Privacy Policy

Your privacy is important to us. It is Alybio Travel LLC’s policy to respect your privacy and comply with any applicable law and regulation regarding any personal information we may collect about you, including via our app, Pullce, and its associated services. Personal information is any information about you which can be used to identify you. This includes information about you as a person (such as name, address, and date of birth), your devices, payment details, and even information about how you use an app or online service. In the event our app contains links to third-party sites and services, please be aware that those sites and services have their own privacy policies. After following a link to any third-party content, you should read their posted privacy policy information about how they collect and use personal information. This Privacy Policy does not apply to any of your activities after you leave our app. This policy is effective as of 2 July 2021. Last updated: 2 July 2021

Your privacy is important to us. It is Alybio Travel LLC’s policy to respect your privacy and comply with any applicable law and regulation regarding any personal information we may collect about you, including via our app, Pullce, and its associated services. Personal information is any information about you which can be used to identify you. This includes information about you as a person (such as name, address, and date of birth), your devices, payment details, and even information about how you use an app or online service. In the event our app contains links to third-party sites and services, please be aware that those sites and services have their own privacy policies. After following a link to any third-party content, you should read their posted privacy policy information about how they collect and use personal information. This Privacy Policy does not apply to any of your activities after you leave our app. This policy is effective as of 2 July 2021. Last updated: 2 July 2021

Information We Collect
Information we collect falls into one of two categories: “voluntarily provided” information and “automatically collected” information. “Voluntarily provided” information refers to any information you knowingly and actively provide us when using our app and its associated services. “Automatically collected” information refers to any information automatically sent by your device in the course of accessing our app and its associated services.

Log Data
When you access our servers via our app, we may automatically log the standard data provided by your device. It may include your device’s Internet Protocol (IP) address, your device type and version, your activity within the app, time and date, and other details about your usage. Additionally, when you encounter certain errors while using the app, we automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is. Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.

Device Data
Our app may access and collect data via your device’s in-built tools, such as:

  • Location data
  • Camera
  • Notifications

When you install the app or use your device’s tools within the app, we request permission to access this information. The specific data we collect can depend on the individual settings of your device and the permissions you grant when you install and use the app.

Collection and Use of Transactional Information
If you enroll in the Pullce app, the Company and its third party Service Providers (Fidel) will collect and monitor information regarding the transactions that you make on Linked Cards, as described in the Pullce Terms and Conditions. This information is referred to as “transactional data” and is treated differently than your personal information. For example, if you register a payment card as a “Linked Card” in connection with transaction monitoring, you authorize us to share your payment card information with the “Payment Networks” so the applicable Payment Network(s) is or are informed of the registration of the Linked Card as a part of Spire Loyalty. You authorize the applicable Payment Network(s) to monitor transactions on your Linked Card(s) to identify “Eligible Transactions” in order to determine whether you have qualified for or earned an offer linked to your Linked Card(s), and for the Payment Network(s) to share such transaction details with us to enable your Linked Card(s) offer(s) and provide offers that may be of interest to you. You may opt-out of transaction monitoring on the Linked Card(s) at any time by either deleting the Linked Card(s) in your account settings.

Notwithstanding anything to the herein or in the Pullce Terms and Conditions, Pullce and its third party Service Providers (Fidel) will use transaction information solely as follows:

  • Use transaction data such as transaction amount, transaction time and merchant location to confirm an Eligible Purchase or return to match transactions to confirm whether you qualify for rewards.
  • Share transaction data with the participating merchant where a transaction occurred as needed for the merchant to confirm a specific transaction occurred. For example, the date and amount of your purchase and the last 4 digits of your card number so the merchant can verify your purchase with its records if there is a missing or disputed transaction;
  • Provide participating merchants or third party Service Providers aggregated and anonymized information relating specifically to registered card activity solely to allow participating merchants and third party Service Providers to assess the results of their campaign; Create a record of the transaction data and thereafter maintain and use data in connection with operating the Pullce Platform;
  • Provide information in order to respond to a request from government authority or a payment organization involved in a transaction with you or a merchant.
  • Members authorize the sharing, exchange and use of transactional information described above and herein by and among Pullce and Pullce’s third party Service Providers (Fidel), applicable Payment Card Networks and applicable Merchants.

Transaction Monitoring
By registering a payment card in connection with transaction monitoring, you authorize Pullce to share your payment card information with Visa, Mastercard and AMEX (Payment Networks) so it knows you are enrolled. You authorize Mastercard, Visa and AMEX to monitor transactions on your registered card(s) to identify qualifying purchases in order to determine whether you have qualified for or earned an offer linked to your payment card, and for Visa, Mastercard and AMEX (Payment Networks) to share such transaction details with Pullce and participating merchants, to enable your card-linked offer(s) and target offers that may be of interest to you. You may opt-out of transaction monitoring on the payment card(s) you have registered by navigating to your settings menu to remove your linked card(s).

Personal Information
We may ask for personal information — for example, when you subscribe to our newsletter or when you contact us — which may include one or more of the following:

  • Name
  • Email
  • Date of birth
  • Phone/mobile number

Legitimate Reasons for Processing Your Personal Information
We only collect and use your personal information when we have a legitimate reason for doing so. In which instance, we only collect personal information that is reasonably necessary to provide our services to you.

Collection and Use of Information
We may collect personal information from you when you do any of the following on our website:

  • Register for an account
  • Sign up to receive updates from us via email or social media channels
  • Use a mobile device or web browser to access our content
  • Contact us via email, social media, or on any similar technologies
  • When you mention us on social media

We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:

  • to provide you with our app and platform’s core features and services
  • for analytics, market research, and business development, including to operate and improve our app, associated applications, and associated social media platforms
  • for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you
  • to comply with our legal obligations and resolve any disputes that we may have

We may combine voluntarily provided and automatically collected personal information with general information or research data we receive from other trusted sources. For example, If you consent to us accessing your social media profiles, we may combine information sourced from those profiles with information received from you directly to provide you with an enhanced experience of our app and services.

Security of Your Personal Information
When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification. Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security. You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our services. For example, ensuring any passwords associated with accessing your personal information and accounts are secure and confidential.

How Long We Keep Your Personal Information
We keep your personal information only for as long as we need to. This time period may depend on what we are using your information for, in accordance with this privacy policy. For example, if you have provided us with personal information as part of creating an account with us, we may retain this information for the duration your account exists on our system. If your personal information is no longer required for this purpose, we will delete it or make it anonymous by removing all details that identify you. However, if necessary, we may retain your personal information for our compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.

Children’s Privacy
We do not aim any of our products or services directly at children under the age of 13, and we do not knowingly collect personal information about children under 13.
Disclosure of Personal Information to Third Parties
We may disclose personal information to:

  • a parent, subsidiary, or affiliate of our company
  • third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, error loggers, debt collectors, maintenance or problem-solving providers, professional advisors, and payment systems operators
  • our employees, contractors, and/or related entities
  • our existing or potential agents or business partners
  • credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you
  • courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights
  • third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you
  • third parties to collect and process data
  • an entity that buys, or to which we transfer all or substantially all of our assets and business

Third parties we currently use include:

  • Fidel Limited to link your personal payment card to our loyalty system but we never hold your card details ourselves;
  • Google Analytics to track cookies and to analyse how frequently persons visit our website, with a view of improving and optimizing our website and app;
  • Azure as a hosting platform for the Pullce website and app

International Transfers of Personal Information
The personal information we collect is stored and/or processed in the United States, or where we or our partners, affiliates, and third-party providers maintain facilities. The countries to which we store, process, or transfer your personal information may not have the same data protection laws as the country in which you initially provided the information. If we transfer your personal information to third parties in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred personal information in accordance with this privacy policy.

Your Rights and Controlling Your Personal Information
Your choice:

By providing personal information to us, you understand we will collect, hold, use, and disclose your personal information in accordance with this privacy policy. You do not have to provide personal information to us, however, if you do not, it may affect your use of our app or the products and/or services offered on or through it.

Information from third parties:
If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Marketing permission:
If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.

Access:
You may request details of the personal information that we hold about you.

Correction:
If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details provided in this privacy policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.

Non-discrimination:
We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example serving particular content to your device), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.

Notification of data breaches:
We will comply with laws applicable to us in respect of any data breach.

Complaints
If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

Unsubscribe:
To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details provided in this privacy policy, or opt-out using the opt-out facilities provided in the communication. We may need to request specific information from you to help us confirm your identity.

Use of Cookies
Our privacy policy covers the use of cookies between your device and our servers. A cookie is a small piece of data that an app may store on your device, typically containing a unique identifier that allows the app servers to recognise your device when you use the app; information about your account, session and/or device; additional data that serves the purpose of the cookie, and any self-maintenance information about the cookie itself. We use cookies to give your device access to core features of our app, to track app usage and performance on your device, to tailor your experience of our app based on your preferences, and to serve advertising to your device. Any communication of cookie data between your device and our servers occurs within a secure environment. Please refer to our Cookie Policy for more information.