Effective: 20 December 2006, revised September 2023.

The Universal Air Travel Plan, Inc. (hereafter referred to as “UATP”) is committed to maintaining the privacy of personal information. This Privacy Policy describes how UATP treats personal information received about you when you visit the UATP website and/or register for UATP’s Airline Distribution event or other UATP events. It also explains how UATP uses personal information it receives from its business customers. UATP may change the Privacy Policy from time to time and will post any material changes on the UATP website.   Be sure to check this site periodically.

Scope and Nature of the Policy

Data Collected

UATP collects personal information from you and about you if you provide such information to UATP directly, including the email addresses of those who communicate via email, information volunteered by you, such as survey information and/or site registrations, and name and address, telephone number, and fax number.  We also may collect information about your interests in and use of our various programs and services.

When providing any personal information to us, in each instance you will fully understand and clearly consent to the collection and processing of such information, and if applicable, to the transfer of such personal information to other countries or territories.  Any such transfer and processing by us will be in accordance with this Privacy Policy.

For each visitor to our web pages, the UATP web server automatically recognizes the consumer’s domain name and email address (where possible or applicable).  We also collect IP addresses and website usage information from you when you visit our website.  This information helps us evaluate how our visitors use and navigate our website on an aggregate basis, including the number and frequency of visitors to each web page and the length of their visits.

Like many other websites, we use “cookies” to help us gather and store information about visitors to our websites. A cookie is a text-only string of information that a website transfers to the cookie file of the browser on your computer’s hard disk so that the website can remember who you are. A cookie will typically contain the name of the domain from which the cookie has come, the “lifetime” of the cookie, and a value, usually a randomly generated unique number.

We also use third party analytics providers to collect information about use of certain products and services, including Google Analytics, with a restricted data processing feature that limits use of your data by Google. Google uses cookies to collect information about the products and services usage and to report website trends to us, without identifying any individuals specifically (individual end-users or visitors) to UATP.  Your information, if included, remains anonymous to us.

You can learn about how Google uses data by going to https://policies.google.com/technologies/partner-sites and you can opt-out by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

We may from time to time use cookies to tailor information and advertising of our products and services to your interests based on the webpages and content you visit, but only after you agree to receive such communications.  These cookies gather personal information such as your name, internet protocol address and location. We will not collect these nonessential cookies if you do not agree. We do not provide your information to third parties for advertising purposes.

You may accept or decline these cookies by clicking where indicated when you first visit our website. You may modify the settings in your browser to decline cookies at any time. However, you may not be able to use all features of our site if all cookies are disabled. There are several ways to manage cookies. Please refer to your browser instructions or help screen to learn more about these functions. For example, in Internet Explorer, you can go to the Tools/Internet Options/Security and Privacy Tabs to adapt the browser to your expectations. If you use different computers, you will need to ensure that each browser is adjusted to suit your cookie preferences.

How Your Information Is Used

We may use the personal information you provide to respond to your requests for information or to register for Airline Distribution or other events as requested.  We also use information you provide to contact you regarding our programs, such as our conference, or to provide you with information about other UATP programs, events, and services in which you may be interested. We never sell to or share your information with third parties.  If you would like to request that we not use information we collect about you for such marketing purposes, please contact us at [email protected].

We may also use information we collect at this site to personalize the content, improve the content of our web page, and/or to provide you with UATP product or service offers.

We may disclose personal information in response to legal process, for example, in response to a court order or a subpoena.  We also may disclose such information in response to a law enforcement or other government agency’s request, or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, to comply with legal requirements, or as otherwise required by law. We may share information in the event of a bankruptcy, or a merger, acquisition, joint venture, or other business combination involving us.

Other than the uses set forth above, we do not disclose personally identifiable information to third parties without your permission.

UATP As a Data Processor

UATP acts as a data processor on behalf of its business customers by operating its transaction processing system and in some cases, by streamlining billing and providing travel managers with detailed activity reports that track a traveler’s name and/or account number, carrier, destination and travel itinerary.  In this capacity, UATP receives personal information from its business customers. UATP acts on the instructions of such customers and does not own or have independent rights to control of the personal information it processes on their behalf.  UATP business customers will obtain consent from you, if applicable, prior to sending your information to UATP for such processing.  UATP will not sell or share personal information it processes or disclose it to third parties, except as permitted or required by the processing agreement with our business customer or applicable law.

California Residents

If you reside in California this section is a notice to comply with the California Consumer Privacy Act of 2018 (CCPA) as amended by the California Privacy Rights Act (CPRA). We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”).

Categories of Personal Information

The categories of personal information UATP collects from consumers (directly or from our business customers) include identifiers (i.e., name, email address, domain name (where possible or applicable) cookies and/or IP address, UATP website activity, account numbers, usernames and certain travel itinerary). We obtain personal information from the following sources:

• Directly from you, such as from forms you complete or meeting registrations or if you are a user of our products and services;
• Indirectly from you, such as from observing your anonymous actions on our website; or
• From our business customers with whom you interact.

UATP will not collect or use additional categories of personal information for materially different, unrelated, or incompatible purposes without providing you notice and obtaining consent when required.

Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill your request for information or to participate in a conference.
• To provide and develop a better website or products, and services.
• To create, maintain, customize, and secure your account with us.
• To process transactions and to prevent or reduce fraud.
• To deliver content and product and service offerings relevant to your interests via email with your consent (where required by law).
• To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

UATP will not use the above personal information for materially different, unrelated, or incompatible purposes without providing you notice and obtaining consent when required.

Disclosing Personal Information

UATP may disclose your personal information to our service providers for a business purpose. When we do so, we enter into a contract that describes the purpose and requires the recipient to both keep personal information confidential and not use it for any purpose except performing the contract. We only exchange your personal information with our service providers. UATP does not sell or share your personal information as described under the CCPA.

Your California Rights and Choices

The CCPA provides consumers that are California residents with specific rights regarding their personal information. You have the right to request that UATP disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we disclosed your personal information for a business purpose, a list disclosing all disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. We do not sell or share your personal information.

You have the right to request that UATP delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for to complete the transaction for which we collected the personal information or otherwise perform our contract with our business customers with whom you have a relationship, or to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

To exercise the rights described above, please submit a verifiable consumer request to us by emailing us at [email protected].

Security

We have put in place appropriate administrative, technical, and physical procedures to safeguard and help prevent unauthorized use of or disclosure of the information we collect online or process for business purposes.

Links to Third Party Sites

UATP’s website may also have links to the sites of other companies.  UATP is not responsible for their privacy practices nor do we monitor or control the information collected when you choose to access those websites.  Since their treatment of personal information may differ from ours, we encourage you to learn about the privacy policies of those companies.

While our primary operations are in the US, UATP may transfer information provided by and about customers to the appropriate office, distributor, partner or consultant to deliver the service or information required to assist the customer.  In order to provide service in a timely, cost effective and efficient manner, information provided by UATP may be made available to authorized UATP users across our global offices that require access to the information for business services.

If you are located outside of the United States, please note that the information you provide to us may be transferred to the United States. When you register on the UATP website, you consent to this transfer.

EU, UK and Swiss Data Privacy Framework Policies

UATP has many international client relationships and as such has developed global practices designed to address applicable data protection requirements.  For personal information transferred from Europe on behalf of our business customers, UATP participates in the Data Privacy Framework (DPF) as set forth by the US Department of Commerce regarding the collection, use and retention of personal data from European Economic Area (“EEA”) member countries, including the European Union (EU), the United Kingdom (and Gibraltar) (“UK”) and Switzerland. Specifically, UATP has certified that it adheres to the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) Principles of: notice; choice; accountability for onward transfer; security; data integrity and purpose limitation; access; and recourse, enforcement and liability, as well as supplemental principles and FAQs (as applicable) that explain and augment those seven privacy principles.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the DPF program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

For more information on UATP’s privacy policy with respect to the Data Privacy Framework, please click here.

Updating Information

UATP makes reasonable efforts to ensure that the persona information we have about you is reliable for its intended uses, accurate, current and complete.  You may request access to the personal information that UATP collects by sending a request to the below address with sufficient proof of identification.  You may correct factual errors in that information by sending a request to us that credibly shows the error.  Consumers can have this information corrected by sending us email at the below address.

Contacting Us

If you have any questions about our privacy policy or practices, you may contact us at the following address or send us an email.

1629 K Street, NW
Suite 300
Washington, DC 20006
[email protected]

Updated: September 2023