Affinion International Limited Company Privacy Policy

The privacy policy sets out how we use any personal information that you give to us, or that we may collect or otherwise process in the course of providing services to you.

1. Who We Are and About this Privacy Policy

This document sets out the privacy policy of Affinion International Limited, ("we", "us", "our" or "Affinion International Limited") in relation to the provision of all our consumer services and our websites. These include any services that you enrol in or otherwise subscribe to and your correspondence with us from time to time in relation to these, whether this be:

online through our service specific and other company websites;
via the telephone when you call our customer service teams;
when you subscribe or communicate with us in writing by email or post;
when we co-ordinate with other institutions in order to provide the relevant services to you (for example insurance underwriters, credit card providers and your bank).

This document explains how we use and process your personal information (meaning any information about you which is personally identifiable or can be related back to you like your name, date of birth, credit or debit card numbers, address, telephone number, email address, preferences, service selections and queries and is generally referred to throughout this policy as "your information").

2. How We Collect and Use Your Personal Information

2.1 General

When you subscribe to any of our services and/or communicate with us about these, you may be asked to provide your information in order to:

authenticate your identity;
register you to receive the relevant services including co-ordinating with other partners in order to do so and to provide such services;
allow us to improve our services to you or to develop new services;
provide you with marketing materials, but only where you have indicated your consent to this (see below for details);
process any query or complaint;
respond to a survey or update your information.

By providing such personal information, you fully understand and consent to the collection and processing of such information. We may record or monitor calls made by you to our customer service desks for quality assurance and training purposes. However, we will always inform you if such recording or monitoring is taking place.

2.2 Information Sharing, Marketing and Disclosure

We may co-ordinate with third parties in the provision of your selected services to you (for example your bank, insurance underwriters and credit providers).

In addition, and with your consent, we (and if applicable, our partners or other trusted third parties) may use your information for certain marketing activities. It is up to you whether we use your information in this way. Our consent notices provided to you when you subscribe for any of our services will generally ask for your permission to send you marketing communications. Such consents relate to:

communications with you from time to time by email and (where you provide us with those details either via the website(s) or elsewhere) by mobile (using SMS or, if your mobile device permits, EMS or MMS messages or similar technologies) and occasionally by post, with information, offers and other material from Affinion International Limited or any of its affiliates which may interest you;
making your information available from time to time to trusted partners and third parties, for them to communicate with you about their products and services as per above.

We may also use your information to conduct market research, for example to ask you to participate in a survey about topical issues, conducted by us or trusted partners or third parties. We will always try to tell you before you participate in the survey how any information you provide in the survey will be used.

Sometimes we may enable third parties acting on our behalf to analyse your information, in a non-personal identifying form, (generally in the form of statistics), so that we can identify trends about usage of our website(s) or services and improve them. We may also request non-personally identifiable information from you, such as annual income, buying preferences, or your age, also known as demographic and profile data, though this information is optional. We may use this data to improve and enhance your experience on the Affinion International Limited web sites. We may also share this information with others, such as advertisers interested in advertising on the Affinion International Limited web sites, in aggregate, anonymous form, which means that the shared information will not contain nor be linked to any personally identifiable information about you or any other person.

Additionally we reserve the right to access and disclose your information in order to comply with applicable laws, to comply with lawful requests from governments, law enforcement agencies or parties whose request we reasonably consider to be justified in connection with any allegations by any party about your abuse of our services, to operate our systems properly or to protect ourselves or our users.

3. Automatic Information

Please note that this section is only relevant in relation to information that we may collect and process in connection with your use of our websites.

3.1 Cookies

"Cookies" are pieces of information that may be placed on your computer by a web site for the purpose of facilitating and enhancing your communication and interaction with that web site. Almost all web sites use cookies for these purposes.

Examples of the information that we collect and analyse using cookies include log-in; email address; password; the internet protocol (IP) address used to connect your computer to the internet; browser type and version; operating system and platform you use to connect; cookie number; areas of the web site(s) you viewed or searched for; the Uniform Resource Locators (URLs) from or through which you visited our web site(s) and from which you left it, including date and time.

We may use cookies (a) to customise your visit to Affinion International Limited web sites, (b) to deliver content consistent with your stated interests and the manner in which you browse and/or buy on our site, (c) to save your password (if you have registered with us) so you don't have to re-enter it each time you visit our site, and (d) for other purposes to make your visit more convenient.

At times, some of our advertisers or their ad serving and tracking providers may set cookies when you select their ad banner and some of our content providers or partners may also set cookies when you visit those portions of our site over which they have control. We do not receive the data collected by those cookies. In addition, we reserve the right to supplement the cookie data which we collect from you with information collected by cookies set by third parties in order to understand how you use the Internet and what products are of interest to you. The information that we receive from these third parties is only aggregate, non-personally identifiable information.

You may stop or restrict the placement of cookies on your computer or flush them from your browser by adjusting your Web browser preferences, in which case you may still use our site, but it may interfere with some of its functionality. We do not use cookies to retrieve information from your computer for purposes that are unrelated to Affinion International Limited web sites or your interaction with Affinion International Limited web sites.

3.2 Internet Protocol (IP) Address

Where you are using our websites, we may use your IP address to help diagnose problems with our server and to administer our web site. Your IP address may also be used to help identify you for the duration of a session and to gather broad demographic information. Your IP address will never be linked to any personally identifiable information unless you are in the process of making a purchase, in which case the link between this information will terminate upon your final purchase.

3.3 Clickstream

As you use the Internet, a trail of electronic information is left at each web site you visit. This information, which is sometimes referred to as "clickstream data", can be collected and stored by a web site's server. Clickstream data can tell us the type of computer and browsing software you use, the address of the web site from which you linked to a Affinion International Limited web site, and, in some instances, your e-mail address. We may use clickstream data to determine how much time visitors spend on each page of our site, how visitors navigate throughout the site and how we may tailor our web pages to better meet the needs of visitors. This information will only be used to improve the Affinion International Limited web sites. Any collection or use of clickstream data will be anonymous and aggregated and will not contain any personal information except where you have selected an email address that identifies your name.

4. Unsubscribing/Amending your information

You can update and correct your information held by us by sending an email to enquires@affinioninternational.com or writing to Affinion International Limited, Charter Court, 50 Windsor Road, Slough, Berkshire, SL1 2EJ or by calling +44 (0) 1753 828 600.

You can remove your information from our marketing database entirely by emailing, writing or calling us using the contact details above, specifying your name, the email or other address/ telephone number you used to register with us and, if referring to a web registration, your user name in the email.

If you only want to remove your information from marketing communications in relation to a specific service simply email, write to us or call us using the above contact details with the information above and the name of the service.

Alternatively, whenever we contact you, (for example to send you an email newsletter which you have requested) you will normally find an email or other address at the bottom of the email, which you can use to tell us if you no longer wish to receive the newsletter or other communication in question.

5. Security

Securing your personal and non-personal information is very important to us. All customer databases are held in a secure environment and (except for law enforcement authorities in limited circumstances), only those Affinion International Limited employees or other persons who need access to your information in order to perform their duties are allowed such access. Any of these employees or persons who violates our privacy and/or security policies may be subject to disciplinary action, including possible termination and civil and/or criminal prosecution.

Where you are using our websites, we attempt to provide for the secure transmission of your information from your computer to our servers by utilising encryption software. However, due to the inherent open nature of the Internet, we cannot guarantee that communications between you and Affinion International Limited, and Affinion International Limited and you, will be free from unauthorised access by third parties, such as hackers.

Our web sites utilise Standard SSL encryption on pages where secure information is transmitted over the Internet. We also use Verisign as our Certificate of Authority. If you would like more information on our Verisign Certificate, click on the seal below.

6. Business Transfers

In the unlikely event that we sell or otherwise dispose of some or all of our business to another party, we reserve the right to transfer your information as part of any assets sold or disposed of.

7. Transfers Overseas

Your information may be transferred outside of the European Economic Area for processing.

Affinion International Limited's affiliate companies in the United States to which your information may be transferred are part of the US Safe Harbour. For more details on this you can see the Information Commissioner's site at: www.dataprotection.gov.uk

Any transfer of your data is done in circumstances ensuring that your data is processed only in accordance with this privacy policy and the UK's Data Protection legislation. By registering on this site and consenting to these terms, you are consenting to this transfer.

8. Other Sites

Our web sites may contain links to other web sites. Other web sites may also reference or link to the Affinion International web sites. Affinion International Limited is not responsible for the privacy practices or the content of such other sites.

9. Your Acceptance of this Policy

In providing personal information to us or using our web sites you signify your assent to our Privacy Policy. If you do not agree to this policy, please do not use Affinion International Limited web sites or provide your data to us. This Privacy Policy supersedes all privacy policies and other similar standards previously issued by us. Since the privacy standards set forth herein are subject to updates and other changes from time to time, please note that this Privacy Policy is subject to change at any time. In the event of any such changes, we will notify all of our members and other customers of such changes in the manner to the extent required by law. Your continued use of our site and services following the posting of changes to these terms means you accept these changes.

This policy was last updated 25 November 2005.