Guestlogix Privacy Policy

Date: August 9, 2019

Thank you for your interest in Guestlogix. Whether you are a traveler, a subscriber to our platform or a merchant operating through our marketplace services, we adhere to three fundamental privacy principles when we process your personal data.

• We use data ethically to empower airlines to provide travelers with more discoveries, more experiences and more connections through personalized offers. 

• We are respectful of the users of our services when we use data for our own business purposes and provide users with meaningful choices.

• We use service providers to power our solutions and operate our business. We expect them to meet our high standards.

Read through the questions below to find out more information on our practices regarding processing of personal data collected through our website (www.guestlogix.com), our mobile app services, and our airline platform.

• Who is Guestlogix and how do we work?

Guestlogix Inc. and its subsidiaries Guestlogix America Inc., Guestlogix UK Limited and Guestlogix Asia Limited (collectively referred to as “Guestlogix” or “we”) transform the way travelers purchased onboard, to now connecting the entire travel ecosystem with a single platform that enhances travel inflight, through destination and back home. Learn more about how Guestlogix works here.

• Does this Privacy Policy apply to the use of personal data by airlines?

This Privacy Policy explains Guestlogix’s practices with respect to personal data collected through our website, our mobile app services, and our airline platform. Our airline partners have their own privacy policies. Please refer to your airline’s privacy policy for information on their practices with respect to your personal data.

• Does this Privacy Policy apply to the use of personal data by merchants?

Our mobile app services allow travelers to make purchases from or make reservations with third-party merchants. For example, travelers may book a hotel or purchase tickets to an event. When travelers make these purchases or bookings, we share information with the merchant in order to facilitate the transaction. 

• What personal data do we collect?

Travelers: If you are a traveler, we may collect the following types of data

App registration data

When you register for an account, we collect information such as your name, email address, mailing address, birth date, and gender. We may collect this information directly from you or from your airline if our mobile app services are integrated into your airline’s mobile app. We also collect the password that you set as well as how long you have been a registered user of our mobile app services.

App usage data

When you use our mobile app services, we automatically collect information about your interactions with our mobile services. This type of data includes the date and time of your use, the content that you visited, and products or services that you have added to your wish list.

Trip data

We may collect information about your travel details or travel interests if you provide them to us. In some cases, your airline may provide this information to us. 

Transaction data

If you make a booking or purchase through our mobile app services, we collect information from you to process your transaction including your booking dates and preferences you include in your request.

Payment card data

We use third party payment processors to process transactions. We may also offer you the option to store your payment card data for future purchases.

Notifications and service request data

We also collect information relating to booking and purchase confirmation as well as your service requests relating to your use of the mobile app and your purchases and bookings.

App technical data

This data is collected about your device when using our mobile app services. This data includes mobile application version, operating system, IP address, network connection type (e.g. WiFi, LTE, 3G), general location, unique device ID, and device preferences (e.g. language).

Voluntary mobile data

In addition to technical data that is collected automatically, we may collect additional information if you permit us to do so in order to allow you to personalize your interactions with our mobile services. This data could include your precise location and other mobile app permissions that you provide to us.

Traveler marketing data

We collect information relating to your marketing preferences, such as whether you would like to be notified of offers by your airline and the merchants offering products and services through our mobile app services.

Airlines and merchants: If you are an employee of an airline subscriber to our platform or a merchant, we may collect the following types of data.

Airline and merchant registration data

Our platform allows airlines to access data about how travelers are using our mobile app services and to customize the mobile app services. In order to access the platform, airline employees require an account. In order for merchants to offer their products and services through the mobile app services, we must create an account for merchants so that we can integrate their offerings with our mobile app services. We collect basic information such as name, email address, and other employment related information in order to create an account. 

Platform usage data

When an airline employee uses our mobile app services, we automatically collect information about the employee’s interactions with our platform services. These types of data include the date and time of access and the features used. 

Platform technical data

We collect data about the devices used to access our platform, including operating system, IP address, network connection type, general location, unique device ID, and device preferences (e.g. language).

Website visitors: If you are visiting our website, we may collect the following types of data.

Communications data

We may offer you the option to communicate with us through our website, register for a demo or to download a whitepaper. We may collect your name, position and contact information and other information relevant to your request.

Website usage data

When you use our website, we automatically collect information about your interactions with our webpages. This type of data includes the date and time of access and the pages visited. 

Website technical data

We collect data about the devices used to access our website, including operating system, IP address, network connection type, general location, unique device ID, and device preferences (e.g. language). Please also see our Cookies and Interest-Based Ads Policy.

• What do we use personal data for?

Travelers: If you are a traveler, we prepared this chart to help travelers understand the purposes for which we use and process your personal data. 

Airlines and merchants

Website visitors

• What are data analytics and insights?

Data analytics involves processing elements of personal data and other information to derive information about the users of our mobile app services, our platform for airlines and our website and how travelers respond to merchant offers. Data analytics inform decisions about how to improve our services or develop new services. When we perform data analytics, we are interested in trends rather than how an individual person uses our services in particular. For example, we may want to understand when travelers are most interested in lounge passes or how far in advance of their travel date that they want to see excursion opportunities.

We may also gather insights from personal data that we collect. When we gather insights, we are analyzing how we can provide a better and more personalized experience for the individual traveler. For example, we may use data collected about a traveler to avoid providing the traveler with lounge pass offers if we already know the traveler has access to the lounge or we may provide the traveler with a customized selection of excursions based on that traveler’s past interests. 

We may be assisted by machine learning algorithms when we perform data analytics and gather insights. If you believe that the personalization of your experience through our mobile app services is unfair or inaccurate, please provide us with your feedback.

• What information do we share with airlines and merchants?

Airlines

We share app account registration data, app usage data, and trip data with the airline using our mobile app services to power their customer’s experiences. We also share data analytics and insights regarding a traveler’s use of the mobile app services with the airline using our mobile app services to power their customer’s experiences. Please see your airline’s privacy policy for how they use this information. 

Merchants

We share transaction data with merchants. The specific types of transaction data depend on the merchant and the product or service that a traveler purchases. For example, for hotel accommodation bookings, we will share a traveler’s requested arrival and departure dates and other information relevant to making a booking as well as the traveler’s name and address. If a payment card is required to make a reservation, we will provide the traveler’s payment card data. In the case of other purchases, it may only be necessary to provide the merchant with the traveler’s email address for a purchase confirmation. 

• Who else do we share personal data with?

Like most businesses, we use third party service providers to provide our mobile app services power our airline platform, to operate our website, to assist us in understanding how individuals use our mobile app services, our platform and our website, and to assist us in delivering online advertising, including interest-based advertising. Even though we use a service provider to process your personal data, this does not mean that that service provider has access to your personal data in a human readable form.

Our service providers are required to protect your personal data. We only authorize service providers to process your personal data for the purposes of assisting us in our business, unless they have a direct relationship with you.

We have prepared a table that lists the main service providers who assist us as of the date of this Privacy Policy. Please also see our Cookie and Interest-Based Advertising Policy for third parties that assist us in website analytics and interest-based advertising.

• Where is personal data located?

Our main mobile app services and airline platform are hosted in data centres in Canada and the United States. Our website is hosted in the United States. However, due to the nature of the Internet and the fact that travelers may wish to use the app from various locations around the world while they are travelling, we may use data centre services and other information technology systems worldwide in order to deliver our services. In addition, depending on your location, the location of your airline or the merchant that you purchase a product or service from, your personal data may be transferred to other countries.

• What rights or choices do you have?

Your rights and choices depend on whether you are a traveler using our mobile app services, you are a visitor to our website, or you are an employee of one of our airline business partners or of a merchant. The following rights and choices apply to users of our mobile app services and our website. If you are an employee of an airline partner or a merchant, please make your request through your employer.

Marketing Choices 

You can opt-out of receiving promotional emails, text messages, telephone calls, and mailings by modifying your promotional preferences in your account profile management section, adjusting your text and notification preferences in your mobile device's settings, or by following the opt-out instructions in the promotional emails we send you. You can also contact us.

Access and Correction 

You have the right to request access to the personal information that we have collected about you. If we have recorded incorrect information about you, you can ask that we correct or rectify that information. To make an access or correction request, contact us.

Deletion and Erasure 

You may request that we delete or erase your personal information, unless we are legally permitted or required your personal information such as: (i) if there is an outstanding order, complaint, or dispute; (ii) to fulfill legal, tax, audit, and accounting obligations or (iii) if we anonymize it. To make a deletion or erasure request, contact us.

Third Party Analytics Providers

You can opt-out of Google Analytics by installing the Google Analytics opt-out browser add on. This opt-out prevents sharing information with Google Analytics but does not affect other use of your Usage Information by us. 

From time to time, we may use service providers to display advertising to you that is based on your online activities across websites and online applications. You can click the AdChoices icon or visit www.youradchoices.ca (Canadian visitors), www.aboutads.info (U.S. visitors), or www.youradchoices.com (European visitors) or information on interest-based advertising or to opt-out of receiving interest-based advertising using your personal information.  You can also visit www.networkadvertising.org/choices for opt-out options for Network Advertising Initiative member companies.

• How long do we retain personal information?

We retain your personal information for no longer than is reasonably necessary for the purposes for which we collected it or as required by law. How long we keep your personal information depends on the type of information and the purpose for collection.

If you have created an account using our mobile app services, app registration data, app usage data, trip data, transaction data, notifications and service request data and traveler marketing data for as long as your account remains open.  For other personal data, including if you are a visitor to our website or a user of our airline platform, the criteria we use to determine the retention period for certain categories of personal is as follows:

• - whether the data is still relevant for the purposes for which we collected it;
• - whether there are contractual obligations that exist that require us to retain the data for period of time;
• - whether there is any ongoing legal claim that relates to any product or experienced purchased by you from a merchant, or that is otherwise related to your relationship with us; and
• - whether any applicable law, statute, or regulation allows for a specific retention period.
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• How do we secure my personal information?

Security of your personal information is a shared responsibility. You should password protect your mobile device if you are using our mobile app services. We or your airline may also offer you the option of using a password for your mobile app. 

You should be careful if you receive unexpected emails from senders. We will never ask you for your payment card or other financial information by email or text message. 

We use (and we require our service providers to use) physical, technical and organizational security measures designed to help protect the security of the personal information we collect. We limit access to those employees, contractors, agents and merchants with a need to know. However, please note that no system is ever completely secure. 

We are not responsible for the security practices of merchants or your airline. You should review the privacy policy of your airline and for the merchant from whom you are purchasing a product or experience for information on their privacy and security practices.

• Do we collect personal information from children?

Our website, mobile app services and platform are intended to be used by individuals who have reached the age of majority in their country of residence. 

If you are a traveler that is a parent or legal guardian of a child, you may enter personal data about your child accompanying you on a trip in the mobile app services. By doing so, you consent to us using this personal data in accordance with this Privacy Policy. 

If you are a parent or legal guardian of a child who is under the age of 13 and believe we have collected personal data directly from your child under the age of 13, please contact us with details and we will investigate and use reasonable efforts to identify and delete that personal data.

• Contacting us with questions, comments or concerns

We welcome your questions, comments and concerns about privacy. You can write to our Privacy Officer in writing at Guestlogix 30 St. Clair Ave. West, Suite 901, Toronto, Ontario M4V 3A1 or privacy@guestlogix.com. 

• California Privacy Rights

We do not share your personal data with third parties for their own direct marketing purposes without your consent. If you are under 18 years old in California, in certain circumstances, you may request and obtain removal of personal data shared by you and posted on our Website or App if we have made that functionality available. To make any request pursuant to California privacy law, please contact us at privacy@guestlogix.com.