Privacy Constructs

We are committed to being consistent in our application of our standardized privacy constructs across our contracting space with third party partners, vendors and service providers.

Our respective roles depend on the services in scope and the processing of personal data associated with those services (crucially, who is materially responsible for determining the purposes and means of processing of personal data in connection with a given service). We have developed our Privacy Contract Terms to align with our standardized privacy construct positions for the different aspects of our business.

At a glance, our respective roles are as set out below:

Quick Key:

Controller

Independent and autonomous controller. In the rare event, we are joint controllers, this will be clearly indicated.

Hybrid

Controller for some of the processing activities and Processor for others.

Third Party Processor

Either we or you (as indicated) are Processor not of the contract counterparty but to one or more other parties with whom we or you contract. We are not in a controller/processor relationship with one another.

Subject to variations

We will assess this on a case-by-case basis and vary the construct accordingly.

 

Contract Type

Our role

Your role

Expedia as recipient of services and where you are the vendor/service provider

General procurement contract

Controller

Processor Subject to variations. May be Controller or Hybrid.

HR benefits

Controller

Controller Subject to variations. May be Hybrid.

Market research vendors

Controller

Controller Subject to variations. May be Hybrid.

Payments processing

Controller

Controller or Hybrid.

Travel Suppliers and connectivity providers

All travel suppliers (air, hotel. vacation rental, car, activities, cruises)

Controller

Controller

API connectivity licence (other than GDS’s)

Controller

Third Party Processor

GDS

Controller

Controller or Hybrid

Expedia Partner Solutions by offering

EPS Rapid (where Partner is Merchant of Record)

Processor

Controller

EPS Rapid (where Expedia is Merchant of Record)

Hybrid (Controller for processing of payment, and Processor for all other processing)

Controller

White label template

Controller

Controller

TAAP

Controller

Controller

3PTP

Controller

Third Party Processor

Other Partners

Affiliates (Partners in cashbacks and other incentive schemes)

Controller

Controller

Openworld

Merchant Shield

Controller

Controller

Virtual Agent

Processor

Controller