Privacy Policy

TravelX VIP Privacy Policy

TravelX VIP Subscription is a Premium Airport Services & Travel services Subscription that enables members to save on all the services catering from door to door. The TravelX VIP Subscription is managed by, owned by, and provided to members by Mirai Labs Inc (TravelX), a Delaware, USA-based organization.

This TravelX VIP Privacy Policy (“Privacy Policy”) sets out what information TravelX (collectively, “we,” “us,” “The Parties”, “our”) collect, and how we use it.

This Privacy Policy also applies when you redeem travel and lifestyle awards from Partners of The Parties.

“Partner” means a business whom which TravelX has made arrangements for Members to offer discounted services on the TravelX VIP Platform; and the relevant information of each Partner will vary from time to time, details of which are available from the TravelX VIP App.

IN THIS TRAVELX VIP PRIVACY POLICY (“PRIVACY POLICY”):

“TravelX VIP Website”, “our website” refers to vip.travelx.ai and any other domain as may be adopted by TravelX to provide services relating to the TravelX VIP Subscription from time to time;

“TravelX VIP App”, “our app”, “mobile apps”, and “mobile applications” refers to TravelX VIP mobile applications for iPhone® or Android™ that may be offered in certain locations.

“Data” refers to any representation of information (including an expression of opinion) in any document, and includes a personal identifier. “Personal Data” refers to data (a) that relates directly or indirectly to a living individual; (b) from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and (c) in forms which access to or processing of the data is practicable.

“Supplier” refers to any individual, business entity, or professional body for which TravelX has no direct ownership, which provides relevant products and services, with or without fees, to support the operation, legal, marketing, communication, and other essential business functions of TravelX.

In this Privacy Policy, words denoting one gender shall include the other gender and the neuter and vice versa, and words denoting the singular number shall include the plural number and vice versa.

In this Privacy Policy, the headings and captions used herein are inserted for convenience of reference only and shall not affect its interpretation.

This Privacy Policy sets out the policies and practices of which any information including Personal Data collected, processed, used, and retained by us for the purposes of our operation of TravelX VIP’s business, provision of services to our customers and offering other services or products of TravelX that may be of interest to our customers. You should read the following carefully to understand our views and practices regarding Personal Data and how we will treat and protect it in accordance with the provisions of the Personal Data (Privacy) Ordinance (Cap.486) (the “Ordinance”).

All non-English versions of this Privacy Policy are translations of the original version in English for information purpose only. In the event of any discrepancy, the English version will prevail.

CONTENTS:

Collection of Information
Cookies
Retention of Personal Data
Purposes for Collection and Use of Personal Data
Disclosure of Personal Data
Consent
Access Rights
Changes to Privacy Policy

Collection of Information

We will request you to provide the following Data for our collection and process of the same, including but not limited to:

Information and/or Data collected from the reservation processes for the purpose of completing the reservation including but not limited to those collected from the online reservation when you make a reservation by calling one of our hotels, and any other Personal Data voluntarily provided by you for making a reservation such as your name, address, telephone number, method of payment, credit card details and special requests;
Information and/or Data collected when you check in the hotel for the purpose of verifying your identities including but not limited to passport numbers, identity card numbers, and driver’s license that may be required by local laws;
Information and/or Data collected during your stay at a hotel for the purpose of complying with our financial reporting requirements and providing more comfortable services to you in the future including but not limited to your food and beverage preferences, special requests, and your spending during your stay;
Information and/or Data collected from you when you set up an account with us including but not limited to name, email address, your registration status with other service brands owned or managed by TravelX, loyalty Subscription registration number, correspondence address, food and beverage preferences, and service requests;
Survey and research information collected from you by online or offline channels;
Device and usage information about your browser or device, including the type of device you are using, your browser and operating system, your internet service provider, your internet protocol (“IP”) address, your device and mobile ad identifiers (e.g., Apple IDFA or Android AAID), the referring website, the web pages of our website that you view, the services and functions you access or use and the ads you click or scroll over. To collect this information, we may use log files that record events in connection with your use of our services, as well as cookies and similar technologies, such as web beacons embedded in marketing emails.
Location information about the location of your device, such as information that identifies your device’s precise location (e.g., GPS latitude and longitude level) or its approximate location (e.g., less precise location estimated based on a browser or device’s IP address). We collect this location information or derive it from your GPS, WiFi, Bluetooth or other device settings for purposes of enhancing or facilitating our services, such as to enable the functionality of our websites or mobile applications that provide you with information about lounges, hotels, services, and partner stores near you, to enable you to enjoy special member’s benefits or offers, make redemptions, check in to lounges and any other functions/services to enrich your TravelX VIP Subscription experience. We may also use your device location information to help us understand how our websites, mobile applications, and other services and functionality are being used, or to deliver more relevant advertising or personalized experiences for you, including tailored marketing offers or messages based on your location, preferences or related context. You may opt out of the collection of this location information by turning off the “location” function in your TravelX VIP app settings and disabling the relevant location/location-sharing settings in your web browser.

Supply of information or Personal Data to us is non-obligatory except that certain Personal Data is required to be provided by local laws. You may also want to be cautious about providing any information or Personal Data through WiFi or any other wireless Internet connection and you should understand and accept that the risk associated with such connection methods are out of TravelX’s responsibility and no security system or system of transmitting information over the Internet is guaranteed to be secure.

2. Cookies

Cookies are used on all online tools available to you including, without limitation, the TravelX VIP Website to distinguish you from other online users, to analyze how viewers navigate the Website with a view to optimize its design, to establish and maintain your logged-on identity if you log on your account with us so that you can move around TravelX VIP Website without being asked to log on again.

You should understand that while cookies, in general, do not tell us your email address or other Personal Data, however, if you voluntarily provide such information or Personal Data to us by, for example, registering an account with us or subscribing for any of our services, such information may be linked to the data in the cookie.

In addition to the information we collect through cookies, we also collect behavioral Data and store such Data for analytical purposes so as to conduct marketing research and improve the quality of our website and mobile applications. Such Data includes information about your visits such as your server address, the date and time of your visit, the page you accessed, the information you downloaded, and the type of Internet browser you used.

The use of any information we collected either through the use of cookies or otherwise shall be subject to this Privacy Policy.

Most web browsers are initially set up to accept cookies. You may choose to edit your browser options to block cookies in the future. If you block cookies, certain features on the TravelX VIP Website may not work properly.

Please take note that cookies from third parties unaffiliated with TravelX or our business partners may be set before, during or after browsing our website. We do not and cannot control these cookies set by third parties and you should check with these third-party websites for more information about their cookies.

3. Retention of Personal Data

Data provided by you will be retained for such period as may be necessary for carrying out the purposes stated in this Privacy Policy and in any event, for as long as required by the applicable law. Unless otherwise agreed, hard copies of any documents containing Personal Data that you have provided to us become our property and we will destroy any documents in possession in accordance with the applicable law.

Data collected by us in order to carry out the purposes or directly related purposes stated in this Privacy Policy will be stored in our databases. The databases owned and managed by TravelX or Suppliers may include Personal Data such as guest name, address, email, and/or phone numbers.

The databases managed by us may also include guest passport numbers or government ID if such is required by local laws or you voluntarily choose to save such information in your account with us for facilitating your future bookings. However, under no circumstances shall credit card payment information be retained or stored in our databases.

All Personal Data stored in our databases are encrypted and treated as confidential information.

We may also store other information such as your special requests, food and beverage preferences, and transaction history in our databases and this information may be shared and/or used by TravelX and/or affiliated business units for marketing and/or analysis to enhance customers’ experience.

As we operate some of the services as well as a variety of international airport services in various countries, the nature of our business requires us to transfer Personal Data to other companies within TravelX, operation units, or service providers that may be located outside of your own country for the purposes mentioned in this Private Policy. You agree to this transfer, storing, or processing by submitting your Personal Data to us. We shall take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy. Where such a transfer is performed, it will be done in compliance with the requirements of the Ordinance in effect. TravelX will take reasonable and exercise due diligence to ensure that Personal Data, after being transferred to recipients located in other countries will not be stored, processed, or used in any manner which, if it were in Hong Kong, would be a contravention of the Ordinance in effect.

4. Purposes for Collection and Use of Personal Data

The purposes for which your Data may be and/or is used by us include, without limitation, in the following ways:

To process and administer your room reservation application;
To fulfill and process requests submitted by you for any services offered by us;
To provide and maintain the TravelX VIP Website and mobile applications or any of our other services to you;
To improve the TravelX VIP Website, mobile applications, and your account with us, including, without limitation, addressing your queries and notifying you of any proposed or actual changes to the TravelX VIP Website;
To compile and provide anonymous statistics about users of the TravelX VIP Website and mobile applications, and provide related usage information to reputable third parties, which will not, in any event, enable any third party to identify individuals;
To provide and/or market the goods and/or services provided by us and/or our affiliated business partners;
To manage the relationship between you and TravelX;
To facilitate our business operations across our group of companies including the fulfillment of any legal requirements; and
To evaluate, develop, offer, and promote goods and/or services provided by us and/or our affiliated business partners.

We will not use your Personal Data to conduct direct marketing via email, push message, direct mail, telephone, fax, and or other forms of communication, to provide you with information about goods and/or services that are part of services offered to you by TravelX unless you have agreed to receive marketing materials in such manner when providing your Personal Data to us.

If you agree to the above direct marketing use, your Personal Data held by us may be shared within TravelX. The intended kinds of Personal Data to be used are all kinds of your Personal Data which necessarily enable us to establish contact with you; and to market or promote a variety of our services, facilities, and related goods and/or services offered by us and/or affiliated businesses. However, we shall not use or provide your Personal Data unless exempted by the Ordinance in effect or we have received your consent.

Your consent to the use of your Personal Data for direct marketing use as indicated above can be given in the following ways:

You may indicate your consent to the above by the following ways: ticking the box(es) indicating your consent when providing us with your Personal Data through our website, mobile applications, or forms; indicating your consent to our customer representative when providing us with your Personal Data through the telephone; or ticking the box(es) indicating your consent when checking in at our hotel;
You may opt-out from receiving marketing communications at any time, free of charge, by the following ways: following the “opt-out” instructions contained in the marketing communications; or writing to us at the address listed below under section 7 – “Contact”.

5. Disclosure of Personal Data

If you have registered a member account with us, you hold the sole responsibility of safeguarding your own login and password information for your account with us and such should not be disclosed to any third parties. We shall not ask you for your password under any circumstances. The risks of the leakage of your Personal Data resulting from your loss of the login and password information lie solely with you.

You acknowledge and understand that the transmission of information via the Internet is not completely secure. Although we have taken practical steps to safeguard your Personal Data, to prevent unauthorized access, and have implemented high-standard security measures to protect any information received, we do not guarantee the security of your Personal Data transmitted via the Internet, and you acknowledge and accept that any transmission is at your own risk.

You authorize us to use and share Personal Data provided by you within TravelX and its affiliated businesses and the Suppliers who provide services to assist in fulfilling the purposes, or directly related purposes for which the Personal Data was collected, or as required under the relevant laws.

You agree to update your own Personal Data from time to time so that it remains accurate.

You authorize our Suppliers to disclose your Personal Data registered with such Suppliers to us, whether such Personal Data has been previously provided to us or not.

You understand that it is an inherent part of our business to provide you quality services and facilities owned, managed, and/or operated by us or our affiliated businesses. As a result, this requires the sharing of your Personal Data with our affiliated businesses, and you may opt out of such sharing by not subscribing to our services or not registering an account with us. You may withdraw your authorization at any time pursuant to Clause 7.3.

6. Consent

By using services provided by us and/or the TravelX VIP Website or by providing any Personal Data to us via registering an account with us, you consent to the collection and/or use of your Personal Data and/or other Data as stated in this Privacy Policy and as set out elsewhere in any legal notices. You should not provide us any Personal Data if you do not consent to such collection and/or use.

7. Access Rights

You may request access and correct your Personal Data held by us. If you wish to obtain a copy of any of such Personal Data, or if you believe that such Personal Data is incorrect, or if you believe that such Personal Data was used beyond the scope of the purposes or directly related purposes as stated in this Privacy Policy or was acquired by fraudulent or unlawful means, please write to us at the address listed below under section 9 – “Contact”.

A request for access or correction to, or deletion of Personal Data, or to obtain a copy of the Privacy Policy must be in writing and sent to us at the address listed below under section 9 – “Contact”.

If at any time you wish to withdraw your consent to be bound by the Privacy Policy or do not wish to remain a subscriber to our mailing list, you are able to unsubscribe from our mailing list by clicking on the “Unsubscribe” link on an email from us, or contact us either by emailing vip@travelx.ai with the subject “Unsubscribe”, We will process your request within 10 business days.

All data privacy is handled in accordance with the Ordinance in effect. Should any provision of this Privacy Policy stipulated herein be found by any court or administrative body of competent jurisdiction to be invalid or unenforceable, the invalidity or unenforceability of such provision shall not affect the other provisions of this Privacy Policy. All provisions not affected by such invalidity or unenforceability shall remain in full force and effect.

8. Changes to Privacy Policy

You accept and agree that we shall have the sole discretion to amend this Privacy Policy upon reasonable notice where it is possible and/or practical to give such notice. Any revised version of this Privacy Policy shall be effective as at the date of publication on the TravelX VIP Website.

Contact

You may visit us at www.vip.travelx.ai or contact us in writing attention to: “Data Protection Officer – AP81, 902, Koregaon Park, Pune 14, Maharashtra, India” if you have any concerns or requests about this Privacy Policy or how we have been using your Personal Data.

TravelX Privacy Policy – Version v1, last updated on March 17, 2023