Data Privacy Framework Policy

1. What is this policy?

This Data Privacy Framework Policy (Policy) describes how ID90T, Inc., a company registered in Delaware, USA, with a trading address at 925 S. Kimball Avenue, Suite 140, Southlake, TX 76092 (we, us, our), collects, uses and discloses personal data that we receive in the US from the European Union and European Economic Area (EU/EEA) and from the United Kingdom (Covered Personal Data).

This Policy supplements our Privacy Policy (our Standard Privacy Notice) and deals specifically with our obligations under the Data Privacy Framework, as explained below. Nothing in this Policy is intended to waive, diminish or contradict our obligations under applicable data protection law or the undertakings in our Standard Privacy Notice.

Unless defined in this Policy, terms have the same meaning as in our Standard Privacy Notice.

2. What is the EU-U.S. Data Privacy Framework?

The EU/EEA and the UK have established strict protections for the handling of personal data, including requirements to provide adequate protection for personal data transferred outside those jurisdictions. To provide adequate protection for Covered Personal Data (about the groups of Data Subjects described in our Standard Privacy Notice and received by us in the US), we have self-certified to the EU-U.S. Data Privacy Framework administered by the U.S. Department of Commerce. We adhere to the Data Privacy Framework Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.

ID90T, Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce. ID90T, Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this Policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov.

Under the EU-U.S. DPF and the UK Extension, ID90T, Inc. is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

3. Personal data collection and use

Our Standard Privacy Notice describes the categories of Covered Personal Data we may receive in the US and the purposes for which we use it. We will only process Covered Personal Data in ways that are compatible with the purpose for which we collected it, or for purposes the individual later authorizes.

We will not use your Covered Personal Data for a purpose that is materially different from the purpose for which we collected it unless you later authorize that use. If you do, we will give you an ongoing opportunity to opt out.

We maintain reasonable procedures to help ensure that Covered Personal Data is reliable for its intended use, accurate, complete and current.

4. Data transfers to third parties

Third-party agents or service providers. We may transfer Covered Personal Data to third-party agents or service providers that perform functions on our behalf, as described in our Standard Privacy Notice.

Where the Data Privacy Framework requires it, we enter into written agreements with those agents and service providers requiring them to provide the same level of protection the Data Privacy Framework requires, and limiting their use of the data to the services they provide on our behalf.

We take reasonable and appropriate steps to ensure that third-party agents and service providers process Covered Personal Data in accordance with our Data Privacy Framework obligations, and to stop and remediate any unauthorized processing. In certain circumstances, we may remain liable for how our agents or service providers handle Covered Personal Data we transfer to them.

Third-party data controllers. In some cases, we may transfer Covered Personal Data to unaffiliated third-party data controllers. These third parties do not act as our agents or service providers and do not perform functions on our behalf. Section 6 of our Standard Privacy Notice sets out when and to whom such transfers may occur.

We will only provide your Covered Personal Data to third-party data controllers where you have not opted out of such disclosures or, for sensitive Covered Personal Data, where you have opted in if the Data Privacy Framework requires consent. We enter into written contracts with any unaffiliated third-party data controllers requiring them to provide the same level of protection the Data Privacy Framework requires, and we limit their use of your Covered Personal Data to what is consistent with any consent you have given and the notices you have received.

Disclosures for national security or law enforcement. In certain circumstances, we may be required to disclose your Covered Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

5. Security

We maintain reasonable and appropriate security measures to protect Covered Personal Data from loss, misuse, unauthorized access, disclosure, alteration or destruction, in accordance with the Data Privacy Framework.

6. Access rights

We will honor the rights set out in our Standard Privacy Notice. You may also have the right to access the Covered Personal Data we hold about you, and to ask us to correct, amend or delete it if it is inaccurate or has been processed in violation of the Data Privacy Framework. These access rights may not apply in some cases, including where providing access would be unreasonably burdensome or expensive in the circumstances, or would violate the rights of someone other than the individual making the request.

To request access to, or correction, amendment or deletion of, your Covered Personal Data, please send a written request using the contact details below. We may ask for specific information to confirm your identity. In some circumstances, we may charge a reasonable fee for access to your information.

7. Questions or complaints

You can send questions or complaints about the use or disclosure of your Covered Personal Data by email to privacy@id90travel.com or by post to 925 S. Kimball Avenue, Suite 140, Southlake, TX 76092.

We will investigate and attempt to resolve any complaint or dispute about the use or disclosure of your Covered Personal Data within 45 days of receiving it.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, ID90T, Inc. commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF to TrustArc, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. The services of TrustArc are provided at no cost to you.

Binding arbitration. In certain circumstances you may be able to choose binding arbitration to resolve your complaint, provided you have: (1) raised your complaint directly with us and given us the opportunity to resolve it; (2) used the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the U.S. Department of Commerce an opportunity to resolve it, at no cost to you. For more information, see the U.S. Department of Commerce’s Data Privacy Framework, Annex I (Binding Arbitration).

8. Contact us

If you have any questions about this Policy, or would like to request access to your Covered Personal Data, please contact us by email at privacy@id90travel.com or by post at 925 S. Kimball Avenue, Suite 140, Southlake, TX 76092.

9. Changes to this Policy

We may amend this Policy from time to time, consistent with the requirements of the Data Privacy Framework. The current version will always be published on this page.

Effective date: October 9, 2023

Last updated: October 22, 2026

Last reviewed: October 22, 2026