Privacy policy for customer feedback sessions and surveys

DATA CONTROLLER

TRAVELPERK, S.L.U. ("TravelPerk"), a company duly incorporated pursuant to the laws of Spain, with registered office at Avinguda Catedral 6-8 1ª Planta, 08002 Barcelona (Spain), with Spanish Tax Identification Code (CIF) B-66-484.57.

PURPOSES OF PROCESSING AND LEGAL GROUNDS

Your personal data shared with TravelPerk during customer feedback sessions (e.g. via screen sharing, direct interviews, etc.) or within feedback surveys will be treated as secret and confidential in compliance with the applicable data protection law, and processed by TravelPerk for the following purposes and based on the following legal grounds:

Customer feedback sessions

Purpose	Legal ground	Data categories
Managing your participation in the relevant feedback session.	Express consent granted when you schedule the relevant session with a TravelPerk team member.	- Name and surname - Job title - Work email address - Company you work for - Details of your TravelPerk account
Understanding user behaviours and needs, gathering user feedback and working on actionable insights for improvements.	Express consent granted when you schedule the relevant session with a TravelPerk team member.	- Name and surname - Job title - Work email address - Company you work for - Details of your TravelPerk account
Conducting user interviews: users will only be asked questions (no screen sharing needed) in view of providing some feedback for the abovementioned purpose.	Express consent granted when you schedule the relevant session with a TravelPerk team member.	- Name and surname - Job title - Work email address - Company you work for - Details of your TravelPerk account
Conducting user testing with prototype: TravelPerk will share a prototype (mock-up) and ask users to share their screen so the TravelPerk team can visualise how users are performing certain tasks within the TravelPerk platform. The prototype is fake and no personal information will be shown.	Express consent granted when you schedule the relevant session with a TravelPerk team member.	- Name and surname - Job title - Work email address - Company you work for - Details of your TravelPerk account
Conducting user testing with the user’s own TravelPerk account: users will be asked to log into their TravelPerk account, share their screen, and once in their account, perform some tasks. Users will be displaying their real accounts, where real personal information (also from other travelers within the user’s company) may be shown.	Express consent granted when you schedule the relevant session with a TravelPerk team member. Personal data of other users/travelers from the user’s company which may be visible via screen sharing during the session will be processed to fulfill a legitimate interest of TravelPerk, expressly acknowledged by applicable data protection legislation. You will be able to ask for a copy of the Legitimate Interest Assessment (LIA) we have conducted in relation to this purpose by sending a message to personaldata@travelperk.com.	- Name and surname - Job title - Work email address - Company you work for - Details of your TravelPerk account - Details of other users/travelers from your company which may be visible via screen sharing during the feedback session
Recording of feedback sessions in view of using such content to understand user behaviours and needs, gather user feedback, and work on actionable insights for improvements.	Express (verbal) consent which you grant once a statement to gather such consent has been read aloud by a TravelPerk team member prior to each feedback session, along with the relevant data protection information.	- Image and voice - Any personal details which may be visible via screen sharing and through the recording of the feedback session

Feedback surveys

Purpose	Legal ground	Data categories
Managing your participation in the survey, carrying out the prize draw, and delivering the prize to the winner.	Express consent given when submitting the survey form. The withdrawal of such consent shall not have any negative effects on participation in the prize draw.	- Name and surname - Job title - Work email address - Company you work for - Your responses to the survey

DATA RECIPIENTS

Data Processors: any suppliers of TravelPerk that need access to your data in order to provide the services that TravelPerk has outsourced to those suppliers. The required confidentiality and data processing contracts are signed between suppliers and TravelPerk in order to protect your privacy.

Law Enforcement Agencies: if TravelPerk is required to provide information in compliance with a legal obligation.

Courts and Tribunals: in the cases provided by Law.

DATA RETENTION

TravelPerk will keep your personal data collected in feedback sessions and surveys for as long as these sessions are held and surveys are conducted, and while the conclusions obtained from the sessions/surveys are being studied and actioned. After that time, your data may also be retained for the applicable statutory retention periods in order to comply with the legal obligations that may arise from the relationship with us, as well as, where appropriate, to comply with legal requirements. TravelPerk maintains specific retention policies and procedures, so that such data is deleted or anonymized after a reasonable time and according to the statutory retention periods.

YOUR DATA PROTECTION RIGHTS

You may exercise their rights of access, rectification, erasure and portability, restriction, right to withdraw consent, and/or right to object to the processing, by contacting TravelPerk at personaldata@travelperk.com.

If you consider that the processing infringes the data protection regulation or your privacy rights, you may also submit a complaint to the Data Protection Officer of TravelPerk at dpo@travelperk.com or to the Spanish Data Protection Agency (AEPD).