with the terms of this Privacy Policy. However, if a Traveller chooses not to submit his or her personal information to Expo Egypt or allow Expo Egypt to provide such personal information to a GDS or other travel supplier, then Expo Egypt may not be able to provide the travel services requested.

By contacting Expo Egypt and requesting travel services information, a Client is consenting to the collection, use or disclosure of Traveler personal information in accordance with the purposes identified in Section 2 of this Privacy Policy. Expo Egypt may seek consent to use and disclose personal information after it has been collected, but before it is used or disclosed for a new purpose. A Traveler may withdraw their consent to the collection, use or disclosure of their personal information by Expo Egypt at any time by contacting us at [email protected]. This will be subject to legal or contractual restrictions and reasonable notice. Expo Egypt will inform the Traveller of the implications of withdrawing Traveler’s consent. Withdrawal of consent does not have retroactive effect.

Expo Egypt may be required or permitted to disclose personal information from time to time in order to comply with legal requirements and will comply with applicable Privacy Laws in doing so.

In addition to collecting, using and disclosing personal information in connection with the provision of services, Expo Egypt may collect personal information from its employees and this personal information may be transferred among Expo Egypt and its Affiliates, and may be subject to the Privacy Laws of a foreign jurisdiction. Employee personal information is not subject to PIPEDA, however, Expo Egypt handles employee personal information in accordance with the Privacy Principles (to the extent possible) and Expo Egypt’ human resources policies.

4. Limiting Collection

Expo Egypt limits the collection of personal information to that which is necessary for the purposes identified by Expo Egypt. Personal information must be collected by fair and lawful means.

Expo Egypt collects, stores and processes only that personal information required to provide travel tour operator services for or to fulfill contractual obligations with regard to Travellers and Clients.

5. Limiting Use, Disclosure and Retention

Expo Egypt shall only use or disclose personal information for the purposes for which it was collected unless the individual has otherwise consented, or when it is required or permitted by law.

Personal information is retained only for the period of time required to fulfill the purposes for which it was collected.

Personal information is only used by Expo Egypt’s employees or agents who have a business need to know such information or whose duties so require, and only as necessary to fulfill that function. Expo Egypt employees are subject to this Privacy Policy and any Expo Egypt employee who utilizes personal information improperly may be subject to discipline, up to and including termination of employment.

6. Accuracy

Personal information is maintained by Expo Egypt in as accurate, complete and up-to-date form as is necessary to fulfill the purposes for which it is to be used. Expo Egypt relies upon the accuracy of the personal information submitted by the Traveler in order to provide the specific travel services, and does not routinely update that information.

7. Safeguards

Personal information of Travellers is protected by security safeguards that are appropriate to the sensitivity of the information.

Keeping a Traveler’s personal information confidential is important to us and Expo Egypt takes reasonable steps to protect that information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction. Expo Egypt employs physical, administrative and technological safeguards to protect the security of personal information. For example, Expo Egypt has implemented physical security measures to protect against unauthorized access to its central and backup data centres where personal information is stored.

Any credit card information is transmitted in an encrypted format using standard SSL (secure socket layer) encryption. Travellers should use caution when disclosing personal information by telephone or other electronic media, as Expo Egypt has no control over such third party providers.

Expo Egypt conducts periodic internal reviews of its data collection, storage and processing practices and the security measures it has implemented to ensure that such security measures provide reasonable precautions and are commensurate with those generally practiced within the travel management industry.

As with all personal information, Expo Egypt will never rent or sell a Traveler’s personal financial information.

Expo Egypt employees who have access to personal information are bound by confidentiality obligations, the violation of which will subject the employee to discipline, which may include termination of employment.

8. Openness

Expo Egypt makes information available to individuals concerning the policies and practices that apply to the management of their personal information, including as set out in this Privacy Policy.

Individuals may contact us at [email protected] if they have any questions about our privacy practices.

9. Individual Access

Upon request, an individual shall be informed of the existence, use and disclosure of their personal information, and shall be given access to it. Individuals may verify the accuracy and completeness of their information, and may request that it be amended, if appropriate.

Expo Egypt will use good faith efforts to provide its Clients, Travellers, and others from whom it obtains personal information the opportunity to review and revise the personal information Expo Egypt has collected. Any review and revision of personal information by such persons is subject to the provisions of this Privacy Policy.

If a Traveller becomes aware of any inaccuracy in his or her personal information or if a Traveler wishes to inquire about his or her personal information, then the Traveler should notify us by contacting us at [email protected]. Expo Egypt will make all corrections and/or deletions of erroneous personal information brought to its attention within a reasonable time period. Expo Egypt will provide access to personal information in accordance with the requirements of applicable Privacy Laws.

10. Challenging Compliance

Individuals may direct any questions or enquiries with respect to this Privacy Policy or about our practices by writing to [email protected], and asking for the Privacy Manager, or by contacting the designated person accountable for privacy in each Expo Egypt office.

A Traveler who thinks that his or her personal information has been misused should direct any questions or complaints to Expo Egypt at [email protected], providing a written description of the complaint. After receiving a written description of the complaint a representative of Expo Egypt will contact the Traveler in order to discuss his or her concerns. Expo Egypt is interested in addressing all legitimate complaints about its adherence to applicable Privacy Laws and will make a good faith effort to promptly resolve any complaint brought to its attention.