Introduction:
At DRAGONFLY TRAVEL, LLC” Dragonfly” we are committed to safeguarding the privacy of our customers. We will never sell, release, or transmit customer information externally for any purpose other than with approved business partners in secure circumstances, and only then for the benefit of creating successful experiences for our clients. All internal information is gathered and retained only for the duration of retained services, except as defined by regulatory requirements, and then based upon the regulatory retention period and/or client request for data archival.
The Privacy Statement describes how we collect, use, protect, and disclose the Personal Information you share with us online and offline unless otherwise provided pursuant to an informed consent signed by you. Dragonfly websites that display this Privacy Statement are committed to only collecting, maintaining, and securing your Personal Information in accordance with the terms of this statement. We encourage you to read this Privacy Statement before submitting any information. By using any Dragonfly website, portal or services, submitting or requesting information, you acknowledge that you understand and agree with the provisions of this Privacy Statement.

Why and How We Collect Data:
Dragonfly Travel, LLC works with our clients in the Research and Pharmaceutical industry to provide Logistics, Event Management, and planning for clinical trials. We collect and process personal data for the sole purpose of providing our clients with information and services, including, but not limited to, Available Service Menus, Request for Information or Proposal, Conference Registration, Travel Arrangements, Virtual Conference Center Access, Informational Portals and Learning Management Systems.  Personal data will be transferred only to third parties directly involved in the fulfillment of Pharmaceutical Logistics, Event Management, and planning for our customers and for that specific purpose only. These third parties include (but are not limited to) airlines, hotels, transportation services, and other related service providers. We respect the privacy of your personal information (any information related to an identified or identifiable individual), and we only collect volunteered information and then only in relation to the provided service to the client.

What Data We Collect:
In the course of providing its Services, Dragonfly may collect, use, store, and disclose personal data. Personal data is any information that can be used to identify you or that we can link to you. You, the user of the Services, may be asked to provide certain personal data when you use our Services, such as:
Name
Position title
Company
Address
Phone number
Email address
Registration information
Banking such as IBAN information for payment purposes

Choice:
When Dragonfly collects Consumer Personal Data in its role as a Controller, Dragonfly  generally offers the relevant Consumers the opportunity to choose whether their Personal Data may be (i) disclosed to third-party Controllers or (ii) used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized by the relevant Consumer. To the extent required by the DPF Principles, Dragonfly shall obtain opt-in consent for certain uses and disclosures of Sensitive Data. These Consumers may contact Dragonfly as indicated below regarding Dragonfly’s use or disclosure of their Personal Data. Unless Dragonfly offers these Consumers an appropriate choice, Dragonfly uses Personal Data only for purposes that are materially the same as those indicated in this Policy.
When Dragonfly obtains Consumer Personal Data in its role as a Processor for its Customers, Dragonfly Customers are responsible for providing appropriate notice to its Consumers and ensuring it provides the relevant Consumers with certain choices with respect to the Customers’ use or disclosure of the Consumers’ Personal Data.
Dragonfly shares certain Consumer Personal Data with its affiliates and subsidiaries. Dragonfly may disclose Consumer Personal Data without offering an opportunity to opt out, and may be required to disclose the Personal Data: (i) to third-party Processors Dragonfly has retained to perform services on its behalf and pursuant to its instructions, (ii) if it is required to do so by law or legal process, or (iii) in response to lawful requests from governmental authorities, including to meet national security, governmental interest or law enforcement requirements. Dragonfly also reserves the right to transfer Consumer Personal Data in the event of an audit or if Dragonfly sells or transfers all or a portion of its business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution or liquidation).

Accountability for Onward Transfer of Personal Data:
To the extent Dragonfly acts as a Controller, except as permitted or required by applicable law, Dragonfly shall provide Consumers with an opportunity to opt out of sharing their Personal Data with third-party Controllers. Dragonfly requires third-party Controllers to whom it discloses such Consumer Personal Data to contractually agree to (i) only process the Personal Data for limited and specified purposes consistent with the consent provided by the relevant Consumer, (ii) provide the same level of protection for Personal Data as is required by the DPF Principles, and (iii) notify Dragonfly and cease processing Personal Data (or take other reasonable and appropriate remedial steps) if the third-party Controller determines that it cannot meet its obligation to provide the same level of protection for Personal Data as is required by the DPF Principles.
With respect to transfers of Consumer Personal Data to third-party Processors, Dragonfly  (i) enters into a contract with each relevant Processor, (ii) transfers Personal Data to each such Processor only for limited and specified purposes, (iii) ascertains that the Processor is obligated to provide the Personal Data with at least the same level of privacy protection as is required by the DPF Principles, (iv) takes reasonable and appropriate steps to ensure that the Processor effectively processes the Personal Data in a manner consistent with Dragonfly’s obligations under the DPF Principles, (v) requires the Processor to notify Dragonfly if the Processor determines that it can no longer meet its obligation to provide the same level of protection as is required by the DPF Principles, (vi) upon notice, including under (v) above, takes reasonable and appropriate steps to stop and remediate unauthorized processing of the Personal Data by the Processor, and (vii) provides a summary or representative copy of the relevant privacy provisions of the Processor contract to the Department of Commerce, upon request. Dragonfly remains liable under the DPF Principles if Dragonfly’s third-party Processor onward transfer recipients process relevant Personal Data in a manner inconsistent with the DPF Principles, unless Dragonfly  proves that it is not responsible for the event giving rise to the damage.

Use of Cookies and Other Tags:
Where permitted by law, non-Personal Information and data may be automatically collected through the standard operation of Dragonfly’s Internet service or through the use of “cookies” or “internet tags” and other similar techniques. This type of anonymous information allows Dragonfly to evaluate customer interest in its websites and perform other market research activities. Cookies are small text files a website can use to recognize repeated usage, facilitate the user’s access to and use of the site, and allow a site to track usage behavior and compile aggregate data that will allow content improvement and targeted advertising. Cookies are programs that come into a user’s system but do not damage files. Generally, cookies work by assigning a unique number to the user that has no meaning outside the assigning site. If a user does not want information to be collected through the use of cookies, there is a simple procedure in most browsers that allows the user to deny or accept the cookie feature; however, users should note that cookies may be necessary to provide the user with certain features (e.g., customized delivery of information) available on Dragonfly’s websites. Dragonfly also may collect and store the name of the domain and host from which you access the Internet; the Internet protocol (IP) address of the computer you are using; the browser software you use and your operating system; the date and time you access our website; the Internet address of the website from which you linked directly to our website.

Do-Not-Track Signals:
Some web browsers that you use may transmit “do-not-track” signals to websites with which the browser communicates. As of the Effective Date of this Privacy Statement, an industry standard on how to respond to these signals has not yet been established. Since industry standards are still evolving, Dragonfly will not separately respond to or take any action with respect to “do-not-track” configurations in your internet browser. Dragonfly will reassess its approach based upon future procedures, but will respond with similar guidelines, based upon only gathering information based upon providing services to existing clients.

Data Security:
Dragonfly Travel has established a privacy program designed to help respect and protect your data privacy rights. We maintain administrative, technical, and physical safeguards intended to protect against the loss, misuse, unauthorized access, alteration, or disclosure of Personal Information and Collected Sensitive Personal Information. Although we take such precautions seriously, it is impossible for us to guarantee the safety and security of Personal Information or Collected Sensitive Personal Information. We cannot ensure or warrant the security of any information.
Retention of Personal Data:
We reserve the right to retain any Personal Data as long as the Personal Data is needed to: fulfill the purposes that are described in above (Why and how we collect data) and comply with applicable law.

Children’s Online Privacy:
Dragonfly websites are not directed or intended for children. The services offered on our websites are designed for individuals who are 18 years of age or older. If your child has submitted Personal Information and you would like to request that such information be removed, please contact Paul.Ghisoi@dragonfly-travels.com. For more information about protecting the privacy of children online in the United States under the Children’s Online Privacy Protection Act, please see http://www.ftc.gov/ogc/coppa1.htm (last accessed January 2013).

Links and Third-Party Websites:
Many of Dragonfly’s websites may contain links or references to third-party websites as a convenience to you. This Privacy Statement does not cover the practices of these websites. Accessing these sources requires that you leave Dragonfly’s websites. Dragonfly does not control the content of these third-party websites and is not responsible for their privacy practices. Please review the privacy policies on each website that you visit.

Your Rights:
If you would like to access, amend, erase, export (i.e., data portability), or object to or restrict the processing of Personal Data collected via the Dragonfly Travels, LLC, you may submit a request to Paul.Ghisoi@dragonfly-travels.com.

Updates to Privacy Statement:
The foregoing terms are effective as of May 25, 2018. Dragonfly may update this Privacy Statement from time to time based on, among other things, changes in applicable laws, the development of new websites, and technological advances. Dragonfly reserves the right to modify, add, or remove portions of this Privacy Statement at any time at our sole discretion. If we decide to revise this Privacy Statement, we will post the revised Privacy Statement at this site. We encourage you to review the Privacy Statement each time you visit our site. This Privacy Statement is not intended to and does not create any contractual or other legal rights in or on behalf of any party.

How to Contact Us:
If you have any questions about our Privacy Statement, or need to contact us for any other reason, you may email us at Paul.Ghisoi@dragonfly-travels.com. If you are located in the European Union, you may contact our representative in the European Union by sending an email to DataRep at datarequest@datarep.com quoting “Dragonfly Travel, LLC” in the subject line.