Luxury Card Privacy Policy
Table of Contents
- Who’s This Policy for and What Does It Cover?
- What Is “Personal Information”?
- Personal Information We Collect and How We Collect It
- How We Use Personal Information
- How We Share Personal Information
- Children’s Privacy
- Cookies and Online Tracking
- Your Rights and Choices
- Links To Third-Party Sites
- Security and Retention of Personal Information
- California Residents
- Virginia Residents
- Changes to This Policy
- Contact Us
1. Who’s This Policy for and What Does It Cover?
Your privacy is important to Black Card LLC d/b/a Luxury Card (“Luxury Card” “we” or “us”). This Privacy Policy (“Policy”) describes how we collect, use and share the Personal Information of customers or potential customers of the Cardmember services we offer, whether received through our public websites (the “Sites”), mobile application or other online services we operate that link to this Policy (collectively, the “Services”), or by other means. It also explains related rights and choices you may have. By using our Service, you consent to the practices described in this Policy.
You may see other privacy notices when we collect your Personal Information for certain purposes. Those notices supplement this Policy. This Policy also contains disclosures specific to California residents and Virginia residents in accordance with laws in those states.
Luxury Card is not a financial institution; Luxury Card credit cards are issued by Barclays Bank Delaware. No banking information (other than the first six digits of your credit card number used to validate that you are a Luxury Card member) is submitted or collected by the Services we operate. For banking-related services, such as the issuance of the Luxury Card credit cards and servicing of your credit card account, our Services will redirect you to Barclays and its privacy policies will apply to information you provide them.
2. What Is “Personal Information”?
When we say “Personal Information,” we mean information that can reasonably be linked to a particular individual or their household. Generally speaking, your Personal Information includes your unique identifiers (full name, phone number, email address, user name, etc.), and information about your characteristics, conditions or behavior that is associated with one of your identifiers or could otherwise reasonably be linked to you.
“Non-Personal Information,” on the other hand, has been anonymized, aggregated or de-identified such that it cannot reasonably be linked to a particular individual or their household.
3. Personal Information We Collect and How We Collect It
Categories
Depending on the nature of your interactions with us, we may collect some or all of the following categories of Personal Information:
- “Identifiers,” such as first and last name, zip code, email address and the first six digits of your credit card number (if you use a Site’s chat feature), IP address, cookie ID and similar information
- “Device or Browser Information,” such as device or browser type and configuration
- “Financial Information,” such as payment information if you make a payment through our mobile app (which is processed securely on our behalf by a trusted vendor)
- “Location Information,” such as your approximate location when you access the Site
- “User Content,” such as information you choose to share through the Site’s chat or email features or comments or other content posted to a form on our Site
- “Internet Activity” or “Usage Data,” such as information about how you use the Service, including the specific pages or links you use, or interactions with email communications or notifications sent on our behalf
- “Profile Information,” which includes inferences we make about your interests for marketing or other commercial purposes based on other types of Personal Information we collect about you
- Other categories disclosed to you at the point of collection
Collection Sources
When You Provide It to Us on Our Site
Luxurycard.com is the Site we use to promote Luxury Card credit cards and related benefits (the “Promotional Site”). We do not collect Personal Information from you on the Promotional Site unless you request additional information from us that is not available on the Site, in which case we may collect your contact information or other Identifiers. If you choose to apply for a credit card from this Site, you will be redirected to an application page, hosted by Barclays. The information you submit from the application page is collected by Barclays, not us, and is governed by its own privacy policies.
Luxurycardtravel.com is the Site we use to provide travel and Concierge services to Cardmembers (the “Travel Site”). You aren’t required to provide any Personal Information to access the Site, but you may choose to provide some when you fill out a form on the Site, use the chat function or send us an email. If you use the chat function, we collect your full name, email address and other Identifiers to verify your Cardmember status.
When You Provide it To Us on Our Mobile App
Our mobile app can only be used by Cardmembers. To use the app, we ask you to provide Identifiers (name, email address, phone number, zip code) and the first six digits of your card number to verify your Cardmember status. If you make a payment through the mobile app, to book travel, for example, your payment information will be processed securely by our trusted vendor.
Automatically from Your Computer or Mobile Device
Like most online services, our Services may automatically collect some information from users’ devices in order to make features function correctly, customize the user experience, understand how the Service is being used or measure the effectiveness of marketing efforts. Some of this data may be collected through the use of browser cookies or similar online tracking technologies, which are explained below. In many cases, we limit this type of collection to Non-Personal Information. However, this data may include Personal Information such as online Identifiers, Device or Browser Information, Location Information or Internet Activity in some circumstances.
From Barclays
Barclays provides us with the contact information and other Identifiers of customers or potential customers, which we may use to promote our co-branded credit cards and related services. To the extent we are a controller of that information (meaning we decide, or decide jointly with Barclays, how the information will be used), this Policy applies to our processing of that information. To the extent we process the information solely for purposes determined by Barclays, that processing is governed by Barclays’ privacy policies. Barclays does not give us access to customers’ credit card numbers or other financial account details.
Through Our Vendors
Some features of our Services are operated by a trusted vendor on our behalf. For example, Aspire Lifestyles America, Inc., is our Cardmember Concierge services provider, and LivePerson operates the Travel Site’s chat function. Those vendors may collect chat and messaging transcripts, Internet Activity and other Personal Information on our behalf.
We may combine information collected through vendors or other sources with information collected from you or your device. To the extent the information, alone or in combination, constitutes Personal Information, we will treat it as Personal Information as described in this Policy.
4. How We Use Personal Information
We may use Personal Information for the following purposes:
- To secure our Services against fraud, malicious activity or conduct that may violate our terms of use;
- To analyze how our Services are used;
- To personalize and improve your experience on the Sites;
- To provide you with information about a service you’ve shown interest in, or another service we think you might like;
- To notify you about changes to our services;
- To provide you with periodic newsletters or offers;
- To contact you and provide you with help if you have a customer service issue;
- To contact you to fill out surveys and participate in other types of marketing research;
- To manage the effectiveness of our marketing efforts;
- To comply with our legal obligations;
- In any other way we may describe when we collect the information; and
- For any other purpose with your consent.
We may use Non-Personal Information for any purpose.
5. How We Share Personal Information
Vendors
We may share Personal Information with contractors, service providers and other vendors who assist or support us in providing the Services. Examples of these third-party services may include hosting our Site, providing Concierge services, operating chat functions on the Site, storing data, performing analytics or supporting our marketing efforts. Our agreements with vendors prohibit them from retaining, using or disclosing the Personal Information we share with them for any purpose other than providing services to us.
Analytics or Marketing Partners
We may share your Personal Information with analytics or marketing partners to measure performance of our Site or marketing efforts. This sharing may involve the use of browser cookies and similar technologies placed throughout our Site by our partners, as explained here. For example, when you visit our Site, our partner’s Cookies may cause your browser to automatically send a request to our partner’s server and provide our partner with your IP address, other Identifiers, Device Information or Internet Activity. (An analytics or marketing partner may have an agreement with us that qualifies them as our restricted vendor, in which case they are prohibited from using or disclosing the Personal Information we share with them for any purpose other than providing services to us.)
Mandatory Disclosures and Legal Proceedings
We may have a legal obligation to disclose Personal Information to government authorities or other third parties pursuant to a valid regulatory request, subpoena or court order. We may also need to disclose and otherwise process your Personal Information in accordance with applicable law to prevent physical harm or financial loss, protect the vital interests of a person, enforce our various policies or terms of use, protect our property, services and legal rights, prevent fraud, support auditing, compliance and corporate governance functions or comply with applicable law.
Change in Control or Merger
We may transfer your information in the event of the sale of substantially all of the assets of our business to a third party or in the event of a corporate merger, consolidation, acquisition or reorganization. However, in such event, any acquirer will be subject to the provisions of our commitments to you or we will not disclose your information.
With Your Direction or Consent
We will share your Personal Information with other third parties as you may direct or otherwise consent.
6. Children’s Privacy
Our Services are not directed to children (individuals under the age of 18). We do not knowingly collect, maintain or process children’s Personal Information unless the child’s parent or guardian consents and provides the information. If we determine that we have received a child’s Personal Information from a source other than the child’s consenting parent/guardian, we will immediately delete the information.
7. Cookies and Online Tracking
What Are Cookies?
A browser cookie is a small piece of data that a website stores in your device’s browser. It holds information that the site uses to function properly, remember your preferences or personalize your experience. A typical cookie contains a cookie ID, which is a unique string of characters used to identify your browser during the browsing session, or in some cases, during subsequent browsing sessions. Cookies, cookie IDs and similar pieces of data may be considered Personal Information (Identifiers or Internet Activity) under applicable law.
Other online technologies, similar to cookies, may allow users to be identified and tracked across multiple browsing sessions, and in some cases tracked across different websites and apps for advertising purposes. These technologies include, but are not necessarily limited to, pixels, web beacons and scripts (collectively with browser cookies, “Cookies”).
How Cookies May Be Used on Our Sites
Our Sites uses “first-party” Cookies, which are set by our web domains. Our Sites also use some “third-party” Cookies, which are set by other web domains associated with our vendors or partners. This means, when you visit our Site, your browser may automatically connect to our partner’s web server, as well as ours, and provide our partner with access to your online Identifiers and Internet Activity, including information about how you use our Site.
Cookies are used on our Site for the following purposes:
- Essential: Essential Cookies are necessary for site security and to enable you to move around our Site and use its features.
- Analytics/Performance: Analytics Cookies allow us to analyze use of our Site to evaluate and improve performance.
- Targeting: Targeting Cookies are set by our marketing partners and may be used to track your activity across different sites for behavioral advertising purposes.
Some Cookies are set by Google Analytics. Click here for more information: https://policies.google.com/technologies/partner-sites
How You Can Block Cookies
You can request to opt-out of non-Essential Cookies using the link that says “Cookies Settings” or “Do Not Sell or Share My Personal Information” at the bottom of our Site.
You can block, disable or delete cookies at any time more broadly by changing the settings in your browser. However, blocking, disabling or deleting cookies may limit your ability to view all the pages of our Site or use the chat function on the Travel Site. You can find more information about cookies and other options you may have for restricting them at www.cookiesandyou.com/, and www.aboutads.info/choices.
Universal Opt-Out Signals
We recognize the Global Privacy Control (GPC) as a universal opt-out signal. If your browser sends a GPC signal, our Site will honor it as a request to opt-out of third-party Analytics and Targeting Cookies. You can learn more about GPC here: https://globalprivacycontrol.org/.
Your browser may offer a Do Not Track (DNT) setting. If you turn that setting on, your browser sends a signal to websites indicating that you don’t want to be tracked over time or across third- party sites. We don’t currently respond to DNT signals because there is not a common understanding of how to process them or a consensus on what “tracking” means.
8. Your Rights and Choices
Opt-Out of Marketing Communications
You may opt-out of our marketing emails by using the unsubscribe link provided in the email.
Your Browser and Device Settings
See Section 7 for options to restrict Cookies.
Area-Specific Rights and Choices
If you are a California resident or Virginia resident, you may have other rights and choices.
9. Links to Third-Party Sites
Our Site may contain links to third-party websites, products or services. If you use these links, you will leave our Site. Such links do not constitute or imply an endorsement, sponsorship or recommendation by us of the third party, the third-party website or the information contained therein, and we shall not be responsible or liable for your use thereof. Such use shall be subject to the terms of use and privacy policies applicable to those sites.
10. Security and Retention of Personal Information
The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially reasonable means to protect your Personal Information, we cannot guarantee its absolute security.
Typically, we retain your Personal Information for the period necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law. Please note that in many situations we must retain all, or a portion, of your Personal Information to comply with our legal obligations, resolve disputes, enforce our agreements, to protect against fraudulent, deceptive, or illegal activity, or for another one of our business purposes.
11. California Residents
Under California’s “Shine the Light” law, California residents with whom we have an established business relationship are entitled to request and receive, free of charge, once per calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses in the previous calendar year. To request a copy, please contact us at conciergeprivacy@luxurycard.com. Please be aware that not all information sharing is covered by the “Shine the Light” law requirements and only information on covered sharing, if any, will be included in our response.
The rest of this section makes additional disclosures to California residents (i.e., “consumers”), and describes rights they have, under the California Consumer Privacy Act of 2018, as amended (the “CCPA”). You can learn more about the CCPA here: https://oag.ca.gov/privacy/ccpa.
Please note: The CCPA does not apply to Personal Information that is handled subject to the Gramm-Leach-Bliley Act (“GLBA”), which is a federal law that applies to personal information processed in connection with providing personal or household financial services. Some of the Personal Information we process in the context of our relationship with Barclays is subject to the GLBA and therefore is exempt from the CCPA.
Collection of Personal Information
The categories of Personal Information we have collected about consumers in the past 12 months are listed in Section 3 of our Privacy Policy.
Sale, Sharing or Disclosure of Personal Information
Under the CCPA, you can request to opt-out of the “Sale” of your Personal Information (which the CCPA defines very broadly to include some service arrangements that do not involve the exchange of data for money) and the “Sharing” of your Personal Information with third parties (which the CCPA defines as sharing for purposes of cross-site targeted advertising). In the past 12 months, we have Sold or Shared the following categories of Personal Information (to the categories of recipients listed):
- Identifiers (Analytics and Advertising Partners)
- Device/Browser Information (Analytics and Advertising Partners)
- Internet Activity (Analytics and Advertising Partners)
We do not knowingly Sell or Share the Personal Information of individuals under the age of 16.
Within the past 12 months, we disclosed the following categories of Personal Information for a business purpose (to the categories of recipients listed):
- Identifiers (to vendors)
- Location Information (to vendors)
- Device/Browser Information (to vendors)
- Financial Information (to vendors)
- Internet Activity (to vendors)
Your Rights as a Californian
California residents have the right to make the following requests to covered businesses. The requests may be made by a consumer, by a consumer on behalf of the consumer’s minor child or by a person authorized by the consumer to act on the consumer’s behalf.
Right to Request Information About Collection, Disclosure, Sale or Sharing
You have the right to request that a business disclose to you: (i) the categories and specific pieces of Personal Information the business has collected about you within the past 12 months, (ii) the categories of sources from which the Personal Information is collected, (iii) the business or commercial purposes for collecting, Selling or Sharing Personal Information, and (iv) the categories of third parties to whom the business discloses Personal Information.
If a business Sells or Shares Personal Information, or discloses it for a business purpose, you also have the right to request that the business disclose the following with respect to the 12-month period preceding your request: (i) the categories of Personal Information that the business Sold or Shared about you and the categories of third parties to whom the Personal Information was Sold or Shared, and (ii) the categories of Personal Information that the business disclosed about you for a business purpose.
This type of request may be referred to as a “Request to Know.” Before we can honor a Request to Know, we need to verify that the person making it is the consumer whose Personal Information we have. Our method for verifying any particular request weighs information we receive as part of the request, the sensitivity of the consumer information at issue and the risk of harm to the consumer from unauthorized disclosure.
Right to Request Deletion
You have the right to request that a business delete any Personal Information that the business has collected from you. This type of request may be referred to as a “Request to Delete.”
Before we can honor a Request to Delete, we need to verify that the person making the request is the consumer whose Personal Information we have. Our method for verifying any particular request weighs information we receive as part of the request, the sensitivity of the consumer information at issue and the risk of harm to the consumer from unauthorized deletion.
We are not required to delete Personal Information if we still need it in order to complete the transaction for which the information was collected, provide a good or service requested by you (or that we reasonably anticipate based on our relationship with you), perform a contract with you, comply with a legal obligation or accomplish any other objective recognized as an exception to the right to deletion under applicable law.
Right to Request Correction
You have the right to request that we correct inaccurate Personal Information about you. This type of request may be referred to as a “Request to Correct.”
Right to Opt-Out of Sale or Sharing
You have the right to direct a business that Sells or Shares Personal Information about you to third parties not to Sell or Share your Personal Information. This type of request may be referred to as a “Request to Opt-Out.”
Right to Limit Use and Disclosure of Sensitive Personal Information
If a business collects Sensitive Personal Information* for the purpose of inferring characteristics about you, you have the right to request that the business limit its use and disclosure of your Sensitive Personal Information to that use and disclosure which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such goods and services. (Luxury Card does not collect Sensitive Personal Information for the purpose of inferring characteristics about you.)
*Sensitive Personal Information includes social security number; driver’s license or state identification number; complete account log-in credentials; precise geolocation; racial or ethnic origin, religious or philosophical beliefs or union membership; the contents of a consumer’s mail, email and text messages (unless the business is the intended recipient of the communication); genetic data; biometric information; health information; and information concerning sex life or sexual orientation.
Right to Non-Discrimination
You have the right not to receive discriminatory treatment by a business for the exercise of your privacy rights under the CCPA.
How to Submit a Request To “Know,” “Delete” or “Correct”
You can submit a Request to Know, Delete or Correct to conciergeprivacy@luxurycard.com. The request must state “CCPA Request” and include:
- your first and last name;
- an email address at which you can be reached for purposes of the request;
- the California county in which you reside;
- for a Request to Know, the disclosure(s) you are requesting;
- for a Request to Delete, a clear statement that you want us to delete your Personal Information; and
- the reason(s) you believe we have collected, disclosed or sold your Personal Information, specifically, within the past 12 months (for example, you purchased a product or received a communication from us)
If you are submitting a request on behalf of another consumer as their authorized representative, you must include the foregoing information about the consumer and provide proof of permission from the consumer to make the request.
After confirming receipt of your request, we’ll contact you if we need more information in order to verify it. If we can’t verify a request, we may deny it.
How to Submit a Request to Opt-Out of the “Sale” or “Sharing” of Personal Information
You can opt out by clicking the link that says “Do Not Sell or Share My Personal Information” at the bottom of our Site.
12. Virginia Residents
Your Rights Under the CDPA
Effective January 1, 2023, Virginia residents who interact with a business in a consumer context (as opposed to a business-to-business or employment context) have certain rights under Virginia’s Consumer Data Protection Act (“CDPA”), including:
- To confirm whether or not a business is processing the consumer’s Personal Information and to access such Personal Information;
- To correct inaccuracies in the consumer’s Personal Information;
- To delete Personal Information provided by or obtained about the consumer;
- To obtain a copy of the consumer’s Personal Information that the consumer previously provided to the business in a portable, and to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another business without hindrance (if the data is processed by automated means); and
- To opt out of the processing Personal Information for purposes of (i) targeted advertising, (ii) the sale of Personal Information, or (iii) profiling in furtherance of decisions that produce legally or similarly significant effects concerning the consumer.
Please note: The CDPA does not apply to financial institutions or Personal Information that is handled subject to the Gramm-Leach-Bliley Act (“GLBA”), which is a federal law that applies to personal information processed in connection with providing personal or household financial services. Some of the Personal Information we process in the context of our relationship with Barclays is subject to the GLBA and therefore is exempt from the CDPA.
How to Exercise Your Rights or Appeal a Decision
To exercise one or more rights under CDPA, please submit a request to conciergeprivacy@luxurycard.com. The request must state “Virginia Privacy Request” and include:
- your first and last name;
- an email address at which you can be reached for purposes of the request;
- the Virginia county in which you reside;
- a description of the CDPA rights you are exercising; and
- the reason(s) you believe Luxury Card has obtained your Personal Information.
After confirming receipt of your request, we’ll contact you if we need more information in order to verify it. If we can’t verify a request, we may deny it.
If we decline to act on your request, you have a right to appeal. To submit an appeal, please contact us at conciergeprivacy@luxurycard.com.
How to Opt-Out of Targeted Ads on Our Services
To opt-out of targeted advertising on our Services, please click the link that says “Cookie Settings” or “Do Not Sell or Share My Personal Information” at the bottom of our Site.
13. Changes to This Policy
We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us or by placing a prominent notice on our website.
14. Contact Us
If you have any questions or concerns about this Policy, please contact us via conciergeprivacy@luxurycard.com.