Effective Date: May 17, 2023
LoungeBuddy, Inc. (hereinafter “LoungeBuddy,” “we,” “our,” or “us”) is committed to safeguarding your privacy. LoungeBuddy is owned by American Express.
- services we operate, such as our websites and mobile applications (“apps”);
- services or content that we offer on third party platforms, such as our electronic communications, social media pages, and digital advertisements; and
Our websites and apps are not intended for individuals under the age of 18 years of age (or the age of majority in the location in which they reside or where a LoungeBuddy lounge is located) (“Minors”). We do not knowingly collect information online from or market online to Minors.
Other Applicable Privacy Policies or Notices
Third-party services, such as our lounge partners’ websites or social media websites, have additional terms that explain how operators of those services collect, use, or disclose your information. Please review the terms of the specific online services you use in connection with LoungeBuddy’s apps and services.
A. Information We Collect
B. Use of Information
C. Sharing & Disclosing
D. Aggregated and Anonymized Information
F. Your Data Rights
G. Your Choices
H. Contacting Us
J. Information for European Economic Area (EEA) and United Kingdom Residents
K. Information for United States Residents
A. INFORMATION WE COLLECT
The type of information we collect depends on which product or service you use. In some cases, we collect information if you directly provide it to us. We may collect the following types of personal information directly from you:
- account login information, such as e-mail address and password when you register for a LoungeBuddy account;
- profile information, such as first and last name, picture, phone number;
- your lounge access method, including your card type, military membership, flight information, or other information that you enter into our app to access a lounge;
- payment details when you purchase entry to a lounge or otherwise enter your card number into the app, including your payment card number, security code, expiration date, cardholder name and billing address;
- user content, such as photos, reviews, and other user generated materials;
- communications between you and LoungeBuddy, including any files or attachments; and
- location information, including country of residence and geolocation data (if you enable geolocation data on your device).
In some instances, LoungeBuddy’s collection and processing of your personal information is mandatory to provide you with LoungeBuddy’s products or services. If you decide not to provide your personal information to us, we might not be able to provide you with that product or service. Any personal information that you provide for marketing purposes is voluntary. If consent is required for marketing by applicable law, you can revoke your consent for marketing (see the “Your Choices” section below).
When you give us consent or enable geolocation on your device, we will collect the latitude and longitude coordinates of your device when you are searching for lounge availability. We use this information to help us improve the relevance of search results and streamline the lounge reservation processes. This information is only collected while the app is running. If you would like to revoke your consent for location tracking, please see the "Your Choices" section below.
We also may use general geographic data inferred from your IP address to identify where you are located to make available lounge reservations more relevant or to personalize your experience.
Cookies and Similar Technologies
We also collect information through Cookies and Similar Technologies when you use our online services or access online content.
A “Cookie” is a small amount of data that a website transfers to your computer. We place Cookies when you visit our website or another company’s website where our ads appear or when you make a reservation or request certain services. If you accept the Cookies used on our website, websites that are “powered by” another company on our behalf, or websites where our ads appear, you may give us access to information about your interests. We use that information to personalize your experience. “Similar Technologies” include clear GIFs, web beacons, and pixel tags, which are typically transparent images on websites. Cookies and Similar Technologies may also help LoungeBuddy or its service providers collect information about your device, operating system and web browser, as well as your use of the device, as described in more detail below.
The information we collect using Cookies and Similar Technologies may include
- the device(s) you use (for example, the operating system or type of device you use to open electronic communications from us);
- information about your IP Address (for example, domain information, internet provider information and general geographic location);
- how you use our websites and apps, such as what you search for on our websites and apps, the pages you view, how long you stay and how often you visit them;
- how you search for our websites or apps, which website or app you came from, and sometimes, whether you have visited a website of one of our business or commercial partners;
- which ads or online content from us and our business or commercial partners you view, access or click on; and
- whether you open our electronic communications and which sections you click on (for example, how many times you open an email from us).
If you use your mobile device to access our products or services, we may collect information about your mobile device (for example, we collect location information to provide location-based content you request).
Other Sources of Information
As outlined above, we may collect or receive information about you from other sources in accordance with product or service-specific privacy notices we give to you. For example, we may receive information about your reservation from any lounge where you make a reservation, including your reservation check-in information and any feedback from the lounge regarding your experience.
B. USE OF INFORMATION
We use information about you either on its own or combined with other information and in accordance with applicable law: (i) where it is necessary to administer our contractual relationship with you; (ii) for our own business interests to provide you with better products and services; (iii) where we have obtained your consent, such as for certain marketing purposes; or (iv) for compliance with applicable laws.
More specifically, we may use information about you:
For administering our contractual relationship with you and delivering our products and services to you, including to:
- process your reservations, e.g., we may provide your personal information to a lounge you select, as described in the “Sharing & Disclosing Information” section;
- manage your account;
- update you about new features and benefits;
- provide location-based services you may request; and
- better communicate with you.
For our business interests, for the business interests of our partners, or as permitted by applicable law, we may use information about you to:
- conduct research and analysis to better understand our online visitors, customers and our business, including to:
- request feedback or reviews about our products and services and those of our commercial and business partners;
- improve our websites or apps and make them easier to use;
- place you in groups with similar customers to make predictions about you, deliver more personalized services and help determine whether you may be interested in new products or services.
- manage our business risks, such as fraud and security risks by using the location and other technical attributes of your mobile device or browser.
- conduct research and analysis to better understand our online visitors, customers and our business, including to:
With your consent, to:
- promote our products and services, where required by law;
- recognize you when you return to our websites, receive our emails, or use our apps including across multiple devices (for example, to send you tailored ads, promotions, offers or content, including targeted advertising). Please refer to the “Cookies and Similar Technologies” section above for more information.
To comply with applicable laws and regulation around the world, we may use information about you to establish, exercise, or defend legal rights or claims and assist in dispute resolution or as otherwise required or permitted by law.
C. SHARING & DISCLOSING INFORMATION
We may share or disclose information about you, including with:
- our service providers, who perform services for us (for example, printing, mail, advertising, marketing, etc.) and help us operate our business (we require all of our service providers to protect personal information according to our standards, and use it only for the purposes we allow);
- regulatory authorities, courts, and governmental agencies to comply with legal or regulatory requirements, assist in legal or regulatory investigations, and protect the rights of American Express or others;
- companies within the American Express Family of Companies;
- business or commercial partners (for example, other financial institutions, loyalty programs, travel partners, and certain advertising partners) with whom we offer or develop products and services;
- necessary parties in the context of a sale of all or part of a company in the American Express Family of Companies or its assets; or
- with other third parties as required or permitted by law or with your consent.
Cross-Border Transfers of Personal Information.
Additional information about cross-border transfers of personal information from the following jurisdictions can be found in the section titled “Additional Information for European Economic Area (EEA) or United Kingdom Residents.”
D. AGGREGATED AND ANONYMIZED INFORMATION
We sometimes process information so that it no longer identifies any individual; this information is referred to as aggregated and anonymized information. We use aggregated and anonymized information to:
- analyze patterns among groups of people (such as online users);
- create business insights or statistical research/reports;
- improve our advertising and our business.
We sometimes share aggregated and anonymized information with third parties, for many of the same reasons that are described above.
We use administrative, organizational, technical and physical security measures to protect the confidentiality, integrity, and availability of personal information. Here’s what you should know:
- these measures include technological safeguards and appropriate access controls to data and facilities;
- we require service providers to safeguard personal information and only use it for the purposes we specify;
- we take reasonable steps to securely destroy or de-identify personal information when we no longer need it.
We keep personal Information as long as necessary to provide you with products or services, unless we are required or permitted to keep it for longer by law, regulation or for the purposes of litigation or regulatory investigations.
F. YOUR RIGHTS
Depending on the privacy laws in your country of residence and your relationship with LoungeBuddy, you may have certain legal rights regarding your personal information. Information about the specific rights available to you based on your country of residence can be found in the sections titled “Information for European Economic Area (EEA) or United Kingdom Residents” and “Information for United States Residents.”
If you would like more information regarding the rights you may have, if you want to exercise any of your rights, if you have questions about how we process information about you, or if you would like to make a complaint, please contact us at [email protected].
If we receive a request from you regarding your rights provided under applicable law, we’ll do our best to address your request as soon as possible and no later than required by the privacy law applicable to your request. If you do not feel your request is satisfactorily addressed, you can follow up via the email address above or submit your request in writing to: LoungeBuddy, c/o American Express, 200 Vesey Street, New York, NY 10075, United States. If we can’t meet the deadline to respond to your inquiry that is set by the applicable privacy law of your country of residence, we’ll contact you to explain the cause of the delay and provide an expected time for the response.
Where permitted under the applicable law of your country of residence, you also may contact the applicable local Data Protection Authority directly. You may also have the option to take your case to the court where you live, work, or where there may have been an infringement.
G. YOUR CHOICES
You have choices about how LoungeBuddy uses information about you for marketing and advertising. The choices available to you may differ depending on whether we are communicating with you through a website, email, app, or social media. We will always respect the choices you make.
Mobile apps.You may exercise choices through your mobile device settings, including by turning off location-based services and device ad tracking.
Email.If you no longer want to receive direct email marketing communications from us, you can opt out by clicking unsubscribe on the bottom of an e-mail communication and following the instructions. Keep in mind, even if you opt out of direct marketing emails, we may still communicate with you to service your account, fulfill your requests, or administer any program in which you have elected to participate. These communications are necessary for us to inform you about the services we provide to you.
H. CONTACTING US
If you are a customer and would like to update your personal information, you can log in to your LoungeBuddy account at any time by clicking on "Account" then "Edit Profile" in the LoungeBuddy app.
J. ADDITIONAL INFORMATION FOR EUROPEAN ECONOMIC AREA (EEA) AND UNITED KINGDOM RESIDENTS
Cross-Border Transfers of Personal Information
Use of Information
Where we say that we use your information as described in the “Use of Information” section above for our business interests, legitimate interests. Please note that we consider and balance any potential impact on you and your rights before processing your personal information for our legitimate interests.
Your Data Rights
Data Subjects in the EEA and the United Kingdom are provided certain legal rights regarding your personal information, including the right to:
- request details on or access the personal information we have about you;
- restrict and/or object to the use of personal information;
- request a manual review of certain automated processing activities that may impact your legal or other contractual rights;
- correct of the personal information we have about you;
- receive your personal information in a structured, commonly used and machine-readable format and/or transmit such data to another data controller; and
- withdraw the consent you have given for the processing of personal information at any time.
If you have questions, you may reach our Data Protection Officer at [email protected], or our member representative by clicking here or emailing [email protected] quoting LoungeBuddy, Inc. in the subject line.
K. ADDITIONAL INFORMATION FOR UNITED STATES RESIDENTS
Your Data Rights
LoungeBuddy is an affiliate of American Express. If you reside in the United States and primarily use LoungeBuddy for personal or family purposes, you are provided with the following rights under the Gramm-Leach-Bliley Act, a federal financial privacy law:
- Opting out of sharing with affiliates: If you do not want your personal information/personal data shared with our affiliates, such as the American Express family of companies, who may use such information for direct marketing purposes, then you may opt out of such sharing by sending an email to [email protected]. Please note that if you opt out in this manner, certain aspects of the Services may no longer be available to you. We will process your request within a reasonable time after receipt.
If you would like to change your choices regarding direct marketing, please see your options in the “Your Choices” section above. If you would like to limit our sharing of your personal information, contact us at [email protected].
California ("CA") residents who primarily use LoungeBuddy for personal or family purposes are provided rights under the Gramm-Leach-Bliley Act, a federal financial privacy law, not the California Consumer Privacy Act ("CCPA"). These rights are described above. California residents may receive additional protections under the California Consumer Privacy Act ("CCPA") for "personal information." Under CCPA, personal information includes information that identifies or could reasonably be linked with a particular individual or household. It does not include information that is publicly available or that has been de-identified or aggregated. This section describes the categories of personal information that LoungeBuddy collects, the purposes for which that information is collected, and any rights you may have with respect to your personal information.
Categories of Personal Information We Collect
Depending on the nature of your relationship with LoungeBuddy (e.g., you are the company representative of a lounge operator), we may have collected the following categories of personal information, including sensitive personal information, about you during the preceding 12 months:
- Identifiers such as name, online identifier, internet protocol address, email address and account name;
- Information that identifies, relates to or is capable of being associated with, a particular individual, such as name, passport number, driver’s license or credit card number, or other financial information;
- Characteristics of protected classifications under California or federal law such as age, sex/gender or marital status;
- Commercial information such as your purchase history
- Internet or other electronic network activity information such as browsing history;
- Geolocation data, available through your device, including precise geolocation data, if enabled;
- Audio, electronic, or similar information;
- Professional or employment-related information;
- Education information;
- Inferences drawn from some categories of information identified above, including about your preferences.
For each of these categories of personal information, please refer to the "Use of Information", “Sharing & Disclosing Information”, and "Security" sections above for more detailed information regarding our purposes for collecting personal information, our sources of personal information, the length of time we retain personal information, and the categories of third parties with whom we may share personal information.
We do not collect or process sensitive personal information for the purpose of inferring characteristics about you and therefore do not offer the choice to limit the use or disclosure of sensitive personal information.
Your CA Privacy Rights
As a California resident, you may have certain rights over the personal information we have about you. Pursuant to the CCPA, you may have the right to request:
- Access to your personal information in a portable format, or other information about our data processing practices;
- Deletion of the personal information we have collected from you; and
- Correction of the personal information we have collected about you.
We will not discriminate against you if you choose to exercise any of these rights. These rights are subject to limitations, such as when we retain personal information to comply with our own legal obligations.
To exercise your rights or if you have any questions or concerns, please contact us at [email protected]. We may need to validate certain information about you to verify your identity before we can fulfill your request. If you are making a request for access, deletion, or correction rights on behalf of another person, we may require you to provide proof that you have been designated as their authorized agent.