AIR MILES PROGRAMME PRIVACY POLICY
 

In this Privacy Policy “we“ or “us” means AIMIA MIDDLE EAST FZ LLC, a Free Zone company incorporated in Dubai, United Arab Emirates with trade license number 19291 and whose office is at 204, Building 15, Dubai Internet City, Dubai, UAE (“Aimia”), a company within the Kognitiv group of companies
 

1. INTRODUCTION
 

This Privacy Policy applies to the Air Miles Programme operated by Aimia and explains how we collect, record, hold, store, use, disclose or otherwise process (collectively “Process”) personal information.

The following additional terms, which also apply to your use of our Air Miles Programme and Air Miles mobile app:

• Our Air Miles Programme Terms and Conditions.
• Our Terms of Use of the Air Miles Middle East, which sets out the permitted uses and prohibited uses of the  Air Miles mobile app or online at www.airmilesme.com,  individually and collectively (the “Site”). When using our Site, you must comply with these Terms of Use

Personal information is any information, or a combination of pieces of information, that can be used to identify you or that we can link to you, including but not limited to a name, address, email address or telephone number.

The Air Miles Programme is not intended for people under the age of 18.  We do not knowingly collect and process personal information relating to young people under the age of 18.

Data Controller: For the purposes of applicable data protection laws, Aimia is the data controller and is responsible for the collection and use of your personal information.

To ask questions about our privacy practices, change your marketing preferences, issue a complaint or exercise any of the rights that applicable data protection law grants you in relation to your personal information, please contact us or Aimia’s Data Protection Officer (DPO) using the details in “Contacting Us” (section 8) at the end of this Privacy Policy.

 

Your privacy

• As the operator of the Air Miles Programme in the Middle East we recognise your trust is fundamental to the value of the programme. Therefore, we are committed to protecting your privacy.
• Protecting the privacy and confidentiality of your personal information has always been a fundamental principle in our relationship with you, our Partners and Reward providers.
• This privacy commitment demonstrates how we will ensure the confidentiality and privacy of the information you entrust us with.

 

2. COLLECTION AND USE OF PERSONAL INFORMATION
 

Personal Information we collect

The types of personal information we collect, store and may use for the Air Miles Programme are the following

• Membership data: Information about you to manage the Air Miles account and accurately record and update Air Miles balances. This includes: first name, last name, residential address, email address, date of birth, mobile number, and similar data regarding any people for whom you obtain flights, hotels or other rewards using your Air Miles. 
• Marketing preferences including ‘nationality’ in order to map your preferences and send you relevant offers.  
• Rewards related data including rewards you have purchased and redeemed with Air Miles from partner suppliers.  
• Travel related personal information
• Apart from the above fields we also track member behavior on the Air Miles mobile app for internal statistical analysis and member segmentation.
• Online data and data for your use of our website
• Services you have used in the past
• We also obtain personal information we collect automatically from you, such as statistical information regarding the use of the Aimia websites and Mobile App, including cookies, website users' IP addresses, location data and the dates and times of visits. Further information about our use of cookies and tracking technologies is available in our Cookies Policy.
• Personal information about you required to process reservations created with third party suppliers such as flight operators, hotels and travel providers. This includes your passport details and email address where required for flight or other travel bookings.

Please note that we may be required by law or as a result of a contractual or other relationship we have with you to collect certain personal information about you. Failure to provide this information may prevent or delay the fulfilment of these obligations. Where required by law, we will inform you at the time your information is collected whether its provision is compulsory and of the consequences of the failure to provide such information.

Our website does not honour “do not track” settings on web browsers and does not offer you the opportunity to request that we not track your use of its services except as otherwise stated in this Privacy Policy or our Cookies Policy.

If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please click here for our Cookie Policy.
 

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
 

Use of your Personal Information

We use your personal information to:

• Administer the Air Miles Programme - including the management of member accounts to accurately record and update Air Miles balances.
• Process member Air Miles redemptions - including the issuance of reward tickets and vouchers.
• Send Member non-marketing communications including but not limited to member operational emails (password reset, profile updates, etc.) monthly e-statements and reward order confirmation.
• Send marketing promotions via app push, email and SMS where consent to marketing has been agreed.
• Communicate information and offers to Members, Partners and suppliers.
• Understand and analyse Member needs and preferences.
• Develop, enhance, market and provide products and services to meet these needs
• Enable Members to participate in promotions and contests.  Periodically you may be asked to provide additional personal information via market research or surveys.

If you choose not to provide this information, it will not affect your ability to collect or spend Air Miles. However where we need to collect personal information by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

 

Legal Basis

We will only use your personal information when the law allows us to. Normally we will use your personal information in the following circumstances:

• Where we need to perform the contract, we are about to enter into or have entered into with you, namely the Air Miles Programme
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Examples of these legitimate interests include but are not limited to: identifying and preventing fraud; enhancing the security of our network and Information systems;  preventing harm and distress; enhancing, modifying, personalising or otherwise improving our services and communications for the benefit of Members; understanding how Members use the Air Miles Programme; determining the effectiveness of marketing / promotional communications.
  You have the right to object to such processing under legitimate interest if you wish by contacting us in writing specifying the reasons for your objection.
• Where we need to comply with a legal obligation.

Save as provided otherwise in this Policy, we do not rely on consent as a legal basis for processing your personal information although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us see below
 

3. DISCLOSURE OF YOUR PERSONAL INFORMATION
 

• We may share your personal information with the parties set out below for the purposes set out in the Use of Personal Information section above:
• If you are a HSBC credit card holder with HSBC Middle East Limited, for the accurate recording of the Air Miles you have collected and spent using your applicable HSBC credit card.
• With our suppliers (acting as data processors):
              to book flights, process Air Miles orders;
              to provide help desk and chat services;
              to operate the Air Miles Travel Rewards;
• With Service Providers (acting as processors) based in India who provide IT and system administration services.
• With Professional advisers (acting as processors or joint controllers) including lawyers, bankers, auditors and insurers based in who provide consultancy, banking, legal, insurance and accounting services.
• With tax authorities, regulators and other authorities (acting as processors or joint controllers) who require reporting of processing activities in certain circumstances.
• With third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

We will use your information from time to time to promote additional products, services, Rewards and Offers from the Air Miles Programme and its Partners which we believe may be of interest to you.

We do not give, rent or sell Member lists from the Air Miles Programme to any organisation or individual other than business units of Aimia affiliated companies within the Kognitiv group of companies, Partners, reward providers and companies contracted to process and manage your transactions, Air Miles spend requests and communications. In addition, your transaction information from one Air Miles Partner is not disclosed to any other Partner.

Marketing 

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
 

Third-party marketing

We will get your express opt-in consent before we share your personal information with any third party for marketing purposes.
 

Opting out of marketing communications

If you do not wish to receive marketing or promotional communications, simply update your communication preference by logging into your Air Miles account at www.airmilesme.com or through the  Air Miles Mobile app. Your ability to collect or spend Air Miles will not be affected. Once unsubscribed, this process will take 30 working days to process your request and you will not be notified of any special offers or promotions.

 

4. TRANSFERRING PERSONAL INFORMATION OUTSIDE THE JURISDICTION IN WHICH IT WAS COLLECTED
 

• We may disclose personal information to destinations outside the jurisdiction from which it was collected.
• In the conduct of our business, we disclose to, hold or access personal information from various countries including without limitation United Arab Emirates, Qatar, Bahrain, Canada, Malaysia, Egypt, India, United Kingdom, Republic of Ireland, Singapore, Hong Kong, Australia and the United States of America.
• The privacy laws of the countries to which we transfer personal information may not provide the same level of protection as the privacy laws of the country from which the personal information was collected or be regarded as ensuring an adequate level of protection for personal information under  United Arab Emirates data protection laws.  However, this does not change our commitments to safeguard your privacy and we will put in place appropriate safeguards in accordance with applicable legal requirements to ensure that your personal information is adequately safeguarded. For more information on the appropriate safeguards in place, please contact us using the details below.

5. LINKS TO OTHER WEBSITES

Our websites may contain links to third party websites, content embedded in our websites that comes from or relates to other websites and services, and buttons from other websites and services such as social media websites (such as Facebook, Google Analytics, Instagram). These third-party websites and services may use cookies or other tracking devices to collect and track information about you across the Internet - please see our Cookies Policy for further details.  As well, these third party websites and services are not under our control and we are not responsible for the content of those websites or services, their data collection practices, nor their privacy practices, and those websites and services are not subject to this Privacy Policy. Before disclosing your personal information on any other website or service we recommend that you examine the terms and conditions and privacy policy of that website or service. Aimia is not responsible for any practices on third party website or service that might breach your privacy rights.
 

6. YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
 

• Subject to local applicable law, you have a number of rights in relation to your personal information, including the right to:
• access your personal information;
• rectify the personal information we hold about you;
• erase your personal information;
• restrict our use of your personal information;
• object to our use of your personal information;
• receive your personal information in a usable electronic format and transmit it to a third party (this is known as the 'right to data portability'); and
• lodge a complaint with your local data protection supervisory
• If you would like to discuss or exercise such rights, please contact us using the details set out in section 9.
• We encourage you to contact us to update or correct your personal information if it changes or if the personal information we hold about you is inaccurate. We will contact you if we need additional information from you in order to honour your requests.
   

7. SECURITY OF YOUR PERSONAL INFORMATION
 

• We will endeavour to take all reasonable steps to keep secure any personal information which we hold about you, and to keep this personal information accurate, up to date and complete. We require our employees and service providers to respect the confidentiality of any personal information held by us, and implement appropriate safeguards as required under local applicable
   
• Data security
  We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. RETENTION OF PERSONAL INFORMATION
 

We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to:

• maintain business records for analysis and/or audit purposes;
• comply with record retention requirements under applicable law;
• defend or bring any existing or potential legal claims; and
• deal with any complaints regarding the products and services we provide under the Air Miles Programme

We will delete your personal information when it is no longer required for the above. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place  appropriate measures  to  prevent any further  processing or use of the information.

 

9. CONTACTING US
 

You may contact us by logging into our website or by contacting the Air Miles Customer Service Centre. We may record your calls to check the quality of our services for training, audit or security purposes

• If you have any concerns or complaints about how we process your personal information, or if you have any questions about this Privacy Policy, please contact us  at DPO@aimia.com
• Aimia ‘s data protection officer can be contacted at: DPO@aimia.com.
• Subject to local applicable law you also have the right to lodge a complaint with your data protection supervisory authority.
   

10. FUTURE CHANGES TO THIS PRIVACY POLICY
 

We operate in a dynamic business environment. Over time, aspects of our business may change as we respond to changing market conditions. This may require our policies to be reviewed and revised. We may change this Privacy Policy at any time.

 

The most current version of this policy will govern our use of your information and will always be available via a link from our website. Please check this link often for changes. Where changes to this Privacy Policy will have a fundamental impact on the nature of the Processing or otherwise have a substantial impact on you, we will give you sufficient advance notice on our website so that you have the opportunity to exercise your rights (e.g. to object to the processing).
 

This Privacy Policy is effective as of 11th November 2021.

 

 

What are Cookies?

Cookies are small pieces of information that a website transfers to your computer, laptop or mobile device. Cookies enable users to navigate websites efficiently and perform certain functions.  Due to their core role of enhancing/enabling usability or site processes, disabling cookies may prevent users from using certain websites.

Our use of Cookies

We use Cookies for the following purposes:

• To improve the performance of our websites by understanding which parts work well, and which don't.
• To deliver relevant online advertising and marketing to you both on our websites and elsewhere. This is sometimes done by combining data that we already have about you with the data collected through Cookies. These Cookies are placed by us and selected third parties and enable adverts to be presented to you on our and third-party. websites.To measure how effective our online advertising and marketing communications are.
• To enable us to collect information about how you and other people use our websites.
• To improve your experience on our websites, for example we use Cookies to remember that you have previously logged into an account and to personalise your experience.
• To measure email analytics to see how many of our emails have been opened and which links are clicked

What Cookies do we use?
 

We use the following Cookies on our websites:
 

Session Cookies
 

These are Cookies that are required for the operation of our website.  They are necessary for the safety, security and integrity of the site.  For example, they help support the structure of the pages that are displayed to you, help to improve navigation and allow you to return to pages you have previously visited. This type of Cookie only lasts for the duration of the time you are visiting the website. When you leave the website, they are deleted automatically.
 

Performance or Analytical Cookies
 

They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. The data is aggregated and anonymised, which means we cannot identify you as an individual.
 

Third Party Cookies
 

Our websites will set several types of third-party cookies, and we do not control the operation of any of them. The third-party cookies which may be set include:

Google Analytics and Google Tag Manager – we use Google Analytics and Google Tag Manager to collect data about website usage. This data does not include personally identifiable information. This might include the number of a user’s website visits, average time spent on the website, what pages have been loaded. You can view the Google Privacy Policy here: www.google.com/policies/privacy/.
 

Functionality Cookies
 

These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).  Cached Cookies will remain on your device until you choose to clear it.  If you choose to do this, you will need to enter your details each time you visit the site.
 

Targeting Cookies
 

These Cookies will collect information about how you browse our sites. and allow us to show you adverts while you are browsing our site and other sites on the internet.  They are set by us or by carefully selected third parties.  They help us to understand the performance of our marketing activities and improve the relevance of the adverts that you see.
 

Blocking or Restricting Cookies
 

You can stop Cookies being used on your device by activating the setting on your browser that allows you to block the deployment of all or some Cookies. Please visit www.allaboutcookies.org to find out how. Please note, if you use your browser settings to block Cookies you may not be able to access all or parts of our site.
 

Contact us

If you have a question about this policy, please contact us by one of the following means:

By email:  DPO@aimia.com
By post:   Data Protection Officer, 9^th Floor, Cannon Green, 27 Bush Lane, London EC4R 0AA