At Asia Miles, we are committed to protecting your Personal Data and your privacy. To ensure that you can make informed decisions and feel confident about sharing certain personal information with us, please read this Privacy Policy to understand who we share your Personal Data with and for what purposes, and the choices you have concerning how your Personal Data is collected and used by us. We may also provide further privacy collection notices highlighting certain uses of your Personal Data, together with the ability to opt in or out of certain uses, when we collect Personal Data from you. The laws of certain countries require us to provide you with additional information about our processing activities and we have included separate appendices to deal with these. As well as this document, please refer to the appendices which apply to you. We will notify you of any changes to our Privacy Policy, including by posting the revised policy on www.asiamiles.com. The changes will be effective from the date of posting.

2.1    We will collect and process some or all of the following Personal Data about you:

(a) Information about you and your membership►Your personal information such as your name, gender, date of birth, nationality, contact details, travel document, your membership number, your username and records of your earning and redemption activities, and details about your redemption group nominees, your parents’/guardian’s names and contact details if you are aged between 2-17, photographs and other images, seat and meal preferences, and any information relating to any special assistance that you require from airline partners such as dietary requirements or health issues; 

(b) Your payment details► Payment details used to redeem our travel and lifestyle awards such as card holder name, credit or debit card number and expiry date, account information relating to other payment services (such as online or mobile payment services or virtual currency) and billing information;

(c) Information we collect in relation to your earning of mileage credits► Information about your earning of mileage credits with our programme partners such as airlines, hotel operators, providers of other travel-related services, finance and insurance partners, restaurants and retailers;

(d) Information we collect in relation to your redemption of travel and lifestyle awards► Information about your redemption of awards, including your travel itinerary, hotel selection, car rental and other travel-related services, details of your travel companions or persons assisting you, and your choice of other lifestyle and experience awards e.g. events or concerts;

(e) Your interests, preferences, habits and opinions► Information that we collect about your interests, preferences, habits and opinions, such as your hobbies, destinations and awards including products, services and events you are interested in, your opinion on our offers, your feedback and satisfaction scores regarding your redemption experiences;

(f) Our interactions with you► A record of any interactions and correspondence between us such as calls made through our call centre, any interactions you have with our staff or representatives for research (e.g. conversations with research interviewer), and non-research (e.g. AML events) purposes and any interactions with us or posts that refer to us on social media;

(g) Survey information► Your responses to surveys, research and contests (for examples stories, photos, ideas, etc.) conducted by us or on our behalf; and

(h) Your use of our website, mobile applications and social media platforms► Details of your visits to our website, your use of social media platforms and our mobile applications and other information collected through cookies and other tracking technology including information that you look at. We may also collect information about you that is publicly available online, including your social media profiles.

2.2    Certain Personal Data (particularly payment details, contact information including delivery address and details of your travel documentation when you redeem certain flights) are required for many of our travel and lifestyle awards and if you fail to supply such Personal Data as requested for specific services, we may be unable to deliver redemption awards in full.

3.1    We will collect some Personal Data from you directly.  We will collect other Personal Data from third parties including:

(a) our service providers and agents such as our call centre agents who provide customer service;

(b) operators of our partner loyalty programmes such as Marco Polo Club;

(c) the third parties that we partner with in connection with Asia Miles, including airlines, hotel operators, providers of other travel-related services, finance and insurance partners, restaurants and retailers;

(d) our third party marketing and research partners;

(e) organisations which conduct credit and fraud checks; and

(f) providers of third party websites, apps and social media platforms.

3.2    If you provide us with information about other individuals such as details of your redemption group nominees, you must tell those individuals and let them know where they can find a copy of this Privacy Policy.

3.3    We allow children under the age of 18 to open Asia Miles Membership accounts provided that they have the consent of an individual who holds parental responsibility for them.  We will rely on this parental consent in respect of both the opening and day to day management of the membership.

4.1    When you share information with us, you help us make our services to you better. Here are some of the ways we will use your Personal Data. 

(a) To operate and facilitate your participation in Asia Miles and other partner loyalty programmes► Where you are a member of Asia Miles, we will use Personal Data that we collect about you for the operations of Asia Miles such as processing your membership application and to ensure that you get the benefit of our programmes and partner loyalty programmes including Marco Polo Club, including to track your earning and redemption activities and record your mileage credits. 

(b) To provide travel and lifestyle awards to you and to administer your earning and redemption  arrangements► To provide travel and lifestyle awards to you such as processing and administering your earning and redemption arrangements including flight and other travel reservation, hotel and event booking and product delivery services, to send you service-related communications, to identify and verify your identity in connection with the services we provide and to provide or facilitate any special assistance you may have asked for;

(c) To tailor and personalise travel and lifestyle awards and offers we provide to you► To tailor and personalise the travel and lifestyle awards and offers that we provide to you.  We may also tailor our communications to you and tailor what we present to you to better match your preferences and interests;

(d) To provide member support► For member support purposes including responding to your enquiries, facilitating special meal and seat requests with airline partners, providing flight re-booking services where flights are delayed or cancelled, and providing general assistance and relaying your feedback and comments to our programme partners;

(e) For marketing purposes► For providing you with marketing communications, as explained in more detail in section [6] below;

(f) For social interactions► To administer campaigns, contests and sweepstakes conducted by us when you choose to participate in them, including disclosing the winners of any such contests;

(g) To improve Asia Miles► For the purposes of improving our programme for the benefit of our members generally, including to ensure that our websites, mobile applications and web pages (including social media pages) function correctly and in accordance with your preferences and circumstances;

(h) For legal and administrative purposes► For legal and administrative purposes such as to comply with our legal and regulatory obligations, verifying and processing payment, screening against fraud, criminal or unlawful activities, or abusive redemption activities and identify suspicious membership accounts that may breach the Asia Miles Terms & Conditions, accounting, billing and audit purposes, developing, maintaining and testing our systems, for claims handling and for understanding, exercising, enforcing or protecting our legal rights and those of others.

In certain circumstances, we will disclose your Personal Data to third parties as described below: 

5.1    Third parties such as programme partners in order to facilitate and administer your  earning and redemption arrangements► We may transfer your Personal Data to programme partners including airlines, hotel operators, providers of other travel-related services, finance and insurance partners, restaurants and retailers.  We may also disclose your Personal Data to third parties in order to facilitate any special arrangements that you may have requested, such as relaying your special meal or seat requests to our partner airlines.

5.2    Our service providers and members of the Cathay Pacific[1]  group who process personal data on our behalf for the purposes described in section 4 ► We will permit our third party service providers, including agents, contractors and other Cathay Pacific group companies, to use your Personal Data on our behalf for the purposes set out in section 4.  Examples of such third parties include operators of our IT systems and call centre agents.

5.3    Our third party partners, for marketing, research and analytics purposes► We may disclose your Personal Data to third parties, including Cathay Pacific, so they can provide marketing services or conduct marketing or social interaction activities on our behalf such as campaigns, contests, sweepstakes, market research, member surveys and data analytics to help us improve and tailor our marketing activities, products and services.  Subject to us having obtained appropriate consent from you, we may also disclose your Personal Data to our third party programme partners, including Cathay Pacific, in order that they may market their products and services to you. If you are a member of the Marco Polo Club, we will also share your Personal Data with Cathay Pacific for the above purposes, as well as to enable Cathay Pacific to combine your Personal Data with the personal data they hold about you. 

5.4    Our Partner Loyalty Programmes► We may transfer your Personal Data to the Marco Polo Club, or to operators of our partner loyalty programmes, to facilitate your participation in the relevant programme.

5.5    Government and regulatory bodies and other individuals, bodies and organisations(for example regulators and the police) for the purposes of complying with our legal obligations, to enable us to provide our travel and lifestyle awards to you, as well as for legal and administrative purposes►  “We may disclose your Personal Data to governments, regulatory authorities and bodies and to other individuals, bodies and organisations such as dispute resolution, prosecution and law enforcement bodies, legal advisers, and organisations which conduct credit and fraud checks, for the purposes of complying with our legal obligations. We may also disclose your Personal Data to such individuals, bodies and organisations to enable us to provide our travel and lifestyle awards to you, as well as for any legal and administrative purposes.” 

6.1    We may use Personal Data for marketing and promotional purposes, including (i) for sending or showing you updates on latest news, offers and promotions, including contests and sweepstakes, in connection with Asia Miles; (ii) for sending or showing you joint marketing offers about our programme partners including airlines, hotel operators, providers of other travel-related services, finance and insurance partners, restaurants and retailers, including contests and sweepstakes; or (iii) for tailoring and tracking your interactions with internet banner advertisement and links from third party websites to our website.

6.2    We may also use Personal Data to analyse our members’ preferences and market trends and derive insights, which we may use to tailor the types of travel and lifestyle awards and offers that we present to you. This may involve us combining Personal Data that we hold about your use of our services with information that we have collected about your web usage. We may also combine information that we have collected about you with information that we have collected about our other customers in order to derive these insights and establish market trends. We may provide these insights to Cathay Pacific and our third party programme partners for their marketing and promotional purposes. We also use advertising services and products provided by third party service providers (such as marketing agencies and social media platforms) for marketing and promotional purposes, which may involve us sharing Personal Data that we hold about you with them.

6.3    We may communicate marketing, promotions and research invitations to you by post, telephone, or online (including by email or through your mobile device or via online banner advertisement) and, as appropriate and where required, we will ask you for your consent, or otherwise provide you with the opportunity to choose not to receive marketing, at the time we collect your data.

6.4    We will provide an option to unsubscribe or opt out of further communication on any direct marketing communication sent to you. You may also opt out by contacting us as set out in paragraph 8 below.

6.5    Please note that if you choose to unsubscribe or opt out of marketing communication, you will still continue to receive administrative emails, account summaries and updates to our services.

IT Security

7.1    No data transmission over the Internet, a website, mobile application or via email or other message service can be guaranteed to be secure from intrusion.  However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your Personal Data in accordance with the requirements of data protection legislation.

7.2    All Personal Data we collect about you is stored on our or our subcontractors’ secure servers. We comply with our security policies and standards when accessing or using this information and restrict access to your Personal Data to those persons who need to use it for the purpose(s) for which it was collected.  You are responsible for keeping any information that we send to you confidential and for complying with any other security procedures that we notify you of.  In particular, where we have given you (or where you have chosen) a password which enables you to access certain parts of our website or mobile applications, we ask you not to share your password with anyone.

Exporting your Personal Data

7.3    Your Personal Data may be transferred outside the country in which you are located, including to countries with a lower level of data protection than in the country in which you are located.

Retention period

7.4    We will retain your Personal Data for as long as is necessary for the processing purpose(s) for which it was collected and any other permitted linked purpose (for example where we are required to retain personal data for longer than the purpose for which we originally collected it in order to comply with certain regulatory requirements).  Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymised (and the anonymised information will be retained) or securely destroyed. 

8.1    General rights

You have the right (subject to various exceptions and in accordance with data protection legislation in your country) to access certain Personal Data held about you and correct any inaccuracies. We may charge a reasonable fee for the processing of any data access request in accordance with data protection legislation in your country. You also have the right to raise a complaint about our processing with the data protection regulator in your jurisdiction.

8.2    Right to opt out of direct marketing

You have the right to ask us not to process your Personal Data for direct marketing purposes.  You can exercise your right to prevent such processing by indicating that you do not consent to direct marketing at the point at which we collect your Personal Data.  You can also exercise the right at any time after we have collected and used your Personal data for direct marketing purposes by: 

(a)   following the opt out instructions contained in the relevant communications; or  

(b)   updating your email subscriptions here for AML newsletter .

8.3    Updating information 

We will take reasonable steps to try and ensure that your Personal Data is accurate.  To help us do this, please notify us of any changes to your Personal Data. 

8.4    Contacting us

Mail box address: DPOAML@cathaypacific.com

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This website contains links to other sites that are operated by third party companies with different privacy practices.  You should remain alert when you leave our site and read the privacy statements of other websites.  We have no control over Personal Data that you submit to or receive from these third parties.

This Appendix applies if you are based in the European Economic Area (the EEA) during your interactions with us (other than where you are in the EEA solely for travel purposes).