PRIVACY STATEMENT
LifeCtyle Privacy Notice as of 28th March 2023
LifeCtyle takes your privacy seriously and understands that your data is yours. We operate in a fast-evolving global environment and are committed to employing data protection and privacy measures and endeavour to keep up with changes in local regulations such as the (i) the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) and other national laws, regulations and secondary legislation, as amended from time and (ii) any successor legislation to the GDPR or the Data Protection Act 1998 (“Data Protection Legislation").
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We collect personal data such as contact details for providing services or sending marketing communications and LifeCtyle will be the data controller. Where LifeCtyle are provided with information from a third party or a customer relating to a passenger that we are arranging a charter for we are data processors and will only process such data in accordance with the customer’s instructions.
What personal data will LifeCtyle collect about me?
When you use LifeCtyle to purchase a service, a product, contact us or complete an online form, we may collect a variety of information, including, but not limited to; your name, job title, mailing address, telephone number, email address, passport details, credit/debit card or bank details. Where you use the website www.lifectyle.com (the “Website”), we may collect technical data such as IP addresses and cookies.
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How is my personal data collected?
You may directly provide your personal data to us, or we may collect your personal data from third parties, such as customers providing your passenger details for arranging a charter. We may also collect information from publicly available sources.
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How is data used and what is LifeCtyle basis for processing?
We have set out below a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your personal data.
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1. To register you as a new customer and verify your identity we require your Identity and Contact information to perform a contract as required by law.
2. To process and deliver the services, including the below we require your Identity, Contact Information, Financial Information and related Transactional Information.
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Manage payments, fees and charges
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Collect and recover money owed to us
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Contacting you and corresponding about the services we provide to you
This is for the performance of a contract and necessary for our legitimate interests, should we need to recover debts due to us.
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3. To create, develop, offer, operate, deliver, and improve our products, services, content and personalised marketing we require Identity, Contact Information, and related transactional Information.
4. For loss prevention and anti-fraud purposes, or national security matters we require Identity, Contact Information, Financial Information and related transactional Information as required by law.
5. To respond to queries and enquiries, we require Identity, Contact Information.
6. To keep you informed and may include communication by post, telephone, SMS or email, about us and our business partners’ content, products and services, events and special offers, we require you Identity and Contact Information, for reasons of Consent (where you are considered a consumer) Legitimate Interests (where you are a business customer).
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When will LifeCtyle contact me?
In relation to any service, activity or online content you have signed up for to ensure that LifeCtyle can deliver, e.g. to ensure payment of your charter, offer other charter related services or upgrades, or to enquire whether you’re in need of our services. In relation to any correspondence, we receive from you or any comment or complaint you make about LifeCtyle.
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To invite you to participate in voluntary surveys about LifeCtyle.
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To update you on any material changes to LifeCtyle's policies and practices.
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To keep you informed periodically about relevant products and services that we think may be of interest to you. Types of communication include newsletters, invites to events, flyers, or emails.
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If you wish to adjust what information we use or choose to opt out, you can do so at any time by contacting us to update your preferences.
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How long will LifeCtyle keep my personal data?
We retain your personal data as long as it is necessary and relevant for our operations. Generally, we keep personal data in accordance with our internal retention procedures, which are determined in accordance with our regulatory obligations and good practice. In addition, we may retain personal data relating to previous booking activity to comply with national laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, and take other actions permitted or required by applicable national laws. After it is no longer necessary for us to retain your personal data, we anonymise part of the data for analytical purposes and dispose of the rest in a secure manner. If you have any questions in relation to our retention periods, please contact us at experience@lifectyle.com
Will LifeCtyle share my personal data with anyone else?
At times LifeCtyle may make certain personal data available to:
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Strategic partners that work with LifeCtyle to provide products and services, such as when we share your personal data with an airline to book your flight.
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With third party consultants selected by LifeCtyle.
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To protect the rights, property or safety of LifeCtyle customers for fraud prevention, law enforcement or national security.
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LifeCtyle will never sell your personal data and it will only be shared by LifeCtyle to provide or improve our products, services and advertising; it will not be shared with third parties for their marketing purposes.
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What rights do I have in relation to my personal data?
Under certain circumstances, you have rights under Data Protection Legislation in relation to your personal data. These include the right to:
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Request access to your personal data;
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Request correction of your personal data;
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Request erasure of your personal data;
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Object to processing of your personal data;
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Request restriction of processing your personal data;
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Request transfer of your personal data;
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Right to withdraw consent.
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Can I delete my data?
Yes in some cases you will be able to. To make a deletion request please contact us via email at experience@lifectyle.com
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Will LifeCtyle employees have access to my personal data?
To make sure your personal data is secure we communicate our privacy and security guidelines to all LifeCtyle employees and strictly enforce privacy safeguards within the company.
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How do I contact LifeCtyle?
For any queries or comments about this privacy policy or updates, amendments and corrections to your records, or for personal data requests, please contact experience@lifectyle.com or by post to: Data Control Officer, LifeCtyle, Suite 4, 14F, CMA Building, 64-66 Connaught Road, Central, Hong Kong SAR
Changes
We will occasionally update this privacy policy. We will post a notice of any material changes on our website prior to implementing the changes, and, where appropriate, notify you using the contact details we hold for you for this purpose. We encourage you to periodically review this policy to be informed of how we use your information.