Effective Date: 10 April, 2020

Welcome to LoungeBuddy ("LoungeBuddy," "we," "us" or "our"). LoungeBuddy provides a fast, easy way to find airport lounges, explore amenities, understand access requirements, and share your airport lounge experiences with photos, reviews, and ratings.

Our Privacy Policy (the "Policy") explains how we collect, use, share and protect your personal information when you access or use our LoungeBuddy mobile applications and services, website (loungebuddy.com), any software or application programming interfaces ("APIs") provided on or in connection with LoungeBuddy services, or any other websites, content, features or pages owned or operated by us (collectively, the "Services"). In addition, this Policy describes your choices about the collection and use of your information. Our Policy applies to all visitors, users, and others who access the Service ("Users").

Acceptance

Please read the Terms of Use before using our Services. By accepting the Terms of Use, you agree with our privacy practices as described in this Policy. If you do not agree with this Policy or the Terms of Use, please stop accessing or using our Services.

Changes to our privacy policy

LoungeBuddy may modify or update this Policy from time to time, so please review it periodically. We may provide you with additional forms of notice as appropriate under the circumstances, such as email notices to the most recent email address we have on file on you. Your continued use of LoungeBuddy or the Service after any modification to this Policy will constitute your acceptance of such modification.

In addition, we may provide you with "just-in-time" disclosures or additional information about the data handling practices of specific parts of our Services. Such notices may supplement this Policy or provide you with additional choices about how we process your personal information.

Information we collect

We may collect the following types of information:

Information you provide us directly:

Account information. When you sign up for our Services, we collect your username, password and e-mail address when you register for a LoungeBuddy account.
Profile Information. You can provide us with additional information in your user profile (e.g., first and last name, picture, phone number). This information is provided by you voluntarily. This information allows us or other users to find you on LoungeBuddy by searching for your user profile information.
Payment Details. When you purchase access to a lounge via the Service, we collect your payment card number, security code, expiration date, cardholder name and billing address.
User Content. We provide a platform for you to create, upload, and share photos, comments, and other materials ("User Content"), and we collect any User Content on our platform.
Communications Between Users and LoungeBuddy. We collect any communications between us, including any files or attachments we exchange. For example, we may send you Service-related emails (e.g., account verification, changes/updates to features of the Service, technical and security notices).
Contacts List. Upon your instructions, LoungeBuddy collects information about your contacts list. If you choose to invite someone to the Service, you may select a person directly from the contacts list on your device and send a text or email from your personal account. Such invitations come directly from your personal account, and LoungeBuddy does not have access to or control this communication.
Geolocation Data. We will collect geolocation data if you choose to share it with us so that we can more accurately filter results on our Services. We may be able to approximate your geolocation based on other information you provide, such as your profile.

Information we automatically collect about you:

Activity Data. We collect information about your use of the Services through third-party analytics tools. These tools collect information sent by your device or our Services, including the web pages you visit, add-ons, and other information that assists us in improving the Service. We de-identify or aggregate such information so that it cannot reasonably be used to identify any individual User.
Cookies and Similar Technologies. When you visit the Services, we may use cookies and similar technologies like pixels, web beacons, and local storage to collect information about how you use LoungeBuddy and provide features to you. Also, we may ask advertisers or other partners to serve ads or services to your devices, which may use cookies or similar technologies placed by us or the third party. Please see the Cookie Policy for more information.
Log File Information. Log file information is automatically reported by your browser each time you make a request to access (i.e., visit) a web page or app. It can also be provided when the content of the webpage or app is downloaded to your browser or device. When you use our Service, our servers automatically record certain log file information, including your web request, Internet Protocol ("IP") address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our Users which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service.
Device Information. When you use a mobile device (e.g., a tablet or smartphone) to access our Services, we may access, collect, monitor, store on your device, and/or remotely store one or more "device identifiers." Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device's operating system or other software, or data sent to the device by LoungeBuddy. A device identifier may deliver information to us or to a third party partner about how you browse and use the Service and may help us or others provide reports or personalized content and ads. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.
Metadata. Metadata is usually technical data that is associated with User Content. For example, Metadata can describe how, when and by whom a piece of User Content was collected and how that content is formatted. We may add or may have Metadata added to User Content including a hashtag, geotag (e.g., to mark your location to a photo), comments or other data. This makes your User Content more searchable by others and more interactive. If your image has a geotag your photo, your latitude and longitude will be stored with the photo and searchable (e.g., through a location or map feature).

Information we obtain about you from third party sources:

Third-Party Services. Upon your request, we may collect or share information about you or others from third-party products or services integrated into our Services. For example, you can request us to import your contact information from your Google email account, or to share your transaction data for expense reimbursement via TripIt or Concur.
Third-Party Marketing Partners and Social Media Platforms. Like many companies, we engage in marketing activities that may result in collection of your personal information. We collect publicly available information, such as your public social media profiles or other content available on the Internet. Collecting such information helps us better understand your interest and preferences so that we can improve the accuracy of our information about you, better understand your needs, and to optimize our Services.

How we use your information

In addition to some of the specific uses of personal information we describe in this Privacy Policy, we may use information that we receive to:

Before we use your personal information for purposes not described in this Policy, we will disclose such other purposes to you prior to our processing. You may choose not to allow us to process your personal information for any purposes that are not compatible with the purposes for which we originally collected your personal information or subsequently obtained your consent. However, you should be aware that if you choose to limit how we use your personal information, some or all of the Services may not be available to you.

Sharing of your information

We will not rent or sell your information to third parties outside LoungeBuddy without your consent, except as noted in this Policy. Please see the CALIFORNIA PRIVACY section below regarding sales subject to the California Consumer Privacy Act of 2018.

Parties with whom we may share your information:

Affiliated Businesses. We may share your personal information with businesses that are legally part of the same group of companies that LoungeBuddy is part of, or that become part of that group ("Affiliates"). Affiliates may use this information to help provide, understand, and improve the Service (including by providing analytics) and Affiliates' own services (including by providing you with better and more relevant experiences).
Our Service Providers, Business Partners and Others. We also may share your personal information with our service providers, business partners or third-party organizations that help us provide the Service to you ("Service Providers"). Such entities will be given access to your information as is reasonably necessary to provide the Service under reasonable confidentiality terms.
De-Identified or Aggregated Data. We may remove parts of data that can identify you and share de-identified data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information.
Sharing Based on Your Actions. Any information or content that you voluntarily disclose for posting to the Service, such as User Content, becomes available to the public, as controlled by any applicable privacy settings that you set. Once you have shared User Content or made it public, that User Content may be re-shared by others. Subject to your profile and privacy settings, any User Content that you make public is searchable by other Users. If you remove information that you posted to the Service, copies may remain viewable in cached and archived pages of the Service. In addition, you may share personal information via third-party services integrated on our Services (e.g., Concur, TripIt, etc.).
Change of Control. If we sell or otherwise transfer part or the whole of LoungeBuddy or our assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, liquidation), your information such as name and email address, User Content and any other information collected through the Service may be among the items sold or transferred. You will continue to own your personal information and the buyer or transferee will have to honor the commitments we have made in this Privacy Policy. We will notify you with any choices you may have regarding your information.
Responding to Legal Requests and Preventing Harm. We may access, preserve and share your information in response to a legal request (like a search warrant, court order or subpoena) if we have a good faith belief that the law requires us to do so. We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.

Marketing

You can unsubscribe from marketing email communications from us by clicking on the "unsubscribe link" provided in such communications or send an unsubscribe to us at support.loungebuddy@aexp.com. We will process your request within a reasonable time after receipt. As noted above, you may not opt out of Service-related communications (e.g., account verification, purchase and billing confirmations and reminders, changes, updates to features of the Service, technical and security notices).

Transfer of your information

When you access or use our Services, your information may be processed in the United States or any other country in which LoungeBuddy, its affiliates or service providers maintain facilities. Such countries or jurisdictions may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. If you do not want your information transferred to, processed, or maintained outside of the country or jurisdiction where you are located, you should immediately stop using the Services.

Update and access your account information

You may update your account at any time by logging in and changing your profile settings. If you have any questions about reviewing or modifying your account information, please contact us directly at support.loungebuddy@aexp.com.

Children's privacy

LoungeBuddy does not knowingly collect or solicit any information from anyone under the age of 18 or knowingly allow such persons to register for the Service. The Service and its content are not directed at children under the age of 18. In the event that we learn that we have collected personal information from a child under age 18 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us at support.loungebuddy@aexp.com.

Security

We use commercially reasonable safeguards to help keep the information collected through the Service secure and take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. However, LoungeBuddy cannot ensure the security of any information you transmit to LoungeBuddy or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed.

Please do your part to help us. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and LoungeBuddy, at all times. Your privacy settings may also be affected by changes the social media services you connect to LoungeBuddy make to their services. We are not responsible for the functionality, privacy, or security measures of any other organization.

Retention

Following termination or deactivation of your account, LoungeBuddy, its Affiliates, or its Service Providers may retain your personal information for a commercially reasonable time for backup, archival, and/or audit purposes, or as long as necessary to comply with our legal obligations, to resolve disputes, or enforce our agreements. Otherwise we will try to delete your personal information upon your request or when we no longer need it for the purposes we originally collected it for. We will not delete any personal information that you share with other users, unless such other users also wish to delete their personal information at the same time.

Any photos you publicly submit to the Services will be kept and displayed on the Services (or displayed in the future) unless you specifically request to have these images removed. To request image removal, you must send an email to support.loungebuddy@aexp.com along with the email address you provided when you submitted the image(s).

We recognize that retention requirements can vary between jurisdictions, but we generally apply the retention periods described below.

Marketing Contact Information. We will retain your marketing contact information until you unsubscribe from our marketing communications. Upon your request to unsubscribe, we will store your contact information on our suppression list to ensure we do not send you marketing communications in the future.
Activity Data. We collect information about your interactions with our Services and any User Content you create, post or share on our Services, which we may store indefinitely after the closure of your account for the establishment or defense of legal claims, audit, or fraud and/or crime prevention purposes.
Web Behavior Data. Any cookie information, including information collected via web beacons, flash cookies, or pixels, is retained up to two years from expiry of the cookie or the date of collection.
Telephone Records. As required by applicable law, we will provide notice on any telephone call with you if we intend to record the call. Such recordings will be stored for a period of up to six years.

If you have any questions about termination or deactivation of your account, please contact us directly at support.loungebuddy@aexp.com.

Other web sites and services

We are not responsible for the practices employed by any websites or services linked to or from our Service, including the information or content contained within them. Please remember that when you use a link to go from our Service to another website or service, our Policy does not apply to those third-party websites or services, even if they are offered within or through our Services. For example, you may be able to sign up for a promotion or visit another company's website linked that is handled by a third-party partner, such as Concur.

Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party's own rules and policies.

In addition, you agree that we are not responsible and do not have control over any third-parties that you authorize to access your User Content. For example, you may share your User Content with TripIt or Concur to process reimbursements for your Service charges and we do not control how TripIt or Concur handle your User Content. If you are using a third-party website or service and you allow them to access your User Content, you do so at your own risk. Always familiarize yourself with the privacy practices of any third party you wish to share your personal information with.

Public information

By using our Service you understand and agree that we are providing a platform for you to post content, including photos, comments and other materials ("User Content"), to the Service and to share User Content publicly. This means that other Users may search for, see, use, or share any of your User Content that you make publicly available through the Service, consistent with the terms and conditions of this Policy and our Terms of Use.

"DO-NOT-TRACK"

We do not track or respond to browser "DO-NOT-TRACK" requests.

California privacy

This section of the Privacy Policy provides additional information to California (“CA”) residents whose personal information is processed pursuant to the California Consumer Privacy Act of 2018 (“CCPA”). It describes the categories of personal information LoungeBuddy collects and your rights.

This section does not apply to personal information that is protected under federal financial privacy laws, or to information that is publicly available or that has been de-identified or aggregated.

Categories of Personal Information We Collect

Depending on the nature of your relationship with us (e.g., LoungeBuddy user or lounge partner), we may collect the following categories of personal information about you, including:

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;
Characteristics of protected classifications under California or federal law such as race, 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, if enabled;
Audio, electronic, or similar information;
Other personal information, as described to you in this Privacy Policy, or otherwise at the point of collection; and
Inferences drawn from any of the information identified above, including about your preferences.

Depending on your relationship with us, we may have collected each of the above categories of personal information about you during the preceding 12 months. In addition, we may have shared each of these categories of personal information with third parties during the preceding 12 months for the business purposes described in this Privacy Policy.

Please refer above for more detailed information regarding our sources of personal information, our use of personal information, and the categories of third parties with whom we may share personal information.

Your CA Privacy Rights

As a California resident, beginning after January 1, 2021, you may have certain rights over the personal information we have about you, depending on the type of relationship you have with us.

We do not offer an opt out of sale link on our homepage for the purposes of the CCPA. We may share personal information with our service providers, with third parties with whom we jointly offer products or services, with third parties from whom you request a product or service through us, in the context of a merger, acquisition, bankruptcy, or other corporate transaction, or as otherwise permitted by the CCPA.

Notice to individuals in the European economic area and Switzerland

This section only applies to Users of our Service that are located in the European Economic Area, United Kingdom and/or Switzerland (collectively, the "Designated Countries") at the time of data collection.

We may ask you to identify which country you are located in when you use or access some of the Services, or we may rely on your IP address to identify which country you are located in. When we rely on your IP address, we cannot apply the terms of this section to any User that masks or otherwise hides their location information from us so as not to appear located in the Designated Countries. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to Users in the Designated Countries.

Our Relationship to You. LoungeBuddy is a data controller with regard to any personal information collected from Users of its Service. A "data controller" is an entity that determines the purposes for which and the manner in which any personal information is processed. Any third parties that handle your personal information in accordance with our instructions are our service providers and are "data processors."

You are a "User." Users are individuals providing personal information to us via our Services, such as by creating an account with our Apps, signing up for our newsletter(s), or otherwise accessing or using our Services.

When you use our Service, you may invite end users or collect information via our Service about others – this is call "end user" information. We are not responsible for how you collect, store, or otherwise process end user information on our Service. You are responsible for end user information and ensuring you are processing such information in compliance with all applicable laws.

Legal Bases for Processing Personal Information. Below is a chart indicating the legal bases we rely in processing personal information.

Section	Purposes of Processing	Legal Basis for Processing
4(i)	Provide the Services	Processing is based on our contract obligations or to take steps at the request of the individual prior to entering into a contract.
4(ii)	Send Service-related Communications
4(iii)	Enforce our Terms, Agreements or Policies
4(iv)	Provide Customer Support
4(v)	Secure our Services
5(i)	Affiliated Businesses
5(ii)	Our Service Providers, Business Partners and Others
3(ii)	Third-Party Marketing Partners and Social Media Platforms	Processing is based on our legitimate interest to better understand you, to maintain and improve the accuracy of the information we store about you, and to better promote or optimize our Services.
4(vi)	Conduct Research and Product Development
4(vii)	Personalize the Services for You
5(v)	Change of Control
4(ix)	Maintain Legal or Regulatory Compliance	Processing is necessary for compliance with our legal obligations, the public interest, or in your vital interests.
5(vi)	Responding to Legal Requests and Preventing Harm

Marketing. We will only contact individuals located in the Designated Countries by electronic means (including email or SMS) based on our legitimate interests, as permitted by applicable law, or the individual's consent. When we rely on legitimate interest, we will only send you information about our Services that are similar to those which were the subject of a previous sale or negotiations of a sale to you.

If you do not want us to use your personal information in this way, or to disclose your personal information to third parties for marketing purposes, please click an unsubscribe link in your emails, or contact us at support.loungebuddy@aexp.com. You can object to direct marketing at any time and free of charge.

Individual Rights. We provide you with the rights described below when you use our Services. We may limit your individual rights requests (a) where denial of access is required or authorized by law; (b) when granting access would have a negative impact on other's privacy; (c) to protect our rights and properties; or (d) where the request is frivolous or burdensome.

If you would like to exercise your rights under applicable law, please contact us at support.loungebuddy@aexp.com. We may seek to verify your identity when we receive an individual rights request from you to ensure the security of your personal information. If you have questions, you may reach our Data Protection Officer at loungebuddy.dpo@aexp.com, or our member representative by clicking here or emailing datainquiry@dpr.eu.com quoting <LoungeBuddy, Inc.> in the subject line.

Right to withdraw consent. For any consent-based processing of your personal information, you have the right to withdraw your consent at any time. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.
Right of access. Upon your request, we will provide you with a copy of your personal information in our files without undue delay and free of charge, unless we are permitted by law to charge a fee. Your access may be limited to the extent it would adversely affect the rights and freedoms of other individuals.
Right to rectification (or "correction"). You may request to correct or update any of your personal information in our files. We may provide you with the ability to update some or all of your personal information directly via the Services.
Right to erasure (or the "Right to be Forgotten"). Upon your request, we will erase any of your personal information in our files that: is no longer necessary in relation to the purposes for which it was collected or otherwise processed; was collected in relation to processing that you previously consented to, but later withdrew such consent; or was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing.
Right to restriction. You have the right to restrict our processing of your personal information where one of the following conditions applies:
1. You contest the accuracy of your personal information that we processed. If you restrict processing based on this condition, you may experience an interruption of some or all of the Services during the period necessary for us to verify the accuracy of your personal information;
2. The processing is unlawful and you oppose the erasure of your personal information and request the restriction of its use instead;
3. We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defense of legal claims; or
4. You have objected to processing, pending the verification whether the legitimate grounds of our processing override your rights.
During the time which restriction of processing applies, we will only process your restricted personal information with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if or when the restriction is lifted.
Right to object to processing. You may object to our processing at any time and as permitted by applicable law if we process your personal information on the legal bases of: consent; contract; or legitimate interests. We may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
Right to data portability. If we process your personal information based in a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another "controller," where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others. Your right to data portability only applies to personal information provided by you to us.
Notification to third parties. When we fulfill your individual rights requests for correction (or rectification), erasure or restriction of processing, we will notify third parties also handling the relevant personal information unless this proves impossible or involves disproportionate effort. Upon your request, we will identify such third parties.

Transfer of Your Personal Information. We transfer your personal information subject to appropriate safeguards as permitted under the Data Protection Laws. Specifically, when your personal information is transferred out of the Designated Countries, we have the required contractual provisions for transferring personal information in place with the third-parties to which your information is transferred. For such transfers, we rely on legal transfer mechanisms such as Standard Contractual Clauses or we work with U.S. based third parties that are certified under the EU-U.S. and Swiss-U.S. Privacy Shield Framework.

Right to Lodge Complaint. If you believe we have infringed or violated your privacy rights, please contact us so that we may resolve your dispute directly at support.loungebuddy@aexp.com. You also have a right to lodge a complaint with a competent supervisory authority situated in a Member State of your habitual residence, place of work, or place of alleged infringement.

How to contact us about a deceased user

In the event of the death of a User, please send us an email to the following email address: support.loungebuddy@aexp.com. We will usually conduct our communication via email; should we require any other information, we will contact you at the email address you have provided in your request.

How to contact us

If you have any questions about this Privacy Policy or the Service, please contact us at support.loungebuddy@aexp.com. This Privacy Policy was written in English (US). To the extent any translated version of this Privacy Policy conflicts with the English version, the English version controls.

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