This Website https://barclays.dragonpasstraveller.com/portalserver/traveller/index (the "Service") is operated by Lifestyle Services Group Limited (“LSG”), with mailing address of PO Box 98, Blyth, NE24 9DL, a member of the Assurant, Inc. group of companies (hereinafter, “We”, “Us”, “Our” or “Company”). LSG is the data controller of your Personal Information in the context of the Service.
This Privacy Notice (“Notice”) describes how We will process and protect personal information relating to an identified or identifiable individual (“Personal Information”) when you use the Service, which allows users to create an account, update your contact details and communication preferences, search for airport lounges, restaurants, and spas, view lounge usage history and number of visits, register and update payment card details, purchase additional lounge visits, reset your password and contact customer support, and applies to your use of the Service. We also use the Personal Information to provide services to you, to communicate with you, and to track usage of the Service and Our products and services. Your Personal Information shall be held and used in accordance with applicable legislation relating to the protection of Personal Information (the “Applicable Law”). Your Personal Information will be shared with Our service providers (e.g., airport lounges), some of which are located outside the EEA and are not subject to an adequacy decision of the European Commission.
This Notice applies to the Service only and does not necessarily reflect practices with respect to information gathered through other services We offer or websites We operate or the collection of information through off-line means. To review the privacy practices of those other services, please refer to the policies provided in association with each.
1. Personal Information We Collect
We collect your Personal Information in the following situations:
1.1 Create an Account
1.2 When you Submit a Payment
We collect Personal Information from you when you make a payment (for example, when you purchase additional visits). We ask you to provide Us with payment details: cardholder name, payment card number, CVC, and expiry date.
1.3 When you communicate with Us or contact Us for Customer Support
When you contact Our customer support team (for example, when you enquire about the status of your account), We will collect information that you provide to Us in your communications (such as the query or issue that you have raised).
1.4 When you access the Service
2. Purposes and Legal Basis for the Processing of your Personal Information
We process your Personal Information for the following purposes:
- To fulfil a contract, or take steps linked to a contract: this is relevant where you have entered into a service contract with Us, where you can access airport lounges. This includes:
- providing the Service
- verifying your identity
- taking payment from you
- making reimbursement payments to you
- communicating with you
- As required by Us to conduct Our business and pursue Our legitimate interests, in particular:
- We will use your Personal Information to provide the Service and other products and services that you have requested, and respond to any comments or complaints you may send Us
- We monitor use of the Service, and use your Personal Information to help Us to track and analyse preferences and trends, evaluate possible new features, functionality and services, and improve Our Service
- We use Personal Information to help Us recognize you on the Service, improve your experience, increase security of Our networks and systems, and measure use and effectiveness of Our Service
- We use Personal Information you provide to investigate complaints received from you or from others, about the Service or our products and services. We also use this Personal Information to track potential issues (for example, issues with fulfilment of services) and trends to better serve you
- We use Personal Information to make decisions about, and to effect, reorganizations or sales of all or part of Our business
- We monitor customer accounts to prevent, investigate and/or report fraud, misrepresentation, or crime, in accordance with Applicable Law
- We will use Personal Information in connection with legal claims, compliance, regulatory and investigative purposes (for example, theft and fraud investigations) as necessary (including disclosure of such information in connection with legal process or litigation)
- We use Personal Information of some individuals to invite them to take part in market research and customer surveys
- We use Personal Information to send you information about Assurant products and services, such as customer experience surveys (where your consent is not required)
- Where you give Us consent:
- We place cookies and use similar technologies in accordance with Our Cookie Notice and the information provided to you when those technologies are used
- On other occasions where We ask you for consent, We will use the data for the purpose which We explain at that time
- For purposes which are required by law:
- In response to requests by government or law enforcement authorities conducting an investigation
- Responding to complaints where We are under a legal or regulatory obligation to adhere to a complaints handling procedure
- Withdrawing consent
- Wherever We rely on your consent, you will always be able to withdraw that consent, although We may have other legal grounds for processing your data for other purposes, such as those set out above. Where you have given Us your consent, you can withdraw it by using the mechanism described to you at the time that your consent was obtained, or by contacting Us
3. Disclosure of Personal Information
3.1 Disclosure to Our Service Providers and Partners
We employ third party companies and individuals to facilitate the Service (for example, customer support, customer communications, audit, application or database hosting, development, logistics, payment processing, and for fraud detection and prevention purposes. These third parties have limited access to your Personal Information to perform these tasks on Our behalf and are obligated to Us. The personnel of such third parties who use your Personal Information is limited to those individuals which are authorized to do so on a need-to-know basis and as necessary to provide these business services to Us. We also share your Personal Information with your bank (for example – to validate your eligibility for the product or service). To provide the Service, we may share your name, contact details (including post code, email address and mobile number), and usage information.
3.2 Disclosure to Public Authorities
We may disclose your Personal Information if required for the purposes above, if mandated by law or if required for the legal protection of Our legitimate interests in compliance with Applicable Law.
3.3 Other Categories of Recipients
We may also disclose your Personal Information, usage information, and other information about you to parties acquiring part or all of Our assets, as well as to attorneys and consultants. Also, if any bankruptcy or reorganization proceeding is brought by or against Us, your Personal Information may be considered a company asset that may be sold or transferred to third parties.
4. Where your Data is Processed
In providing the Service, your Personal Information may be processed both inside and outside the European Economic Area (“EEA”) by Our service providers (such as airport lounges), subject to contractual restrictions regarding confidentiality and security in accordance with applicable data protection laws and regulations.
Your use of the Service (for example – when you access airport lounges outside the EEA) may involve transfers outside the EEA to the UK. For example, the airport lounge you visit may process your Personal Information, such as your membership ID, upon entry to the lounge.
Where Personal Information is processed outside the EEA in a country that is not subject to an adequacy decision by the EU Commission, it is adequately protected by European Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor’s Processor Binding Corporate Rules. If you would like more information on the relevant transfer mechanism or additional information on the transfers, please address these requests to Us.
5. Your Choices and Rights
In some countries, you have the right to request access to, correction of, and deletion of your Personal Information, and to restrict the processing of your Personal Information, under Applicable Law. You also have the right to request a structured commonly-used and machine-readable copy of Personal Information that you have provided to Us for a contract or with your consent, and to ask Us to transmit (port) this Personal Information to another controller.
You may also object to Our processing of Personal Information in certain circumstances (in particular, where we don't need to process the information to meet a contractual or other legal requirement, or where we are using the data for customer experience surveying purposes (see section 2)
You can exercise any of your rights by contacting Us. In order to safeguard your Personal Information from unauthorized access, We may ask that you provide sufficient information to identify yourself prior to providing access to your Personal Information.
In certain situations, and subject to Applicable Law, We may not be able or obliged to comply with part or all of your individual requests. For example, We may not comply with an access request if doing so would reveal Personal Information about another person, or comply with a deletion request relating to information which We are required by law to keep or have compelling legitimate interests in keeping.Please note that we have the right to refuse requests which are manifestly unfounded or excessive (for example, due to their repetitive character).
If you have unresolved concerns, you have the right to complain to an EU data protection authority ('supervisory authority') where you live, work or where you believe a breach may have occurred.
To provide certain parts of the Service (for example - Creating an Account and Making Payment), the provision of Personal Information is mandatory: If relevant data is not provided, then We will not be able to provide certain parts of the Service. [All other provision of your information is optional. If you do not wish to provide optional information, then your experience on our website may be less personalized.
6. Communications from Us
We communicate with you through email and SMS. We will send you service-related communications (for example – information about your usage of the service), customer satisfaction and market research surveys.
You can change your email and contact preferences through this website or by contacting Customer Service or contact Us. Please be aware that you cannot opt-out of receiving service-related messages from Us.
7. Data Retention
We typically delete logs and other backup information through the deletion process within 30 days of your last activity, except as noted in Section 5. Where we process Personal Information in connection with performing a contract, we keep the data for 6 years from your last interaction with us.
8. Information Security
We have implemented safeguards designed to protect your Personal Information in accordance with industry standards.
We have measures in place to restrict access to Personal Information to those individuals whom We know have a valid business purpose to have access to such data. We maintain physical, electronic and procedural safeguards. We follow generally accepted standards designed to protect the Personal Information submitted to Us, both during transmission and once We receive it. We require those who provide services for Us and to whom We provide Personal Information collected through the Service to keep such information secure and confidential. However, no method of transmission over the Internet or method of electronic storage is totally secure. Therefore, We cannot guarantee its absolute security.
9. Important Information
9.1 Minimum age
We do not knowingly collect Personal Information from anyone under the age of 18. You must be at least 18 years of age to use the Service.
9.2 Changes to this Notice
We may update this Notice from time to time. If We make any material changes to Our Notice, We will notify you by email or by means of a notice through the Service, or by other means prior to the change becoming effective, so that you may review the changes before you continue to use the Service. Please review changes carefully.
9.3 Contact Us
For customer enquiries, please contact us at: LSG, PO Box 98, Blyth, NE24 9DL, or call us.
We welcome your questions or comments regarding this Notice. Please write to LSG (an Assurant group company), Data Protection Officer, PO Box 98, Blyth, NE24 9DL, or send Us an email at email@example.com. You may also write to Us at Assurant Privacy Office, Post Office Box 979047, Miami, FL 33197-9047, USA.
Effective date: 24/05/2018