Premium Travel Club

Premium Travel Club Prospect and Member Privacy Notice

1. PURPOSE AND SCOPE OF THIS PRIVACY NOTICE

This privacy notice ("Notice") sets out the basis on which we use, process, store or disclose any personal information about you ("Personal Data"), that we collect from you or that you provide to us when you engage with us in relation to, or become a member of, the Premium Travel Club. For the purposes of this Notice, the controller of your Personal Data is Travel Concepts Limited ("we", "us" or "our") of 3rd Floor, The Anchorage, 17-19 Sir John Rogerson's Quay, Dublin 2, D02 DT18, Ireland.

2. OVERVIEW OF THIS NOTICE

This Notice applies to our processing of your Personal Data when you:

engage with us in connection with Premium Travel Club membership
are a member of Premium Travel Club
visit our website, www.premiumtravelclub.com (the "Website"); and/or
log into the member area, Premium Travel Club Access, on our Website.

If you have any queries, concerns or would like to exercise any of your data protection rights arising from this Notice, please contact: dpo@premiumtravelclub.com.

3. WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?

We will collect and process the following Personal Data about you in the following instances:

Personal Data	Details
Prospect Data	When we engage with you about, and express our interest in you, becoming a member of Premium Travel Club, we will collect Personal Data from you in connection with your prospective membership. Examples of the Personal Data we will collect include: your name, residential address, contact details, country of origin, date of birth, gender, hotel reservation details (including, other guests included in your reservation), travel preferences/habits, details about your family/dependents, financial income information, marital status and dependents' details.
Member Data	When you are a member of Premium Travel Club, we will collect Personal Data from you in connection with your membership. Examples of the Personal Data we will collect include: your name, residential address, contact details, date of birth, gender, bank and payment details, financial income, information, travel habits, details about your family/dependents, marital status and details about your reservations at any affiliated hotels.
Member Support Data	You may choose to give us your Personal Data when you interact with us for help or support with queries or to make a complaint. Examples of the Personal Data we will collect include: your name, residential address, hotel reservation details, contact details, details about your family/dependents , details of technical issues of may be experiencing (e.g. regarding the Premium Travel Club Access area on the Website), and details about your query or complaint.
Website Data	When you visit the Website as a Website user, we will collect Personal Data relating to your: (a) visits and interactions with the Website including which webpages you visit, time and date of access, what you click on, when you perform these actions; and (b) device data including your IP address, location data, device type and language, browser type and other related information. Most of this Personal Data is collected using cookies on the Website. Please see our Cookies Policy for more information about how the Website uses cookies.

Please note that the above list of Personal Data which we may collect about you, while intended to be as complete and accurate as reasonably possible, is not exhaustive and may be updated from time to time.

4. HOW & WHY DO WE USE YOUR PERSONAL DATA?

The reasons why (“Legal Basis”) and how (“Purposes”) we process your Personal Data in each particular data processing activity are explained in the below table:

Data Processing Activity	Purposes	Legal Basis
Prospecting Premium Travel Club membership	It is necessary to process your Prospect Data to take steps to enter into a membership contract with you, including for the following purposes: To engage with you as a prospective member of Premium Travel Club To organise a meeting with you about prospective membership to Premium Travel Club To assess if you are eligible to become a member of Premium Travel Club; and/or To offer you membership to Premium Travel Club. IMPORTANT: it is a pre-contractual requirement for you to provide your Prospect Data for the purposes set out above. If you do not provide us with such Personal Data so that we can process it for these purposes, you will not be able to become a member of Premium Travel Club.	To take steps to enter into a contract with you
To manage your Premium Travel Club membership	It is necessary to process your Member Data to enter into and perform our contract with you under your membership with Premium Travel Club, including for the following purposes: To manage your bookings and reservations in affiliated hotels or otherwise manage our contract with you To receive payments from you; and/or To perform our membership contract or any contractual terms with you or other connected parties. IMPORTANT: it is a contractual requirement for you to provide your Member Data for the purposes set out above. If you do not provide us with such Personal Data so that we can process it for these purposes, you will not be able to become a member of Premium Travel Club.	Contractual necessity
To serve our members and our business	It is necessary to collect and process your Member Data, Member Support Data and Website Data for the purpose of pursuing our legitimate business interests where we have an appropriate need to use such Personal Data including, for the following purposes: To enrol you in our partners programs To conduct assessments into our business performance to improve our products / services and for business planning; To send you direct marketing e-mails with deals and promotions; To offer you a membership upgrade, renewal or extension To manage any support requests from you (including, any complaints or queries) To verify the accuracy of any information and any Personal Data we receive from you (including your identity) For the creation, signing and storage of your membership contract (or related documentation) To maintain and store records in relation to you/your membership To exercise, establish or defend our legal rights (where applicable) (e.g. in the context of actual or prospective legal proceedings); and/or To protect your Personal Data and keep it secure by way of appropriate technical and organisational security measures. IMPORTANT: when we process your Member Data, Website Data and/or Member Support Data based on our legitimate interests, we make sure to consider and balance any potential impact on you and your data protection rights. We will not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by applicable law). You have certain rights when we process your Personal Data on this basis, such as the right to object. For more information on exercising this right please see section 8 of this Notice (*Your Data Protection Rights*).	Legitimate interests
Compliance with legal obligations	We may process your Prospect Data, Member Data, Member Support Data or Website Data where it is necessary to comply with legal obligations to which we are subject under local or European Union Member State laws.	Compliance with legal obligations

IMPORTANT: it is a contractual requirement for you to provide your Personal Data for the purposes set out above. If you do not provide us with such Personal Data so that we can process it for these purposes, you will not be able to become a member of Premium Travel Club.

5. RECIPIENTS

In order to process your Personal Data for the purposes set out in section 4 of this Notice, your data will be shared with hotel staff (including concierge, marketing team, customer service team, etc.), group entities (e.g. business leadership, management, legal, customer support, etc.), third parties who provide services to us (e.g. software providers, legal and professional advisors, etc.) and, where necessary, regulatory authorities or bodies (e.g. data protection authority).

6. TRANSFERS OF YOUR PERSONAL DATA

Individuals who are resident in the European Economic Area ("EEA") should be aware that we will transfer Prospect Data, Member Data and Member Support Data outside of the EEA to staff of our affiliated hotels and certain recipients who are located in countries with laws and practices that do not contain equivalent data protection rights for your Personal Data (e.g. the Dominican Republic, Mexico and Jamaica). Where such transfers occur, we ensure that appropriate safeguards are in place by making it our policy that: a) transfers do not occur without our prior written authority; and b) that an appropriate transfer agreement is put in place to protect your Personal Data (such as Modules 1 and 2 of the European Commission's Standard Contractual Clauses or other approved transfer mechanisms approved by the European Commission and supervisory authorities). If you would like to find out more about any transfers which affect your Personal Data, please contact us by e-mailing dpo@premiumtravelclub.com.

7. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

Generally, your Personal Data will be retained for no longer than is necessary and will be managed in accordance with our data retention standards and in line with the retention periods set out in the table below:

Personal Data	Retention Period
Prospect Data	If you do not become a Premium Travel Club member: 12 to 18 months from the date on which we engage with you about Premium Travel Club membership; If you do become a Premium Travel Club member: see Member Data section below.
Member Data	We will retain your Member Data based on the following the criteria: the length of our relationship with you as a member of Premium Travel Club, this period generally ranges from 3 to 25 years whether there is a legal obligation to which we are subject which requires us to retain your Member Data; and whether retention is prudent in light of our legal position (such as with respect to statutes of limitations, litigation or regulatory investigations), in which case the Personal Data may be kept for up to 7.5 years from date on which your Premium Travel Club membership expires.
Member Support Data	The length of time it takes to address your query or complaint, plus a reasonable time after your query or complaint is closed.
Website Data	See our cookies policy for more details.

8. YOUR DATA PROTECTION RIGHTS

You have a number of rights in relation to your Personal Data, which are set out below. In particular, these rights include the right to object to processing of your Personal Data where that processing is carried out for our legitimate interests. Note that these rights are not absolute. You can exercise these rights by e-mailing dpo@premiumtravelclub.com.We will aim to respond to your request within one-month of receiving it. We may have to extend the timeline of our response up to 2 further months if necessary, but we will contact you if this need arises. Please also note that we may need to verify your identity when you exercise your data protection rights.

Right	Details
Right to Information	You have a right to be provided with clear, transparent and easily understandable information about how we process your Personal Data. We give effect to this right by making this Notice available to you.
Right to Object	You have a right to object to our processing of your Personal Data where we rely on our legitimate business interests to process such data. You can request that we stop processing your Personal Data, and we will do so, unless we can demonstrate compelling legitimate grounds to continue processing your Personal Data or if we need your Personal Data in connection with any legal claims.
Right of Access	You have the right to access the Personal Data we process about you. If you exercise this right, you will receive confirmation about whether we process your Personal Data and, if so, a copy/copies of your Personal Data.
Right to Rectification	You have the right to correct the Personal Data we process about you if the Personal Data we hold about you is accurate or incomplete.
Right to Erasure	You have a right to request, in certain circumstances, the deletion of your Personal Data - for example if you exercise the right to object and we do not have an overriding reason to continue processing your Personal Data or if we no longer need to process your Personal Data.
Right to Restriction	You have the right, in certain circumstances, to restrict our processing of your Personal Data – for example, if you contest the accuracy of the Personal Data we hold about you or you object to us processing your Personal Data.
Right to Lodge a Complaint	You have the right to lodge a complaint with a data protection authority in your country of residence in the European Union or, if you are not resident in the European Union, the Data Protection Commission of Ireland. We encourage you to contact us before raising a concern with a data protection authority to see if we can resolve any concerns you have about our processing of your Personal Data.
Right to Data Portability	You can ask us to provide you with your data in a format which allows you to use it across different services.

9. CHANGES TO THIS NOTICE

This Notice will be regularly reviewed and may be amended and updated from time to time as necessary. Any updates to this Notice will be notified to you.

10. CONTACT US

If you have any questions, comments or concerns about the way your Personal Data are being used or processed by us, please submit your question, comment or concern by e-mailing dpo@premiumtravelclub.com.