Aeroplan® and its Partners share personal information about Aeroplan® members in order to administer members’ accounts, and about members’ preferences in order to offer and provide quality rewards, benefits, products, goods and services to members efficiently. However, Aeroplan® will not collect, use or disclose Personal Information about a member without the member’s consent. Our foremost concern in this regard is our members’ trust in our custodianship of their personal information.
The purpose of this Policy is to inform you of our commitments for the protection of personal information and the rules we intend to follow when we collect, hold, use or disclose personal information.
Our Policy is designed to meet or exceed the requirements of Canadian privacy law, including the recently enacted Personal Information Protection and Electronic Documents Act (PIPEDA), and the principles set forth in the Canadian National Standard for the Protection of Personal Information (CAN/CSA-Q830-96.) We are committed to constant self-evaluation of our practices and procedures, and to responding to members’ comments.
To better understand and respond to members’ expectations regarding protection of personal information, we have designated a member of senior management as the Aeroplan Privacy Officer. Anyone may contact the Aeroplan Privacy Officer to provide information, to request access to or rectify their Aeroplan® personal information or to make complaints. The Aeroplan Privacy Officer constantly reviews our practices and procedures to ensure compliance with this Policy and to meet our members’ expectations in this regard.

1. We will only collect the personal information necessary to administer the Aeroplan® Loyalty Program and to offer our members rewards, benefits, products, goods and services under the Program.

2. We do not collect, use or disclose personal information about a member without the consent of the member, except where required by law.

3. From time to time we may transfer personal information to our agents for processing in order to determine which members may be most interested in rewards, benefits, products, goods and services offered by Aeroplan® or its Partners. We use contractual and other means to protect your information while it is being processed by our agents.

4. To increase opportunities for members to accumulate miles under the Program, to facilitate the redemption of miles under the Program, or to obtain special benefits for members, Aeroplan® may temporarily share personal information with a Partner. Use by the Partner for any purpose other than the Aeroplan® Loyalty Program is strictly prohibited.

5. We will provide our members with a detailed explanation, when they enroll and periodically thereafter, of how they can have their name deleted from the lists we share with our Partners. Our members may contact us at any time at the address below to have their names deleted from the lists.

6. We maintain the security and confidentiality of the information furnished by our members according to the strictest standards. Compliance with these standards is constantly verified and revised as needed.

7. In the administration of the Aeroplan® Loyalty Program, if we communicate information to our Partners, agents, or representatives, we assume the responsibility arising from these communications and take actions to ensure that the commitments and rules set forth in this Policy are observed by our Partners, agents, or representatives.

8. We require every organization that provides us with administrative or information processing support services to comply with this Policy and with the privacy protection rules it contains.

9. Our members are entitled to examine the information we hold regarding them, subject to the restrictions provided by law, and may request rectification of inaccurate or incomplete information. If applicable, we will disclose this information to the person concerned or rectify it promptly.

1. Aeroplan® is a Loyalty Program which allows its members to accumulate miles when they fly on Air Canada and its affiliated carriers and when they travel with a member airline of the Star Alliance^TM network. Aeroplan® members may also accumulate miles when they buy goods or services from other Aeroplan® Partners.

2. Aeroplan® Partners are enterprises with whom Aeroplan® has signed an agreement whereby the Partner agrees to award Aeroplan® miles or other benefits to members when these members acquire goods or services from the Partner, or to offer rewards to members. The list of Aeroplan® Partners is updated constantly and available on the Aeroplan® Internet site, as well as in the official documentation which Aeroplan® distributes periodically to members.

1. The Aeroplan Privacy Officer takes steps to ensure that Aeroplan®’s commitments regarding privacy and the rules contained in this Policy are observed by Aeroplan® employees and by its Partners.

2. Aeroplan® requires that all agents, representatives, and other organizations that provide support services to Aeroplan® undertake by contract or certificate of compliance to comply strictly with the commitments and rules mentioned in this Policy. They are prohibited from using Aeroplan® personal information for purposes other than those for which the information was provided to them. These agents, representatives and other organizations include our advertising agencies, our direct marketing agents, data processing and storage firms as well as mailing houses, and providers of administrative support services.

3. Aeroplan® implements security measures to ensure the confidentiality of personal information.

4. Aeroplan® issues directives to its employees to remind them of the obligations incumbent upon them to observe this Policy, and provides training on privacy matters to ensure employees understand its importance and how to protect personal information.

5. Aeroplan® issues reminders to its Partners that they and their agents and representatives must observe commitments and rules mentioned in this Policy;

6. Aeroplan® has established procedures to receive and investigate complaints and to provide the members with a prompt response.

1. Aeroplan® collects personal information for the following purposes:

(a) to verify members’ identities, to contact and to communicate with them;
(b) to answer members’ questions about a membership application, an account or any other service;
(c) to manage the Aeroplan® Program, particularly to record and update members’ accounts of Aeroplan® miles accumulated with Aeroplan® Partners;
(d) to manage and process requests for rewards, including the issuing of airline tickets, reservation of hotel rooms, car rentals, and other goods and services which can be obtained in exchange for Aeroplan® miles;
(e) to bill members and Partners;
(f) to have a better understanding of members’ preferences, needs and interests;
(g) to offer and to allow our partners to offer our members rewards, benefits, products, goods and services under the Aeroplan® Program; and
(h) to obey the laws and regulations in force and ensure the security and processing of information.

2. At the member’s request, Aeroplan® may record a member’s food choices and needs and disclose them to the airline companies with which the member travels. This information is transmitted to the food services department of the airline companies concerned or their contracted catering companies and to the cabin crew and serves exclusively for the aforementioned purposes.

3. Aeroplan® members may also take advantage of certain discounts or benefits for their children. To ensure their eligibility and issue airline tickets or certificates appropriately, we must obtain the name and date of birth of the child when the reservation is made. For verification purposes at the airport, members will have to present proof of the child’s identification and date of birth.

4. To comply with government-issued airport and air travel security regulations, Aeroplan® members requesting air travel rewards may be required to provide personal information, such as their full given names, date of birth, nationality, gender and passport or travel document number. This information is collected and may be transmitted to government authorities strictly for the aforementioned purposes.

1. Aeroplan® collects personal information from the following sources:

(a) from members:

(i) When a member enrolls in the Aeroplan® Program, Aeroplan® collects identifying information, including the member’s name, address, telephone number, Internet address, preferred language of communication, gender. To process payments, the member may also provide Aeroplan® with the member’s credit card number and expiry date.

(ii) When a member uses the Internet or other means to query the member’s account, claim rewards, purchase goods or services or inform us of the member’s needs or preferences, Aeroplan® collects the information provided by the member.

(iii) When a member completes a survey concerning the member’s preferences, needs or interests, conducted by Aeroplan®, its agents or representatives, and consents to the collection and use of the information for the purposes of the Aeroplan® Program, Aeroplan® collects the information provided by the member.

(b) from Partners:

(i) When a member makes purchases that allow the member to accumulate Aeroplan® miles, the Partner transmits to Aeroplan® the member’s identity, address and/or contact information, membership number, the number of miles earned, and the posting date. This allows Aeroplan® to know, in general, the identity of some businesses from which the member may have obtained products or services. However, Aeroplan® is not informed in any way by its Partners of the details of the transactions, except as described in the following paragraph regarding transactions effected with Air Canada and its affiliated carriers. In particular, Aeroplan® does not collect the details of purchases made using a Partner credit card; only the aggregate monthly Aeroplan® miles accumulation is disclosed to Aeroplan®.

(ii) Aeroplan® members have the opportunity to accumulate miles under Air Canada’s Frequent Flyer tier program. Since these miles are credited automatically, it is necessary for Aeroplan® to collect the following information: date, origin and destination of flight, flight number, booking class and class of service, member’s name, address and telephone number and member’s Aeroplan® membership number. This information is collected when the members make reservations.

(iii) When a member claims or uses a reward, goods or services offered by a Partner under the Aeroplan® Program, the Partner transmits to Aeroplan® the member’s identity, address and/or contact information, membership number, and the number of miles redeemed.

(c) from providers of rewards, benefits, products, goods and services, who are not Aeroplan® Partners, where a customer of the provider has consented to disclosure of personal information to us:

(i) so that we can offer them Aeroplan® membership, or

(ii)to receive rewards, benefits, products, goods and services offered by Aeroplan® and its Partners.

2. In responding to offers from Partners forwarded to members by Aeroplan® or its Partners, members may provide personal information to Partners. Provision of information by members to Partners and collection of information about members by Partners does not involve collection of personal information by Aeroplan® and so is the responsibility of individual members and the Partners alone.

1. Personal information collected by Aeroplan® is primarily used to communicate with members, to manage members’ accounts by keeping a record of the accumulation and redemption of miles, and to manage requests for rewards.

2. Personal information about members’ preferences, needs and interests is used to determine which members may be most interested in products or services offered by Aeroplan® and its Partners. The information is used solely to allow Aeroplan® and its Partners to communicate offers of rewards, benefits, products, goods and services under the Aeroplan® Program that are most likely to be of interest to the members. Aeroplan® does not provide individualized profiles of individual members to Partners or third parties.

3. When a Partner wishes to make an offer to members, offers will generally be forwarded to the members by Aeroplan® and not directly by the Partner.

4. On occasion Aeroplan® may provide the Partner with a list of the members to whom the offer has been sent, to assist the Partner in processing responses to the offer. From time to time Aeroplan® may also provide a Partner with a list of members who meet certain general criteria, while ensuring through contractual means or otherwise that the Partner is strictly limited to using the list for the following purposes:
(a) making an offer to members that allows them to accumulate or redeem miles under the Aeroplan® Loyalty Program, or
(b) making an offer to members that provides members with a benefit or privilege available exclusively to Aeroplan® members.
Use by the Partner for any other purpose is prohibited.

5. Personal information may be disclosed to agents, representatives or other organizations whose services are retained by Aeroplan® as described in section B(2) of this Policy. These agents, representatives or organizations must sign a confidentiality agreement and may only use the information disclosed to them for the purposes mentioned in the agreement, after which they must return this information to Aeroplan® or destroy the information, without keeping a copy. They are formally prohibited from disclosing the information to third parties without obtaining appropriate consent in advance. Such consent may only be granted for administrative support purposes.

6. Personal information may be disclosed to other Loyalty Programs managed by Aeroplan® when the identity of these programs is brought to the members’ attention and the members are offered in advance the possibility of refusing disclosure.

7. Personal information may be disclosed when the disclosure is required by law.

1. When a member has not earned or redeemed Aeroplan® miles during a three (3) year consecutive period, the membership may be canceled and information held regarding the member destroyed.

2. When a member's account has been inactive for seven (7) years, all information concerning the member is necessarily destroyed.

3. If a member informs Aeroplan® that the member wishes to terminate enrollment in the Program, all the information held regarding the member by Aeroplan® is archived within sixty (60) days and retained strictly for compliance verification purposes until the three or seven year period described above has elapsed.

1. Aeroplan® will not collect, use or disclose any Personal Information about a member without the consent of the member, except where required by law.

2. Aeroplan® will inform the members periodically, by means of brochures, correspondence, its Internet site, and/or its interactive voice response telephone system, of any change in its Policy on protection of personal information and privacy, and of any new collection, use or disclosure of personal information, to ensure appropriate consent. In such circumstances, Aeroplan® will use a combination of these methods to ensure that it has taken reasonable steps to contact all of its members.

3. Consent to the collection, use or disclosure of personal information beyond what is necessary for the administration of the Program is not a requirement for participation in the Program. Specifically, withdrawal of consent to the use of personal information to forward offers of products and services that may be of particular interest to a member will not result in the loss of the member’s privileges.

4. Aeroplan® will provide opportunities for members to withdraw consent for any use other than the collection or redemption of Aeroplan® miles or the administration of the Aeroplan® Program. Specifically, members can have their names deleted from the lists we share with our Partners by completing an opt-out request form.

5. When a member completes a survey concerning the member’s preferences, needs or interests, conducted by Aeroplan®, its agents or representatives, members will be provided with specific notice of the purposes for which personal information collected through the survey is to be collected, used, and/or disclosed. Any such survey will contain a statement reminding members that by completing and returning the survey, they are consenting to the collection, use and disclosure of the information provided in the survey for the purposes identified on the survey.

1. Aeroplan® updates personal information regarding members based on the information communicated to it by the member or by the Aeroplan Partners.

2. Aeroplan® does not continually update the personal information it holds regarding members unless this is necessary to achieve the purposes for which this information was collected. These updates are made in accordance with section D above.

3. As it is often fastest and most effective for members themselves to notify Aeroplan® when their information, such as name or address, changes, Aeroplan® requests that members ensure that the information they provide to Aeroplan® is up to date and accurate, and that where possible they inform Aeroplan® of changes to such information.

1. The security measures put in place by Aeroplan® are intended to protect personal information against loss or theft and against unauthorized consultation, disclosure, copying, use or alteration.

2. To ensure the confidentiality of personal information, Aeroplan® uses physical means, such as locking filing cabinets and restricting access to its offices, administrative measures, such as security clearances and selective access of its employees, agents and representatives, and technical or technological measures, such as the use of passwords and encrypted data. When it uses information technologies such as the Internet, Aeroplan® reminds its employees, agents, representatives and Partners of the importance of protecting the confidentiality of personal information.

3. Aeroplan® will implement measures to ensure secure destruction and disposal of personal information.

1. Individual applicants must identify themselves, provide their membership numbers and sign their applications so as to prevent fraud or the unjustified transmission of personal information to third parties. Individuals must provide sufficient information so that it is possible for Aeroplan® to inform them of the existence, use and disclosure of personal information.

2. Aeroplan® processes applications for access to or rectification of personal information within thirty (30) days of receipt of the application. This deadline may be extended by an additional period of thirty (30) days when processing of the application would seriously impede Aeroplan®’s activities or the circumstances or scope of the application make it impossible to comply with this deadline.

3. In general, Aeroplan® does not charge any fee for allowing a person to have access to the personal information held regarding that person and to obtain rectification of information. However, minimal fees may be charged when the application for access or rectification is complex.

4. Aeroplan® rectifies personal information to the extent that the person concerned establishes the incompleteness or inaccuracy of the information. Rectification may involve correction or deletion of the information or the addition of supplementary information.

5. If the person concerned is not satisfied with the response provided to an application for access or rectification, the person may file a complaint with the Aeroplan Privacy Officer.

1. A complaint or a request for an investigation may be addressed in writing to the Aeroplan Privacy Officer at the following address: Aeroplan Privacy Office, P.O. Box 23000, station Pointe-Claire-Dorval, Pointe-Claire, Quebec, H9Y 1K2.

2. Complaints or requests for an investigation shall be the object of an investigation or a response within sixty (60) business days. If the complaint is justified, Aeroplan® will take appropriate measures to address the complaint, including by allowing access to the requested information, by proceeding with rectification or, as the case may be, by amending its Policy and practices.