Website Privacy Notice
Effective Date: January 1, 2020

Aspire Lifestyles and its affiliates (collectively "Aspire Lifestyles Group") (collectively, "Aspire", "we", "us", or "our") respect your privacy.

This Privacy Notice applies to our privacy practices pertaining to Personal Information in the context of the Concierge Website (the "Site") and aims to give you information on how Aspire Lifestyles collects and processes your personal data, why and how we collect such data, how we use and safeguard that information, and what choices you have, including how to access and update or ask us to delete your information. Information is collected through your use of this website, or by you sharing personal data with us when you call our concierge service to make a request.

This Privacy Notice does not cover the collection and use of your Personal Information in the context of other programs, by third parties on the Site, on other non-Aspire branded websites or applications, by your Card issuers (e.g. your bank), or any other information or communications that may reference Aspire outside the Site services except as otherwise provided herein.

This privacy statement is provided in a layered format so you can review the specific areas set out below:

Personal Information We May Collect

How We May Use Your Personal Information

How We Share Your Personal Information

Your Rights and Choices

How We Protect Your Personal Information

Data Transfers

Features and Links to Other Websites

Updates to This Privacy Notice

How to Contact Us

1. Personal Information We May Collect

In connection with your use of the Site, we may collect certain Personal Information such as your email address, mobile phone number, the location information you provide, information about your mobile device and your Site usage data. We collect Personal Information about you from the following sources: (i) directly from you through the Site feedback function; and (ii) through your mobile phone such as mobile device identifiers like the IMEI number, MAC address, and IP address. We may also receive your geo-location information if you consent to our use of GPS or geo-location services within the Site.

2. How We May Use Your Personal Information

We may use the Personal Information we obtain about you to:

Where you have given us consent to fulfill Concierge requests submitted by you through the Site;
Provide customer service and respond to your inquiries in relation to your use of the Site and notify you about any changes to our service;
Provide, administer and communicate with you about products, services and promotions (including contests, sweepstakes, programs and other offers), including the display of customized content and advertising;
Operate, evaluate and improve our business (including by developing new products and services; managing our communications; determining the effectiveness of our advertising; analyzing our products, services and websites; facilitating the functionality of our websites; and assisting third parties in the provision of products or services that you request from third parties);
Administer, support, improve, optimize and develop the Site;
Monitor the use of and improve our interactive assets;
Perform data analyses to determine, among other measurements, business performance, number of registrants, channels, transaction spend and site performance;
Perform auditing, research and analysis in order to maintain, protect and improve our services;
Use your information on an aggregated basis (not personally identifiable) to do such things as operate our site, enhance our site and deliver messages. We may disclose aggregated information about our users but that information contains no Personal Information.

We may also use your Personal Information to notify you of the latest services and our exciting new offers if you have either requested marketing communications from us, or consented to receive marketing communications such as the Concierge Service newsletter. You may opt out from receiving marketing communications at any time by following the procedure to ‘unsubscribe’ that is specified in any marketing email that you receive.

Where we need to collect personal data, and you fail to provide that data when requested, we may not be able to fulfil your request or enquiries and provide our services (for example, to provide you with our Concierge services) or provide you with any support you are seeking from us. In this case, we will notify you if this is the case at the time.

3. When We Share Your Personal Information

Aspire does not sell or otherwise disclose your Personal Information we collect about you, except as described herein or otherwise disclosed to you at the time the data is collected to fulfill your Concierge service requests.

We may share your Personal Information with third parties, but only to perform the services requested by you in connection with your use of the Site. For example, we will share your Personal Information required to complete a dining reservation with a restaurant in order to fulfill your reservation request. When you use the service to make a reservation with a third party, you authorize us to disclose the information required by such third party to complete the booking. These third parties are not controlled by Aspire and Personal Information disclosed to them is subject to the applicable third party's privacy policy and security practices.

We may disclose your Personal Information about you to your issuing bank and its service providers in connection with the Concierge service for the purpose of addressing your requests and/or inquiries.

We may share your Personal Information any member of our group of companies (which includes any of our subsidiaries).

We also may share your Personal Information with our service providers who perform services on our behalf. We do not authorize these service providers to use or disclose such data except as necessary to perform certain services on our behalf or comply with legal requirements. We require these service providers by contract to appropriately safeguard the privacy and security of Personal Information they process on our behalf.

We also may disclose your Personal Information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.

We also reserve the right to transfer your Personal Information in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use Personal Information you have provided to us in a manner that is consistent with this Privacy Notice. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.

4. Cookies

We use a feature of your browser called a "cookie" to assign a unique number that automatically identifies your computer when you visit the site.

A cookie is a piece of data stored on your hard drive containing information about you. For instance, by setting a cookie on our site, you would not have to log in a password more than once, thereby saving time while on our site. If you reject the cookie, you may still use our site.

The only drawback to this is that you will be limited in some areas of our site, or may have to enter passwords or identifying information more than once. We may collect Personal Information from you at other points on our site that state that Personal Information is being collected. In the event of a complaint, we may also receive Personal Information about you from other users or third parties who may communicate information to us about you in relation to that complaint.

5. Your Rights and Choices

You may have certain rights regarding the Personal Information we maintain about you. We offer you certain choices about what Personal Information we collect from you, how we use that information, and how we communicate with you. At any time, you can access your account by logging into your account in the Site. You can view or change your personal details through your account in the Site.

You may choose not to provide Personal Information to Aspire. However, if you do not provide Personal Information when requested, you may not be able to benefit from the full functionality of the Site and/or we may not be able to provide you with relevant information, products and/or services.

Subject to applicable law, you may have the right to request access to and receive information about the Personal Information we maintain about you, update and correct inaccuracies in your Personal Information, and have the information blocked or deleted, as appropriate. The right to access Personal Information may be limited in some circumstances by local law requirements. To update your preferences, ask us to remove your Personal Information or submit an access request, please contact us as specified below under Section 11 "How to Contact Us".

6. How We Protect Personal Information

We restrict access to Personal Information about you to those employees who need to know that information to provide products or services to you. We maintain reasonable administrative, technical and physical safeguards that comply with state and federal regulations to protect the Personal Information we have about you. We also take measures to destroy or permanently de-identify personal information when there is no longer a business need to keep the information. The types of measures we take vary with the type of information, and how it is collected and stored. Unfortunately, no data transmission can be guaranteed to be 100% secure. Thus, while we strive to protect your Personal Information, we cannot ensure or warrant the security of any data transmission.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data Transfers

We may transfer Personal Information to countries other than the country in which the data was originally collected. These countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your Personal Information to other countries, we will protect that information as described in this Privacy Notice.

Aspire Lifestyles is a global business. To offer our services, we may need to transfer your personal information among several countries, including the United States. We comply with applicable legal requirements providing adequate safeguards for the transfer of personal information to countries outside of the European Economic Area or Switzerland.

8. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, any legitimate administrative or operational purposes, your requirements, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in connection with our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of your personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

When it is no longer necessary to retain your personal data, we will securely delete or in some circumstances we may anonymise your personal data (so that it can no longer be linked with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Features and Links to Other Websites

Within the Site, you may choose to use certain features for which we partner with other entities, or click on links to other websites or applications for your convenience and information. These features, which may include social networking and geographic location tools, and other websites, may operate independently from Aspire Lifestyles. They may have their own privacy notices or policies, which we strongly suggest you review. To the extent any features or linked websites you visit are not owned or operated by Aspire Lifestyles, we are not responsible for any content or use of the third parties’ sites or applications, or the privacy practices of such sites or applications.

10. Updates to This Privacy Notice

This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our Personal Information practices. We will post a prominent notice on the Site to notify you of any significant changes to our Privacy Notice and indicate at the top of the notice when it was most recently updated. Your continued use of the Site subsequent to any changes to the Privacy Notice (as notified on our website) constitutes your acceptance of the changes. Please review our Privacy Notice on our websites periodically to ensure that you are aware of any changes or updates.

11. How to Contact Us

All notices to a party shall be in writing or electronic communication and shall be made either via email or U.S. mail. Notice shall be deemed given 24 hours after an email that is not returned to the sender is sent, or 7 days after deposit in the U.S. mail, to you at the address provided by you upon registration and to Aspire at the address set forth below:

Privacy@aspirelifestyles.com

OR

Aspire Lifestyles (Americas), Inc.
Attn: Data Protection Officer
515 King St #410
Alexandria, Virginia 22314

VISA CONCIERGE PRIVACY NOTICE

Last updated as of: November 2020

Thank you for using the Visa Concierge website or mobile app. Visa Concierge is a concierge service intended to enhance your Visa cardholder experience. Visa Worldwide Pte Limited ("Visa," " us ," " we " or similar pronoun) owns and operates the Visa Concierge website and mobile app (“Platform”) itself or through third party service providers on behalf of the issuer of your Visa card (“Issuer”).

Visa Concierge is described in more detail in the Visa Concierge Terms of Service at www.concierge-asia.visa.com/terms-and-conditions. We highly value and respect the privacy of the personal information we obtain from you in connection with your use of Visa Concierge, including your name, address, account numbers and other information that can be used to individually identify you (collectively, " Personal Information ") and we have created this privacy notice (the " Privacy Notice ") to inform you about how we collect, use and share your Personal Information, and our privacy practices in general. As used in this Privacy Notice, the term “Visa Concierge” includes the Platform and any other Visa concierge channels operated by Visa or its third party providers that reference this Privacy Notice. As described in this Privacy Notice, Visa Concierge uses information that we obtain from you in connection with your use of Visa Concierge and from other third parties to enable you to participate in and take advantage of the various Visa Concierge features and functionality, for our own internal analysis, and to make Visa Concierge and our other programs and features more useful and interesting to you. Please note that your Issuer’s privacy policy may also apply to any Personal Information collected via the Platform.

Applicability of this Privacy Notice

This Privacy Notice applies solely to Personal Information we collect through the Platform. This Privacy Notice does not apply to information collected by other third parties through other means, such as by merchants through their merchant-owned or -operated websites or by third parties through social networking platforms.

This Privacy Notice is specific to the Visa Concierge services. Further details of Visa’s use of personal information more generally and Visa’s Global Privacy Notice are available at https://usa.visa.com/legal/privacy-policy.html

A special note about minors

Visa Concierge is not available to minors below the legal age of majority and Visa does not knowingly collect Personal Information from such minors.

NOTICE

Information Visa collects:

Visa may collect information in a number of ways in connection with Visa Concierge, including, without limitation, as follows:

When you enroll in Visa Concierge, set up a Visa Concierge account (" Account ") and make changes from time to time, we will collect the Personal Information you voluntarily choose to provide, such as your name and mailing, shipping and email addresses, phone numbers, birthdates, driver’s license numbers, and passport numbers. We may also collect your security questions and answers, username, password and other demographic information and preferences.
We collect credit, debit, prepaid or other payment card or other financial account information you provide to us in connection with Visa Concierge (" Card Details ").
We collect rewards program numbers, frequent flyer numbers, and other loyalty program numbers you provide to us in connection with Visa Concierge (“Loyalty Numbers”).
When you make a purchase through Visa Concierge or you otherwise provide purchase information to Visa Concierge, we may collect certain purchase and shipping tracking information.
When you ask us to send goods or services to a third party (“friend”), we collect certain personal information about your friend for the purpose of providing the fulfilling your request. If you are going to provide personal data of any friend to us as part of the Service, you will ensure that the third party is aware of this Privacy Notice. Where we require consent in respect of certain use of any personal data, including your or any other third party's personal data, you will consent or will have obtained the corresponding consent from such third party before you provide the personal data to us.
When you ask us a question, we collect email address or other contact information you choose to provide.
We collect information you voluntarily submit when participating in one of our various services, programs or surveys.

HOW VISA USES YOUR INFORMATION:

To process your requested transactions and bookings.

To send you Visa Concierge promotional emails and offers through your mobile device.

To email or message you with important information and updates about Visa Concierge and your Visa Concierge Account, including confirmation of transactions and bookings.

To generally provide the features and functionality of Visa Concierge to you.

To conduct surveys.

To respond to questions and comments.

To improve, enhance and tailor Visa Concierge for you, and to improve and enhance the overall Visa Concierge experience for all Visa Concierge users.

TO WHOM VISA DISCLOSES YOUR PERSONAL INFORMATION:

Visa may disclose to third parties all categories of Personal Information that it collects as follows:

To Your Issuer: Since Visa operates the Website on behalf of your Issuer, we may disclose your Personal Information to your Issuer.
Provision of Services: We disclose your Personal Information to third parties where necessary to provide Visa Concierge services to you.
At Your Request: We disclose your Personal Information to a third party whenever you request us to do so.
Business transfers: If a third party acquires all or substantially all of Visa's assets, your Personal Information, aggregated information, and any other information that we have collected in connection with Visa Concierge may be transferred to such third party as part of our business assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered one of our assets and may be sold or transferred to third parties.
Disclosure of Personal Information for legal purposes and protection of Visa and others: We reserve the right to share your Personal Information with third parties if required to do so by law, or if we believe such action is necessary in order to: (1) conform to the requirements of the law or comply with legal process served upon us; (2) protect or defend our legal rights or property, Visa Concierge, or our users; or (3) investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of the Visa Concierge Terms of Service.
Service Providers: We use third-party service providers to perform certain services on our behalf, such as processing, storing, maintaining and transmitting data, processing and fulfilling email and other promotional campaigns, and providing marketing assistance, web analytics and data analysis. We may provide your Personal Information to these third-party service providers when the information is necessary for them to perform their duties. These third-party service providers are contractually restricted from using Personal Information for any other purpose and required to comply with all applicable laws with respect to the Personal Information they receive.
Government Agencies: We will disclose your Personal Information to a government agency if required to do so by law.
As Otherwise Permitted By Law. We may disclose your Personal Information to third parties as otherwise permitted by applicable law.

Automatically collected non-Personal Information:

When you use Visa Concierge, we also may collect certain standard information from your browser and personal computer that websites often collect, such as your IP address, your browser information (including browser type, capabilities and language), your operating system and the date and time you accessed Visa Concierge. We also capture the country from which the visit came and the paths taken as you move from one website or webpage to another website or webpage (i.e., your "click stream" activity). We may use certain or all of this information to identify you in future visits to the Platform. We may group some or all of this information into aggregate data in order to describe the use of Visa Concierge by our users to our existing or potential business partners, sponsors, advertisers or other third parties, or in response to a government request. We may also group demographic information that we collect from Visa Concierge users into aggregate data for the same purposes. We reserve the right to use and share any such non-Personal Information with third parties for any lawful purpose.

Except for the purpose of identifying you in future visits to the Platform, Visa does not typically associate such non-Personal Information with any individual. However, to the extent Visa associates your Personal Information with non-Personal Information within our database, we will treat all the associated information as Personal Information under this Privacy Notice. Except as noted in this Privacy Notice, we do not share this associated information with third parties.

Browsing and the use of cookies, Web beacons and other tracking technologies; mashups and log

Visa uses cookie technology as part of Visa Concierge’s statistical reporting and for other purposes related to making Visa Concierge available to you. A cookie is a small piece of information sent by a website that is saved on your hard disk by your computer's browser. It holds information a website may need to personalize your experience (such as, rotating images on the home page of the website).

We also utilize cookies to identify if you are logged into your Visa Concierge Account, including for purposes of providing certain features of Visa Concierge to you. Cookies may be operable for varying periods of time, depending on the Visa Concierge feature or features with which they are associated. If you prefer, you can configure your browser to reject all cookies, or to notify you when a cookie is set. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie and privacy preferences. However, if you reject cookies, your use of Visa Concierge will be materially impaired or may altogether preclude your use of Visa Concierge.

A Web beacon is an electronic image, also called a single-pixel or clear GIF, placed in the code of a webpage or in emails. The Platform uses Web beacons to track traffic patterns of users as they navigate from one page to another. This information lets us tune and improve our users' browsing experience. The information that Web beacons collect is aggregated, anonymous "click stream" data, and is not associated with you as an individual.

We also use Web beacons through a third party website analytics provider, as well as standard Web server log files, to help us count visitors and evaluate the Platform’s technical capacity. This information tells us how many people visit the Platform, and helps us decide how to arrange pages in the most user-friendly way. This also helps us keep the Platform browser/mobile-friendly and more useful to our users. We record information on Platform traffic, but not on individual visitors to the Platform, so no Personal Information about you will be kept or used.

LOCATION-BASED SERVICES:

The Platform may offer certain location-based services to you. You understand that these location- based features require the location details of your mobile device to function properly and your use signifies your agreement to use your location for purposes of the service. If you do not want the Platform to use location-based information, please refrain from using a location based service or click "DON’T ALLOW" when your mobile device requests your location-based information. If location-based information has been enabled on your mobile device, you may choose to disable this at any time by accessing the User Settings on your mobile device. Except as set forth in this Privacy Notice, your location will not be shared with third parties without your specific consent.

SURVEYS:

From time to time, Visa may conduct surveys through the Platform using a third-party service provider. If you choose to participate, unless otherwise noted in the applicable rules, terms and conditions, or disclaimers, we may use the information you provide to publish survey results in aggregate on the site. Except where necessary to administer the survey, unless you have otherwise agreed or unless required by law, we will not share or publish any response you give connected to your name or address. We will hold these responses only as anonymous statistics.

Questions and Comments via Email:

When you send us a comment or question via email, we use your email address to thank you for your comment or reply to your question. We store your communication and our reply in case we correspond further. Beyond our initial reply, we will not use your email address to send you any unsolicited message or information, nor will we share it with, or sell it to, anyone else for such use, other than as specified in this Privacy Notice.

Third party websites, content and resources:

Please be aware that when you are using Visa Concierge, you could be directed via hyperlinks or other means to third party websites, content and resources that are not affiliated with Visa Concierge. You may also have the opportunity to transmit data from Visa Concierge to another website, or receive data through Visa Concierge from another platform, without leaving the Platform (for example, if you choose to share an offer by posting it at or through a social networking platform). These third party websites, content and resources may send their own cookies to visitors, collect data or solicit and use your Personal Information in ways different than set forth in this Privacy Notice. The privacy policies of these third party websites, content and resources may be very different from this Privacy Notice. We are not responsible for the privacy practices of the providers of these other websites, content and resources and cannot guarantee the security of any of your Personal Information collected, used or shared there.

Our policy regarding selling or renting of Personal Information:

It is our policy not to sell or rent your Personal Information to any third parties, except in the event of a bankruptcy or reorganization, or a sale of all or substantially all of our assets, as further provided in this Privacy Notice.

YOUR PRIVACY RIGHTS AND CHOICES:

You can direct us not to share your Personal Information with third parties and opt out of receiving emails by sending an email to privacy@concierge-asia.visa.com.

You can cancel your enrolment by emailing us at privacy@concierge-asia.visa.com. If you choose to cancel your enrolment and your Account is no longer accessible, we still may retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

HOW YOU CAN ACCESS AND EDIT YOUR PERSONAL INFORMATION:

You can review or modify your Personal Information at any time by accessing the My Profile or Settings section on the Platform. You can also submit a request to edit your Personal Information at any time by sending an email to privacy@concierge-asia.visa.com and requesting the change.

BANNERS AND OTHER ADVERTISEMENTS ON THE PLATFORM:

The Platform may display banners and other advertisements that may be placed by third parties. Such advertisers may collect non-Personal Information when you click or scan one of their advertisements, by placing cookies on your computer or by using other technology. We encourage you to review the privacy policies of any such third parties. In addition, we may share aggregate information about our visitors to third-party ad servers or potential advertisers in order to provide advertisements on the Platform about products and services that may be of interest to you.

HOW WE PROTECT THE SECURITY OF YOUR PERSONAL INFORMATION:

The security of your Personal Information is very important to us, and we are committed to protecting the Personal Information we collect. We maintain physical, electronic and procedural safeguards that comply with applicable privacy and data security laws and regulations to protect your Personal Information. Unfortunately, no transmissions or data available through the Internet can be 100% secure and, accordingly, we cannot guarantee or warrant the security of any Personal Information or other information you provide to us. As with any transmission over the Internet, such data may be accessed by unauthorized parties. You should always log out of the Platform after you have finished using Visa Concierge or are not using your device in order to minimize the chance of others accessing your Account.

CONSENT TO TRANSFER OF DATA:

Please note that information collected via the Platform may be stored and processed in other countries, including the United States, which may have different data protection laws than the country you reside in. You consent to our storage and processing of this information in the United States and other countries by using the Platform.

In order to provide the Visa Concierge services, we will be sharing your Personal Information with our Concierge service provider Aspire Lifestyles APAC Pte. Ltd. (“Aspire.”). Aspire will capture, store and manage your Personal Information as a third party supplier of Visa.

Further, Aspire may share your data with other 3^rdparty providers to enable or allow the provision of requested services to you. This includes and is not limited to merchants providing dining, travel, shopping and other services.

PRIVACY NOTICE UPDATES:

This Privacy Notice was updated on the "Last Updated" date noted above. We continually strive to find new ways to enhance Visa Concierge and Visa reserves the right to change, modify, or amend this Privacy Notice from time to time to reflect changes in our privacy practices. You are encouraged to review this Privacy Notice periodically and to check the "Last Updated" date at the top of this Privacy Notice for the most recent version to inform yourself about how your Personal Information is collected, used and shared when you use Visa Concierge. To the fullest extent under applicable law, your use of Visa Concierge after the "Last Updated" date means you are subject to Privacy Notice then in effect.

CONTACT US:

If you have any questions or comments about this Privacy Notice, our privacy practices or the way either of them affects you, please email us at privacy@concierge-asia.visa.com or write to us at:

Address:

Visa Worldwide Pte Limited

71 Robinson Road #08-01

Singapore 068895

Attention: Regional Privacy Counsel