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Loyalty Data Co Privacy Policy

This Privacy Policy explains what data we collect from visitors to the Loyalty Data Co website www.LoyaltyData.co (including all subdomains, the “Site”) and/or our services and in connection with our events, and sales and marketing activities, how we process and protect personal data and your rights and choices with respect to your personal data in our capacity as a data controller.

What is the purpose of this privacy policy?

Loyalty Data Co provides a software product and services (together, “services”) that enable travel industry companies (i.e., Loyalty Data Co’s “business partners”) to offer their customers (“travelers”) the opportunity to upgrade their travel experience, subject to each business partners' individual discretion and the availability of the offering.

Protecting privacy is important to us and to our business partners. This is why we are committed to ensuring the security and confidentiality of the personal data we receive and process from our business partners as part of the services we provide to them. We are also committed to providing a software product that meets industry best practices and regulatory requirements for privacy and data protection.

The purpose of this Privacy Policy is to inform Loyalty Data Co’s business partners and travelers about our privacy and data handling practices. This Privacy Policy also applies to data we collect from visitors of the Site and in connection with our events, and sales and marketing activities.

This Privacy Policy explains how Loyalty Data Co processes personal data, how we protect it in the course of our business and your rights.

The information contained in this privacy policy includes:

What personal data does Loyalty Data Co process?

As a third-party service provider to travel industry companies (i.e., Loyalty Data Co’s “business partners”), Loyalty Data Co generally receives personal data that was initially disclosed by travelers to our business partners in connection with a travel booking or purchase, for the purpose of providing the Services to our business partners in accordance with the applicable service contract.

Loyalty Data Co may also receive from its business partners information about travelers’ service requests (e.g. flight meal preferences, class of travel). When such information is processed by Loyalty Data Co and is associated to an individual, it is treated as personal data for the purposes of this Privacy Policy.

We collect from our business partners, prospects and Site visitors information that is entered on our Site or sent to us electronically, for example when business partners purchase our Services or when our Site visitors request more information. We may also collect personal data that you provide to us when you attend one of our events, during phone calls with sales representatives or when you contact customer support.

a) Personal Data About Travelers:

We process personal data provided by travelers in connection with a booking or purchase of travel services from travel industry companies (i.e., Loyalty Data Co’s “business partners”), on behalf of our business partners. This typically includes or may include the following categories of personal data:

b) Personal Data About Business Partners, Prospects, Site Visitors:

Personal Data That You Provide To Us.

We collect information that you enter on our Site or send to us electronically, for example, when you request information, including a product demo, register for a webinar or other event, or subscribe to emailing lists. While the type of data we collect depends on the nature of the inquiry, this typically includes your name and contact details, company information, and phone number. We may also collect personal data that you provide to us when you attend one of our events (such as your contact details), during phone calls with sales representatives, or when you contact our customer support.

Automatically Collected Data.

Log Data. When you visit our Site, our servers record information (“log data”), including information that your browser automatically sends whenever you visit the Site. This log data includes your Internet Protocol (“IP”) address (from which we understand the country you are connecting from at the time you visit the Site), browser type and settings, the date and time of your request.

Cookies. When you visit the Site, we and our service providers acting on our behalf will automatically collect information about you through cookies (small text files placed on your device).

From where does Loyalty Data Co obtain personal data?

a) Personal Data About Travelers:

Loyalty Data Co obtains personal data provided by travelers in connection with a booking or purchase of travel services from travel industry companies (i.e., Loyalty Data Co’s “business partners”), for the purpose of enabling travelers to participate in booking upgrades and related services provided by Loyalty Data Co in accordance with the applicable service contract.

b) Personal Data About Business Partners, Prospects, Site Visitors:

Loyalty Data Co obtains the personal data that it processes, stores and discloses when this data is provided to us or collected as described under the “What personal data does Loyalty Data Co process?” paragraph.

What are the legal basis and purposes for which Loyalty Data Co processes personal data?

We use travelers’ information to provide the Services to the travel industry companies we work with (i.e., Loyalty Data Co’s “business partners”). We will also use this information to help improve product features or provide service enhancements and support our business partners in their current program and ongoing growth pursuant to our service contract.

The use of an individual's personal data will be limited to the purposes for which it was collected by our business partners - to provide the booking upgrades and related services - as agreed to in our service agreement with our business partners.

It is the responsibility of our business partners to ensure that they lawfully obtain personal data from travelers. As Loyalty Data Co provides the technology upon which our business partners provide services to travelers, when travelers wish to change their options regarding their personal data, Loyalty Data Co will process such wishes on behalf of our business partners and pursuant to their instructions.

We use our business partners’, prospects’ and Site visitors’ personal data as necessary to respond to inquiries regarding our services, fulfil the relevant contract, send promotional emails and other communications (so long as you agree to receiving these communications) and as necessary for our legitimate interests in the processing.

a) Personal Data About Travelers:

Loyalty Data Co uses travelers’ personal data in the course of providing services to its business partners for the purpose of providing the services to the business partners in accordance with the applicable service contract: To the extent necessary for those purposes, we take reasonable steps to ensure that personal data is accurate, complete, current and reliable for its intended use. Such steps include following Loyalty Data Co’s internal processes to manage our business partners’ requests to update, in a timely and effective manner, travelers’ personal data received from them.

b) Personal Data About Business Partners, Prospects, Site Visitors:

To provide the Services to you and respond to your requests. When you ask for information about the Services (for example, when you request a demo or ask us to send you offers or price information), or register to a webinar or an event, we will use your contact information to respond to your request. For EU data subjects, such use is necessary to respond to or implement your request.

We use account-related data provided by our business partners in connection with the purchase, sign-up, use or support of the business partner account (such as usernames, email address and billing information) to provide you with access to the Services and/or the Site, contact you regarding your use of the Services and/or the Site or to notify you of important changes to the Services and/or the Site. For EU data subjects, such use is necessary for the performance of the contract between you and us.

For marketing purposes. We will use your email address to send you information about new products and services, upcoming events or other promotions. You may opt-out of receiving such emails by following the instructions contained in each promotional email we send you. Our sales representatives may also use your phone number to contact you directly by phone, in connection with such new products and services, upcoming events or other promotions.

Where required by applicable law (for example, if you are an EU data subject), we will only send you marketing information by email or mail, or contact you by phone, if you consent to us doing so at the time you provide us with your personal data (in such case, our legal basis for the processing of your Personal Data will be your consent). When you provide us with your consent to be contacted for marketing purposes, you have the right to withdraw your consent at any time by following the instructions to “opt-out” of receiving marketing communication in each marketing email we send you. In addition, if at any time you do not wish to receive future marketing communications or wish to have your name deleted from our mailing or calling lists, please contact us [email protected]. Please note that if you opt out from marketing communications, we may still contact you regarding issues related to our Services and to respond to your requests.

To analyze, administer, support, improve use of the Site and the Services. We use data relating to your use of and interaction with the Site and the Services, including information that we obtain through cookies, to analyze, administer, support and improve your access to and use of the Site and the Services. We may also compile, anonymize and/or aggregate your Personal Data and other data and use such anonymized and/or aggregated data for our business purposes, including sharing it with affiliates and business partners. This aggregate information does not identify you. For EU data subjects, this use of your Personal Data is necessary for our legitimate interests in understanding how the Site and our Services are being used by you and to improve your experience on it. You have a right to object to the processing of your personal data based on our legitimate interest, as described under the “What privacy rights do individuals have regarding their own personal data?” section below.

If you are an EU data subject, please see the “What privacy rights do individuals have regarding their own personal data?” section below for information on your rights in relation to the personal data we hold about you.

How long does Loyalty Data Co retain personal data?

Loyalty Data Co retains travelers’ personal data for the duration of our service agreement with our business partners, unless a longer or shorter retention period is requested, required or permitted by applicable laws.

We keep the other personal data subject to this Privacy Policy only for as long as is reasonably necessary for the purposes described in this Policy, or for the duration required by law, whichever is the longer.

Does Loyalty Data Co share personal data with third parties?

Loyalty Data Co shares travelers’ personal data to third parties only as necessary to fulfil our service contract with travel industry companies we work with (i.e., Loyalty Data Co’s “business partners”) and pursuant to our business partners’ instructions, or otherwise required by the applicable law.

Loyalty Data Co shares our business partners’, prospects’ and Site Visitors’ personal data with third parties who support our business operations or as required or permitted by the applicable law.

Loyalty Data Co may share personal data with third parties in circumstances described below:

What privacy rights do individuals have regarding their own personal data?

Data subjects in the European Union (EU) have certain rights with respect to the processing of their personal data, described below (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, where applicable, Switzerland).

a) Travelers’ Rights:

Travelers have the right to submit the following requests regarding their personal data to the travel industry companies (i.e., Loyalty Data Co’s “business partners”) to whom travelers have previously provided their personal data, subject to applicable law:

Request access to and/or correction of their own personal data

Request the erasure of their own personal data

Request that Loyalty Data Co’s business partners stop processing or restrict the processing of their own personal data

Request that Loyalty Data Co’s business partners provide them with their personal data in a structured, commonly used and machine-readable format and transmit those data to another organization

Upon notification from our business partners of a traveler’s request to exercise their rights, we will enable such requests to ensure our business partners’ compliance with applicable regulatory requirements in accordance with the service contract with the applicable business partner.

b) Business Partners’, Prospects’, Site Visitors’ Rights:

Subject to applicable law, you have the following rights in relation to your personal data:

Right of access: If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.

Right to rectification: If your personal data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your personal data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.

Right to erasure: You may ask us to delete or remove your personal data, such as where you withdraw your consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data with so you can contact them directly.

Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it. We will tell you before we lift any restriction on processing. If we shared your personal data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.

Right to data portability: You have the right to obtain your personal data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will give you your personal data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.

Right to object: You may ask us at any time to stop processing your personal data, and we will do so if we are relying on a legitimate interest to process your personal data (unless we demonstrate compelling legitimate grounds for the processing) or if we are processing your personal data for direct marketing.

Right to withdraw consent: If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your data before we received notice that you wished to withdraw your consent.

Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your personal data, you can report it to the data protection authority that is authorized to hear those concerns.

You may exercise your rights by contacting us as indicated under the “How to contact Loyalty Data Co?” section below.

How does Loyalty Data Co protect personal data?

Loyalty Data Co will take reasonable precautions, including the implementation of appropriate physical, electronic and administrative procedures, to protect personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction. Although we employ technical safeguards, we cannot guarantee the security of personal data on or transmitted via the Internet.

We have implemented strong security measures as part of our services to the travel and hospitality companies we work with (i.e., Loyalty Data Co’s “business partners”). In particular, we have taken the appropriate measures to protect company resources and assets, including data, application architecture, application code, network access, location access, and hardware/device access. We have also taken appropriate measures to ensure timely availability and access to personal data in the event of a physical or technical incident, as well as implemented internal processes for regularly testing, assessing, and evaluating the effectiveness of the security measures.

How is this privacy policy enforced at Loyalty Data Co?

Loyalty Data Co follows an internal compliance monitoring process, to assure compliance with this Privacy Policy and periodically verifies that it is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible, and in conformity with privacy and data protection legislation applicable to Loyalty Data Co.

We will review the information in this Privacy Policy on an ongoing basis and make sure that it remains relevant to the organization practices and compliant with the upcoming privacy and data protection regulatory requirements. Occasionally, we may also, in our discretion, make changes to this Privacy Policy.

When we make material changes to this Privacy Policy, we will provide individuals with a prominent notice as appropriate under the circumstances and pursuant to the applicable law. These notices may be under the form of an email or a prominent notice on our website. The continued use of our services after that notice will constitute acceptance of the changes.

How to contact Loyalty Data Co?

Loyalty Data Co acts as the data processor for the processing of travelers’ personal data on behalf of travel industry companies (i.e., Loyalty Data Co’s “business partners”), pursuant to our service contract with the applicable business partner.

We act as the data controller for the processing of personal data about our business partners, prospects and Site visitors for the purposes described in this Privacy Policy.

Questions, comments or complaints regarding our Privacy Policy or data processing practices can be mailed or emailed directly to Loyalty Data Co’s Data Protection Officer:

[email protected]

Questions, comments or complaints regarding our Privacy Policy or data collection and processing practices concerning EU data subjects can be mailed or emailed to Loyalty Data Co’s EU based Representative

If you feel you haven’t received a timely or satisfactory response from us to your question or complaint, please contact the applicable data protection authority.

© 2019-2021 Loyalty Data Co on behalf of . All rights reserved.
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