Travel Tech Urges FTC to Target Deceptive Personalized Pricing While Preserving Competitive Travel Shopping Tools 

Travel Tech submitted comments to the Federal Trade Commission (FTC) on the agency’s proposed Enforcement Policy Statement on Personalized Pricing, supporting the FTC’s efforts to address unfair or deceptive uses of consumers’ personal data to set individualized prices. 

In its comments, Travel Tech encouraged the FTC to focus its enforcement efforts on situations where companies use personal information to determine what a specific consumer is willing to pay and then adjust prices accordingly without appropriate transparency or consumer protections. 

At the same time, Travel Tech cautioned against conflating personalized pricing with longstanding business practices that help consumers find better travel options and lower prices. The association emphasized that many common practices used throughout the travel industry are distinct from personalized pricing because they do not rely on assessing an individual consumer’s willingness to pay. 

“Consumers benefit from a travel marketplace that is transparent, competitive, and innovative,” said Laura Chadwick, President and CEO of Travel Tech. “As policymakers examine personalized pricing, it is important to distinguish potentially harmful uses of personal data from tools and practices that help travelers compare options, access discounts, and find the best value.” 

In its filing, Travel Tech highlighted several travel industry practices that should remain clearly outside the scope of any FTC enforcement policy on personalized pricing, including: 

• Dynamic pricing based on market conditions, supply, and demand 
• Inventory management and revenue optimization tools 
• Promotional discounts and limited-time offers 
• Loyalty and rewards programs 
• Employer, membership, government, and negotiated rates 
• Standard travel search inputs such as destination, travel dates, party size, and cabin class 
• The use of algorithms and automated decision-making tools when they are not used to evaluate an individual consumer’s willingness to pay 

Travel Tech noted that dynamic pricing has long been a feature of travel markets, allowing prices to respond to factors such as demand, availability, seasonality, and booking timing. These practices differ fundamentally from personalized pricing based on consumer-specific characteristics or personal data. 

The association also stressed the important role travel technology platforms play in helping consumers compare prices and options across a wide range of suppliers. Clear distinctions between personalized pricing and traditional travel pricing practices will help ensure that efforts to address potentially harmful conduct do not inadvertently limit competition or reduce consumer choice. 

Travel Tech will continue engaging with policymakers and regulators on issues related to pricing transparency, consumer protection, competition, and innovation throughout the travel marketplace. 

Travel Tech Association (Travel Tech) is the unified voice for the travel technology ecosystem. Travel Tech brings together enterprise leaders, growth-stage companies, and emerging innovators to advance public policies that support competition, innovation, and a strong technology-enabled travel marketplace. Through advocacy, regulatory intelligence, and cross-sector collaboration, Travel Tech helps shape the future of modern travel. 

To schedule an interview with a Travel Tech spokesperson, contact Jessica Matthias: [email protected].