Plusgrade Privacy Policy
Effective Date: August 1, 2015

Introduction

Plusgrade provides a software product that enables travel and hospitability companies to offer travelers the opportunity to enhance their travel experience, subject to each company's individual discretion and the availability of the offering. Protecting consumer privacy is important to us and to the companies to which we provide services. As such, Plusgrade makes it a high priority to ensure the security and confidentiality of the personal information that is provided to us and that is used in the processing of the information by our software. This Privacy Policy identifies the purposes for which personal information is collected, used and disclosed by Plusgrade.

EU Safe Harbor

Plusgrade complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Plusgrade has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Plusgrade’s certification, please visit http://www.export.gov/safeharbor/

Personal Information - Collection and Use

Personal information that Plusgrade collects will be used for the purposes for which it was collected and in accordance with the form of consent required by applicable law. As a third-party service provider, primarily to companies in the travel and hospitality industry, Plusgrade generally receives personal information that was initially disclosed to the travel and hospitability companies in connection with a travel booking or purchase. In addition, consumers may disclose additional information on Plusgrade's own website or hosted pages or various applications. The information we collect may include: name, email address, postal address, telephone number, booking confirmation number, frequent flyer or loyalty program number, frequent flyer or loyalty program status level, travel itinerary information, fare type, value of goods or services under consideration for purchase (either in monetary terms or in loyalty points), the number of travelers, and credit card information. We use this information to provide products and services to you, either directly or via the travel and hospitality companies that we work with to build features that will make our products and services easier to use, and to contact you about our products and services.

Plusgrade will also collect non-personal or other non-identifiable information, and when such information is collected and is associated to an individual, it shall be treated as personal information for the purposes of the Privacy Policy. Such information, whether associated with an individual or not, may be used (1) to administer the Plusgrade website, its hosted pages, or its various applications, (2) to diagnose system issues, and (3) to enhance the product. Examples of this type of information include the usage of the Plusgrade website or hosted pages or various applications, and the domain names and addresses of the users' internet service providers. The methods by which Plusgrade obtains this information vary, but one method may include the use of cookies, which are data files stored on an individual's computer and which are associated with a domain and a browser. Cookies allow a domain to identify whether a user has visited the site before, to remember some types of information the user may have previously provided, and to track site usage.

Choice

When Plusgrade collects personal information, how it may be used depends in part on the form of consent at the time such information was made available by the individual. As noted in "Personal Information – Collection and Use", the use of an individual's personal information will be limited to the objectives for which it was collected. Regardless, the form of consent can vary from implied consent to express consent, depending on the circumstances and the sensitivity of the type of information collected. Consent may have been obtained from the travel and hospitality companies that Plusgrade works with on their respective websites where an individual's personal information was originally collected. In such circumstances, Plusgrade may not be required, depending on applicable law, to obtain express consent, but will receive and process the information under implied consent. Nevertheless, Plusgrade will offer individuals the opportunity to choose (i.e., "opt out") whether their personal information is (1) to be disclosed to a third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

With respect to sensitive personal information, where "sensitive" is defined as information about an individual's race, ethnic origin, sexual orientation, political views, religious or philosophical beliefs, trade union membership, or information that concerns an individual's health, Plusgrade will provide an opportunity to affirmatively or explicitly consent (i.e., "opt in") to the disclosure of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized.

Onward Transfers

Plusgrade only transfers personal information to third parties that have provided written assurances that they offer the same level of privacy protection as that provided for by the U.S.-EU Safe Harbor Framework principles or are subject to laws providing for the same level of privacy protection. In addition, without further notice to you, you explicitly consent that Plusgrade may share personal information with third parties in certain circumstances, including:

Access

Plusgrade shall allow individuals access to their personal information and allow individuals to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated.

Data Security

Plusgrade shall take reasonable precautions, including the implementation of appropriate physical, electronic and administrative procedures), to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. Although we employ technical safeguards, we cannot guarantee the security of personal information on or transmitted via the Internet.

Plusgrade's data security practices include the use of data encryption, layered firewalls, strong password protection protocols, and other security technologies to prevent unauthorized access to our systems. In addition, our employees and any third parties we use are contractually bound to protect the confidentiality of your information, and access is restricted to those with a need to know the information to carry out the identified purpose.

Data Integrity

Plusgrade only processes personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, we take reasonable steps to ensure that personal information is accurate, complete, current and reliable for its intended use.

Enforcement

Plusgrade uses a self-assessment approach to assure compliance with this Privacy Policy and periodically verifies that it is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible, and in conformity with the principles articulated in the US-EU and US-Swiss Safe Harbor Principles. In compliance with the US-EU and US-Swiss Safe Harbor Principles, Plusgrade commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss citizens with inquiries or complaints regarding this privacy policy should first contact Plusgrade via postal mail or email using the information listed under the Contact Information section below.

Plusgrade has further committed to refer unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Plusgrade, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

Amendments

This Privacy Policy may be amended from time to time consistent with the requirements of the U.S-EU Safe Harbor Framework and/or the U.S.-Swiss Safe Harbor Framework. We will post any revised policy on this website.

Contact Information

Questions, comments or complaints regarding our Privacy Policy or data collection and processing practices can be mailed or emailed to:

Plusgrade LP
16 West 36th Street, 4th Floor
New York, NY 10018
Attn: Privacy Policy
info@plusgrade.com