Privacy Policy

California Notice of Collection of Personal Information
FlyerClub collects the personal information listed below under "What Personal Information we collect" for the purposes described below under "How we use the personal information we collect." To learn more about your California privacy rights, including your right to opt out of the sale or sharing of your personal information, please scroll down to "US State Privacy Rights" under "Your rights in respect of Personal Information."

Other US State’s Privacy Rights
Some US states have passed privacy laws, if you are a resident of any of these states and wish to learn about your rights, please scroll down to "US State Privacy Rights" under "Your rights in respect of Personal Information.

If you are located within the European Economic Area, for the purposes of applicable data protection legislation, FlyerClub is the data controller of Personal Information collected from you. Please see the Privacy Questions section below for further details.

INTRODUCTION
At FlyerClub, we understand the importance of your privacy. As a responsible data controller and processor, we are committed to maintaining the confidentiality of the information provided by our users.
Our commitment to data protection & privacy and safeguarding your personal information is paramount, so we have created this Privacy Policy. This document outlines how FlyerClub and its subsidiaries and affiliates handle and secure our users' Personal Information in accordance with all applicable North American, EU, and global data protection laws. Our Privacy Policy includes information on how we collect, use, disclose, transfer, and store any Personal Information you provide.
This Privacy Policy applies to any individual ("User") interested in purchasing or inquiring about FlyerClub's products or services available through various customer interface channels, including the company's website and offline channels such as call centers and offices. These channels collectively form FlyerClub's "Services.”
This Privacy Policy is also applicable to all Services provided by FlyerClub, including its website, mobile site, mobile app, call centers, and offices.
For the purpose of this Privacy Policy, wherever the context so requires, "you" or "your" shall mean User and the term "we", "us," or "our" shall mean FlyerClub. For the purpose of this Privacy Policy, www.flyer-club.com means the website(s), mobile site(s) and mobile app(s) (Collectively referred to as “Site”).
Personal information includes information collected on-site, over the phone and exchanged securely online when you either visit FlyerClub’s (and its subsidiaries and affiliates) offices or call centers or interact online with our websites, mobile sites, mobile applications, social media pages, direct marketing campaigns or other online communications (collectively the "Services"). Please read this Privacy Policy with our Terms and Conditions and Client Services Agreement.
This Privacy Policy applies solely to those who purchase or inquire about FlyerClub's products or services. It does not extend to third-party websites or products, even if they are linked to FlyerClub's site. Users should note that the privacy practices of FlyerClub's business partners, advertisers, sponsors, or other linked sites may differ from this Privacy Policy. Therefore, reviewing these third-party sites' privacy statements and policies is advisable before engaging with them.
This Privacy Policy is an essential component of FlyerClub's User Agreements, and any capitalized terms not defined herein will have their common meanings. By accessing or using FlyerClub's Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you disagree, please refrain from accessing or using FlyerClub's Services.
What Personal Information do we collect
For the purposes of this privacy policy, there is no distinction between personal information and personal data, and both refer to information that identifies or is reasonably capable of being associated with or could reasonably be linked, directly or indirectly, with you or your household. We collect or may collect the following categories of Personal Information/Personal Data:

1.
Identity Data: Which comprises a person's first and last names, a username or other unique identifier, their marital status, their title, their date of birth, their photos, their social security number, their job title, their vehicle registration number(s), their age, and their gender;
2.
Contact Data: This includes billing address, delivery address, personal email, and phone numbers;
3.
Booking data: For example, each traveller's name, frequent flyer information, passport number and expiry date, redress control number, the nation of citizenship, booking reference number, and itinerary, which may include the name of the airline or carrier, hotel or vessel, port of destination, port of arrival, date and time of departure and/or check-in, date and time of arrival and/or check-out, meal preferences, luggage information, and layover or transfer information;
4.
Financial Data: This includes payment details such as card details or bank names.
5.
Transaction Data: This contains your payments to us, the goods and Services you have purchased from us, and the activities you have engaged in.
6.
Technical Data: Including any information that is automatically gathered from any device that accesses the Site or our Services. Such data may comprise, but not be limited to - your device's IP address, login information, browser type and version, time zone offset settings, geolocation, CPU, screen resolution, device memory, installed fonts, draw canvas logic, browser plug-in types and versions, operating system and platform, full "Uniform Resource Locators," clickstream to, through, and from the Site (including date and time), and other technology on the decentralized internet;
7.
Profile Data: This contains your username and password, any orders or purchases you've made, your likes and preferences, comments and survey answers, as well as any items you've looked at or searched for; page response times, download issues, the duration of visits to specific pages, and page interaction data (such as scrolling, clicking, moving the mouse cursor over areas of the page, and how you navigated away from it);
8.
Usage Data: includes information about how you use our site, products, and services;
9.
Marketing and Communications Data: It includes your preferences for how you want to communicate with our third parties and us, as well as how you want to receive advertisements from us; please note that you can always opt-out at any time from receiving future marketing communications by contacting – privacy@flyer-club.com or + 1 844-447-0007 .
10.
Information that can include: Search history, IP address, screen resolution, the browser that was used, operating system, access times, and referring URL. We may also get information about your mobile device, its settings, and your location if you're using one;
11.
Customer support information: We will record any questions, complaints, or other details you may send to our support team when you contact our customer support Services;
12.
Any other information you provide to us;
13.
Kindly take note of the following:

i.
We will only collect, handle, and keep your personal data securely once you confirm that all the information you have provided is complete, truthful, and accurate regarding yourself.
ii.
You guarantee that you have the authority to provide us with this information and permit us to use it in accordance with our Privacy Policy when you send any personal information related to other individuals to us or our service providers in connection with the Services. We reserve the right to ask for confirmation of authority when you send any personal information related to other individuals to us or our service providers to reduce fraud and protect our users.
iii.
When requested, your providing your personal data is necessary for the proper execution of the contract between you and us and to enable us to comply with our legal obligations, except when we rely on consent as a legitimate basis for processing and/or our legitimate interest. Without it, we may be unable to provide you with all the requested Services. All the personal data you give us must be correct and accurate. This includes, for example, ensuring that we always have your accurate contact details (including email).
iv.
If we need to collect your personal data in accordance with the law or the terms and conditions of a contract with you (customer), and you do not provide the requested data, we cannot complete the contract we have or are attempting to enter into with you. As a result, we may need to cancel a service, and where this is the case, we will provide advance notice to you.
How do we collect your Personal Information
1.
Personal Information You Provide
At FlyerClub (and its subsidiaries and affiliates), we may collect your personal information directly when you use our concierge or other value-added services. This could include registering for our service, making travel arrangements, or contacting customer care. We may also receive personal information automatically when you visit our website, mobile sites, interact with our mobile applications, visit our office or call our call centers. This may include information such as IP addresses, browser types, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We may share this information with third-party service providers to improve our products, services, content, and advertising. However, you are not required to provide us with the requested personal information. Please note that if you choose not to do so, we may not be able to provide you with our products or services or respond to your queries.

We may automatically collect information about your online activity and interactions with us using technologies such as cookies, web beacons, pixel tags, mobile analytics software, log files, or other technologies. This allows us to track analytics and certain statistical information, monitor your interactions with the Services for compliance verification purposes, and provide you with more relevant services. We may also use third-party service providers to receive, collect, and store Personal Information on our behalf using similar technology.

We may collect your IP address or other unique identifier for the device you use to access the Services, including hardware model and mobile network information. We may also collect information about the location of your device and use this to provide the Services, analyze trends, track your interactions with the Services, and retarget online and mobile advertisements to you across devices. We may use third-party analytics and tracking tools, such as Google Analytics, to help us analyze the Services' usage and serve more targeted advertising to you.

We may combine the personal information we receive from you and about you, including Personal Information you provide to us and Personal Information we automatically collect through the Services, as well as Personal Information collected across other computers or devices that you may use from other online or offline sources, and third-party sources. We use this combined personal information to improve our products, services, content, and advertising.
2.
Personal Information You Provide
We may collect your personal information directly anytime you contact FlyerClub (and its subsidiaries and affiliates) or any third-party service providers to use our concierge or other value-added services. Some instances where you provide us with your personal information include when you register for our service, make travel arrangements, or contact our customer care.

FlyerClub (and its subsidiaries and affiliates) or any of our third-party service providers may share this information and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, services, content, and advertising. You are not required to provide the Personal Information that we request, but if you choose not to do so, in many cases, we will not be able to provide you with our products or services or respond to any queries you may have.

Please note that when you visit our website or mobile sites or interact with our mobile applications and social media pages or visit our office or call our call centres, we or our providers receive and may store information automatically, including IP addresses, browser types, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. Furthermore, if you contact us for any other reason, we may keep a record of that correspondence.
3.
Personal Information Collected Automatically
Whenever you visit or interact with the “Services,” we and any third-party advertisers or service providers may use various technologies that automatically or passively collect information about your online activity. FlyerClub may collect your Personal Information as stated above in the following ways and only for the purpose of providing you with a requested service or answering your inquiry:

Electronic Activity: We may automatically collect your IP address or other unique identifier for the computer, mobile device, tablet or other device you use to access the Services, including the hardware model and mobile network information. We may use this information to provide the Services, help diagnose problems, analyze trends, track your interactions with the Services, and retarget online and mobile advertisements to you across computers or devices you may use.
Geolocation Information: We may collect information about the location of your device when you access or use the Services. In addition, we may collect and use your geolocation information if you turn on your Bluetooth, Wi-Fi or other geolocation functionality when you use our mobile applications. We may use third-party analytics and tracking tools, such as Google Analytics, to help us track, segment and analyze/improve our website user’s experience. These tools may use technology such as cookies, web beacons, pixel tags, log files, Flash cookies, or other technologies to track online activity. They may also combine information from your interaction with the Services with information they collect from other sources. We do not have access to or control over these third parties' use of cookies or other tracking technologies.

How do we use Personal Information, we collect

We will hold, process, and disclose your Personal Information to carry out actions that align with the specific purposes for which you provided the Personal Information, and these purposes include and are in accordance with the bases set out below:

Purpose(s) for processing		Basis for Processing
	To establish and maintain the contractual relationship for the provision of the product and/or service that you have requested.	Your consent, which you can withdraw at any time
	To contact you regarding your account or use of our Services and features.
	To authenticate your account credentials and identify you, as necessary, to log you into the Services and ensure the security of your account.
	To communicate with you regarding your booking or purchase and to complete/fulfill your booking or purchase, including processing your payment.
	To offer you customer services when you contact us, answer any questions, and fulfill your requests.
	To contact you, sending you important information about the Services, newsletters and any updates to our user agreement, terms and conditions, and policies.
	To provide you with exclusive and personalized offers and experiences.
	Continue communicating with you regarding our relationship, including updates to this Privacy Policy.
	As we may disclose to you from time to time.
	To communicate with you and act as a mediator with third parties providing services to you.	The processing is necessary to support our legitimate business interests in providing the requested services to you.
	To ensure the provision of any services you contracted to a third-party service provider.
	To pay any third-party service provider for services provided to you.
	To fulfill FlyerClub’s obligations under a contract with you and arising from any contracts entered by you with third-party service providers, as well as conduct other actions aligning with our business relationship with you.	The processing is further necessary for the performance of a contract or to take steps at your request subject to a contract to which you are a party.
	In relation to FlyerClub's legal and tax obligations:	The processing is necessary to comply with a legal obligation or order to which FlyerClub is subject
	For the purpose of fraud protection and credit risk reduction.
	To protect FlyerClub in the event of litigation or to protect FlyerClub's legal rights.
	To meet FlyerClub's tax obligations.
	To ensure that FlyerClub meets the compliance requirements of all applicable global data protection and privacy laws.
	To protect our colleagues, business partners, suppliers or clients, and the public's property or safety where there are reasonable grounds to believe that the safety of such rights, or property have been, or could be, affected.
	Responding to a demand by law enforcement authorities conducting a criminal investigation or responding to civil or administrative authorities pursuing a pending civil case or administrative investigation where due processes have been followed.
	When you access our Services:	The processing is necessary to support our legitimate business interests in managing our resources, managing, organizing and protecting our business and improving our services, provided such interests are not overridden by your interests and rights
	To help us address problems with and improve our Services design, products and services.
	To correct our records and make delivering your next communication easier or serving you better.
	To respond to your requests and to contact you if necessary.
	To protect the security and integrity of the Services and our business.
	And for other purposes as disclosed when you provide your information or otherwise with your consent.
	In connection with our website analytics when you access our websites:	Where required by applicable law, your consent, which you can withdraw at any time, and to support our legitimate business interests to manage and improve our services, provided such interests are not overridden by your interests and rights
	To analyze trends and statistics in terms of how our website is used and understand the flow of traffic on our website to provide a better and more personalized website experience and to understand the needs of our clients.

Additional information regarding individuals in the European Economic Area: For purposes of applicable data protection laws, the bases for processing outlined above comprise, in each case, the "legal basis" for processing Personal Information for each listed purpose. We will only use your Personal Information for the purposes for which we collect it, and subject to the legal basis for each purpose as outlined above, in compliance with applicable data protection laws.

How we share your Personal Information
If we must share your information with a third party, we will do so after you have given your express and documented consent and only in the following circumstances:

With Your Consent: We will share only after you have expressly given consent.
Necessity: if this action is strictly necessary to provide our Services.
Legal: if it is necessary to send information to a lawyer to begin the litigation resolution process.
Business Integrity & Continuity: in the event that it is necessary to uphold the integrity and transparency of our business.
Fraud detection: Our business partners may also receive information regarding your personal data. Certain of these business partners might use your personal information for fraud detection, including an email address, to identify, stop, or otherwise handle fraud, security, or technical concerns.
Services Survey/Opinion Poll: To determine the level of your satisfaction with our Services, we may also disclose your anonymized information while asking a partner to develop an application, questionnaire, etc.
Categories of Personal Information Disclosed: In the last 12 months, we have disclosed the following categories of Personal Information for a business purpose to service providers who are restricted from using your Personal Information outside the scope of their services for us:

Identifiers/Contact Information, disclosed to E-Commerce Platforms, Data Analytics Providers, Social Networks, and Cloud Data Storage Providers;
Geolocation Data, disclosed to Data Analytics Providers;
Commercial Information, disclosed to E-Commerce Platforms, Payment Merchants and Customer Service Providers;
Internet/Electronic Activity, disclosed to Data Analytics Providers, Operating Platforms, and Social Networks;
Visual/Audio Information, disclosed to Security and Fraud Protection Service Providers;
Inferences, disclosed to Data Analytics Providers.
Use and Disclosure of Sensitive Personal Information: To the extent that we collect, use, or share "sensitive personal information," as that term is defined in applicable California law, we limit our use or disclosure of sensitive personal information to permitted business purposes.
How we store and protect your data
Our business is in the USA, and all information processed and stored on our platform is done so in the U.S.A. If you are located outside the U.S., we may transfer your information to the U.S. and have put the necessary security measures in place to prevent unauthorized access, use, or loss of your personal data. Only authorized personnel, such as employees, agents, and contractors, who need to know the information for business purposes, will have access to it. They must comply with our confidentiality policies and will only process your data per our instructions.

If you are in the European Economic Area (EEA) or Canada: Please note that the recipients may be in countries that do not provide a similar or adequate level of protection to that provided by the country where you reside. To the limited extent that it is necessary to transfer Personal Information outside of your country of residence, we will take measures to ensure appropriate safeguards are in place, such as standard contractual clauses under GDPR Article 46.2 or an adequacy decision concerning the country at issue under GDPR Article 45. If you would like further information regarding safeguards, please contact us.

If you ever suspect that your account with us has been compromised or that your interactions with us are no longer secure, please notify us immediately via email at privacy@flyer-club.com.

We have taken reasonable steps to secure the Personal Information in our control. Still, no security measures are guaranteed to be effective against all threats of unauthorized Personal Information access or use. Our steps include physical, contractual, technical, and managerial safeguards to protect your Personal Information. However, security lies in your hands as well. It is important for you to protect against unauthorized access to your passwords and to your computers and other connected devices. Be sure to sign oﬀ when ﬁnished using a shared device and log out of our websites or any FlyerClub app if you finish using them.
Children’s/Minor's Data & Privacy
Neither this website nor our services are intended for children (children can form part of a group but must be booked for by and always accompanied by an adult), and we do not collect Personal Information about persons under the age of 16. If you are under the age of 16 or the equivalent minimum age in the relevant jurisdiction, please do not attempt to provide us with any Personal Information about yourself. If we learn that we have collected Personal Information from a child under the age of 16 or equivalent minimum age in the relevant jurisdiction, we will promptly delete that information. If you know that your child or an individual under 16 (or equivalent minimum age in the relevant jurisdiction) has provided their Personal Information through our website, please contact us at privacy@flyer-club.com If we learn that we have received Personal Information on a child under the age of 16, we will delete that information from our records and systems.
Data retention
We consider the data's quantity, nature, and vulnerability and the purposes for which we process your Personal Information. We only retain your Personal Information for the period necessary to fulfil the services you requested reasonably and for the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
Your rights in respect of Personal Information
We respect your right to be informed of the purposes for collecting your personal information, request access to, correction of, erasure of, restriction of processing of your Personal Information, or to object to the processing of your Personal Information, as well as the right to portability in accordance with applicable law. In each case, these rights are subject to restrictions contained in applicable laws. If you want to exercise your Personal Information rights, please contact us at privacy@flyer-club.com. We will respond to your request in accordance with applicable law.

If you request access to a copy of your Personal Information, which FlyerClub holds, your request will be dealt with as quickly as reasonably possible and in any event in accordance with applicable law.

EEA and Canada Residents
Under the European Union General Data Protection Regulation and applicable Canadian privacy laws, you may have certain rights regarding your Personal Information, including:

i.
Right to be Informed: You have the right to be informed of the purposes of the processing to validate your consent.
ii.
Right to access your information: You have the right to confirm whether and how we use your Personal Information, why we use it, how long we keep it, and who we share it with. You also have the right to request a free copy of the information we hold about you.
iii.
Right to Correct/Rectify your information: If you believe that we hold Personal Information about you that is inaccurate, misleading, or incomplete, you have the right to request that we correct/rectify that information in our records.
iv.
Right to Object/Withdraw consent: Where you provide consent to our use of your Personal Information, you can withdraw your consent at any time by contacting us.
v.
Right to complain to a supervisory authority: If you have any concerns regarding how we handle your Personal Information, please don't hesitate to contact us at privacy@flyer-club.com. We are always happy to assist you in resolving any issues you may have, and we will do our best to ensure that we address your concerns promptly and fairly.
However, if you feel unsatisfied with our response. In that case, you can complain to the data protection supervisory authority or privacy commissioner in your home country or jurisdiction.

EEA residents specifically have the following additional rights:

i.
Right to portability: You can request a copy of your Personal Information for your personal use, including sharing with other entities.
ii.
Right to request that we limit the use of your information: You also have the right to request that our use of your Personal Information be restricted.
iii.
Right to Erasure: You can request that we erase, delete and remove your Personal Information from our records.
US State Privacy Rights
If you are a California resident, you may take advantage of the following privacy rights:

Right to Know: You have the right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.
Right to Correct: You have the right to correct inaccurate personal information that we may maintain about you, subject to appropriate verification.
Right to Delete: Request that we delete any Personal Information that we have collected from or about you. Note that there are some reasons we will not be able to fully address your request, such as if we need to complete a transaction for you, to detect and protect against fraudulent and illegal activity, to exercise our rights, for our internal purposes, or to comply with a legal obligation.
Right to Opt-Out of the Sale or Sharing of Personal Information: You also may request to opt out of the "sale" or "sharing" of your Personal Information to third parties for their commercial use. This means that if you opt-out, we will not share your Personal Information with such third parties to use for their purposes unless you later direct us to do so. To effect the opt-out, please don't hesitate to contact us at privacy@flyer-club.com.
For Colorado, Connecticut, Utah, or Virginia residents, FlyerClub has certain obligations, and you have certain rights over your personal information, including:

Right to confirm whether the controller is processing the consumer’s personal information and the right to access such information.
Right to correct inaccuracies in personal information
Right to delete personal information
Right of data portability
Right to opt-out from targeted advertising
Right to opt-out from the sale of personal information
In certain states, you also have the right to opt-out from profiling in furtherance of decisions that produce legal or similarly significant effects on the consumer (such as Virginia, Colorado, and Connecticut) and appeal a decision regarding a denial of a request to exercise your rights.

To take advantage of these rights, please visit your Privacy Settings page on www.flyer-club.com or contact us at privacy@flyer-club.com. You can also contact FlyerClub to make such requests at our toll-free number at + 1 844-447-0007. We must verify your identity before processing your rights where technically feasible based on the information provided. We value your privacy and will not discriminate regarding exercising your privacy rights. We will confirm receipt of your request within 10 business days and respond within 45 calendar days after proper verification unless we need additional time, in which case we will let you know.

If you exercise any of the preceding rights, we will not discriminate against you, including by denying access to our products or services or restricting your access to products or services of a certain quality or price level.

Agent Requests: You may authorize someone to request privacy rights on your behalf (an authorized agent). Authorized agents must demonstrate that you've authorized them to act on your behalf. We retain the right to request confirmation from you confirming that the agent is authorized to make such a request or to request additional information to confirm the agent's status as an authorized agent. An authorized agent is prohibited from using a consumer's Personal Information, or any information collected from or about the consumer, for any purpose other than to fulfill the consumer's requests, for verification, or for fraud prevention.
Consequences of failure to provide information
If FlyerClub asks for information and you do not wish to give it to us, or if you wish to withdraw consent to the use of your information, FlyerClub will explain the consequences based on the specific information concerned, including whether it is a legal or contractual requirement that we use such data. However, if FlyerClub cannot collect the necessary information from you, it may make it difficult or impossible for us to provide our services through our website, app or otherwise. If you have any queries regarding the consequences of not providing information or withdrawing your consent, please contact us at privacy@flyer-club.com with the subject header - Withdrawing Consent.
FlyerClub’s commitment to your privacy
To help make sure your Personal Information is secure, we communicate our privacy and security guidelines to all FlyerClub employees and strictly enforce these safeguards within the company.
Privacy Questions
If you wish to contact us or have any questions about or complaints in relation to our Privacy Policy or the way FlyerClub handles your Personal Information, please contact us at privacy@flyer-club.com and we will try to address your concerns swiftly and resolve any issues you might have.

For general inquiries about FlyerClub, please email info@flyer-club.com

FlyerClub may update its Privacy Policy from time to time. When we change the policy in a material way, we will update the Privacy Policy on our Services.

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Privacy Policy

INTRODUCTION

What Personal Information do we collect

How do we collect your Personal Information

How do we use Personal Information, we collect

How we share your Personal Information

How we store and protect your data

Children’s/Minor's Data & Privacy

Data retention

Your rights in respect of Personal Information

Consequences of failure to provide information

FlyerClub’s commitment to your privacy

Privacy Questions

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