Privacy Notice for Clients/Agents & Suppliers/Contractors
As part of your interaction with the G2, we may be required to process certain aspects of information that can lead to an identified individual (“Personal Data”). For the purpose of this notice, “G2” means the G2 Entity that you are interacting with, and the “G2 Entity” means G2 Travel Ltd., G2 Travel (FIT) Ltd., or one of their affiliates. The controller of your personal information will be determined in accordance with the G2 Entity you are interacting with.
We are committed to ensure that our Personal Data privacy and security practices are in strict compliance with the provisions of applicable data protection and privacy legislation, including without limitation, the GDPR. As part of our commitment to the rights of individuals whose Personal Data we process, we provide below the relevant information on the purpose, the legal basis and the duration for which we process your Personal Data, who we share it with, as well as on the rights you are entitled to and how you can exercise those rights.
Nothing in this Privacy Notice will serve as an obligation to enter into a binding agreement between the parties.
What Personal Data do we process?
In order to determine the nature of the contractual engagement between G2 and you (if any), and in order to ensure the performance of any agreement with you, we may be obliged to process the following types of data (the information below is meant to provide you with general examples of the types of information. Not all types of Personal Data may be required. Also, additional types may be collected, if the need arises):
• Identification data (name, surname, photograph, series and number of identity documents, civil status certificate, driving license);
• Contact details (phone number, e-mail address, home, residence);
• Financial data (bank account information);
• Data about your education and previous employment history;
• Information collected as part of reviewing possible future engagements (copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process, such as past employment records, job titles, training records, professional certifications);
• Information collected as part of your engagement with the G2, such as transactional history and support issues.
How do we collect your Personal Data?
Prior to entering into an engagement: we collect Personal Data through the application and review process, either directly from suppliers or sometimes from a background check provider. We may also collect additional information from third parties including former employers, credit reference agencies or other background check agencies or publicly available resources (such as social networks).
During an ongoing engagement: we will collect Personal Data in the course of the performance of your obligations throughout the period of the engagement, including information that you share voluntarily. Such communication may be recorded.
Why do we process your Personal Data?
We must process your Personal Data in order to comply with our contractual obligations when we enter into an engagement with you. We may also have a legal obligation to process such data to comply with various regulations, such as payment of taxes and compliance with anti-money laundering and bribery regulations.
Additionally, processing is necessary for conducting negotiations relating to any future engagement between the parties. Processing may also be necessary for our or your legitimate interests.
We may also process Personal Data when it is needed in the public interest or in protection of our rights, such as dealing with legal disputes, including incidents which occur during the provision of your services.
How long do we retain your Personal Data?
In general, your Personal Data is processed for the duration necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. For example, if you are engaged as a supplier to provide a certain service, we may retain your data for the duration of your service agreement and store it for an additional period, in accordance with our general retention policy.
Additional periods may be necessary to enable us to protect the rights conferred to us by the law for the period fiscal statute of limitation. However, we do not undertake to keep these data for the entire period mentioned above and we may delete or anonymise your Personal Data earlier if we do not have a legal obligation to keep them.
To whom do we disclose your Personal Data?
We do not sell, transfer, disclose or allow access to your Personal Data to third parties not related to its activity.
Where required by law, necessary to administer the contractual relationship with you or where we have another legitimate interest in doing so, we may have to share your Personal Data with third parties, including third-party service providers and other entities in the Company group.
We require third parties to respect the security of your Personal Data and to treat it in accordance with the law. We may transfer your Personal Data outside the EU. If we do, you can expect a similar degree of protection in respect of your Personal Data.
In order to achieve the goals described above, we may disclose your Personal Data to our suppliers of products and services, namely:
• providers of services and products involved in managing the contractual relationship between you and us, such as legal, tax or financial advisors, payment service providers, banks, suppliers of telecommunication services, travel agencies etc.
• IT service providers assisting us or other entities in our group for the operation and maintenance of our systems and equipment;
We may also provide your contact details to any contractual partner to enable them to contact you in connection with the performance of the contract concluded by them with us.
In all the cases described above, the disclosure of your Personal Data is limited to the Personal Data strictly necessary for the achievement of each purpose and is performed on the basis of a contract with the recipients of the data whereby they commit themselves to use the data solely for the purpose for which they were entrusted, to observe the obligation of confidentiality and to ensure the security of data, as well as to comply with all the provisions of the legislation in force regarding the protection of personal data.
Transferring Personal Data outside the EU or the UK
In cases where the entities in the group or the contractual partners to whom we disclose your Personal Data in the situations described above are located outside the European Economic Area or the United Kingdom, the disclosure shall be done only when the European Commission or the UK Information Commissioner’s Office have confirmed an adequate level of protection for the respective country or if adequate protection measures have been implemented (for instance the application of standard EU contractual clauses and UK Addendum).
We may also disclose your Personal Data to public authorities, on the basis and within the limits of the legal provisions and as a result of requests expressly made by them.
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your Personal Data. We do not allow our third-party service providers to use your Personal Data for their own purposes. We only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
What rights do you have and how can you exercise them?
You may request to:
• be informed whether we process your Personal Data and what data is processed;
• request correction of processed data, if it is incorrect or incomplete;
• oppose to processing and to restrict the processing of your Personal Data for justified and legitimate reasons relating to your particular situation and only if the processing of such data is not a legal obligation for us or is not essential for the performance of our agreement;
• ask for the deletion of your Personal Data, except where the law forbids deletion or if the data is essential for the performance of the agreement;
• ask to receive your Personal Data in a structured commonly used and machine-readable format and to transmit such data to another party.
As noted above, the exercising of these rights may be subject to regulatory requirements or our legitimate interests.
You may exercise the above rights by contacting our Data Protection Officer at email@example.com. To protect your personal data and your interests, we may request additional information to identify you.
Protecting the privacy of your Personal Data
When processing your Personal Data, we use technical and organisational measures to ensure the confidentiality, availability and accuracy of your data.
However, no information security system is infallible. That is why we are working continuously to ensure that our security measures are kept at the highest level and we commit ourselves to inform you on time of any security incidents that could pose a significant risk to your rights.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your Personal Data.