Compliance With Safe Harbor Principles

As described below, for certain data transferred from Europe by, or on behalf of ARC participants, ARC adheres to the Department of Commerce's Safe Harbor Principles.

ARC is based in the United States and its operations take place in the United States. ARC's primary interactions are with the travel industry and related businesses (e.g., travel agents, carriers and system providers, etc.). In ARC's role as a settlement clearinghouse for transactions involving ARC participating carriers, ARC-accredited entities and other ARC participants ("Participants"), ARC regularly receives Personal Information about the traveling public (e.g., passenger name and credit card information) that are the subjects of those transactions ("Individuals").

For the purposes of this policy,

"Personal Information" refers to any information that is associated with your name or personal identity. This includes, but is not limited to, name, address, phone number, fax number, e-mail address, financial profiles, social security number, and credit card information. Personal Information does not include information that does not identify an individual. On some ARC sites, you may be able to register for and/or order ARC products or services, participate in surveys, request information, apply for a position, which may require that you provide personal information.

ARC does not receive, collect or process any sensitive Personal Information; that is information relating to a person's race, religion, ethnic origin political opinions, trade union membership, sex life or health or medical conditions.

Such Personal Information is available only to ARC and the Participant or other contractual parties directly involved in the performance of that contract and financial intermediaries whose payment systems are involved in the transaction. ARC does prepare individual reports based on the aggregated or consolidated statistical data of processed transactions. These reports do not contain any data specifically pertaining to an individual or that would enable the recipient to identify an individual.

Such transactional data is retained for approximately 39 months. That period represents the period during which disputes between the parties to the transactions (e.g., the passenger, the travel professional who issued the transaction and the carrier) are likely to arise and with respect to which Personal Information associated with the transaction will continue to be relevant.

Access To Personal Information

Individuals, and the Participants that submitted the transaction containing Personal Information about that individual, shall have the right to access the information that ARC holds about that individual and shall have the opportunity to correct, amend, modify or delete inaccurate data. However, ARC may refuse such requests where:

• The burden or expense of providing access would be disproportionate to the risk to the privacy of the individual in question; or
• The rights of persons other than the individual requesting amendment would be violated.

ARC shall respond to such requests within a reasonable time period. Depending on the nature of the request, ARC reserves the right to charge a reasonable fee to cover the costs of providing access. Personal Information may be deleted by ARC where the Personal Information is not complete, current, and accurate or is inappropriate for its original intended use. Any deletion or modification may be subject to the consent of the Participant that originally submitted the Personal Information. In order to request access to information or to request amendment, modification or deletion of data, or if you believe that ARC is not complying with the Safe Harbor Principles, or this policy, please contact ARC by mail, e-mail or telephone at:

In the event that any citizen of the European Union is not entirely satisfied with the resolution of a complaint proposed by ARC, ARC will cooperate with the relevant European Data Protection Authorities to resolve that individual's complaint.

Your Consent

By providing any information to ARC, Personal Information, or otherwise, you acknowledge understanding ARC's policies and consent to the processing and collection of such information.

Changes

ARC reserves the right to change this EU Safe Harbor privacy policy at any time and will notify users of any material changes by updating the policy here. Visitors to the site are responsible for consulting this posting for any changes. The effective date will be noted to indicate the last time modifications were made.

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Last Revised April 18, 2008