1.Overview
The Plaza Premium Group manages and operates a wide range of airport hospitality and ancillary passenger services under various brands, including but not limited to “Plaza Premium Lounge”, “Plaza Premium First”, “Airport Dining”, “ALLWAYS”, “Aerotel”, Smart Traveller, and all associated brands (“Plaza Premium Group”). We, the Plaza Premium Group, are committed to protecting and respecting your privacy. In this Privacy Notice, we inform you of how we collect, process, and use your personal data. Personal data means any information relating to an identified or identifiable natural person (“Personal Data”).
1.1 Consent
By providing your Personal Data to us, you hereby consent to the processing of your Personal Data in accordance with this Privacy Notice. You are free to decide whether or not to supply us with your Personal Data. However, do note that in some cases we need your Personal Data to provide our products and/or Services to you. If you do not provide your Personal Data, we may not be able to provide our products and/or Services to you. If you are acting on behalf of companies and/or organisations supplying Personal Data of your officers, employees, authorised signatories, directors, partners, individual shareholders, individual guarantors, individual security providers / suppliers / vendors and/or other individuals (“your individuals”) to us, you have warranted that you have obtained their consent and have highlighted this Privacy Notice to the attention of your individuals.
1.2 Definitions
In this Privacy Notice:
“Aerotel” refers to the group of airport transit hotels owned, managed and/or operated by any company of Plaza Premium Group under the brand “Aerotel” or other associated brands of Plaza Premium Group;
“Business Partner” refers to any individual, business entity, including but not limited to our corporate client, airline client and/or any other party who carries out business with the Plaza Premium Group in connection with the Services;
“Data Controller” means the party who determines the purposes and means of the processing of Personal Data;
“Data Processor" means the party who processes Personal Data on behalf of the Data Controller. There may be circumstances where we process your Personal Data as a Data Processor on behalf of a Data Controller, such as when you access our products or Services through our Business Partners, who are usually the Data Controller;
"Data Protection Laws" means the EU General Data Protection Regulation 2016/679 (“GDPR”) as amended, replaced or superseded from time to time and/or any other applicable data protection laws and regulations from time to time in force in relation to Personal Data;
"Location” means a location where the Services are offered by the Plaza Premium Group;
“Messaging Feature” means the reservation, customer support, alert and notification features offered to you via WhatsApp or any other messaging platform, as the case may be;
"Services" means the services which are stated on any one of the Websites or on the Smart Traveller mobile application, offered by us online or at a Location which may be revised, updated, varied, modified or amended by us from time to time at our sole discretion;
“Smart Traveller” means the Plaza Premium Group’s Smart Traveller loyalty program;
“Supplier” refers to any individual, business entity or party engaged or appointed by Plaza Premium Group to provide relevant products and/or Services, to support the operation, legal, marketing, communication and other essential business functions of Plaza Premium Group in connection with the Services;
“Website” or “Websites” refers to an online website as may be adopted by Plaza Premium Group to provide the Services, including but not limited to the following which are subject to change from time to time:
(a) www.plazapremiumgroup.com;
(b) www.plazapremiumlounge.com;
(c) www.myaerotel.com;
(d) www.allwaysvip.com;
(f) www.plazapremiumfirst.com;
(g) www.intervalsbar.com;
(i) www.yqnowgroup.com;
(j) www.partner.yqnowgroup.com; and
(k) all other associated websites, including microsites of Plaza Premium Group relating to a Location.
1.3 Where does this Privacy Notice apply?
This Privacy Notice applies to our Locations, Websites, Smart Traveller and the Messaging Feature only and not to the locations, and websites of other companies, individuals, or organisations to which we provide links or from which there are links.
2. Data Controller
When we are the Data Controller, we can be contacted at the details in Section 3 – “Contacting Us” below.
3. Contacting Us
Data Protection Officer - Plaza Premium Group
Email: [email protected]
Please note that this email address is for enquiries concerning the processing of Personal Data only.
4. Information required by local Data Protection Laws
We may be required by certain local Data Protection Laws to provide to you with additional information relating to data privacy, which shall be updated from time to time when such notices are uploaded.
5. How and when do we collect your Personal Data?
5.1 We may obtain your Personal Data from yourself and/or other source(s), including but not limited to when:
(a) you book our Services directly through us, including on the Websites, or through our Messaging Feature;
(b) you access to any of our Locations where there are Closed Circuit Television (CCTV) installed at our Locations which may capture your Personal Data when recording;
(c) you use any of our Services and we are required to collect your Personal Data;
(d) you access and use our Services through our Business Partners and we receive your Personal Data from them;
(e) you access and use our Services through our Business Partners and we need to verify your identity;
(f) you make any enquiries with us, including orally or virtually, and you provide to us your Personal Data;
(g) you communicate with us by email, telephone, in writing, or through our social media platforms, and you provide to us your Personal Data;
(h) you sign up for a member account with Smart Traveller through our Websites or the Smart Traveller mobile application;
(i) you subscribe to our mailing list to receive our marketing or promotional materials;
(j) you respond to our surveys or research outreach efforts via online or offline channels where you provide to us your Personal Data;
(k) you use your account(s) with us where we can analyse the transactions and obtain your Personal Data; and/or
(l) other sources provide to us your Personal Data for which you have given your consent to disclose information relating to you and/or where not otherwise restricted.
5.2 We may also collect Personal Data from your authorised representative(s) or third parties validly acting on your behalf (e.g. your travel agents or other service providers).
5.3 Automated decision-making: We may use automated decision-making processes, including basic profiling, under the applicable Data Protection Laws to support certain functions of our Services. This means certain decisions may be made automatically by systems based on your Personal Data.
6. Why do we process your Personal Data?
We process your Personal Data in the following manner, and which corresponds with specific legal bases under the Data Protection Laws.
6.1 To perform our contract with you
A contract is entered between you and us when you book our Services directly through us. In that connection, we process your Personal Data to do the following:
(a) To facilitate the booking process and to process your booking;
(b) To provide you with the Services pursuant to your booking or purchase. We do this by verifying your booking at the Location, which includes use of your Personal Data;
(c) To perform any requests made by you, including to comply with your indicated food and beverage preferences.
In addition, we also use your Personal Data to handle your interactions with us in connection with your booking. This includes any of your inquiries with us in relation to your booking, any requests to modify or cancel your booking with us, or any communications relating to your booking.
Legal basis: The processing of your Personal Data in this scenario is on the basis of performing our contract with you.
6.2 To verify your eligibility for our Services
When you access our Services through our Business Partners, we may need to first verify your eligibility for the Services in question. This is done pursuant to our contract with our Business Partners. For example, this includes when you wish to access a Plaza Premium Lounge using your credit card or airline entitlement.
To complete the verification process successfully, we will need to process your Personal Data.
Legal basis: The processing of your Personal Data here is on the basis of our legitimate commercial interest.
6.3 To respond to enquiries
As a service provider, we from time to time receive enquiries in relation to our Services. If you submit such an enquiry in howsoever manner (e.g. orally, virtually), we may need to process your Personal Data to manage, respond to, or administer your enquiry and/or request.
Legal basis: The processing of your Personal Data here is on the basis of our legitimate commercial interest.
6.4 To comply with our legal obligations
We operate in multiple jurisdictions worldwide. In some places, local laws may require us to obtain certain Personal Data from you in the course of our commercial operations.
Legal basis: The processing of your Personal Data here is necessary to comply with a legal obligation.
6.5 To register and maintain your Smart Traveller member account
If you sign up for a Smart Traveller member account with us, you will be required to provide your Personal Data so that we can process your registration, send you communications relating to your account, and to generally maintain your account on our backend systems.
Legal basis: The processing of your Personal Data here is on the basis of consent given by you for the registration of your Smart Traveller member account, and pursuant to both parties’ legitimate commercial interest.
6.6 For marketing purposes
If you subscribe to our mailing list, we will send you marketing communication about our Services, products, offers, news, and other information directly to you. When subscribing, you will need to provide us with your Personal Data so that we can send you these marketing communications.
Please refer to Section 13 – “Marketing Communications” for more information on how we use your Personal Data for marketing purposes.
Legal basis: The processing of your Personal Data here is on the basis of consent given by you specifically for direct marketing communications.
6.7 For other operational purposes
(a) To improve the provision of Services to you;
(b) To manage your Smart Traveller member account with us, including, without limitation, to address your queries and notify you of any proposed or actual changes to the Website or Smart Traveller;
(c) To compile and provide anonymous statistics about users of the Website, and provide related usage information to reputable third parties, which will not in any event enable any third party to identify individuals;
(d) To provide you with information on our and/or third party products, services and/or offers that may be of interest to you;
(e) To manage the relationship between you and Plaza Premium Group;
(f) To facilitate our business operations across our group of companies;
(i) To improve on our products and/or Services and to develop new products and/or Services;
(j) To respond to your feedback and complaints as well as to administer offers and promotions;
(k) For audit, compliance and risk management purposes;
(l) For such other purpose that is incidental, ancillary or in furtherance to the above purposes;
(m) Analyse the way you use and manage your account(s) and/or Services with us.
Legal basis: The processing of your Personal Data here is on the basis of our legitimate commercial interest.
7. What Personal Data and information do we collect?
7.1 We collect specific Personal Data depending on the circumstances of the collection and the services requested or transaction undertaken by you. These Personal Data include, but are not limited to:
(a) Personally identifiable information, such as your name, passport number, identity card number, driver’s license number, date of birth, loyalty programme membership number, or other such personal identification numbers.
(b) Contact details, such as your mailing address, phone number, and email address.
(c) Travel information, such as your flight or transport information, presented in a way that is personally identifiable to you.
(d) Payment information, such as your payment card information. This includes the cardholder name, card number, billing address, and card expiry date.
(e) Other information attributable to you, such as your service requests, food and beverage preferences, special requests, or your spending during your use of our Services.
7.2 Minors’ Personal Data: Our products and Services are not directed at minors, being children under the age of 16 (or other age in accordance with the applicable local Data Protection Laws), and our Websites and Messaging Feature cannot distinguish the age of individuals who access and use them. If a minor has provided us with their Personal Data without parental or guardian consent, their parent or guardian should contact us to remove the minor’s Personal Data and/or to terminate or restrict their Personal Data. If we become aware that Personal Data has been collected from a minor without parental or guardian consent, we can delete the minor’s Personal Data and, where that minor has an account with us, terminate the minor’s account.
7.3 Special categories of Personal Data (Sensitive Data). Where required or permitted by Data Protection Laws or where you have given us your explicit consent, we may ask for special categories of Personal Data as defined by the applicable Data Protection Laws, which may include data concerning your health.
7.4 In addition to Personal Data, we also collect the following information when you use the Smart Traveller mobile application:
(a) Device and usage information about your browser or device, including the type of device you are using, your browser and operating system, your internet service provider, your internet protocol (“IP”) address, your device and mobile ad identifiers (e.g., Apple IDFA or Android AAID), the referring website, the web pages of our website that you view, the Services and functions you access or use and the ads you click or scroll over. To collect this information, we may use log files that record events in connection with your use of our Services, as well as cookies and similar technologies, such as web beacons embedded in marketing emails; and/or
(b) Location information about the location of your device, such as information that identifies your device’s precise location (e.g., GPS latitude and longitude level) or its approximate location (e.g., less precise location estimated based on a browser or device’s IP address). We collect this location information or derive it from your GPS, WiFi, Bluetooth or other device settings for purposes of enhancing or facilitating our Services, such as to enable the functionality of our websites or mobile applications that provide you with information about lounges, hotels, Services and partner stores near you, to enable you to enjoy special member’s benefits or offers, make redemptions, check in to lounges and any other functions/Services to enrich your Smart Traveller experience. You may opt out of the collection of this location information by turning off the “location” function in the Settings of your Smart Traveller mobile application, and disabling the relevant location/location-sharing settings in your web browser.
8. Disclosure of Personal Data
We may have to disclose your Personal Data to other parties in order to provide you with our products and Services. By providing your Personal Data to us, you are acknowledging and consenting to our disclosure of your Personal Data as set out below.
8.1 Within the Plaza Premium Group
We may disclose your Personal Data to our affiliates and associates within the Plaza Premium Group to provide our Services to you pursuant to any of the purposes stated above.
Disclosure of your Personal Data may also be necessary for our own intra-Group administration, or our affiliates’ own processing purposes, or for the purposes of improving our products and Services.
8.2 To other parties
We may share your Personal Data to other companies or parties, such as airport authorities, Business Partners and/or our Suppliers, to assist in fulfilling the purposes, or directly related purposes for which your Personal Data was processed. They may then in turn disclose your Personal Data to other parties, such as companies within their own group of companies, their own affiliates, service providers, or regulators, depending on their own processing purposes, contractual obligations to the Plaza Premium Group or other legal obligations.
We may also share your Personal Data with our service providers that provide data analytics services to us. For example, we use Google Analytics for analytical purposes to improve our Services (click here for more information).
8.3 Your responsibilities
(a) If you have registered a Smart Traveller member account with us, you hold the sole responsibility of safeguarding your own login and password information for your account with us and you should not be disclosed to any third parties. We will not ask you for your password under any circumstances. The risks of the leakage of your Personal Data resulting from your loss of the login and/or password information lie solely with you.
(b) You acknowledge and understand that the transmission of information via the Internet is not completely secure. Although we endeavour to take practical steps to safeguard your Personal Data to prevent unauthorised access, including implementing high standard of security measures to protect any information received, we do not guarantee the security of your Personal Data when transmitted by you via Internet, and you acknowledge and accept that any such transmission is at your own risk.
9. Transfer of your Personal Data
As a global business, we may have to transfer your Personal Data across national or regional borders when we disclose your Personal Data in the manner listed in Section 8 – “Disclosure of your Personal Data” above. Where such a transfer is performed, it will be done in compliance with the requirements of the applicable Data Protection Laws. Plaza Premium Group will take reasonable care and exercise due diligence to ensure your Personal Data, after being transferred to recipients located in other countries, will not be stored, processed, or used in any manner which would be a contravention of the Data Protection Laws.
One of the ways in which we ensure adequate protection of your Personal Data is to conclude Personal Data processing agreements with our Business Partners and/or Suppliers, which contain enforceable contractual obligations on either party concerning the protection of Personal Data. This may also include appending standardised clauses (“standard contractual clauses”) approved by the appropriate data protection authority containing obligations when Personal Data is transferred across borders. An example of standard contractual clauses that we use can be found here.
When you provide us your Personal Data, you are consenting to the transfer of your Personal Data for the purposes set out in this Privacy Notice. We will take all reasonable steps necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Notice.
10. Retention of your Personal Data
10.1 We retain your Personal Data for as long as is necessary to fulfil the specified purposes for which it was collected, or for as long as required by the relevant applicable laws, or for our legitimate business needs in line with our data retention policies.
10.2 Data collected by us in order to carry out the purposes or directly related purposes stated in this Privacy Notice will be stored in our databases. The databases owned and managed by Plaza Premium Group, Business Partners and/or the Suppliers may include Personal Data such as guest name, address, email address, and/or phone number.
10.3 We may also store other information such as your special requests, food and beverage preferences and transaction history in our databases and this information may be shared and/or used by Plaza Premium Group and/or affiliated businesses units for marketing and/or analysis purpose to enhance your experience relating to our Services.
10.4 If we destroy any Personal Data in our possession, it will be done in accordance with the Data Protection Laws and/or applicable local laws.
11. Your Rights
You may have certain rights under certain Data Protection Laws in respect of your Personal Data being processed by us.
11.1 You have the right to know whether or not we process your Personal Data. If we do, you have the right to:
(a) access your Personal Data.
(b) request us to make corrections to your Personal Data being processed by us, if you find it to be inaccurate or incomplete.
(c) Information on how we process your Personal Data, namely the purposes of the processing, the categories of your Personal Data concerned, the recipients of your Personal Data to whom we have or will disclose your Personal Data, and to the extent possible, information about how long we store your Personal Data.
(d) request a copy of your Personal Data being processed by us. If you request for more than one copies of your Personal Data, we may charge you an administrative fee. We may also reject your request for a copy of your Personal Data if providing the copy will adversely affect the rights and freedoms of other individuals.
11.2 Additionally, you may also have the right to request us to erase your Personal Data, object to or to restrict its processing. These rights may be subject to or limited by the operation of applicable Data Protection Laws.
11.3 If you previously consented to us processing your Personal Data (including Sensitive Data) for one or more specific purposes, you may at any time withdraw your consent. This will not affect the lawfulness of the processing before you withdrew your consent.
11.4 In connection with paragraph 11.3 above, if you have previously consented to receiving marketing communications from us, you may opt-out from receiving marketing communications at any time, free of charge, by the following ways: following the “opt-out” or “unsubscribe” instructions contained in the marketing communications; or by email to us with the subject “Unsubscribe” at the email address listed in Section 3 – “Contacting Us” above.
11.5 Data portability: Where required or permitted by Data Protection Laws, you may also request your Personal Data to be transmitted to another Data Controller in a structured, commonly used and machine-readable format. This right is subject to technical feasibilities.
11.6 A request for access or correction to, or deletion of Personal Data or to exercise any of your rights under the applicable Data Protection Laws, or to obtain a copy of the Privacy Notice must be in writing and sent to us at the email address listed above under Section 3 – “Contacting Us”.
11.7 You may also lodge a complaint about how your Personal Data is handled by us with your national or state data protection authority.
11.8 When you wish to exercise any of these rights, we may require you to prove your identity by providing us with information necessary to confirm your identity and to process your request.
11.9 We handle your Personal Data in accordance with the Data Protection Laws. Should any provision of this Privacy Notice be found by any court or administrative body of competent jurisdiction to be invalid or unenforceable, the invalidity or unenforceability of such provision shall not affect the other provisions of this Privacy Notice. All provisions not affected by such invalidity or unenforceability shall remain in full force and effect.
12. Cookies
12.1 Cookies are used on all online tools available to you, including, without limitation, the Website to distinguish you from other online users, to analyse how viewers navigate the Website with a view to optimise its design, to establish and maintain your logged-in identity if you log into your account with us so that you can move around the Website without being asked to login again.
12.2 You should understand that while cookies in general do not tell us your email address or other Personal Data, however, if you voluntarily provide such information or Personal Data to us by, for example, registering an account with us or subscribing to any of our Services, such information may be linked to the data in the cookies.
12.3 In addition to the information we collect through cookies, we also process behavioural data and store such data for analytical purposes so as to conduct marketing research and improve the quality of our Website. Such data includes information about your visit such as your server address, the date and time of your visit, the page you accessed, the information you downloaded and the type of Internet browser you used.
12.4 The use of any information we collected either through the use of cookies or otherwise shall be subject to this Privacy Notice.
12.5 Most web browsers are initially set up to accept cookies. You may choose to edit your browser options to block cookies in the future. If you block cookies, certain features on the Website may not work properly.
12.6 Please take note that cookies from third parties unaffiliated with Plaza Premium Group or our Business Partners may be set before, during or after browsing our Website. We do not and cannot control these cookies set by third parties and you should check with these third-party websites for more information about their cookies.
13. Marketing Communications
13.1 We use your Personal Data to conduct direct marketing via email, push message, direct mail, telephone, fax and or other form of communication, to provide you with information about products and/or Services offered by the Plaza Premium Group. You will only receive these marketing communications if you have subscribed to our mailing list or explicitly agreed to receiving marketing materials in such manner when providing your Personal Data to us.
13.2 If you wish to stop receiving marketing communications from us, you may withdraw your consent by following the “opt-out” or “unsubscribe” instructions contained in the marketing communications; or by emailing us with the subject “Unsubscribe” at the email address listed in Section 3 – “Contacting Us” above.
14. Changes to Privacy Notice
You accept and agree that we shall have the sole discretion to amend this Privacy Notice at any time. Please check back for any updates or changes to this Privacy Notice, which will be dated as of the most recent update. If you continue to provide us with your Personal Data or use our products and/or Services, you will be deemed to have agreed to accept such changes.
15. Conflict
In the event of any conflict between the English version of this Privacy Notice and any corresponding translations of the Privacy Notice, the English version shall prevail.