Privacy Policy

General

When you communicate with Capital Drive, we collect information about you to help us provide and improve our services, websites, mobile application, features and content, online marketing and advertising, and to administer our relationship with you (together, the “Service”). In this Privacy Policy, we describe the sources and types of information we collect, how we use it, when it may be shared with others, and how we reasonably attempt to safeguard its confidentiality and security. This Privacy Policy represents our policies and intended business practices; it is not a contract and does not create any legal rights or obligations.

What We Collect and How We Collect It

When you interact with Capital Drive directly or through our company websites at capitaldrive.com and app.capitaldrive.com (our “Sites”), our mobile applications (“Apps”), social media properties, promotional activities, or otherwise communicate with us or certain third parties, we may receive information about you. We collect and maintain information about you and your travel companions when you book travel, make purchases, participate in promotions, register for or attend webinars, events, or sponsored events in which Capital Drive participates, visit our offices, or interact with our Sites or Apps or otherwise communicate with us. Terms and conditions for those users that log into Capital Drive Sites or Apps and that book travel and make purchases with Capital Drive may be found via our Terms and Conditions link on your emailed confirmation or via the web here.

Personally Identifiable Information

Some of the information we collect can be used to contact or identify you or otherwise consists of personally identifiable information (“Personal Information”).  The Personal Information we may receive includes, but is not limited to:

  • Name, physical addresses, e-mail addresses, and telephone numbers;
  • Credit card numbers, and associated billing information (credit cards are processed and stored via third-party Level 1 PCI-compliant processor);
  • Travel-related information such as itineraries, address book locations, travel companions, travel coordinator contacts, and preferences;
  • Transactional data, online activity data, IP address, and location data
  • Corporate contract, employer, or other affiliation (such as employer name, title, and contract information);
  • Other personal information you may voluntarily provide to customer-service representatives or via your participation in surveys, advisory boards, focus groups, and promotions.

We also receive information that is not Personal Information (“Non-Identifying Information”), such as information about your browser or device. Certain Non-Identifying Information will be considered a part of your Personal Information if it is combined with other identifiers in a way that identifies you (e.g., combining your zip code with your street address). For the avoidance of doubt, the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other Non-Identifying Information.

User provided data will be stored and accessible if you create a Capital Drive account, if you sign into your Capital Drive account through the Sites or Apps or use Capital Drive’s services.

Automatic Data Collection

In addition to the information you provide to us yourself, when you visit the Sites, whether as a registered user or an unregistered browser (either of these, a “Capital Drive User”), our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This log data includes, but is not limited to, information such as your computer’s Internet Protocol (IP) address, browser type or the website from which you are visiting, pages of our Sites that you visit, time spent on those pages, information you search for, access times and dates, and other statistics. We may use this information to monitor and analyze use of the Sites and the Service, increase the Sites’ functionality, security, and user-friendliness, and better tailor the Sites to our visitors’ needs. For example, some of this information may be collected so that when you visit the Sites again, it will recognize you, and serve Capital Drive information appropriate to you and your interests. We also use this information to verify that visitors to the Sites meet the criteria required to process their requests.

The Apps may collect certain information from you automatically to improve your experience and maximize functionality. This information may include but is not limited to your domain name, what App features you use, transaction history and details, amount of time you use the App, your device identification, data concerning your operating system and/or browser, and App links you click.

Cookies

Like many websites, we use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use persistent cookies to save your registration ID and login password for future logins to the Sites. We also utilize session ID cookies to enable certain features of the Sites, to better understand how you interact with the Sites, and to monitor aggregate usage by visitors and web traffic routing on the Sites.

We also may use cookies to manage our advertising on other sites. In these cases, our advertising partners may use cookies or similar technologies to collect non-personal information such as your browsing history. This is used to provide you advertising based upon your browsing activities and interests. To learn more about targeted advertising and your ability to opt-out of interest-based advertising, click here.

You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from websites you visit. However, if you do not accept cookies, you may not be able to use all portions of the Sites or all functionality of the Service.

Pixel Tags

When you use our Services, we may collect data from pixel tags (also known as clear GIFs web beacons) which are used to anonymously track your use of our Sites. This information facilitates more accurate reporting and improvement of our Services.

How Your Information is Used

We may use Personal Information (in some cases, in conjunction with Non-Identifying Information) to:

  • Provide, operate, maintain, and improve our Service
  • process and complete transactions, and send you information related to those transactions
  • manage your user accounts and profiles
  • administer your inquiries and respond to your feedback
  • send updates, promotional materials, surveys, new service or feature announcements, and other information that may be of interest to you
  • complete statistical analysis
  • manage visitors to our offices
  • administer event registrations and attendance
  • process and deliver incentives, rewards, and contest entries
  • personalize the websites, apps, and Services including by providing features and content that match your interests and preferences
  • promote security and stability of our websites, apps, and other technology
  • comply with legal obligations
  • data analysis and audits
  • fraud monitoring and prevention
  • execute marketing campaigns, including but not limited to email campaigns and behavioral marketing campaigns

Personal information may be used in these ways on the grounds of fulfilling a contract, with your consent, and/or in the pursuit of our legitimate interest, except where such interests are overridden by the interest or fundamental rights and freedoms of the data subject.


How Your Information is Shared

We may employ third party companies and individuals to provide or assist in providing the services or products you request, perform Site-related services (e.g., maintenance services, web analytics, and database management), or for other businesses purposes such as marketing or advertising. These third parties have access to your Personal Information only as necessary to perform these tasks and are contractually obligated not to disclose or use it for any other purpose. We may also disclose Personal Information concerning your travel to third parties, such as employers, who have arranged for discounts or purchased travel or other services on your behalf.

Capital Drive does not share your personal information with third-party vendors for their own direct marketing purposes. All of our vendors are required to protect your information in any way they interact with it, and are limited to using it only in accordance with their intended purpose.

Capital Drive may share your personal information with third-party vendors for our direct marketing purposes., including but not limited to email campaigns and behavioral marketing campaigns. All of our vendors are required to protect your information in any way they interact with it, and are limited to using it only in accordance with their intended purpose.

We may share aggregated information such as demographic information, domain names, other site traffic information, etc., with third parties for industry analysis, demographic profiling, and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.

Registered Users

When you register through the Sites and interact with the Sites or Apps, Capital Drive personnel will see the Personal Information you provide.

Affiliated Entities

We may also share your Personal Information with other affiliates within the Travel Research Advisors corporate group to the extent this is necessary to fulfill a request you have submitted via our websites, or for customer support, marketing, technical operations and account management purposes.

Social Networking

When you connect with Capital Drive through a forum, chat room, or other social networking platform (including, without limitation, Twitter, Facebook, or LinkedIn), any Personal Information you share may be visible to other users and can be read, collected, or used by them or us. You are responsible for the information you choose to submit in these instances and are encouraged to read the privacy policies or statements of these social networking sites.

Testimonials

From time to time, we may post testimonials on our Sites that may contain personal information. We obtain your consent to post your name along with your testimonial. If you wish to update or delete your testimonial, you can contact us at support@capitaldrive.com.

Community Forums

Our Sites may offer publicly accessible blogs, comments sections, or other interactive features. You should be aware that any information that you post in an interactive area might be read, collected, and used by others who access it. To request removal of your personal information from an interactive area, contact us at support@capitaldrive.com.

Compliance with Laws and Law Enforcement

Capital Drive complies with all local, national, and international laws and regulations.

As required by law, we will disclose your Personal Information to government authorities or private parties pursuant to subpoenas or other legal process. We may also use or disclose your Personal Information as permitted by law to protect the property and rights of Capital Drive, our customers, our Sites and Site users, for fraud detection or prevention, for the prevention, detection, apprehension or prosecution of criminal acts, or when we, in our sole discretion, believe that disclosure is in the interest of travel security or otherwise necessary or advisable.

Business Transfers

In the event Capital Drive is part of a business transaction with another company, such as a merger, corporate reorganization, acquisition, the sale of all or a portion of our assets, or in the event of bankruptcy, information that we have collected from or about you or your devices may be disclosed to such other entity as part of the due diligence or business integration process and may be included in any related transfer of assets.

How Your Information is Protected

Security and International Transfer

Safeguarding your information is important to Capital Drive. We employ physical, procedural, and technological measures to protect your information from unauthorized access. This includes utilizing Secure Sockets Layer (SSL) encryption software and storing your information behind a firewall designed to block access from outside our network. While Capital Drive reasonably attempts to safeguard and prevent unauthorized access to your private information including, without limitation, your Personal Information, we cannot be responsible for the acts of those who gain unauthorized access, and we make no warranty, express, implied, or otherwise, that we will prevent unauthorized access to your private information. IN NO EVENT SHALL CAPITAL DRIVE OR ITS AFFILIATES BE LIABLE FOR ANY DAMAGES (WHETHER CONSEQUENTIAL, DIRECT, INCIDENTAL, INDIRECT, PUNITIVE, SPECIAL OR OTHERWISE) ARISING OUT OF, OR IN ANY WAY CONNECTED WITH, A THIRD PARTY’S UNAUTHORIZED ACCESS TO YOUR INFORMATION, REGARDLESS OF WHETHER SUCH DAMAGES ARE BASED ON CONTRACT, STRICT LIABILITY, TORT OR OTHER THEORIES OF LIABILITY, AND ALSO REGARDLESS OF WHETHER CAPITAL DRIVE WAS GIVEN ACTUAL OR CONSTRUCTIVE NOTICE THAT DAMAGES WERE POSSIBLE.

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored Personal Information to you via e-mail or conspicuous posting on the Sites within a commercially reasonable time and without unreasonable delay, subject to (i) the legitimate needs of law enforcement; or (ii) any measures necessary to determine the scope of the breach and restore the integrity of the data system.

Your information may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, Capital Drive transfers Personal Information to the United States and processes it there. By using or accessing our Service, Sites, Apps, or other technology or submitting Personal Information to us, you consent to this Privacy Policy and to such transfer, processing, storage, and access of your Personal Information.

Phishing

Identity theft and the practice currently known as “phishing” are of great concern to Capital Drive. Accordingly, safeguarding information to help protect you from identity theft is a priority. We do not and will not, at any time, request your credit card information, your account ID, or your login password in an unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.

Links to Other Sites

Our Sites and Apps contain links to other websites. If you click on a third-party link, you will be directed to that third party’s website. Our provision of such third-party links or advertisements is not an endorsement, authorization, or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over these third-party websites. Other websites follow different rules regarding the use and disclosure of the personal information you submit to them, and we encourage you to read the privacy policies of the other websites you visit. We are not responsible for the content, accuracy, or opinions expressed on any third party website or for the privacy practices or security standards used by third parties on their respective websites.

Email Transmission

It is important to note that any email communication is not secure. This is a risk inherent in the use of e-mail. Please be aware of this when requesting information or sending forms to us by email. We recommend that you do not include any confidential information (i.e. credit card information) when using email. For your protection, our email responses to you will not include any confidential information.

Your Privacy Rights

You have certain rights regarding your Personal Information, subject to local data protection laws.

When you register with Capital Drive, or provide Personal Information through another avenue, you will be given the opportunity to request to receive marketing communications from us. You always have the option to opt-out of receiving future communications for marketing purposes. If you choose to do so, you may opt out by emailing support@capitaldrive.com or following the instructions at the bottom of any promotional message you receive from us. If you opt-out of receiving promotional information from Capital Drive, we may still contact you with non-promotional emails concerning the Services, your specific transaction or transactions, and your communications with us.

You may review, update, correct, download or delete select Personal Information in your Capital Drive profile and the Capital Drive profiles of those travelers that you manage by logging into your Capital Drive account. For verification and security purposes, before we allow you to review, update, or delete your Personal Information, you may be asked to provide us certain Personal Information.

You have the right to object to our processing of your information and to restrict our processing of your information. If you are an EU data subject and believe that we have violated any of your rights under the European Union General Data Protection Regulation, you have the right to contact the responsible data protection authority in your jurisdiction.

To exercise any of your rights as an EU data subject, or to withdraw your consent to our use of your information for marketing purposes at support@capitaldrive.com or by contacting the Capital Drive team. Please understand that doing so may impact your ability to maintain an account with Capital Drive or use certain features of our Service.

California Rights Policy

California law entitles residents to ask us for a notice describing what categories of personal information we share with third parties or with corporate affiliates for those entities’ direct marketing purposes. To make such a request, please send an email to support@capitaldrive.com. If you want to request a notice or have any questions about our privacy practices, please contact us.

Our Policy Towards Children

Capital Drive services are available to travelers aged 21 and over. Minors must be accompanied by an adult. Our Service, Sites, App, and other technology are not directed to children under 21. We will not knowingly collect personally identifiable information from children under the age of 13 without prior consent from a parent or guardian. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact Capital Drive and we will delete such information from our files.

Your Acceptance of this Policy

By using or accessing our Service, Sites, Apps, content, offices, or events, you signify your acceptance of our Privacy Policy. If you do not agree to this Privacy Policy, please do not use or access our Service, Sites, Apps, content, offices, or events.

We reserve the right, at our sole discretion, to update, amend and/or change this Privacy Policy without prior notice and at any time. Updates to this Privacy Policy will be posted here. You are encouraged to revisit this Privacy Policy from time to time in order to review any changes that have been made. Your continued use of the Service, Sites, Apps, Content, offices, or Events following the posting of any such changes shall automatically be deemed your acceptance of all changes.

Contact Us

If you have any questions about this Privacy Policy, please do not hesitate to contact us at support@capitaldrive.com.

Last modified March 24, 2022