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Privacy Policy

SWISSPORT GB LTD / ASPIRE AIRPORT LOUNGES / www.executivelounges.com
PRIVACY POLICY

1. WHAT IS THIS?

At Swissport GB Ltd T/A www.executivelounges.com / Aspire Airport Lounges (referred to as “we”, “us”, “our”) we take privacy seriously and we are committed to protecting it.

This policy explains when and why we and companies in our group (which means our subsidiaries, our ultimate holding company and its subsidiaries from time to time, as defined in section 1159 of the UK Companies Act 2006) collect personal information about individuals, how this information is used, the conditions under which it may be disclosed to others and how it is kept secure.

This policy may change from time to time so please check this page occasionally to ensure that you’re happy with any changes.
This policy was last updated on 24/05/2018. Please see changes to this policy: Archive Policy.

2. WHO WE ARE

We (Swissport GB Ltd T/A executivelounges.com / Aspire Airport Lounges registered in England and Wales under company number 509585) is the data controller in relation to the processing activities described below. This means that we decide why and how your personal information is processed.
Where this policy refers to “we”, “our” or “us” below, unless it mentions otherwise, it’s referring to the particular company that is the controller of your personal information.

3. HOW WE COLLECT YOUR PERSONAL INFORMATION

When you use this website, our products or services, the categories of information that we may collect about you are as follows:
This is information about you that you give to us by entering information via:
• our site (executivelounges.com);
• our mobile applications;
• social media platforms;
• corresponding with us by phone, email or otherwise,

and is provided entirely voluntarily. This includes information provided at the time of registering to use our site, making a purchase through our website, posting material or requesting further services, managing your account online (including accessing documentation and engaging in correspondence with us by phone, email or otherwise). We may also ask you for information when you report a problem with our site. If you complete any surveys that we request you complete for research purposes, we will collect information in such circumstances as well. The information you give us includes your name, the name of any potential lead passenger within a booking if you are making a purchase on behalf of someone else, your address, your email address and phone number, enquiry details and may include records of any correspondence and responses to any surveys.

Personal information we collect about you:

We may automatically collect the following information: details of transactions you carry out through the site, and your visits to our site, including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources you access. We may also automatically collect technical information, including anonymous data collected by the hosting server for statistical purposes, the Internet protocol (IP) address used to connect your computer or device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. Please see Cookies (https://www.executivelounges.com/cookie-policy) for further information. We may also collect any personal information which you allow to be shared that is part of your public profile or third party social network, type and version, time zone setting, browser plug-in types and versions, operating system and platform.

Personal information we may receive from other sources:

We obtain certain personal information about you from sources outside of our business for customer service reasons which may include our group companies or other third party companies. We offer some of our services on or through other websites and the personal information that you provide to those sites may be sent to us in order to deliver the service. The personal information we receive from third party sources is your name, your booking reference number or other transactional identifier, the date on which you used or will use our service, your email address, the reason for travel and the number of guests that wish to use or have used our service. The third parties that may send us personal information about you are as follows:

Source of personal information

Privacy policy

Brand/business name

The categories of personal information we obtain from these sources

Each Collinson Group company

https://www.prioritypass.com/en/privacy-policy

Priority Pass, LoungePass

Your Name, The date which you used our service or plan to use our service

Holiday Extras Limited

https://www.holidayextras.co.uk/privacy.html

Holiday Extras

Your Name, Your booking reference number, The date which you used our service or plan to use our service

Loungebuddy

https://www.loungebuddy.co.uk/privacy-policy

Loungebuddy

Your Name, Your booking reference number, The date which you used our service or plan to use our service

Birmingham Airport

https://www.birminghamairport.co.uk/privacy-policy-and-cookies/

 

Birmingham Airport

Your Name, Your booking reference number, The date which you used our service or plan to use our service

Liverpool Airport Limited

https://www.liverpoolairport.com/privacy-policy/

Liverpool John Lennon Airport

Your Name, Your booking reference number, The date which you used our service or plan to use our service

Edinburgh Airport Limited

https://www.edinburghairport.com/help/policies/privacy-notice

Edinburgh Airport

Your Name, Your booking reference number, The date which you used our service or plan to use our service

Bristol Airport Limited

https://www.bristolairport.co.uk/privacy-policy

Bristol Airport

Your Name, Your booking reference number, The date which you used our service or plan to use our service

TUI UK Limited

https://www.crystalski.co.uk/our-policies/privacy-policy/

Crystal Ski Holidays

Your Name, Your booking reference number, The date which you used our service or plan to use our service

DragonPass International Ltd

https://en.dragonpass.com.cn/info/privacypolicy

DragonPass

Your Name, Your membership number, The date which you used our service or plan to use our service


4. HOW WE USE YOUR PERSONAL INFORMATION

The purposes for which we use your information and the legal basis under data protection laws on which we rely to do this are explained below.

Where you have provided CONSENT

We may use and process your personal information where you have consented for us to do so for the following purposes:
• contact you via email providing marketing information about our goods and services if you (i) register for an account with us online and indicate that you would like to receive such marketing from us; (ii) sign up to our newsletter emails via our website or other medium where available; or (iii) when you refresh your marketing preferences when responding to a request from us to do so;

You may withdraw your consent for us to use your information in any of these ways at any time. Please see the ‘Withdrawing your consent’ section for further details.

Where there is a LEGITIMATE INTEREST

We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, or that of a third party, for the following purposes:

• for marketing activities (other than where we rely on your consent to contact you by email or text with information about our products and services or share your details with third parties to do the same, as explained above);

• for analysis to inform our marketing strategy, and to enhance and personalise your customer experience (including to improve the recommendations we make to you on our website);

• to correspond or communicate with you;

• to verify the accuracy of data that we hold about you and create a better understanding of you as a customer;

• for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;

• for prevention of fraud and other criminal activities;

• to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);

• to assess and improve our service to customers through recordings of any calls with our contact centres;

• for the management of queries, complaints, or claims; and

• for the establishment and defence of our legal rights.

Where there is a LEGAL REQUIREMENT

We will use your personal information to comply with our legal obligations: (i) to assist Border Force or other public authority or criminal investigation body; (ii) to identify you when you contact us; and/or (iii) to verify the accuracy of data we hold about you;

Where it is required to complete a CONTRACT

We may use and process your personal information where we have supplied you (or continue to supply you) with any of our products and services, where we have arranged for the supply of another company’s products or services to you, or where you are in discussions with us about any new product or service. We will use this information in connection with the contract for the supply of our products and services when it is needed to carry out that contract with you or for you to enter into it. Please see Personal Information We Collect About you in section 3 or details of the types of personal information we process for these purposes.

5. DATA ANONYMISATION AND USE OF AGGREGATED INFORMATION

Your information may be converted into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from it. Aggregated data cannot be linked back to you as a natural person. We may use this data for analytical and research purposes.
For more information on how we use cookies and how to switch them off on your device, please visit our Cookie Policy https://www.executivelounges.com/cookie-policy and our section on Cookies below.

6. OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION

Group companies

We may share your information with other companies within Swissport group. They may use your personal information in the ways set out in ‘How we use your personal information’ section, in connection with the products and/or services that complement our own range of products and/or services. The purpose of us sharing your details with any one of our group of companies is in order to carry out their obligations arising from any contracts you have entered into with them.

These third party product providers may share your information with us, which we will use in accordance with this policy.

Please see Schedule 1 at the end of this policy for the details of our group companies with whom we may share your personal information.

Our suppliers and service providers

We may disclose your information to our third party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include cloud service providers (such as hosting and email management), advertising agencies and administrative services.

When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.

Third parties who provide products and services

We work closely with various third parties to bring you a range of products and services that are complementary to those that we provide. In particular, we may offer third party Lounge access products

When you enquire about or purchase one or more of these products or services through us, the relevant third party may use your details to provide you with information and carry out their obligations arising from any contracts you have entered into with them.

These third party product providers may share your information with us, which we will use in accordance with this policy.

Credit/debit card payment processors
When you purchase any products or services online via our website, your credit/debit card payment is processed by a third party payment processor, who specialises in the secure online capture and processing of credit/debit card transactions. If you have any questions regarding secure transactions, please contact us using the details at the end of this policy.

Customer satisfaction surveys and review collation

As customer satisfaction is important to us, we may ask a third party research company to contact you for the sole purpose of gathering general information and specific information relating to us and our products and services. This includes but is not limited to Liquid New Media Limited T/A www.reviews.co.uk (whose privacy policy can be found here: https://www.reviews.co.uk/front/user-privacy-policy), TripAdvisor.co.uk (whose privacy policy can be found here: https://tripadvisor.mediaroom.com/UK-privacy-policy)

Other ways we may share your personal information


We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal information if we’re under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers. We will always take steps with the aim of ensuring that your privacy rights continue to be protected.

7. WHERE WE STORE YOUR PERSONAL INFORMATION

Some information that you provide to us, such as your name, booking reference number and destination, may be transferred to countries outside the European Economic Area (EEA). By way of example, this may happen where any of our Group companies are incorporated in a country outside of the EEA or if any of our servers or those of our third party service providers are from time to time located in a country outside of the EEA. These countries may not have similar data protection laws to the UK.
If we transfer your information outside of the EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy. These steps include imposing contractual obligations on the recipient of your personal information or ensuring that the recipients are subscribed to ‘international frameworks’ that aim to ensure adequate protection. Please contact us using the details at the end of this policy for more information about the protections that we put in place and to obtain a copy of the relevant documents.
If you use our services whilst you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.

8. HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR

If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We do not retain personal information in an identifiable format for longer than is necessary.

We may need your personal information to establish, bring or defend legal and / or financial claims. For this purpose, we will always retain your personal information for 7 years after the date it is no longer needed by us for any of the purposes listed under How we use your personal information (section 4) above. The only exceptions to this are where:

• the law requires us to hold your personal information for a longer period, or delete it sooner;
• you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law; or
• in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.

9. SECURITY AND LINKS TO OTHER SITES

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our website and any transmission is at your own risk. Once we have received your personal information, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.
Where we have given (or where you have chosen) a password which enables you to access an account, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Our website may contain links to other websites run by other organisations. This policy does not apply to those other websites‚ so we encourage you to read their privacy statements. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links that we provide. In addition, if you linked to our website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.

10. COOKIES

Like many other websites, our website uses cookies (including Google Analytics cookies to obtain an overall view of visitor habits and visitor volumes to our website). 'Cookies' are small pieces of information sent to your computer or device and stored on its hard drive to allow our websites to recognise you when you visit.

It is possible to switch off cookies by setting your browser preferences. For more information on how we use cookies and how to switch them off on your device, please visit our Cookies Policy (https://www.executivelounges.com/cookie-policy).

11. OUR MARKETING

We may collect your preferences to receive marketing information directly from us by email or telephone in the following ways:

• if you register an account with us online, we will ask you if you would like to provide your consent to receive marketing information directly from us; or
• if you make a sales enquiry or place an order we may contact you with marketing information in the ways mentioned in the notices presented to you, except where you indicate you would prefer otherwise.

If you do not complete a purchase and have indicated that you would like to receive marketing information from us, we may send a reminder to you about your incomplete purchase.

From time to time, we may ask you to refresh your marketing preferences by asking you to confirm that you consent to continue receiving marketing information from us.

We may contact you with marketing information by email or with targeted advertising delivered online through social media and platforms operated by other companies by using your personal information, or use your personal information to tailor marketing to improve its relevance to you, unless you object.

12. YOUR RIGHTS

You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either (i) the date that we have confirmed your identity or (ii) where we do not need to do this because we already have this information, from the date we received your request.

• Accessing your personal information

You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

• Correcting and updating your personal information

The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you.

In the meantime, if you change your name or email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us in any of the details described at the end of this policy.

• Withdrawing your consent

Where we rely on your consent as the legal basis for processing your personal information, as set out under How we use your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this policy. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can do so using our unsubscribe tool. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.

• Objecting to our use of your personal information and automated decisions made about you

Where we rely on your legitimate business interests as the legal basis for processing your personal information for any purpose(s), as out under How we use your personal information (section 4) above, you may object to us using your personal information for these purposes by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.
You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use our unsubscribe tool.

• Erasing your personal information or restricting its processing

In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.

You may also ask us to restrict processing your personal information where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. In these situations we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.

• Transferring your personal information in a structured data file (“data portability”)

Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under How we use your personal information (section 4) above, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine readable form, such as a CSV file.

You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

• Complaining to the UK data protection regulator

You have the right to complain to the Information Commissioner’s Office (ICO) if you are concerned about the way we have processed your personal information. Please visit the ICO’s website https://ico.org.uk/ for further details.

13. CHANGES TO THIS POLICY

We may review this policy from time to time and any changes will be notified to you by posting an updated version on our website and/or by contacting you by email. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on our website, whichever is the earlier. We recommend you regularly check for changes and review this policy whenever you visit our website. If you do not agree with any aspect of the updated policy you must immediately notify us and cease using our services.

14. CONTACT US

Our head of legal matters is Jenny Porter (Head of Legal UK & Ireland). Please direct any queries about this policy or about the way we process your personal information to our head of legal using our contact details below.

If you wish to write to us, please write to the address given at the start of this policy.

Our email address for data protection queries is customerrelations@executivelounges.com

If you would prefer to speak to us by phone, please call +44 (0) 161 694 7220.


SCHEDULE 1 - GROUP OF COMPANIES

Swissport Group Company

Registered Address

Registration Number

Swissport GB Ltd

Swissport House, Hampton Court, Manor Park, Runcorn, Cheshire, United Kingdom, WA71TT

GB509585

Swissport GB T/A Aspire Airport Lounges

Swissport House, Hampton Court, Manor Park, Runcorn, Cheshire, United Kingdom, WA71TT

GB509585

Swissport GB T/A Executivelounges.com

Swissport House, Hampton Court, Manor Park, Runcorn, Cheshire, United Kingdom, WA71TT

GB509585

Swissport International Ltd

P.O. Box CH-8058 Zurich-Airport

CH02030076675

Swissport Canada Inc.

100, boulevard Alexis-Nihon Suite 400 Montreal QC H4M 2N9 Canada

1056059-6

Swissport Finland OY

Rahtikuja 1 01530 VANTAA

2420280-3

Swissport Denmark AS

c/o Terminal 2 Københavns Lufthavn 1, 2770 Kastrup

20566981

Swissport Nederland BV

STRAWINSKYLAAN 1431, 1077XX, AMSTERDAM,

33291389

 

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