Introduction

Virgin Experience Gifts Inc. (“us”, ”we”, “our”) is committed to protecting your privacy. This Privacy Policy applies to your interactions with us for the purpose of redeeming and using a Leisure Choice Gift Card (“Gift Card”), including interactions on our website https://leisurechoice.com/ (hereinafter “Site”) for this purpose. This Privacy Policy describes what information we collect, how we use it, and how we share it. It also tells you about your rights and choices with respect to your personal information, including how you can reach us to get answers to your questions.

We collect personal information from you as part of our business of supporting our enterprise clients’ (“Clients”) rewards and incentives programs. Our Clients provide rewards and incentives in the form of a Gift Card, which you can exchange on our Site to purchase a selection of goods or services offered by a selection of our partner businesses (“Services”). In order to use your Gift Card, you will be required to interact with us on the Site. This Privacy Policy describes the information we may collect from you or that you may provide when you interact with us for that purpose.

Please note that this Privacy Policy does not apply to any personal information we collect from our Clients. Our collection and use of that information is governed by our Leisure Choice Gift Card Terms and Conditions and the data processing agreements we enter into with our Clients. When we receive or process information on behalf of one of our Clients, the privacy practices that apply to the processing of that information are also governed by our Client’s privacy notice, and you should direct any data processing questions to the appropriate Client.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this Privacy Policy. We encourage you to review the Privacy Policy whenever you interact with us to stay informed about our personal information practices and the choices available to you.

If you disagree with this Privacy Policy, then you are free to discontinue use of our Site and forfeit use of the Gift Card. If you agree to the Privacy Policy, please continue using our Site to facilitate the use of your Gift Card.

Collection of Information – Personal Information we collect from you

We collect certain personal information you provide to us directly via the Site when you want to swap (or redeem) your Gift Card.

The types of personal information we may collect include the following:

• Contact information including name and email address
• Any other personal information you choose to provide

Information About Your Use Of Our Services

We collect information about your use of our Services, such as the gift card brands you choose to swap to.

Personal Information We Collect Automatically

We automatically collect certain personal information about you when you access or use our Services, including:

• Log Information: We collect information about your use of our Site, such as the type of browser you use, access times, pages viewed, your IP address and the referring link through which you accessed our Site.
• Device Information: We collect information about the device you use to access our online Services, including the hardware model and operating system and version.
• Transaction Information: When you purchase or swap a gift card, we collect information about the transaction such as the brand you have swapped for.
• Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) use cookies, web beacons and similar tracking technologies to collect information about you when you interact with our Site, including information about your browsing and purchasing behavior. We may combine this information with other information we collect about you and use it for various purposes, such as improving our Site and your online experience, understanding which areas and features of our sites are popular, counting visits, understanding campaign effectiveness, tailoring our communications with you, determining whether an email has been opened and links within the email have been clicked and for other internal business purposes. For more information about cookies and how to disable them, please see the “Cookies” section below.

Personal Information We Collect From Our Partners And Other Sources

We may obtain personal information about you from other sources and combine that with information we collect about you.

Personal Information We Derive

We may derive personal information or draw inferences about you based on the other types of personal information we collect. For example, we may infer your location based on your IP address, or that you are interested in purchasing a certain type of Experience based on your browsing behavior on our Site.

Use of Personal Information

We may use personal information we collect about you for various purposes, including to:

• To facilitate and improve your online shopping experiences;
• Ensure delivery of your Gift Card purchase via the Site by providing our Clients with information they need to accomplish your Gift Card transaction;
• Conduct internal research and development and make business decisions about current and future Service offerings;
• Respond to your comments, questions and requests and provide customer service;
• Communicate with you about Services, offers, promotions, rewards and events and provide news and information we think will be of interest to you (for information about how to manage these communications, please see “Your Choices” below);
• Personalize your online experience and provide advertisements, content or features that match your profile and interests;
• Monitor and analyze trends, usage and activities;
• Detect, protect against and prevent security incidents and illegal or unauthorized activities, investigate complaints and claims and provide other security protections, such as identity verification;
• Protect users of our Services from fraudulent, malicious, deceptive, abusive or unlawful activities of others;
• Debug and repair errors in our Services and other activities to maintain and improve the quality and safety of our Services;
• Cooperate with law enforcement and protect the rights (including free speech), interests, safety or property of us or our customers, service providers and other third parties;
• Comply with and enforce applicable legal and regulatory obligations and respond to governmental requests;
• Enforce our policies, terms and conditions or other agreements;
• Defend against or pursue claims, disputes or litigation – in court or elsewhere; and
• Carry out any other purpose readily apparent to you or described to you at the time the personal information is collected.

Sharing of Personal Information

We may share certain personal information about you as follows:

• With our service providers, vendors, consultants and other service providers who need access to such personal information to carry out work on our behalf, including companies that assist us with web hosting;
• Fraud prevention, customer service, analytics, marketing and advertising;
• In response to a request for personal information if we believe disclosure is in accordance with any applicable law, regulation or legal process or as otherwise required by any applicable law, rule or regulation;
• If we believe your actions are inconsistent with our user agreements or policies or to protect the rights, property and safety of us or any third party;
• In connection with, or during negotiations of, any merger, sale of company assets, financing or transfer of all or a portion of our business to another company;
• With our current and future parents, affiliates, subsidiaries and other companies under common control and ownership;
• With our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests; or
• With your consent or at your direction.

As discussed further below, personal information we may share with third parties does not include data, information, or other details regarding the redemption or use of Gift Cards. All such data, information, and details are strictly proprietary to us and constitute trade secrets.

We may share aggregated or de-identified information, which cannot reasonably be used to identify you. Subject to applicable law, we may use such de-identified information for research and marketing purposes. We may also share that data with third parties including advertisers, partners and sponsors.

Advertising and Analytics

We engage third parties to serve advertisements on our behalf across the Internet and to provide analytics services. These entities may use cookies, web beacons and other technologies to collect personal information about your use of our Site, such as your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This personal information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Site and other websites and better understand your online activity. Please note that you need to renew this choice on each device and browser you use to access our Services.

We may also work with third parties (such as Google, Facebook and Instagram) to serve ads to you as part of a customized campaign on their platforms. If you prefer not to see customized ads from us, you can usually opt out by changing your account settings or preferences on such platforms.

Data Retention and Redemption

Our retention periods for personal information are based on business needs and legal requirements. We retain personal information for as long as is necessary for the processing purpose(s) for which the personal information was collected and any other permissible, related purpose. In no event will we collect any information that can be used to determine your address, other than any billing address information associated with a credit card purchase.

As a rule, we do not disclose to any party any data, information, or other details regarding the redemption or use of Gift Cards. All such data, information, and details are strictly proprietary to us and constitute trade secrets. Nevertheless, there are limited circumstances that such data may be disclosed, such as to law enforcement, by court order, or when a party is contractually bound to confidentiality.  If disclosure is necessary, we will give our best effort to only disclose such information on an anonymous basis.

Children

Unless indicated otherwise, our Site and Services are intended for use by individuals older than 18 years of age.  We do not, in providing the Services, knowingly collect personal information from persons under the age of 16.  If you have reason to believe that a child has provided personal information to us via the Services, please contact us, and we will endeavor to delete that personal information from our databases.

Your Choices

Opting Out Of Promotional Communications

You can opt out of receiving promotional communications from us at any time by following the instructions provided in those communications or contact us at as indicated in the “Contact Us” section below.

Please note that even if you opt out of receiving promotional communications, we may continue to send you non-promotional emails, such as those about your account, our ongoing business relations or the Services.

Cookies

Most web browsers are set to accept cookies by default.  When you visit our Site, we store cookies on your browser to collect information.  The information collected might relate to you, your preferences or your device, and is mostly used to make the Site work as you expect it to and to provide a more personalized web experience.  However, you can choose not to allow certain types of cookies, which may impact your experience of the Site and the services we are able to offer.  Nevertheless, you cannot opt-out of any cookies that are strictly necessarily deployed in order to ensure the proper functioning of our Site (such as prompting the cookie banner and remembering your settings to log into your account, to redirect you when you log out, etc.).

If you do not want your information to be collected through cookies, you may be able to change the preferences in your particular Internet browser. Some Site functionality may not work properly if your browser does not accept cookies. Please consult your chosen Internet browser for instructions on how to change your cookie settings.

Linked Websites

 Our Site may provide links to other third-party websites and services that are outside our control and not covered by this Privacy Policy. We bear no responsibility for the accuracy, legality or content of the external site or for that of subsequent links. You should review the privacy statements and other terms and conditions of use posted on those websites you visit.

 Rights for Residents of Certain States

 The rights discussed in this Section of the Privacy Policy apply where applicable laws or regulations grant those rights. States that have granted consumer privacy laws currently include:

• California
• Colorado
• Connecticut
• Delaware
• Florida
• Indiana
• Iowa
• Montana
• Nevada
• Oregon
• Tennessee
• Texas
• Utah
• Virginia

 If you are a resident of one of the foregoing states, you may have the following rights:

1. You may have the right to request the deletion of any of your personal data that we collected from you and retained, subject to certain exceptions.
2. You have the right to confirm whether we process your personal data and you have the right to access your personal data that is in our possession. Information you may be entitled to includes the following:

• Categories of Personal Information we collected about you
• Categories of sources from which we collected the Personal Information;
• Business or commercial purpose(s) for collecting or selling your Personal Information;
• Categories of third parties with whom we shared the Personal Information;
• Specific pieces of Personal Information we collected about you; and
• If we sold or disclosed your Personal Information, the categories of Personal Information we sold or disclosed about you.

3. You have the right to request that we correct any inaccurate personal data that we maintain about you.
4. You may have the right to obtain a readily usable digital copy of your personal data from us.
5. You have the right to opt out of the processing of your personal data for purposes of (1) targeted advertising, (2) the sale of personal data or (3) profiling in furtherance of a decision that produces a legal or similarly significant effect on you.

 In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems, including your name and information about recent purchases that you have made or other actions by you. Although we try to limit the personal information collected in connection with a request to exercise the right to know and the right to deletion, certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know and right to deletion, particularly where we are unable to verify your identity.

 Residents of states with consumer privacy laws can exercise their rights by contacting us via email at info@leisurechoice.com.

 If you have an authorized agent, that person also may submit requests relating to your consumer privacy rights via that email address or form. We will need to obtain verification of the agent’s identity and their authority to act on your behalf.

 To the extent you wish to appeal a decision issued by us regarding your rights under relevant consumer privacy laws you may do so via email at info@leisurechoice.com.

 You have the right not to receive discriminatory treatment for exercising any of the rights described above.

 Your rights under applicable consumer privacy laws may not be waived or limited by contract or otherwise.

Contact Us

Email: info@leisurechoice.com
Mail: 228 Park Ave S, PMB 45957, New York, NY 10003-1502 US

What are cookies?

Cookies are tiny files which websites use in order to work properly and provide important visitor data to us. They can be placed on your computer when you visit a website and help to make your web experience quicker, easier and tailored to you.

Session cookies are those which expire upon the closing of the web browser and persistent cookies are those which remain in place after a session has ended.

Types of cookies

• Essential cookies (ecommerce checkout and basket functionality, location targeting, device targeting).
• Website information cookies (enables us to understand traffic and visitor engagement levels to improve the quality of the website).
• Setting cookies (enables an improvement is usability by adapting font size, style and page layout).
• Advertising cookies (improve the quality of advert targeting, ensuring you see what’s most relevant to you).

Disabling cookies

If you would like to disable cookies, please follow the links below which are attributed to key browsers.
Chrome
Internet Explorer
Firefox
Safari

User agreement

By continuing to use our site, you agree to the placement of cookies on your device. If you choose not to receive our cookies, we cannot guarantee that your experience will be as fulfilling as it would otherwise be.

Processing your personal data

We may process your personal data in a secure manner that meets European Privacy Laws. As a company we process under the concept of ‘legitimate interests’. Therefore, when you provide your personal details to us, we ensure that your data is processed for a distinct purpose whilst ensuring that your interests, rights and freedoms have been thoroughly considered. We will not use personal data for activities where our business interests are overridden by the impact on your privacy or other interests.
We will carefully process the personal information you have supplied to us to conduct and manage our business, to provide relevant marketing communications, fulfil our service commitments and provide the best possible customer service whilst delivering a secure experience.

If you are not happy about the manner in which we process your data, the ‘your rights’ section of this page provides details on how you can withdraw from processing.
We will not transfer your collected data to storage outside the European Economic Area (EEA) in compliance with requirements set by the General Data Protection Regulation.
By giving us your personal data to fulfil your order or to allow us to provide services to you, we will endeavour to keep your data secure. We pursue ongoing improvement in the methods used to transfer and store data, ensuring that we align with industry standards.
Personal data may be stored securely on third party platforms which are used for marketing or operational purposes.

Retaining data

When storing data, we aim to retain the data for no longer than is necessary for the purpose in which it was obtained, with the objective to ensure the highest level of data accuracy. Where identified as inaccurate, data is either rectified or destroyed in a secure manner.
Data retention periods may vary between operational activities, with the business providing consideration as to the length of time data is held for on a case by case basis.
Regarding storage, there are several ways in which your data may be stored:

• Within cloud servers. When utilising platforms to fulfil our operational requirements, third party solutions may be used to store the data. As a company, we aim to utilise partners who have data centres within the European Economic Area (EEA).
• Within physical servers. We maintain several physical servers which are securely located at our Head Office.
• Hard copy, where hard copies of data are retained, they are kept in a secure and clean environment.

Data sharing

We avoid sharing your personal data with third parties for marketing purposes, unless you have provided explicit consent for us to do so.

We may disclose your information in the following cases:

• To develop and create an improved customer experience. Often, this data is anonymised anyway.
• For a supplier to fulfil your experience gift operationally.
• We can disclose it if we have a legal obligation to do so, or to protect your or other people’s property, safety or rights.
• We can exchange information with specific third parties to protect against fraud or credit risks.

Where data is transferred between systems, we ensure an encrypted connection is utilised. We are PCI (The Payment Card Industry Standard) compliant when taking payments via the web, with all payment partners meeting the highest level of compliance (Level 1). All of our associated websites maintain valid SSL certificates to allow secure connections from the web server to your browser, you will notice the padlock symbol is present within your search bar when browsing.

Your rights

In line with the General Data Protection Regulation, you have the following rights:

• Subject access request – To see what information we hold on you, use our Subject Access Request form to complete the application.
• Right to be forgotten – Once you know what personal information we hold on you, you can request us to delete the relevant information, use our Subject Access Request form to complete the application.
• Right to object from us processing your data – You can object to processing from direct marketing communications using our unsubscribe form. For other types of processing, please complete our Subject Access Request form.
• Right to correct your data – Once you have completed a Subject access request, if any of your personal data we hold isn’t accurate, let us know and we’ll get it updated for you.

We aim to comply with legislation and respond within thirty days of receiving personal data requests. These requests are handled by our Business Support department.
Third parties seeking access to an individual’s data should initially contact the individual regarding such requests.

Supervisory authority

We adhere to guidance from the ICO (Information Commissioner’s Office), they are the UK’s independent body that have been set up to uphold information rights. The ICO have stated that In line with the GDPR, details we provide to you about how we process personal data must be:

• Concise, transparent, intelligible and easily accessible.
• Written in clear and plain language.
• Free of charge.

If you have a concern about information practices, you can raise your concerns with the ICO.