Aimia Proprietary Loyalty U.S. Inc. Safe Harbor Privacy Policy

We've Updated our Privacy Policy
On October 17, 2016 we updated our Privacy Policy to reflect clarification of our dispute resolution process.

Introduction

Aimia Proprietary Loyalty U.S. Inc. (“Aimia”) is a provider of Business to Business marketing and loyalty services.  Aimia receives personal data from and about individuals for purposes of fulfilling data processing services at the request of, and in accordance and direction of, its clients.  Aimia utilizes the data it receives to provide client incentive programs, loyalty marketing, travel and related travel accommodation fulfillment.  In addition, Aimia may use personal data in order to properly manage the employment or contractor relationship with the individual that is the subject of such data.

Aimia’s privacy practices are consistent with the European Union Data Protection Directive and the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland.

To learn more about the Safe Harbor program, and to view Aimia’s certification, please visit http://www.export.gov/safeharbor/.

Safe Harbor Principles

Definitions

For purposes of this Policy, the following definitions shall apply:

"Agent" means any third party that collects or uses personal information under the instructions of, and solely for, Aimia or to which Aimia discloses personal information for use on its behalf.

"Personal information" means any information or set of information that identifies or is used by or on behalf of Aimia to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.

"Sensitive personal information" means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns an individual's health. In addition, Aimia will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

Privacy Principles

The privacy principles in this Policy are based on the Safe Harbor Principles.

Notice

Where Aimia collects personal information directly from individuals in the EU or Switzerland, it will inform them about the type of personal information collected, the purposes for which it collects and uses the personal information, and the types of non-agent third parties to which Aimia discloses or may disclose that information, and the choices and means, if any, Aimia offers individuals for limiting the use and disclosure of their personal information.

Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Aimia, or as soon as practicable thereafter, and in any event before Aimia use or disclosure of the information for a purpose other than that for which it was originally collected.

Where Aimia receives personal information from its clients, affiliates or other entities in the EU/EEA or Switzerland, it will use and disclose such information in accordance with the terms and notices provided by such entities and the choices made by the individuals to whom such personal information relates.

Choice

Aimia will offer individuals the opportunity to choose (opt-out) whether their personal information is (1) to be disclosed to a non-agent third party, or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

For sensitive personal information, Aimia will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

Aimia will provide individuals with reasonable mechanisms to exercise their choices such as providing the physical mailing address and e-mail addresses below.

Data Integrity

Aimia will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual.  Aimia will take reasonable steps to ensure that personal information is relevant to its intended use, and is accurate, complete and current.

Onward Transfer Third Parties

Aimia will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include a contract obligating the agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles. Where Aimia becomes aware that an agent is using or disclosing personal information in a manner contrary to this Policy, Aimia will take reasonable steps to prevent or stop the use or disclosure.

Aimia may transfer your personal information to another entity that has acquired the stock or substantially all of the assets of Aimia as the result of a sale, merger, or reorganization, insolvency, dissolution or liquidation. If such a transfer occurs, the acquiring entity's use of your personal information will still be subject to this notice. There are other limited circumstances in which we may share or transfer your personal information to unrelated third parties, including for example, when we believe disclosure is appropriate to comply with a law, regulatory requirement, court order, or a subpoena; to cooperate with law enforcement or other governmental investigations; to prevent or investigate a possible crime, such as fraud or identity theft; to protect legal rights, property or safety of you, Aimia, our employees, agents, other guests, or the public in general.

Access and Correction

Upon request, Aimia will grant individuals reasonable access to personal information that it holds about them.  In addition, Aimia will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

Security

Aimia will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Enforcement

Aimia will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy.  Any employee that Aimia determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

Dispute Resolution

Any questions or concerns regarding the use or disclosure of personal information should be directed to Aimia's Privacy Office at the mailing address or e-mail address given below.   Aimia will make every effort to address and resolve issues.  Aimia will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy.   

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Limitation on Application of Principles

Adherence by Aimia to these Safe Harbor Principles may be limited (1) to the extent required to respond to a legal or ethical obligation; and (2) to the extent expressly permitted by an applicable law, rule or regulation.

Links to Other Websites

Our websites link to other websites, many of which have their own privacy policies. Be sure to review the privacy policy on the site you're visiting.

Contact Information

Questions or comments regarding this Policy should be submitted to the following by mail or e-mail as follows:

Aimia Proprietary Loyalty U.S. Inc.
Attention Privacy Officer
100 North Sixth Street, Suite 700B
Minneapolis, MN 55403
e-mail: privacy.us@aimia.com

Please provide your full name and contact information, detailed nature of concern and expected outcome.

We reserve the right to periodically change the privacy notice.  If or when we do, we will post the new notice and change the effective date shown on the site.

Privacy Policy Last Modified August 5, 2015