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Privacy Policy

Presentation

The LifeMiles loyalty program (the “LifeMiles Program” or the “Program”) is a coalition loyalty program owned and operated by LifeMiles B.V., a private limited liability company (besloten vennootschap) organized and existing under the laws of Curacao (“LifeMiles BV”). 

Each Member of the LifeMiles Program is subject to the Terms and Conditions of the LifeMiles Program established from time to time by LifeMiles BV (the “Terms and Conditions”) and to the Privacy Policy set forth below (this “Privacy Policy”).

Upon accepting the Terms and Conditions, a Member also expressly accepts this Privacy Policy.  
Potential Members of the Program that request membership in the Program and persons that are not Members or potential Members that access and use the Program website (www.lifemiles.com) (the “Website”) are subject to this Privacy Policy as applicable to them.

Except for the obligations expressly indicated in the Terms and Conditions, none of the integrated airlines of Avianca Holdings S.A. and the other companies with which LifeMiles has entered into agreements to participate in the LifeMiles Program, such as other airlines, banks, hotels, auto rental companies, retailers of goods and services, among others, (“collectively, Partners”) have any responsibility for the operation of the LifeMiles Program.

This Privacy Policy establishes the terms and conditions and the objectives under which LifeMiles BV collects, stores, uses, shares, deletes and handles the personal information of the Members of the LifeMiles Program and the security and confidentiality conditions of such information, and it also establishes the procedures for the owners of the information to exercise the rights provided under the laws of personal information protection.

For effects of this Privacy Policy, the term “Member” means any natural individual enrolled in the LifeMiles Program and that therefore has a LifeMiles identification number.


Collection and Handling of Personal Information

In order to operate the LifeMiles Program and offer its benefits to Members and for the other purposes expressed herein, LifeMiles BV needs to collect, directly or through Partners or other third parties, among other information, the following information from persons seeking membership in the Program or its Members: name and last name, birth date, gender, mail address, residency and alternate address, email address, telephone, identification number according to the country of citizenship, passport number, country, language, Program account number and personal preferences.  The owner of the information being provided expressly accepts that that LifeMiles BV may handle, obtain, compile, share, update, process, reproduce and/or dispose its personal information, partially or totally with the objective expressed in the Terms and Conditions and this Privacy Policy.

To request the registration of the Member in the LifeMiles Program through the different channels of contact with the customers, such as administrative offices, airports and/or call centers, LifeMiles BV or any Partner may collect personal information such as complete name, birth date and electronic mail address to be able to have subsequent contact with the person requesting membership. In order to activate an account in the LifeMiles Program, an email shall be delivered with the instructions to complete the registration in the LifeMiles Program to the email address collected.  The owner of the information expressly authorizes LifeMiles BV to use such information according to the objective herein contained.

Personal information collected through the Website

LifeMiles BV may collect personal information from a Member or any person that uses the Website when he/she uses the Website. A Member may store such Personal Information through the Website in order to facilitate accrual, redemption and purchase transactions and any other LifeMiles Program transaction.
LifeMiles BV may also automatically collect personal information through the use of the Website through cookies, web beacons, log files and other technologies, including, but not limited to, the following:

  • Domain name;
  • Browser type and operating system;
  • IP address;
  • Web pages viewed by Members;
  • Links clicked by Members;
  • Length of time of Member visits;
  • Member activities on the Website
  • Referring URL or webpages that led Members to the Website.

Use of cookies, web beacons and other similar technologies

LifeMiles BV and its third party service providers may collect personal information by using technologies and methodologies, such as cookies, tags, web beacons or other similar technologies that enable tracking as Members and other persons browse the Website. LifeMiles BV may use these technologies to authenticate a Member as a user, to remember his/her preferences for using the Website, to present offers that may be of interest and to facilitate transactions, such as award tickets and other redemption transactions. LifeMiles BV and its third party service providers also use these tools to analyze use of the Website and its services. LifeMiles BV may use this personal information in the aggregate or combine it with personal information that LifeMiles BV has already collected about Members.

  • Cookies. Cookies are small bits of information that are stored on a computer by its web browser. Web beacons or pixel tags are small strings of code placed on a web page or in an email message for the purpose of transferring information. Cookies and the other technologies discussed in this section allow LifeMiles BV to recognize Member and other user preference information, to track Member transactions and to facilitate effective Website administration.

Cookies help establish a user session and allow a server to provide Website users with appropriate information, advertisements and services. LifeMiles BV also uses cookies to ensure Members obtain information requested, to authenticate his/her authority to access the Website and to track the usage of the Website in order to improve it according to Member needs. If a Member is a registered user on the Website and such Member elects to have the Website store his/her Program account number, the cookie stored on his/her computer will contain such Program number.

If a Member does not want his/her personal information to be collected through cookies, such Member can change the preferences in his/her particular web browser. Some Website functionality may not work properly if a web browser does not accept cookies. Specifically, if a Member chooses not to accept cookies and is a registered user, such Member will not have access to his/her personal information, such as his/her user profile, accrual and redemption transactions, LifeMiles Program miles (“Miles”) balance information, on the Website. Members should consult his/her selected web browser for instructions on how to change cookie settings.

  • Local storage objects. LifeMiles BV may use Flash Local Storage Objects ("Flash LSOs") to store Member preferences and to personalize their visits. Flash LSOs are different from cookies because of the amount and type of data stored. Typically, a Member cannot control, delete or disable the acceptance of Flash LSOs through his/her web browser. For more information on Flash LSOs or to learn how to manage settings for Flash LSOs, Members should go to the Adobe Flash Player Help Page, choose “Global Storage Settings Panel” and follow the instructions. To see the Flash LSOs currently on a Member’s computer, choose “Website Storage Settings Panel” and follow the instructions to review and, if a Member wants, to delete any specific Flash LSO.
  • Clear GIFs, pixel tags and other technologies. These technologies allow LifeMiles BV to recognize Member preference information, keep track of transactions and facilitate effective Website administration. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on a Member’s computer’s hard drive, clear GIFs are embedded invisibly on web pages. LifeMiles BV and its third-party service providers may use clear GIFs (also known as web beacons, web bugs or pixel tags), in connection with the Website and services to, among other things, track the activities of visitors, help LifeMiles BV manage content and compile statistics about usage. LifeMiles BV and its third party service providers may also use clear GIFs in HTML emails sent to Members to help LifeMiles BV track email response rates, identify when its emails are viewed and track whether its emails are forwarded.

Personal Information collected through the mobile application

LifeMiles BV may collect personal information from a Member when he/she uses the Program mobile application. A Member may store such personal information through the mobile application in order to facilitate accrual, redemption and purchase transactions.  

LifeMiles BV also may collect personal information automatically through a Member’s use of the Program mobile application (through cookies, web beacons or other tracking technologies designed for mobile applications), including, but not limited to, the following:

  • Physical location information from technologies such as GPS, Wi-Fi, or cell tower proximity (geo-location tracking), if a Member grants permission to track such information;
  • Domain name;
  • Device ID or alternative ID where required by the platform provider;
  • Electronic data concerning operating systems and computing devices/browser, including types;
  • Features used and links clicked by such Member;
  • Amount of time spent on the Mobile App;
  • Installs and uninstalls; and
  • Transaction details and history.

The owner of the information expressly authorizes LifeMiles BV to collect information under the terms herein expressed and to verify, supplement and update such personal information of the Member, anytime, with other data bases handled by third parties in order to update the Member’s


Objectives of Information Management

It is necessary that the personal information of the Members be collected, stored, used, shared, processed and/or managed in order to:

  1. Develop and operate the LifeMiles Program;
  2. Identify a Member and communicate with the Member, including without limitation, the delivery of the membership card, information on accrual transactions and/or redemptions carried in each account and the delivery of other physical or electronic communications;
  3. Credit Miles in the Member’s account, both for flights operated by airline Partners and goods and/or services purchased from other Partners;
  4. Permit a Member to redeem Miles for air tickets for flights operated by airline Partners, and other goods and/or services rendered by Partners;
  5. Assist a Member in getting the goods and/or services redeemed with its Miles;
  6. Maintain Miles in accounts updated and supported;
  7. Ensure a Member does not have to repeatedly provide its personal information and make more efficient the Miles accrual and redeeming process;
  8. Deliver offers and/or communications to a Member based on its preferences and/or previous behavior;
  9. Offer a Member products specially designed to provide more options to accrue and/or redeem Miles;
  10. Provide a Member with attractive options of accrual and redemption of Miles;
  11. Subcontract third parties to process the information of Members and/or to carry any other activity required by LifeMiles BV in relation to the LifeMiles Program;
  12. Other objectives provided in the Terms and Conditions and this Privacy Policy; and
  13. For other purposes such as statistic and marketing analysis; development and improvement of our products, commercial and promotional initiatives; information updating, identification of which of our products or of our Partners may be of interest to Members; identification and prevention of fraud, money laundering and other illicit activities; to carry out regulatory revisions and marketing research.

By accepting this Privacy Policy, a Member authorizes LifeMiles BV to manage, obtain, collect, share, process, reproduce and/or dispose of its personal information, partially or totally, and to transfer such partial or total information to third countries, including the country of origin of LifeMiles BV or the Partners for the purposes referred to herein and/or with the objective that LifeMiles Corp and the other Partners are able to offer their products and/or services to the Members and a better experience for the Members within the LifeMiles Program.

As part of the management of the personal information collected, it is also necessary that the personal information of Members be stored and processed in a sole platform for LifeMiles BV in one country, which currently is El Salvador; for which if the information is collected outsider El Salvador, the Member expressly consents for such information to be transferred to El Salvador for its management. 

Additionally, it is necessary to be able to transfer personal information to Partners of the LifeMiles Program. Also, Life Miles Corp may contract third parties to process the Members´ information and/or to carry out any other activity required by LifeMiles BV. In both cases, this may require the transfer of such personal information to other countries, including those with a level of data protection different than the country where the information was collected, for which the Member expressly consents to such transfer.

Also, the Member authorizes LifeMiles BV to share its information with Partners and other third parties with which it has business agreements, for the purposes provided herein, and these Partners shall be bound to comply with this Privacy Policy.

The Member also authorizes LifeMiles BV and the Partners to share its personal information between them.

With the acceptance of this Privacy Policy, the Member declares that it is aware that LifeMiles BV may provide this information to judicial or administrative institutions and governmental entities exercising control of its operations when required by law.  The Member also accepts that it may be the object of internal or external audit controls by companies that perform these reviews.

Upon enrolling the LifeMiles Program or receiving its benefits, such as accrual and/or redemption of Miles, the Members expressly authorize the management of its personal information as set forth in this Privacy Policy.


Security And Confidentiality

To secure privacy and confidentiality protection of the information, the Website includes measures such as codification of data, automatic closing of sessions by inactivity and automatic blockage of unauthorized access.

The information a Member enters in the Website is kept strictly confidential and is not shared with third parties other than those indicated in this Privacy Policy and the Terms and Conditions. The data shall be codified before its transference to provide the most security possible.

Online access to the account of a Member requires a code to guarantee the confidentiality and security of the information.

Payment transactions with credit cards have a standard security certificate for electronic payments of these transactions, which guarantees the integrity of the information.

LifeMiles BV shall keep the personal information of the Members under the security and confidentiality terms herein provided and for the objectives of this document, during the entire time in which they remain affiliated to the LifeMiles Program and for ten (10) more years after their withdrawal as a Member.


Information of Children, Teenagers and Minors

The LifeMiles Program permits children and teenagers under 18 to be Members.

LifeMiles BV shall oversee the appropriate use of the personal information of children and under aged, securing the respect to their fundamental rights and, if possible, taking into account their opinion as owners of their personal information.

Therefore, if a Member correctly provides its information upon enrolling the LifeMiles Program which permits to identify that the Member is underage, LifeMiles BV shall act according to the provisions herein contained to handle such information under the present Privacy Policy.


Updating the Personal Information of Members

A Member may update its personal information by accessing its account at the Website using its password.  Subsequently it must access “my profile” to update its information.

Also, a Member may access its account at the Website and to its profile to request not to deliver communications or not be contacted by a third party to offer a good or service related to the LifeMiles Program.


Procedure to Exercise the Rights of the Owners of the Information

To exercise the rights provided by applicable law to each Member, the Member may request it through: soporte@lifemiles.com, and LifeMiles BV will follow the respective legal procedures.

LifeMiles BV may be contacted at soporte@lifemiles.com or at the telephone numbers published in the section of assistance on the Website.


Effectiveness and Term

LifeMiles BV reserves the right to modify this Privacy Policy at any time.  Any change shall then be notified and published in www.lifemiles.com

The latest revision of this Privacy Policy was made on October 24, 2016, when it became effective.


Annex - Colombia

In the event in which the personal data processing takes place in Colombia, the following provisions will also be applicable:

The rights of the Member and personal data subjects, in addition to those set forth in this Privacy Policy are the ones established in article 8 of the Colombian Data Protection Law (Law 1581/2012).

Members and personal data subjects are entitled to see and know the details of the processing of personal data required by LifeMiles BV, as well as to rectify them if inaccurate or incomplete and to request their deletion if not used for legal or contractual purposes or when not complying with the purposes and terms set out in this Privacy Policy.

By accepting this Privacy Policy, Members freely and expressly state that they were previously informed about the following rights to which they are entitled by applicable laws as Personal data subjects:

  1. To know, update and rectify their personal data and information before the entity that is responsible or in charge of the processing of their personal data and information.
  2. To request proof of the authorization granted to the entity that is responsible for the processing of their personal data and information, unless such request constitutes an express exception for such processing.
  3. To be informed, upon request, by the entity that is responsible for the processing of their personal data and information about how such personal data and information have been used.
  4. To file complaints before the corresponding authorities for violations to the applicable data protection provisions.
  5. To revoke the authorization and/or request the removal of the personal data and information under the terms of this Privacy Policy.
  6. To access personal data and information that was subject to processing, upon previous request to LifeMiles BV and under the provisions of the corresponding valid and applicable regulations. If the requests exceed one per month, LifeMiles BV will charge the owner requesting such information for its shipment, reproduction and, if applicable, certification costs.

The procedures for the exercise of their rights will be the following:

  1. Consultations: Owners, authorized persons or assignees may access their personal data and information in our databases, in which case we will supply the requested information, after verification of their entitlement to make the request. The request will be processed within a maximum term of ten (10) working days from the date of receipt thereof. In the event such request cannot be processed within said term, we will inform the reasons for the delay, indicating the date on which the request will be processed, which in no case shall exceed five (5) working days from the expiry of the first term.
  2. Claims: If owners, authorized persons or assignees consider that the personal data and information in our databases must be corrected, updated or deleted, or if they become aware of a potential breach to any of the duties set forth in the regulations, they may file a claim before LifeMiles BV, which will be processed under the following rules:
  1. The claim shall be made through a request to LifeMiles BV with their identification, the description of the facts related to the claim, their address, and the accompanying documents they want to enforce. If the claim is incomplete, we will require the missing information within five (5) days from the date of receipt thereof in order to rectify the information. If after two (2) months from the date of request the interested party has not filed the required information, we will consider the claim as abandoned.
  2. If we are not able to resolve the claim, it will be forwarded to the appropriate entity within a maximum term of two (2) business days and will be promptly informed thereof.
  3. The maximum term to process the claim will be fifteen (15) working days from the day following the date of the appropriate receipt thereof. If it is not possible to satisfy the claim within this term, we will inform you of the reasons for the delay and the date your claim will be processed, which in no case may exceed eight (8) working days following the expiry of the first term.
  4. The request to suppress the information and the revocation of the authorization or the request for limitation of use and disclosure of the personal information when the owner has a legal or contractual obligation to remain in the database, in accordance with the provisions of applicable law.

Members and personal data subjects may exercise their rights to know, update, rectify or delete their personal data by sending a request to soporte@lifemiles.com.

The area in charge of taking requests, inquiries or claims before which the Members and personal data subjects may enforce their rights is:

Attention to Clients Division
Edificio Santa Elena, Nivel A y B
Avenida Bella Vista y Calzada El Almendro, Poligono L
Bosques de Santa Elena II, Antiguo Cuscatlan, La Libertad,
El Salvador
Tel.: 330-2030 Option 3
Email: soporte@lifemiles.com

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