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: email@example.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:
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.
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.
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.
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:
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:
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.
|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:
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).
|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.
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 firstname.lastname@example.org.
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|
We will retain your Member Data based on the following the criteria:
|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.
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 email@example.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 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 firstname.lastname@example.org.