In this Privacy Policy “we“ “us” or "our" means AIMIA MIDDLE EAST FZ LLC. A Free Zone company incorporated in Dubai, United Arab Emirates, a company within the Kognitiv group of companies, with trade license number 19291 and whose office is at 204, Building 15, Dubai Internet City, Dubai, UAE (“Kognitiv”).
This Privacy Policy applies to the Air Miles Middle East Programme (“Air Miles Programme”) operated by Kognitiv 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, the Air Miles Website, 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 terms of use of the Air Miles Middle East Website. at www.airmilesme.com and Air Miles Middle East mobile app, (individually and collectively the “website”). Your use of the website is governed by 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, without limitation, 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, Kognitiv 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 as described in Section 9 “Contacting Us” below.
Personal Information we collect
The types of personal information we collect, store and may use for the Air Miles Programme include:
- Membership data: Information about you, and your Air Miles account including: 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 to understand your preferences and send you relevant offers.
- Rewards related data including rewards you have purchased and redeemed with Air Miles.
- Travel related information, including personal information
- Information about your use of the Air Miles Web site and mobile app for internal statistical analysis and member segmentation.
- We also obtain personal information that we collect automatically from you, such as statistical information regarding the use of our websites including the 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, and your choices relating to cookies, 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 transaction or our relationship with you to collect certain personal information about you. Failure to provide this information may prevent or delay the fulfilment of transactions or other programme services. Where required by law, we may capture additional information and will inform you at the time of being collected whether its provision is compulsory and of the consequences of the failure to provide such information.
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 without limitation 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.
- Enable Members to participate in promotions and contests. Periodically you may be asked to provide additional personal information via market research or surveys.
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. - Where we have your consent (which you may withdraw).
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) 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 party service providers 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 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 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 through the Air Miles Mobile app. Your ability to collect or spend Air Miles will not be affected. Once unsubscribed, this process may take up to 30 working days to process your request and you will not be notified of any special offers or promotions unless you elect to receive marketing communications again.
- 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 in, or access personal information from various countries including without limitation United Arab Emirates, Qatar, Bahrain, Australia, Canada, Hong Kong, India, Malaysia, Republic of Ireland, Singapore, Sri Lanka, United Kingdom 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 such laws. However we will continue to have privacy safeguards in place in accordance with applicable legal requirements.
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. Kognitiv is not responsible for any practices on third party website or service that might breach your privacy rights.
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 authority.
- 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.
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 by applicable law.
Data security
We have implemented security measures to help 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.
We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has ended, 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;
- 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 needed. 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.
You may contact us on 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: privacy@kognitiv.com.
- Subject to local applicable law you also have the right to lodge a complaint with your data protection supervisory authority.
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.
Dated 04/04/2024 © Aimia Middle East FZ LLC, 2024
