Partner Solutions Canada Privacy Notice

Effective Date: April 1, 2021 

This Privacy Notice explains how we collect, use, disclose, retain, destruct and otherwise process personal information in connection with our services. This Privacy Notice is not, however, a contract and does not create any legal rights or obligations. 

Who We Are: cxLoyalty is a leading provider of loyalty technology services with rewards content in relevant categories including travel, gift cards and merchandise and world-class personalized customer experience. When we use the terms “cxLoyalty”, “we”, “us”, or “our” in this Privacy Notice, we are referring to cxLoyalty Global Holdings, Inc. and its subsidiaries. 

Our Services: When we use the term “services”, we are referring to our Canada facing Internet websites and Canada-facing programs we offer and manage on our own behalf, including: 

•  Our corporate websites that link to this Privacy Notice; and 
•  Our travel services. 

This Privacy Notice does not cover or address: 

• Offerings we make available in other countries; 
• Offerings that we provide solely on behalf of our clients; or 
• Personal information and privacy practices relating to job applicants, employees and other cxLoyalty personnel. 

For offerings provided on behalf of our clients, please refer to the privacy notice of the client with which you have a relationship for information on how they engage service providers, like us, to process personal information on their behalf. 

What is Personal Information? 

When we use the term “personal information” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. It does not include aggregated or deidentified information that is maintained in a form that is not capable of being associated with or reasonably linked to you. 

Chief Privacy Officer and Privacy Authorities

Responsibility: We are the responsible controller for the processing of the Personal Information we collect on our behalf. We have appointed a Chief Privacy Officer (the “CPO”) who ensures that cxLoyalty complies with privacy laws applicable in Canada. 

Contact details of responsible controller:
cxLoyalty
Data Privacy Office
77 North Water Street, Norwalk, CT 06854 USA
1-844-300-4222 

CPO Contact Details: cxLoyalt
Chief Privacy Officer
77 North Water Street, Norwalk, CT 06854
USA Phone: 1-844-300-4222
Email: privacy@cxloyalty.com 

Privacy Authorities: If you submit your Personal Information when you are in Canada directly to us you are entitled to file a complaint at any time, depending on your location, to the Access to Information Commission (www.cai.gouv.qc.ca) if you are in Quebec, the Office of the Information and Privacy Commissioner of Alberta (https://www.oipc.ab.ca/) if you are in Alberta, the Office of the Information and Privacy Commissioner for British Columbia (www.oipc.bc.ca/) if you are in British Columbia or the Office of the Privacy Commissioner of Canada (https://www.priv.gc.ca/en) if you are elsewhere in Canada. 

We would however appreciate being able to answer your questions or discussing your issue with you before you contact such authority. We would appreciate if you would contact us first at privacy@cxloyalty.com. 

Our Collection and Use of Personal Information 

The personal information we collect, the way we collect it and how we use it will depend on how you are interacting with us and the type of services you use. 

Website & Online Services 

Collection of Personal Information 

As is true of most digital platforms, we and our third-party providers and partners collect certain personal information automatically when you visit or interact with our websites and other online services: 

• Log Data: Including your internet protocol (IP) address, operating system, browser type, browser ID, the URL you entered and the referring page/campaign, date/time of your visit, the time you spent on our services and any errors that may occur during your visit to our services. 
• Analytics Data: Including the electronic path you take to our services, through our services and when exiting our services, as well as your usage and activity on our services, such as the links, objects, products and benefits you view, click or otherwise interact with (also known as “Clickstream Data”). 
• Location Data: Including your general geographic location based on the Log Data we collect or more precise location when permitted by law. 
• Application Data: Some of our services offer mobile or browser applications to allow you to take advantage of our service offerings on the go and/or when visiting third-party websites and other online services. Certain of these applications also allow us to access more precise Location Data about you and collect information about your use and interactions with third- party websites and online services (including the products or services you are interested in or purchase) to better serve you. 

For information about our and our third-party providers and partners’ use of cookies and related technologies to collect information automatically on our online services, and the choices you may have in relation to those practices, please visit our Cookie Notice. 

In addition to the personal information we collect automatically, we also collect personal information directly from you through our websites and online services: 

• Newsletters and Email Communication: Many of our websites and online services provide you an opportunity to sign up for our newsletters and email communications by providing your email address. We use your email address to communicate with you about our services and exciting developments at cxLoyalty, which may include marketing communications. Please see the Your Communication Preferences section below for additional information about opting out of our marketing communications. 
• Contact Us: Our websites and online services provide individuals and representatives of prospective business customers and partners the ability to connect with us through an online web form that collects contact information (such as first and last name, email address, phone number, company name, and title with company), area(s) of interest or concern, and a custom message from you. We use this information to communicate with you in connection with your request, including corresponding with you about cxLoyalty’s services, offerings, customer service, business partnership opportunities or media inquiries. 

Although we often collect the personal information described above directly from you, we also collect this information through service providers and other third parties that collect it on our behalf, such as communications providers, analytics providers, website hosting providers and marketing providers. Please note that our systems may record personal information that you type into our websites and other online services even if you do not choose to submit it. 

Use of Personal Information 

We use the personal information we collect through our websites and other online services to: 

• Help to optimize your experience with our websites and other online services
• Administer and improve our websites and other online services
• Test different configurations of our websites and other online services
• Diagnose errors and problems with our websites and other online services
• Conduct research and analytics on visitor usage and activity trends relating to our websites and other online services
• Remember you and the choices you have made in relation to our services
• Connect you to the requests and transactions you make on our websites and other online services
• Identify how you use our websites and other online services, determine products/services that may be of interest to you and customize our personalized offerings and marketing efforts accordingly
• Provide you with news about products and services we offer
• Deliver marketing communications and advertisements based on your interests and interactions with us
• Assess the performance of marketing campaigns and facilitate remarketing efforts
• and Respond to your comments and questions and provide customer service.

Please note that we link the personal information we collect through our websites and online services with the other personal information that we collect about you and may use it for the purposes we describe in more detail in the other sections of this Privacy Notice. 

Surveys, Contest and Promotion Entries 

Collection of Personal Information 

From time to time we may provide you the opportunity to participate in surveys, contests and/or promotions. If you choose to participate, we will request personal information from you in connection with your entry, which typically includes: 

• Contact Information: Such as your full name, email address, mailing address, telephone number, company name and title. 
• Demographic Information: Such as your specific or approximate date of birth, age, gender or annual income. 
• Survey, Contest or Promotion Entry: Including any personal information you choose to provide in connection with your survey, contest or promotion entry, such as products/services of interest or your satisfaction with us. 

Although we often collect the personal information described above directly from you, we also collect this information through service providers and other third parties that collect it on our behalf, such as communications providers, analytics providers, survey, contest and promotion entry providers and marketing providers. 

Use of Personal Information 

We use the personal information we collect in connection with surveys, contests and promotions to: 

• Learn how we can improve your experience with our services
• Understand our customers and the users of our services, including the service configurations and products that may be of interest to our customers in the aggregate
• Conduct research and analytics on our customer base, users of our services, and the performance of us and our services
• Incorporate ideas from your responses into our business operations and customer service models
• Improve and customize our services and product offerings to address the needs and interests of our customers
• Develop new services and product offerings
• Contact you regarding your survey responses and announce contest and promotion winners
• Provide you with news about our business, as well as products and services we offer
• and Deliver marketing communications and advertisements based on your interests and interactions with us.

Unless noted otherwise in our initial request, we may link the personal information we collect through your contest, promotion and survey responses with the other personal information that we collect about you and for the purposes we describe in the other sections of this Privacy Notice. The survey, contest, or promotion request you receive may contain additional details about how any personal information you provide may be used or otherwise processed. 

Travel Services 

Scope of Travel Services 

Our travel services include (but are not limited to): 

• Bookings and savings for flights, hotels, rental cars, cruises and travel activities; 
• Rewards accrual and redemption on travel products made available through our services; and 
• Price guarantees, travel protection plans and insurance. 

Collection of Personal Information 

When you use and interact with our travel services, we collect personal information from you, our travel booking providers, travel partners, payment processors, service providers and other third parties who collect personal information on our behalf, which may include:

• Contact Information: Including your full name, email address, mailing address and telephone number. 
• Traveler Information: Including your travel companions’ names and relationships, as well as your and your travel companions’ full legal name, age, date of birth, sex, gender, travel loyalty program membership numbers, driver’s license number, passport number and passport details (such as expiry date, country of nationality and issuing country), special accommodations or restrictions and events that you report occurring during your travel. 
• Payment Information: Including payment status, billing address, billing phone number, credit/debit card name, number, expiry date and security code (CVV), and third-party payment identifiers and confirmations. 
• Flight Information: Including flight confirmation numbers, frequent flyer number, airline name, airline brand name, flight number, departure date & time, arrival date & time, flight origin, flight destination, flight duration, departure airport code, arrival airport code, and seat number.
• Hotel Information: Including hotel confirmation numbers, hotel membership number, hotel name, hotel chain, check-in date, check-out date, and number of guests. 
• Rental Car Information: Including rental car confirmation numbers, rental car membership number, rental car company, rental car, car pickup date & time, car drop-off date & time, car pickup location, and car drop-off location. 
• Cruise Information: Including cruise confirmation numbers, cruise line, cruise ship, cruise departure date & time, cruise arrival date & time, cruise departure location and cruise arrival location. 
• Travel Activity Information: Including travel activity confirmation number, travel activity name, travel activity description, travel activity start date, travel activity end date, and travel activity locations. 
• Coverage Information: Including the travel and activities covered by guarantees, protection plans and warranty extensions, the type and length of coverage provided, and claims made under the coverage. 
• Rewards Information: Including cash back, points and other rewards earned/redeemed, earning/redemption statements, rewards status, rewards expiry dates, rewards earning cap status, and transaction identifiers used to connect your transactions to you to provide the associated benefits and rewards. 
• Service Profile Information: Including flights, hotels, rental cars, cruises and travel activities of interest, favorite travel providers, recently viewed travel opportunities and our understanding of your preferences and interests. 
• Feedback Information: Including feedback and ratings you provide relating to our services, products and rewards. 

Use of Personal Information 

We use the personal information we collect in connection with our travel services to: 

• Provide and improve the services, offerings, travel opportunities and rewards that you request and we facilitate
• Communicate with you regarding our services, offerings, travel opportunities and rewards (including by sending you service-related emails)
• Determine your preferences and interests to better serve you
• Personalize your experience, including providing tailored promotions and marketing offers
• Determine your eligibility to travel and participate in travel activities, including fulfilling travel provider requirements
• Process payment for the services, offerings, travel opportunities and rewards that you request
• Facilitate your travel bookings with our travel booking providers, travel partners, service providers and other third parties
• Fulfill your travel itineraries in accordance with travel provider requirements
• Process claims available under your existing coverage
• Process the cash back, points and other rewards you earn and/or redeem
• Provide customer support relating to the services, offerings, travel opportunities and rewards
• Conduct research and analytics on our customer base, users of our services, and the performance of us and our services
• Improve and customize our services and travel offerings to address the needs and interests of our customers
• Audit transactions conducted in connection with our services
• and Investigate and prevent fraud in connection with your account and/or transactions.

Please note that we link the personal information we collect in connection with your travel services with the other personal information that we collect about you and may use it for the purposes we describe in more detail in the other sections of this Privacy Notice. 

Other Uses of Personal Information 

In addition to the uses identified above, we use the personal information we collect to: 

• Facilitate our day-to-day business operations, such as maintaining accounts and processing transactions
• Develop new products and services, and improve existing products and services
• Aggregate information we receive from you and third parties to help understand your needs, customize our services and offerings to you, and provide you better service
• Conduct research and analytics designed to understand our customer base and improve our products, services and customer experience
• Prevent, investigate or provide notice of fraud or unlawful or criminal activity
• Enforce and carry out contracts and agreements
• and Comply with legal obligations.

Retention 

We retain Personal Information for only as long as is reasonably necessary to fulfil the purpose for which it was collected, including for the purposes of satisfying any legal, accounting or reporting requirements and to assert or defend our legal rights. 

To determine the appropriate duration of the retention of your Personal Information, we consider the number, nature and sensitivity of the Personal Information, the potential risk level and the seriousness of the unauthorized use or disclosure of your Personal Information and if we can attain our objectives by other means, as well as the legal, regulatory, tax, accounting and other applicable obligations. 

Therefore, we retain your data for as long as you continue to use the product/service for the purposes explained above. When you cease your membership of the product/service, we will retain your Personal Information for as long as necessary to comply with our legal obligations, to resolve disputes and defend claims, as well as, for any additional purpose based on the choices you have made such as to receive marketing communications that you provided your consent to. In particular, we will retain call recordings, the data you supplied when joining the product, including complaints, claims (for insurance products) and any other Personal Information you supplied during the duration of your contract with us for your product/service for a period of up to 7 years from termination or expiry of your service in line with industry standards and Canada statutory limitation periods for the defence of contractual claims. 

For any questions about the retention of Personal Information, please contact cxLoyalty’s CPO, whose contact details are shown above. 

Accuracy 

We use reasonable efforts to ensure the accuracy of your Personal Information and that it is kept as complete and up to date as possible. We will not routinely update your Personal Information unless this is necessary. If you note any inaccuracies in our records or if your Personal Information changes, please immediately update such information in your online account, if any, or notify our CPO. 

Protection of Personal Information 

We are committed to protecting the confidentiality, integrity, availability and privacy of your Personal Information. We employ security safeguards that are in line with industry standards and which are reasonable considering the sensitivity of the Personal Information, including physical, electronic and organizational measures. 

Unfortunately, the transmission of information by Internet is not completely secure and we cannot guarantee the security of information transmitted by Internet. Such transmission by you is done at your own risk. Once we have received information from you, we will apply our security practices to try to prevent any unauthorized access, use and disclosure. 

We have entered into agreements and uses controls with our third-party service providers who have access to your Personal Information requiring that they use the information for the purpose received and protect your Personal Information in accordance with applicable laws and industry standards. 

Your Rights and How to Exercise Them 

You have various rights with respect to our use of your Personal Information: 

• Access: You have the right to request a copy of the Personal Information that we hold about you or to consult it. Access to your Personal Information is free of charge. In certain circumstances, for example, if the request is excessive or unfounded, we may charge administration fees for the transcript, reproduction or transmission of your Personal Information. We may also charge for additional copies. Before completing a request for access, we shall notify you if any fees are to be charged. We will generally answer any access requests within 30 days following the receipt of all of the required information. If we are unable to grant access, or if extra time is required to complete the request, we shall notify you in writing.
  
  However, we may not transmit some type of information to you due to exceptions provided by applicable law (for example, when cxLoyalty’s records contain information about other person, if the information was produced in a dispute settlement process, if the information was collected for the purposes of an investigation about the breach of an agreement or of applicable laws or if the information is covered by legal privilege). We will to the extent possible, delete the information that is not transmitted and shall grant access to the other information to you. If we are unable to grant access to the Personal Information to you, or to disclose it to you, we shall give an explanation, subject to restrictions. 
• Accuracy: We aim to keep your Personal Information accurate, current and complete. We invite you to update such information in your online account, if any, or to contact the CPO using the contact details given above to let us know if any of your Personal Information is inaccurate or changes, so we can keep your Personal Information up to date. 

• Complaints: If you believe that your data and Personal Information protection rights have been breached you have the right to lodge a complaint with the applicable privacy authority or to seek a remedy through the courts. 

You may exercise any of the above-mentioned rights at any time by contacting the CPO using the contact details above. 

Our Disclosure of Personal Information 

We disclose personal information in the following ways: 

• Within cxLoyalty: We are able to offer you the products and services we make available because of the hard work of the entire cxLoyalty team. cxLoyalty entities disclose personal information to other cxLoyalty entities for purposes and uses that are consistent with this Privacy Notice and applicable law. For example, the cxLoyalty entity providing our services to you may share personal information relating to transactions with another cxLoyalty entity that provides the system used to review available offerings and complete transactions for the services we are providing. 
• Business Partners: We often make our services available to customers and/or employees of our business partners. 
• Data Analytics Providers: We share personal information with data analytics providers who analyze statistics and trends relating to the usage of and activity relating to our services. These data analytics providers produce reports and make suggestions for our customer and business strategy based on the personal information and other information analyzed. 
• Affiliate Networks and Merchants: In order to facilitate your orders and provide you the rewards you are eligible to receive, we may disclose personal information to affiliate networks and merchants to enable them to fulfill your orders and identify which of their customers are connected to our services. For example, we often provide affiliate networks and merchants an online identifier showing that you were referred from our services to the affiliate network’s and/or merchant’s site and connecting your purchases to your rewards account. 
• Payment Processors and Online Payment Systems: We share personal information with payment processors, online payment system providers and other billing agents to process your payment for the services and products you order, as well as to provide refunds, cash back and/or rebate checks. 
• Transaction Fulfillment and Delivery Providers: We share personal information with transaction fulfillment and delivery providers in order to fulfill your transactions through our services and deliver the products and experiences that you order through our services.
• Insurance and Coverage Providers: We often engage insurance companies, financial institutions and other third parties to provide you with the guarantees, protection plans and extended warranties made available through our services. In order for these third parties to administer and service your coverage in connection with the services, we share personal information about you with them. 
• Marketing Partners: We coordinate and share personal information with our marketing partners, including advertisement networks, social networks, re-targeting partners and marketing communication providers, in order to communicate with you about our products and services and market our products and services to you. We may also share aggregated demographic information with third parties interested in advertising on our online services to assist them in understanding the audience they would be reaching, but this information is not designed to be identifiable to a specific individual. 
• Customer Service and Communication Providers: We share personal information with third parties who assist us in providing our customer service experience and facilitating our communications with you, including third parties that provide call center, email and chat support services 
• Other Service Providers: In addition to the third parties identified above, we engage other third parties to perform certain functions on our behalf in connection with the uses of personal information described in the Our Collection and Use of Personal Information section above, including rewards tracking, communication printing, website hosting, information technology support, content development and fraud monitoring. Depending on the function the third party serves, the service provider may process personal information on our behalf or have access to personal information while performing functions on our behalf. 
• Public Disclosure: With your consent, we may disclose certain personal information about you, such as first name/initial, last name and city of residence, publicly as an example of representative savings and/or to identify you as a user of our service. 
• Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership. 
• Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
  • In connection with the establishment, exercise, or defence of legal claims;
  • To comply with laws and regulations or to respond to lawful requests and legal process;
  • To protect our rights and property and the rights and property of our agents, customers, and others, including to enforce our agreements, policies, and terms of use;
  • To detect, suppress, or prevent fraud;
  • To reduce credit risk and collect debts owed to us;
  • To protect the health and safety of us, our customers, or any person; or
  • As otherwise required by applicable law. 
• Consent: We may disclose personal information about you to certain other third parties with your consent. 

Limited Authorization. We require that any third-party service providers respect the security of your Personal Information and process such pursuant to law. Our own service providers agree to deal with your Personal Information for specific purposes and according to our instructions. We have entered into agreements with our third-party service providers to require that they protect your Personal Information which they store, handle and process in a manner that is comparable to what is specified in this Privacy Notice and industry standards. 

International Transfers 

We are based in the United States; therefore, we process store and transfer your Personal Information in the United States. We may also process, store, and transfer your Personal Information in and to a foreign country other than the United States, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of the United States or that country may be able to obtain access to your Personal Information through the laws of such foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to applicable privacy legislation. 

You are welcome to contact our CPO whose contact information is given above to obtain further information about our policies regarding service providers based outside of Canada. 

By submitting your Personal Information or engaging in the Services, you consent to this transfer, storage, or processing. 

Your Communication Preferences 

In connection with our services, we may send you email messages, direct mail offers, SMS messages, push notifications or other communications, including telephone calls, regarding our services. You may ask us not to send you marketing communications or request a change to the method or frequency of communication by: 

• Following any available opt-out or communication preferences instructions in the marketing communications; 
• When available, accessing the “Unsubscribe” or “Communication Preferences” settings in your account profile page; 
• Sending a request to service@cxloyalty.com with the words “Opt Out” or “Communication Preferences” in the subject line, the address or number at which we contacted you and your request; or 
• Sending a request to the following address identifying the address or number at which we contacted you and your request: 

cxLoyalty
Data Privacy Office
77 North Water Street Norwalk, CT 06854 USA 1
-844-300-4222 

Please allow up to 10 days for your request to be processed. If you request to opt out of marketing communications, please note that we may continue to send you non-marketing communications, such as those directly related to the fulfillment of a specific transaction you requested, maintenance of your account or status of our ongoing business relations. 

Children’s Personal Information 

Our websites and online services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If you are under the age of 13, please do not use our websites or online services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information. 

We do, however, process personal information about children, including their Social Security numbers, when it is necessary for the services we are offering and you provide it to us. This personal information is used to provide you the full benefit of the service you have chosen, such as travel services for flights, hotels or cruises. 

Third-Party Websites 

Our websites and online services may include links to or redirect you to third-party websites, plug-ins and applications, including social media services where you may connect with us. Third-party websites may also reference or link to our websites and online services. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices or policies. 

Updates to this Privacy Notice 

We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the “Effective Date” at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify you by prominent posting at the beginning of this Privacy Notice. 

Contact Us 

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to privacy@cxloyalty.com. 

Alternatively, inquiries may be addressed to: cxLoyalty Data Privacy Office 77 North Water Street Norwalk, CT 06854 USA 1-844-300-4222

cxLoyalty
Data Privacy Office
77 North Water Street
Norwalk, CT 06854
1-844-300-4222