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 |