Template - Controller to Controller Agreement

Last updated: 29 March 2024

The clauses of this Controller to Controller Agreement (C2C Agreement) are supplemental to and incorporated by reference into, the Marketing Purchase Agreement or any other agreement (the Agreement) between Expedia (us) and Partner (you) referencing or otherwise incorporating this C2C Agreement. Terms that are not defined in this C2C Agreement shall have the meaning given to them in the Agreement.

9.1 Definitions: For the purposes of this C2C Agreement, appropriate technical and organizational measures, controller, personal data, personal data breach, process/processing/processed, processor and supervisory authority (or reasonably equivalent terms) shall each have the meaning given to them in Applicable Data Protection Law, and:

  1. Applicable Data Protection Law(s) means any applicable laws and regulations in any relevant jurisdiction relating to the use or processing of End Customer Data;
  2. CBPR Country means a country that is a full or associate member of the CBPR System;
  3. CBPR Party means an organization that holds a current certification under the CBPR System;
  4. CBPR System means the Asia-Pacific Economic Cooperation Cross Border Privacy Rules System;
  5. Current Audit Report means a current version of the PCI DSS attestation of compliance and the SSAE 16 Audit Report, or its industry standard successor, for our data center providers;
  6. DPF means the EU-U.S. Data Privacy Framework and/or Swiss-U.S Data Privacy Framework  or any successor self-certification program operated by the U.S Department of Commerce and approved by the European Commission from time to time and which has not been invalidated (and in each case, includes the UK Extension to the EU-U.S. Data Privacy Framework and any other country extension to such framework that operates to extend the application of the EU-U.S. Data Privacy Framework to that country); 
  7. End Customer Data means personal data of an End Customer processed pursuant to the Agreement;
  8. Permitted Purpose means in relation to Schedule 3 (Template) of the Agreement, the purpose of (i) fulfilling Bookings; (ii) providing customer support for Bookings; (iii) improving our services and user experience, including optimizing the booking experience for End Customers; (iv) generating reports for you, including commission statements and any further processing required for reconciliations, complaints handling and similar activities connected with servicing Schedule 3 (Template) of the Agreement; (v) creating reports for analytics, business intelligence and business reporting; (vi) fraud prevention; (vii) responding to law enforcement requests and tax audit requests; (viii) facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales); (ix) otherwise complying with our obligations under the Agreement, this C2C Agreement and/or applicable laws; and (x) for the determination, calculation, reporting of Travel Taxes and other applicable taxation purposes as may be required from time to time, and together these constitute the Permitted Purposes;
  9. Restricted Transfer Country means a country located in the European Economic Area, Switzerland, the United Kingdom and Brazil;
  10. Restricted Transfer Data means Template End Customer Data relating to a Booking made via a point of sale intended by us to be accessed by individuals in a Restricted Transfer Country;
  11. Standard Contractual Clauses/ SCCs means the approved European Commission’s Standard Contractual Clauses for the transfer of personal data from the European Union to third countries, as issued on 4 June 2021, as amended, replaced, supplemented, or superseded from time to time, and the full current version of which can be found following this link: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.
  12. Template End Customer Data means End Customer Data collected by us via the Template or otherwise collected by us or you in connection with facilitating bookings made using the Template.

9.2   Relationship of the parties  

You and we shall each collect and process Template End Customer Data to fulfil our respective rights and obligations under Schedule 3 (Template) of the Agreement, as well as your and our respective responsibilities under applicable laws. As such, each of the parties shall: (a) process Template End Customer Data as independent and autonomous controllers; (b) comply with Applicable Data Protection Law; and (c) be responsible for any of its acts or omissions in breach of Applicable Data Protection Law. 

9.3   Your responsibilities

You must in particular:

  1. satisfy a legal basis in order to make available any Template End Customer Data provided by you to us to process for the Permitted Purposes; 
  2. ensure that End Customers are made aware, via your privacy policy and by any other appropriate means, that their personal data will be shared with us for the Permitted Purposes;
  3. direct End Customers to our privacy policy for more information about our handling of their personal data; 
  4. satisfy a legal basis to send any marketing communications to End Customers;  and
  5. cooperate with and provide reasonable assistance to us to assist us with our compliance with Applicable Data Protection Law in the course of our processing of Template End Customer Data in connection with Schedule 3 (Template) of the Agreement and this C2C Agreement. 

9.4  Our responsibilities

We (and our Group Members, where applicable) will:

  1. only process Template End Customer Data in connection with a Permitted Purpose; 
  2. not divulge the whole or any part of the Template End Customer Data to any person, except in connection with a Permitted Purpose; and 
  3. cooperate with and provide reasonable assistance to you to assist you with your compliance with Applicable Data Protection Law in the course of your processing of Template End Customer Data in connection with Schedule 3 (Template) of the Agreement; and
  4. display and comply with our lawful and up-to-date cookie notice (if required) and our privacy policy on the Templates (where relevant).

9.5   Data security and breaches

You and we in our respective capacities as controllers agree that we will:

  1. maintain appropriate technical and organizational measures to protect Template End Customer Data you and we each process against a personal data breach; and
  2. in the event of a confirmed personal data breach within systems under that party’s possession or control, promptly notify the other party if the personal data breach both (i) affects Template End Customer Data that is also processed by the other party under the Agreement; and (ii) is reportable to a supervisory authority, providing full details of the same. In such event, both parties shall cooperate reasonably and in good faith to remedy or mitigate the effects of the personal data breach, and the reasonable costs of such cooperation shall be borne by the party that suffered the personal data breach.

9.6  Cross-border data transfers

You and we agree and acknowledge that in this clause 9.6, wherever the word ‘transfer’ is used, it includes access being provided by one controller/processor to another controller/processor and:

  1. General: neither we nor you shall (and shall not permit any other party to) transfer Template End Customer Data outside the territory of origination unless we take any required compliance measures to enable such transfer legally in accordance with Applicable Data Protection Law.
  2. Asia-Pacific Region and CBPR:
    1. The Parties agree and acknowledge that:

      1. a CBPR Party is bound by a legally enforceable set of obligations to provide comparable protection to Applicable Data Protections Laws; and
      2. Expedia is a CBPR Party.

      Where the Partner is also a CBPR Party, the provisions of this paragraph (b) will be construed to apply two-way.

    2. Subject to paragraph (iii) below, the Parties agree that where:

      1. Template End Customer Data is being transferred from one CBPR Country to another CBPR Country; and
      2. the data importer is a CBPR Party,    

      then, to the extent that and for so long as the CBPR System is a recognized method of transfer by a relevant supervisory authority, the CBPR System shall be the agreed mechanism for cross-border transfers of Template End Customer Data to such CBPR Party.

    3. The CBPR System will only apply for transfers that involve at least one of the Parties being located in an Asia-Pacific Region country that is also a CBPR Country.
    4. Expedia confirms that it will provide at least the same level of protection for the Template End Customer Data as is required under the CBPR System; and it will promptly notify the other Party if it makes a determination that it can no longer provide this level of protection. In such event, or if the other Party otherwise reasonably believes that Expedia is not protecting the Template End Customer Data to the standard required under the CBPR System, the other Party may either:

      1. instruct Expedia to take reasonable and appropriate steps to stop and remediate any unauthorized processing, in which event the Parties will promptly cooperate in good faith to identify, agree and implement such steps;
      2. agree an alternate safeguard that may apply to the processing under Applicable Data Protection Law; or
      3. if (A) and (B) fail to resolve the issue, terminate this C2C Agreement and the Agreement (or, at the other Party’s election, any affected portion thereof) without penalty by giving notice to Expedia.

      If the other Party also holds a current CBPR System certification, then the above provisions will be deemed to be apply as if the obligations are two-way.

  3. DPF: You and we agree that in respect of transfers of Restricted Transfer Data between you and us to the United States or to a country which has not been deemed "adequate" under the Applicable Data Protection Laws of the originating Restricted Transfer Country:

    1. to the extent that and for so long as the DPF is a recognized method of transfer by a relevant authority, the DPF shall be the agreed mechanism for cross-border transfers of data originating from a Restricted Transfer Country to us in the United States; and
    2. to the extent that and for so long as the DPF is not a valid method of transfer (including for transfers of Restricted Transfer Data to a country which has not been deemed "adequate" under the Applicable Data Protection Law of the originating Restricted Transfer Country),

    the SCCs shall apply to such transfers and we will enter into them on the basis set out in paragraph (h) below. Where you also hold a current DPF certification, transfers of Restricted Transfer Data to you can similarly be made under the DPF with SCCs as a fallback mechanism as set out above. 

  4. With regards to the DPF, we agree that we will provide the same level of protection as required by the DPF. If you reasonably believe we are not protecting Template End Customer Data to the standard required by the DPF, we may either: 
    1. rely on the SCCs as set out in paragraph (h) below;
    2. if SCCs are not a viable or appropriate solution, take your instructions on reasonable and appropriate steps to stop and remediate any unauthorized processing, which we will in good faith implement using commercially reasonable efforts; or
    3. terminate this C2C Agreement and the Agreement without penalty. 
  5. If you are certified under the DPF, you will comply with the Notice and Choice Principles of the DPF (as defined in the EU-U.S. DPF). For the avoidance of doubt, if You are not DPF-certified or accessing or receiving the Template End Customer Data in a country deemed ‘adequate’ by the European Commission, then the SCCs will be relied on for transfers of Restricted Transfer Data from us to you. 
  6. You and we agree that we may each disclose this C2C Agreement and any relevant privacy provisions in the Agreement to the US Department of Commerce, the Federal Trade Commission, any European data protection authority, or any other US or EU judicial or regulatory body upon their request and that any such disclosure shall not be deemed a breach of confidentiality. 
  7. Extension of SCCs to Non-Restricted Transfer Countries: In relation to transfers of Template End Customer Data between you and us originating from a country that is not a Restricted Transfer Country but is otherwise subject to safeguards that, according to Applicable Data Protection Law, must be applied before a transfer can be made of that End Customer Data outside of the country of origin (each a Non-Restricted Transfer Country), then you and we agree that:
    1. the SCCs set out in paragraph (h) below shall be deemed to extend to such additional transfers to the extent that such deemed extension would satisfy the safeguards of that particular country; and/or
    2. where the measures set out in paragraph (h) below are insufficient or require supplementary measures, the parties agree to take such further measures, including, for example, execution of relevant documents, collection of consent, making of required filings, as may be required from to time in order to satisfy Applicable Data Protection Law.
  8. SCCs. Subject to the paragraphs of clause 9.6 above, you and we hereby agree to enter into the SCCs on an unchanged basis save for the following selections:
    1. Where Partner is located inside the European Economic Area or otherwise in a country deemed “adequate” in accordance with Article 45 of the GDPR, (Adequate Country) Module one (1) of the SCCs will apply one-way only in respect of transfers from you to us. Otherwise, Module one (1) applies two-way to cover transfers from both you to us and us to you.
    2. For the purposes of clause 11(a) of the SCCs, the optional language is deleted.
    3. For the purposes of clause 13 of the SCCs, the relevant paragraph is “The supervisory authority of the Member State in which the representative within the meaning of Article 27(1) of Regulation (EU) 2016/679 is established, as indicated in Annex I.C, shall act as competent supervisory authority”.
    4. For the purposes of clause 17 of the SCCs, the governing law is Ireland.
    5. For the purposes of clause 18(b) of the SCCs, the selection is Ireland.
    6. A new clause 19 is added to the SCCs to cover transfers of personal data from the United Kingdom to outside of the United Kingdom as follows:     

      “Clause 19

      UK GDPR and DPA 2018

      The Parties agree that these Clauses will extend and apply, to the extent relevant to the transfer in question, to cover extra-territorial transfers that fall under the scope of UK GDPR and Data Protection Act 2018 (a UK transfer). For the purposes of such UK transfer, the provisions of the International Data Transfer Addendum to the EU Commission Standard Contractual Clauses shall apply as set out in the form attached as the Addendum.”

    7. A new clause 20 is added to the SCCs to cover transfers of personal data from Switzerland to outside of Switzerland as follows:

      “Clause 20

      Swiss – FADP

      The Parties agree that these Clauses will extend and apply, to the extent relevant to the transfer in question, to cover extra-territorial transfers that fall under the scope of Federal Act of Data Protection (FADP) (referred to in this Clause as a Swiss transfer). For the purposes of such Swiss transfers, the governing law shall be deemed to be the selected Member State, the choice of forum shall be the selected Member State and the Federal Data Protection and Information Commissioner (FDPIC) shall be the competent supervisory authority. The Parties further agree that such further changes shall be construed to be made to the Clauses in respect of a Swiss transfer as are deemed necessary by the FCPIC to comply with the UK GDPR and FADP, and the Clauses shall be interpreted in accordance with the requirements for Swiss transfers arising under those laws or as otherwise set out in guidance issued by the FDPIC, without the Parties having to enter into separate standard contractual clauses prepared specifically for their Swiss transfers. The Parties shall further do all such acts and things as may be necessary to ensure compliance with the FADP when engaging in Swiss transfers.”

    8. A new clause 21 is added to the SCCs to cover transfers of personal data from Brazil to outside of Brazil as follows: 

      “Clause 21

      Brazil – LGPD

      The Parties agree that these Clauses will extend and apply, to the extent relevant to the transfer in question, to cover cross-border transfers that fall under the scope of the Brazilian General Data Protection Law No. 13,709/18 (Lei Geral de Proteção de Dados) (LGPD) (referred to in this Clause as a Brazilian transfer). For the purposes of such Brazilian transfers, the governing law shall be deemed to be the selected Member State, the choice of forum shall be the selected Member State and Brazil’s National Data Protection Authority (ANPD) shall be the competent supervisory authority. The Parties further agree that such further changes shall be construed to be made to the Clauses in respect of a Brazilian transfer as are deemed necessary by the ANPD to comply with the LGPD, and the Clauses shall be interpreted in accordance with the requirements for Brazilian transfers arising under those laws or as otherwise set out in guidance issued by the ANPD or other relevant Brazilian authority, without the Parties having to enter into separate standard contractual clauses prepared specifically for their Brazilian transfers. The Parties shall further do all such acts and things as may be necessary to ensure compliance with the LGPD when engaging in Brazilian transfers.”

    9. A new clause 22 is added to the SCCs to cover transfers of personal data from any other country not hitherto specified where the SCCs may be extended to ensure appropriate safeguards for transfers of personal data originating from that country to a party located outside of that country as follows:

      “Clause 22

      Other third country transfers

      The Parties agree that these Clauses will extend and apply, to the extent relevant to the transfer in question, to cover cross-border transfers that fall under the scope of the any other applicable laws and regulations in any relevant jurisdiction, relating to the use or processing of personal data (Applicable Data Protection Laws) requiring terms and protections broadly equivalent to these Clauses in order to transfer personal data from that country to another (referred to in this Clause as a Third Country transfer). For the purposes of such Third Country transfers, the governing law shall be deemed to be the selected Member State, the choice of forum shall be the selected Member State and the data protection authority or regulatory body of that country shall be the competent supervisory authority. The Parties further agree that such further changes shall be construed to be made to the Clauses in respect of a Third Country transfer as are deemed necessary by such supervisory authority to comply with the Applicable Data Protection Law of that country, and the Clauses shall be interpreted in accordance with the requirements for Third Country transfers arising under those laws or as otherwise set out in guidance issued by the relevant supervisory authority, without the Parties having to enter into separate standard contractual clauses prepared specifically for their Third Country transfers. The Parties shall further do all such acts and things as may be necessary to ensure compliance with the Applicable Data Protection Law(s) when engaging in Third Country transfers.”

  9. Annex 1 to this C2C Agreement (SCCs Processing Overview) constitutes Annex 1 of the SCCs. Unless the Partner has provided an alternative Annex 2 (Technical and Organizational Measures) which has been accepted as sufficient by Expedia for the purposes of the SCCs, Annex 2 to this C2C Agreement will apply to both Parties for the purposes of the SCCs to the extent Module one (1) applies two-way, and references to Expedia Group will be deemed to generally apply to both the Expedia Group and the group of companies to which the Partner belongs. The Addendum to these C2C Agreement constitutes the UK Addendum for the purposes of the SCCs.

9.7 PCI

We acknowledge that we are responsible for the security of cardholder data that we possess, store, process, or transmit and shall comply with the PCI DSS as issued by the PCI Security Standards Council, as updated from time to time. We shall provide you with a copy of our annual certificate of compliance upon request. 

9.8 Notices

Any notices under this C2C Agreement will be deemed effective if delivered by email to the contact(s) provided by either Party to the other for these purposes in accordance with the notice provisions in the Agreement. In the case of Expedia, this will require an email being sent to the account/relationship manager from time to time and copied to the Expedia privacy mailbox provided from time to time. 

ANNEX I – SCCs PROCESSING OVERVIEW

MODULE ONE (1), Part One (1): Controller to Controller (you to us)

A. LIST OF PARTIES

Data exporter(s):

Party

The party/ies identified as “you”, Partner or equivalent term

Address

As specified in the Agreement

Contact name, position & contact details

Effective notice is deemed made when an email is sent to  account/relationship manager provided to Expedia from time to time

Activities relevant to data transferred

Bookings made via the Template provided by us to you in accordance with the Agreement

Role

Controller

Data importer(s):

Party

The non-EU parties identified as “us” or “Expedia” and being relevant to the Template that we make available to you under the Agreement

Address

As specified in the Agreement

Contact name, position and contact details

Effective notice is deemed made when an email is sent to both (1) account/relationship manager; and (2) the Expedia privacy mailbox, in each case using email address(es) provided to Partner from time to time

Activities relevant to the data transferred

Bookings made via the Template provided by us to you in accordance with the Agreement

Role

Controller

B. DESCRIPTION OF TRANSFER

Categories of data subject

End Customers

Categories of personal data

Identification data:

  • first and last names
  • date of birth
  • gender
  • login details
  • nationality (from passport)
  • TSA details
  • loyalty program information / numbers

Contact details:

  • postal address
  • email address
  • telephone numbers (fixed and mobile)
  • emergency contact information

Financial details:

  • bank account number
  • bank details
  • payment card details

Travel information: booking history and travel preferences

Other information as requested by, and agreed with, the Partner, including without limitation personal data required in connection with:

  • Single sign on credentials
  • Reporting

Sensitive Data

None

The frequency of the transfer (e.g. whether the data is transferred on a one-off or continuous basis)

Continuous or ad hoc basis in accordance with the needs of Partner’s business

Nature of the processing

All processing operations required to facilitate purposes set out below

Purpose(s) of the data transfer and further processing

Permitted Purposes, as defined in the C2C Agreement

The period for which the personal data will be retained, or, if that is not possible, the criteria used to determine that period

In accordance with the retention policy of the Expedia Group, provided that to the extent that any Template End Customer Data is retained beyond the termination of the Agreement for back up or legal reasons, Expedia will continue to protect such personal data in accordance with the Agreement

For transfers to (sub-) processors, also specify subject matter, nature and duration of the processing

https://support.ean.com/hc/en-us/articles/360000986389-EAN-Data-Services-Vendor-List, as updated from time to time

C. COMPETENT SUPERVISORY AUTHORITY

Identify the competent supervisory authority/ies in accordance with Clause 13 of SCCs Irish Data Protection Authority

IRISH DATA PROTECTION AUTHORITY

MODULE ONE: Part Two 2: Controller to Controller (us to you)

A. LIST OF PARTIES

Data exporter(s):

The Party/ies identified as Data Importers in Module one (1), Part one (1) (you to us) above. See above for further details.

Data importer(s):

The Party/ies identified as Data Exporter(s) in Module one (1), Part one (1) (you to us) above. See above for further details.

B. DESCRIPTION OF TRANSFER

  • Categories of data subject
  • Categories of personal data
  • Sensitive Data

As per Module one (1), Part one (1)

  • Frequency of transfer
  • Nature of processing
  • Purposes

As per Module one (1), Part one (1)

The period for which the personal data will be retained, or, if that is not possible, the criteria used to determine that period

In accordance with the retention policy of Partner

For transfers to (sub-) processors, also specify subject matter, nature and duration of the processing

Not applicable

C. COMPETENT SUPERVISORY AUTHORITY

As per Module one (1), Part one (1)

ANNEX II - TECHNICAL AND ORGANIZATIONAL MEASURES

The technical and organizational measures that apply to us/Expedia for the purposes of Module 1, Part 1 are set out below.

SUBJECT

MEASURE

Measures of pseudonymisation and encryption of personal data

  • Expedia Group ("EG") supports industry standard encryption protocols for data transmission based on Expedia Group’s Information Classification and Handling Standard.
  • Data handling requirements are based on a categorical basis. Depending on the data being handled, different security requirements are in place across Expedia Group. For example, credit card data is considered Highly Sensitive and required to be encrypted both in transit and at rest.
  • Personal data of the customer (and its employees) is pseudonymized (and anonymized) by Expedia Group when possible and as required according to EG’s Information, Classification and Handling Standards.
  • Credit card numbers are tokenized/pseudonymized to eliminate processing of clear text credit card numbers.
  • Expedia Group utilizes encrypted connections through VPN, SSL, etc. and utilizes multi-factor authentication mechanisms.

Measures for ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services

  • Expedia Group maintains responsibilities and procedures for the management and operation of all information processing facilities to ensure complete, valid and accurate processing of data.
  • The monitoring of key processing facilities is in place, with a robust SOX program where controls over data processing and integrity are tested and attested to on an ongoing basis.
  • Industry standard logging and monitoring is in place on EG’s systems to ensure and protect against unauthorized access, modification and/or deletion.
  • Expedia Group maintains service resilience through redundant architecture, data replication, and integrity checking.

Measures for ensuring the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident

  • Expedia Group’s systems are specifically designed to impede or prevent common attacks and ensure availability for operation, monitoring and maintenance. For this purpose, Expedia Group regularly carries out simulated tests and audits to confirm that its systems maintain availability.
  • Servers are patched against Expedia Group’s robust patching policy and protected by industry standard AV/AM programs. Additionally, vulnerability assessments, thorough testing, and network reviews are conducted to ensure EG’s systems are maintained.
  • Availability and reliability monitoring is in place to ensure Expedia sites remain online, with minimal interruptions of service.
  • Expedia Group maintains a Disaster Recovery Plan that accounts for emergencies and contingency plans to ensure that customer services are uninterrupted according to severity and are tested regularly to ensure viability.

Processes for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures in order to ensure the security of the processing

  • Expedia Group’s technical and organizational measures are audited annually by external assessors as well as through robust internal testing.
  • EG conducts annual PCI assessments utilizing a third-party assessor and ensures ongoing compliance with PCI.
  • EG’s comprehensive internal testing function is comprised of quarterly vulnerability testing, internal and external penetration testing, network, system and firewall scanning and reviews. Additionally, an internal audit department conducts annual risk assessments to prioritize operational audits.

Measures for user identification and authorisation

Measures for the protection of data during transmission

Measures for the protection of data during storage

  • Expedia Group systems are aligned with industry best practices and have in place communication practices such as time-out sessions, lock-out protocols, and robust password and authentication controls.
  • Expedia Group maintains requirements for account provisioning and oversight to prevent unauthorized access or misuse of Expedia Group information and uses industry best practice as required, such as the Least Privilege Access principle, unique ID’s and multi factor authentication for strong authentication purposes.

Measures for ensuring physical security of locations at which personal data are processed

  • A Security Operations Center provides 24x7 coverage, with a formal incident response plan reviewed and tested at least annually.
  • All systems are regularly controlled and tested by external service providers.
  • Each Expedia Group customer receives their own customer ID. All datasets of the respective customer are stored under this ID and all customer data is logically segregated. Due to administration rights and database structures, the customer can only access datasets which are assigned to that user ID and data centers/AWS controls.
  • Only persons who are expressly authorized by Expedia and have a ‘need to know’ have access to personal data. Controls and monitoring are in place to ensure least privileged access and unauthorized access attempts to the system.

Measures for ensuring events logging

  • Expedia Group maintains robust logging and monitoring requirements to account for the who, what, where, when, target, source, and success/failure of the logged event.

Measures for ensuring system configuration, including default configuration

Measures for internal IT and IT security governance and management

Measures for certification/assurance of processes and products

  • Expedia Group’s (EG) Information Security program is aligned with industry frameworks and standards, working through its risk management program to ensure a robust and comprehensive security posture. Expedia Group maintains secure operational processes to support the security, availability, integrity and confidentiality of the environment and customers’ data.
  • Expedia Group’s build standards only enable system components, services, and protocols that serve a business requirement. Operating Systems, databases, and off-the-shelf applications must be discoverable to satisfy legal and regulatory audit requirements, supports configuration management tools, or deploys configuration management that successfully enforces security controls, must enable encryption for all remote administrative access to a system, display proper use of the system, the system is being monitored to detect improper use and other illicit activity there is no expectation of privacy while using the system.
  • Expedia Group takes a layered / defense-in-depth strategy to security. Critical capabilities and controls are in place across the enterprise (e.g.: anti-malware, WAF, network segmentation, DLP, etc.), utilizing a suite of policies, operations and technologies to ensure the environment is monitored through a central security organization and alerts responded to accordingly.
  • Expedia's systems are hosted on Amazon Web Services (AWS) and in Data Centers that provide Expedia Group with annual SOC 2 reports to ensure compliance.

Measures for ensuring data minimisation

Measures for ensuring data quality

Measures for ensuring limited data retention

Measures for ensuring accountability

  • Minimisation: Expedia Group ensures only minimum amount of data is collected, processed and stored. We only use identifiable format where necessary.
  • Retention: The Expedia Group data retention policy sets out different retention periods and backups depending on the category of data, including any legal obligation or other exemption which requires such data to be retained until certain legal obligations, such as tax and accounting purposes, have been extinguished.
  • Quality: Expedia Group has a formalized, quality management program, the Customer Experience Management (CEM) program. We are always striving for improvement within EG’s environment and seeking to streamline processes for higher efficiencies resulting in consistent, high-quality services and interactions with our partners, clients and travelers.
  • Accountability: Expedia Group ensure accountability oversight with consistent implementation of policies, industry regulations/frameworks and legal requirements by maintaining a formalized Governance program, and Legal/Privacy body.

Measures for allowing data portability and ensuring erasure

  • Expedia Group is directly responsible for ensuring compliance with data protection laws (including in relation to requests from data subjects). Expedia Group responds to all subject requests, including access, deletion and portability in accordance with applicable data protection law.
  • EG’s data retention policy sets out different retention periods and backups depending on the category of data, including any legal obligation or other exemption which requires such data to be retained until certain legal obligations, such as tax and accounting purposes, have been extinguished. In the event that Expedia Group is unable to destroy personal data, Expedia Group shall continue to extend relevant protections of the Agreement between the parties governing such personal data and terminate any further processing.

For transfers to (sub-) processors, also describe the specific technical and organizational measures to be taken by the (sub-) processor to be able to provide assistance to the controller and, for transfers from a processor to a sub-processor, to the data exporter

  • Expedia Group conducts due diligence into the information security practices of its vendors and requires vendors to meet comprehensive security requirements, including obligations requiring vendors to have in place and maintain appropriate technical and organizational measures.
  • Expedia Group has formalized detailed Security Impact Assessment (“SIA”) process. All new vendors accessing data are screened prior to engagement and during the term where necessary.
  • Additionally, Expedia Group also has robust vendor processor terms that are imposed on all vendors, ensuring the flow down of obligations to any of their sub-processors.

International Data Transfer Addendum to the EU Commission Standard Contractual Clauses (Addendum)

This Addendum has been issued by the Information Commissioner for Parties making Restricted Transfers. The Information Commissioner considers that it provides Appropriate Safeguards for Restricted Transfers when it is entered into as a legally binding contract.

Part 1 Tables

Table 1: Parties

Start Date

The date of the Agreement incorporating the SCCs to which these are attached (Approved EU SCCs)

Parties

Key Contact

Exporter: As per Approved EU SCCs

 

Importer: As per Approved EU SCCs

 

Table 2: Selected SCCs, Modules and Selected Clauses

Addendum EU SCCs

The version of the Approved EU SCCs to which this Addendum is appended

Table 3: Appendix Information

Appendix Information” means the information which must be provided for the selected modules as set out in the Appendix of the Approved EU SCCs (other than the Parties), and which for this Addendum is set out in:

Annex IA: List of Parties

Annex 1B Description of Transfer

Annex II: Technical and organizational measures

As per Approved EU SCCs

Table 4: Ending this Addendum when the Approved Addendum changes

Which Parties may end this Addendum as set out in Section 19

Neither Party

Part 2: Mandatory Clauses

Mandatory Clauses of the Approved Addendum, being the template Addendum B.1.0 issued by the ICO and laid before Parliament in accordance with s119A of the Data Protection Act 2018 on 2 February 2022, as it is revised under Section 18 of those Mandatory Clauses.