Effective from March 8, 2023

Privacy Statement

At Corporate Coach, LLC (“Corporate Coach”), we highly value your privacy as our client and recognize its significance to you. We are committed to ensuring that you have a clear understanding of how we collect, use, and disclose your Personal and Other Data (collectively referred to as “Data”).

Privacy Preferences: We respect your privacy at Corporate Coach and offer you choices, information, and options to express your preferences regarding data sharing and communication preferences.

DATA COVERED BY THIS PRIVACY STATEMENT

This Privacy Statement pertains to the privacy practices of Corporate Coach regarding the collection of Data through various channels, including:

• Our Websites, such as https://www.cccarservice.com/, as well as other websites owned or controlled by Corporate Coach that are linked to this Privacy Statement.
• Software applications (Apps) developed by Corporate Coach, accessible on computers and mobile devices.
• Social Media Pages managed by Corporate Coach and linked to this Privacy Statement.
• Email communications that contain links to this Privacy Statement, as well as any online or in-person interactions with us.
• Data obtained from third parties, including Authorized Licensees and Other Sources, such as public databases, marketing partners, and other external parties.
• Information collected during your travels as a client within our vehicles.
• Together, these encompass our Online Services (including Websites, Apps, and Social Media Pages) and, when combined with Vehicle Travels and Offline Interactions, are collectively referred to as “Services.”

THE DATA WE COLLECT

Throughout your journey as a client, we gather Personal Data with the aim of delivering outstanding services. Personal Data refers to information that can specifically identify you as an individual or is closely related to your identification. The following categories outline the types of Personal Data that we collect and process:

• Name
• Gender
• Postal address
• Telephone number
• Email address
• Financial details (such as credit card or payment information)
• Language preference
• Music preference
• Date and place of birth
• Nationality, passport information, visa details, or other government-issued identification data
• Significant dates, including birthdays, anniversaries, and special occasions
• Data associated with the Gold Tie Membership Program (Member Program)
• Safety and security preferences
• Employer information (applicable to business-related bookings)
• Travel itinerary, tour group details, or activity information
• History of past client travels or interactions, goods and services purchased, and specific requests for special services and amenities
• Social media account identifiers, profile photos, and publicly available data or data made accessible by linking your social media and Member Program accounts

In certain limited circumstances, we may also collect:

• Data concerning family members and other fellow travelers
• Biometric data
• Images, videos, and audio recordings obtained through security cameras situated in and on vehicles or through body-worn cameras utilized by armed guard personnel.

We may also collect information about your travel preferences to enhance your current and future travel experiences with us. This includes information about your interests and other relevant details that we learn about you during your travel. It may also include feedback regarding our services, music preferences, dietary restrictions, health considerations, and personal needs to ensure your well-being. Additionally, we may gather your “Personal Preferences,” which can include details about special anniversaries (such as birthdays or wedding anniversaries), preferred activities while traveling, hobbies, and information about individuals you typically travel with, their relationship to you, and your marital status.

If you provide us with any Personal Data about other individuals, such as making a reservation on their behalf, you confirm that you have the authority to do so and permit us to use the data in accordance with this Privacy Statement.

ONLINE AND MOBILE DATA WE COLLECT

We typically do not collect Personal Data through your use of the Online Services. However, we may collect “Other Data” that does not directly identify you. If Other Data reveals your specific identity or relates to an individual, we will treat it as Personal Data.

“Other Data” includes:

System Data: When you access the Online Services through desktop or mobile devices, certain data is collected through your browser or automatically through your device. This data includes your computer type, screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version, and the name and version of the Online Services you are using.

IP Address: We collect your IP address, which is automatically assigned to your device by your Internet Service Provider (ISP). Your IP address, along with the time of visit and the pages visited, is logged in our server log files. We use IP addresses to calculate usage levels, diagnose server problems, administer the Online Services, and determine your approximate location from your IP address.

Precise Location-Based Services: With your consent, we may collect the precise physical location of your device using satellite, cell phone tower, Wi-Fi signals, or other technologies. This data is only collected if you opt-in through the App or other program to enhance special offers and enable location-driven capabilities. You can specify your location-sharing preferences via your device’s operating system settings.

Cookies and Similar Technologies on our Websites: When you visit our Websites from desktop or mobile devices, we may collect and use cookies or other identifiers. These technologies serve various purposes such as personalizing advertisements, measuring website interaction, and maintaining your preferences. To learn more about cookies, please visit our Cookie Policy at https://www.cccarservice.com/cookie-policy/.

Apps and Mobile Devices: When you download and use an App, certain data is collected, including App usage data, access timestamps, and downloaded data based on your device ID. Our Apps may also incorporate third-party software development kits (SDKs) that collect and transmit data to enable specific features. With your consent, we may collect mobile device advertising identifiers to enhance your experience and deliver relevant content or ads.

Aggregated and Segmented Data: We may aggregate the data we collect, and such aggregated data will not personally identify you. We may also use both Personal Data and Other Data to segment customers for more targeted advertising, including third-party advertising.

HOW AND WHERE WE COLLECT YOUR DATA

This Privacy Statement outlines Corporate Coach’s privacy practices for Personal and Other Data collected through the following means:

Corporate Coach: We collect Personal Data and Other Data from within Corporate Coach for purposes described in this Privacy Statement, such as providing personalized services, communications, facilitating the Member Program and business purposes.

Authorized Licensees and Subcontractors: Personal Data and Other Data are collected from companies operating under a contract or similar agreement to sell goods or services on behalf of Corporate Coach or using a Corporate Coach brand. Authorized Licensees operate independently.

Linked Accounts: Personal Data and Other Data are collected when you use your Member Program number or Online Services login for third-party services. Integration with social media accounts also involves the disclosure of Personal Data and Other Data to third parties. If you do not wish your data to be collected in this manner, please refrain from providing your Member Program number, using your Online Services login for third-party promotions, or linking your Online Services account with third-party accounts.

Promotional Activity: Personal Data and Other Data are collected from third parties offering promotions such as sweepstakes, contests, or other offers.

Other Sources & Service Providers: Personal Data and Other Data are collected from various third parties, including public databases, joint marketing partners, and online travel agencies.

Online Services: Personal or Other Data is collected when you interact with our Online Services, such as browsing, making reservations, purchasing goods and services, communicating with us, posting on social media pages, signing up for newsletters, or participating in promotional offers.

Client Service Centers: Personal Data is collected during phone reservations, email communication, online chat services, or customer service interactions. These communications may be recorded for quality assurance and training purposes.

Internet-Connected Devices: Personal and Other Data are collected from internet-connected devices available in our vehicles, such as when you connect a device to the vehicle’s internet or utilize a vehicle’s online entertainment system.

LEGAL BASIS FOR DATA COLLECTION

Please be aware that in certain jurisdictions, your agreement to the collection of Personal Data is necessary for Corporate Coach to provide its services.

Booking & Client Reservation: The collection of data related to reservations, bookings, pre-arrival communications, and payment processing is necessary to fulfill the contract between Corporate Coach and the individual making the booking. It also serves the legitimate interests of the client and enables compliance with financial transaction obligations.

Corporate Coach Operations & General Business: The collection of data for customer care, security, troubleshooting, data analysis, system maintenance, support, reporting, and business purposes serves the performance of the contract, legitimate interests, and legal obligations related to financial transactions and records maintenance.

Legal & Compliance: The collection of data for legal compliance, responding to legal processes and requests from authorities, national security or law enforcement requirements, enforcing terms and conditions, protecting operations, rights, privacy, safety, or property of Corporate Coach and relevant individuals, and pursuing legal remedies falls under legal obligations, legitimate interests, and individuals’ vital interests.

Emergency & Incident Response: The collection of data for ensuring on-site security, handling accidents and emergencies, monitoring properties, and sending notifications and alerts in case of incidents or emergencies serves the performance of the contract, legitimate interests, legal obligations, and individuals’ vital interests.

Member Program & Relationship Management: The collection of data for registration in the Member Program, eligibility determination, personalized services, access to Online Services, payment processing, notifications, and handling requests and inquiries is based on the performance of the contract, consent, legitimate interests, and legal obligations.

Marketing, Promotions, Contests & Third-Party Products: The collection of data for communicating about products and services, providing personalized advertisements, facilitating participation in promotions, and handling requests, inquiries, and complaints relies on the performance of a contract, consent, legitimate interests, and legal obligations.

By collecting and processing your Data for these purposes, we ensure the provision of quality services, personalized experiences, and compliance with legal requirements.

MORE INFORMATION ABOUT YOUR PERSONAL PREFERENCES

Our objective is to serve you better and meet your expectations and preferred level of hospitality throughout your journey with us. The following items are obtained out of legitimate interest to provide you with exceptional service:

Special Occasions: When you travel with us, we want to help you celebrate special occasions, such as anniversaries or birthdays. We may make a note of these dates to provide you with greetings or advertising.

Activity Preferences: We may retain your preferences for activities you enjoy participating in during your travels with us, allowing us to offer similar experiences in the future.

Travel Companions: We understand that your preferences may vary depending on who you are traveling with. For example, if you are traveling with small children, we can make arrangements for additional accommodations such as car seats or booster seats.

Vehicle and Travel Preferences: We may retain your preferences for our vehicles, vehicle amenities, music, restaurants, hotels, and pick-up and drop-off arrangements based on your past travel preferences.

HOW AND WHEN WE SHARE YOUR DATA

To provide you with the highest level of hospitality and services, we may share Personal Data and Other Data with the following:

Corporate Coach: We disclose Personal Data and Other Data within Corporate Coach for purposes described in this Privacy Statement, such as providing and personalizing the Services, communicating with you, facilitating the Member Programs, and accomplishing our business purposes. We share your Personal Data and Other Data used for making reservations with a Corporate Coach entity to fulfill and complete your reservation.

Partner Organizations: We may share your information with partner organizations, such as jet service providers, restaurants, spas, health clubs, golf clubs, concierge services, and other outlets, to provide you with services and their own marketing. This sharing enables us to offer you a comprehensive source for purchasing packages that include travel-related services.

Promotional Activity: We partner with third parties who may provide promotions to you, such as sweepstakes, contests, discounts, or other offers.

Service Providers: We disclose Personal Data and Other Data to third-party service providers, including companies that provide website hosting, data analysis, payment processing, order fulfillment, information technology and infrastructure provision, customer service, email delivery, marketing, auditing, and other services.

Vehicle Owners: As the vehicle you are booked to travel in may not be owned by Corporate Coach, we disclose Data to owners of Corporate Coach branded vehicles for purposes described in this Global Privacy Statement. Owners have a limited right to use certain Personal Data for their own purposes and qualify as independent data controllers to comply with their own legal obligations, including maintaining books & records and other compliance obligations.

Other Uses and Disclosures: We may use and disclose Personal Data as necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal processes; (c) to respond to requests from public and government authorities, including authorities outside your country of residence, and to meet national security or law enforcement requirements; (d) to enforce our terms and conditions; (e) to protect our operations, such as in the event of reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of the Corporate Coach business, assets, or stock (including bankruptcy or similar proceedings); (f) to protect the rights, privacy, safety, or property of Corporate Coach, you, or others; and (g) to allow us to pursue available remedies or limit damages that we may sustain.

We may use and disclose Other Data for any purpose, except where prohibited under applicable law.

YOUR DATA, YOUR CHOICES: PREFERENCES AND RIGHTS REGARDING YOUR PRIVACY

At Corporate Coach, we strongly believe in giving you control over your data. We offer you various options, information, and choices to express your preferences regarding the sharing of your data and the way we communicate with you.

Communication Preferences: If you no longer wish to receive marketing emails from us, you can opt-out by replying “Unsubscribe” to any marketing email you receive from us.

You may also opt-out of marketing emails by sending an email to clientservices@cccarservice.com with the subject: Unsubscribe.

Please note that even if you opt-out of marketing emails, you will continue to receive transactional messages, such as reservation information and account security updates.

Cookies and Other Data: For information on your choices related to Cookies and Other Data, please refer to our Cookie Policy available at https://www.cccarservice.com/cookie-policy/.

Individual Rights: If you or your authorized agent would like to request access, correction, deletion, restriction, confirmation of use, or objection to the processing of your previously provided Personal Data, please email your request to legal@cccarservice.com. For your protection, we only fulfill requests for Personal Data associated with the email address and/or Member Program account number provided in your request, and we may need to verify your identity before fulfilling certain requests.

Corporate Coach respects your privacy and will make reasonable efforts to comply with your request as soon as practicable and in accordance with applicable law. Please note that not all individual rights may be available to all clients or users of our services under applicable law.

Opting-Out of Sale, Sharing, and/or Targeted Advertising: To exercise your rights to opt-out of the sale and/or sharing of your Personal Data or to opt-out of the use of your Personal Data for targeted advertising (where afforded to you under U.S. State law), please email clientservices@cccarservice.com and specify which of the three you would like to opt-out of. Please confirm that the email address corresponding to this request is the one from which the request is being sent. Please submit no more than one request per email.

Please note that by exercising your opt-out choices, you may limit certain services or functionalities available to you.

IMPORTANT PROVISIONS

Non-Corporate Coach Entities: This Privacy Statement does not cover the privacy, data, or other practices of entities outside of Corporate Coach, including Franchisees, Owners, Subcontractors, Authorized Licensees, or any third-party operating a site or service linked through the Services, payment service, Member Program, or website serving as the landing page for high-speed Internet providers. The inclusion of a link on the Online Services does not imply our endorsement of the linked site or service. We have limited control and are not responsible for any third-party’s collection, use, and disclosure of your Personal Data.

Additionally, we are not accountable for the data collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, Booking Tool, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer.

This also includes Personal Data you disclose to other organizations through the Apps or our social media pages.

Security: We implement reasonable organizational, technical, and administrative measures to protect Personal Data. However, no data transmission or storage system can be guaranteed to be 100% secure. If you suspect that your interaction with us is no longer secure (e.g., if you believe the security of your account has been compromised), please promptly notify us at legal@cccarservice.com.

Retention: We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Statement, unless a longer retention period is required or permitted by law.

In determining our retention periods, we consider various factors, including the duration of our ongoing relationship with you and the provision of Services, any legal obligations we are subject to, and the advisability of retention in light of our legal position.

Sensitive Data: We only collect Sensitive Personal Data when it is necessary to reasonably perform expected services or as required by law. We kindly request that you refrain from sending or disclosing any Sensitive Personal Data (e.g., social security number, taxpayer identification number, passport number, driver’s license number, government-issued identification number; credit or debit card details or financial account number, with or without access codes or passwords; credit history; information on race, religion, ethnicity, sex life or practices, or sexual orientation; medical or health information; genetic or biometric information; biometric templates; political or philosophical beliefs; political party or trade union membership; background check information; judicial data such as criminal records; or information on other judicial or administrative proceedings) to us through the Services.

Use of Services by Minors: The Services are not intended for children, and we do not knowingly solicit or collect personal data from children under the age of sixteen (16) without parental consent. We kindly request that minors refrain from providing Personal Data through the Services.

Updates to This Privacy Statement: The “Effective Date” at the top of this page indicates the most recent revision of this Privacy Statement. Any changes will be effective upon posting the revised Privacy Statement on the Online Services. If you would like to review the version of the Privacy Statement effective immediately prior to this revision, please contact us at legal@cccarservice.com.

Additional Information:

DATA CONTROLLER

For residents of the United States, Corporate Coach, LLC is the data controller responsible for your personal data. Corporate Coach also acts as an independent data controller in relation to subcontractors, who have a limited right to use the Data we collect.

FEDERAL COMMUNICATIONS COMMISSION

Lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection laws occurs. For the US, one can submit a national data policy violation complaint on the FCC website.

If you have any questions regarding this Privacy Statement, please contact our data protection department legal@cccarservice.com.