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HILTON HONORS GOLD STATUS UPGRADE PROGRAM-ASIA PACIFIC REGION PRIVACY POLICY. Offer is valid for cardholders in Asia Pacific (except Japan), Middle East & Africa

UPDATED AS OF: 12 December 2015

YOU ARE REQUIRED TO CAREFULLY READ AND ACCEPT THE TERMS AND CONDITIONS AND THE FOLLOWING PRIVACY POLICY ("PRIVACY POLICY) BEFORE REGISTERING FOR OR UTILISING THE HILTON HHONORS GOLD STATUS UPGRADE PROGRAM (THE "UPGRADE PROGRAM"). BY CLICKING ON THE "ACCEPT" BUTTON BELOW, YOU AGREE TO BE BOUND BY THIS PRIVACY POLICY (THE "PRIVACY POLICY") AND REPRESENT AND WARRANT THAT YOU HAVE THE RIGHT, AUTHORITY, AND CAPACITY TO AGREE TO AND ABIDE BY THIS PRIVACY POLICY.

Unless otherwise defined or the context otherwise requires, all capitalized terms used herein (such as "Upgrade Program", "Visa" and "Hilton Honors" have the same meanings ascribed to them in the Terms and Conditions.

For the purposes of this Privacy Policy, "personal information" means information from which an individual can, either alone or in conjunction with other information, be identified.

A. COLLECTION AND USAGE OF PERSONAL INFORMATION

1. Required Personal Information: In order to provide and fulfil the Upgrade Program benefits, Visa requires the following personal information (“Required Personal Information”) to be furnished by a person registering for the Upgrade Program (“User”):
  • Country of issuance of the Eligible Visa Card
  • Payment card account number (full 16 digit), or “Full Card Number” of the Eligible Visa Card
  • Hilton Honors account number
2. The Required Personal Information will be used/processed by Visa, Visa’s affiliate company and Hilton Honors as follows:
  • Full Card Number will have to be entered by the User for the purposes of Visa’s validation of the User’s card account as being eligible under the Upgrade Program. The Full Card Number will be transmitted via Visa’s proprietary system (“Phoenix”) to Visa Inc, Visa USA Inc and related Visa entities in the United States for validation. Upon validation, User will be redirected to fill in a registration form. If the Full Card Number is not valid, Phoenix will send the User an error message. The Full Card Number will be validated real time by Phoenix.
  • In the event that the User is successfully directed to the registration form (which resides in Visa’s Singapore server), the User will need to fill up all the Required Personal Information on the registration form except for Full Card Number. Upon completing the registration form and clicking “Submit”, the registration form and all information provided therein will be submitted via an automated process (protected by “Visa Secure” system” which includes password protection mechanism) to Hilton (located in the United States).
    All Required Personal Information contained in the registration form submitted by the User will be retained and processed by Hilton Honors in order for Hilton Honors to process the request for upgrade by the User under the Upgrade Program. Visa cannot control, and User agrees and acknowledges that Visa is not responsible for, any acts or omission on the part of Hilton in the use or processing of personal information by Hilton. Users may be required to agree and consent to additional privacy policies relating to the collection or usage of personal information by Hilton to which Visa is not a party and for which Visa is not responsible.
3. In addition to the above, Visa uses the Required Personal Information to:
  • Provide and operate the Upgrade Program benefits and any associated services requested by User;
  • Analyze usage and improve the Upgrade Program benefits and associated service(s);
  • Ensure the security and integrity of the Upgrade Program benefits;
  • Enforce Visa’s policies; and
  • Perform other activities with User’s consent
4. Visa may use and/or release Personal Information of any User, including where necessary with other companies and organizations outside of the User’s country of residence, when Visa in good faith believes that such release is necessary to:
  • comply with the law, including laws outside the User’s country of residence;
  • respond to governmental or regulatory bodies’ inquiries;
  • enforce or apply the Terms of Use and any other agreements to which Visa or the User is subject;
  • protect the rights, property, or safety of Visa, our employees, other Users, or others;
  • investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of the terms and conditions of using the Site
5. When a User accesses the registration site or webpage https://www.visa-promotions.com/promotions/HiltonHHonors/tnc.jsp (the “Registration Site”), Visa automatically receives and records information on Visa’s server logs from User’s browser or mobile platform, including User location , IP address, cookie information, and the page requested by User. Visa also uses session data, collected through cookies and pixel tags, to better understand how the Site is navigated, how many visitors arrive at specific pages, the length and frequency of stays at the Site, the variety of searches of the Site’s database, the types of browsers and computer operating systems used by visitors to the Site and the internet protocol addresses from which visitors connect to the Site. Visa treats all data obtained from the foregoing activities listed in this Clause A5 as non-Personal Information, except where Visa is required to do otherwise under applicable law. Visa may provide aggregate information to Visa’s partners (banks or merchants) about how Users collectively, use the Site and register for the Upgrade Program, so that Visa’s partners may be aware of frequency, numbers and activities of the Users on the Registration Site as well as understand how often people use the Registration Site and register for the Upgrade Program. However, for the avoidance of doubt Visa will not make specific identity references to any User in the provision of such aggregate information to its partners under this Clause A5.

6. Visa will neither rent nor sell User’s Personal Information to anyone. Visa may share User’s Personal Information only as described in this Privacy Policy.

B. THIRD PARTY WEBSITES

If User visits any third-party websites that are linked from the Registration Site, or uses any third-party services or applications linked to or connected to the Registration Site, User understands and acknowledges that certain Personal Information of User may be retrieved or tracked (by automated or other means) by third-party website owners or applications developers, over which Visa may have no control and Users should review such third party website’s privacy policy. Visa shall not be responsible in this regard, and makes no representation or guarantee that such third parties will protect the User’s Personal Information or follow Visa’s Privacy Policy.

C. TRANSFER TO ACQUIRER OR LIQUIDATOR

If Visa or substantially all of its assets are acquired, or in the unlikely event that Visa goes out of business or enters bankruptcy, Users understand and agree that their Personal Information will be transferred to or acquired by the relevant third party acquirer or liquidator. Users also understand and agree that prior to the consummation of any such transactions, their Personal Information may also be shared by Visa for purposes of facilitating such transactions.

D. COOKIES

1. The Registration Site may use cookie technology to improve user experience on the Registration Site and gather data for web site statistical reporting. The cookie technology that Visa uses does not capture individual email address or any personal information. 2. A cookie is a small piece of information sent by a web site that is saved on a user’s hard disk by the user’s computer’s browser. It holds information a site may need to personalize a user’s experience and gathers web site statistical data, such as which pages are visited, what is downloaded, the Internet provider’s domain name and country that visitors come from and the addresses of sites visited immediately before and after coming to the Registration Site website. However, none of this is associated with a User as an individual and is measured only in aggregate. 3. To browse without cookies, a User can configure his/her browser to reject all cookies or to notify User when a cookie is set. (Each browser is different, so User should check the “Help” menu of his/her browser to learn how to change User’s cookie preferences.) A User’s experience of the Site may be different if User sets his/her browser to block cookies.

E .SECURITY OF PERSONAL INFORMATION

1. Visa uses security technologies including firewalls and secure socket layers to help protect the personal information that Visa collects from Users. Visa's policies restrict access to personal information to those employees and service providers who need to know the information in order to provide Users with the relevant services under the Program. Visa uses its best endeavours to maintain physical, electronic and procedural safeguards to protect personal information. 2. While Visa endeavours to safeguard all Users’ personal information to ensure that each User’s personal information is kept private, as described in Clause E1 above, Visa cannot guarantee the security of User’s personal information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of User information at any time and User understands, acknowledges and assumes this risk.

F. USER ACCESS OF OWN PERSONAL INFORMATION

In the event that User wishes to access his/her Required Personal Information on the registration form that User had submitted for the purposes of rectification/correction, User may contact Visa through email in accordance with Section I below.

At any time, a User may revoke the consent regarding the collection, transfer, and/or entrustment of his/her personal information by Visa. User may exercise his/her rights of revocation of consent by contacting Visa through email in accordance with Section I below

G. RETENTION PERIOD

In the event of any of the following, Visa will delete or destroy the collected personal information by using technical means to render such data unusable:
  • When a User revokes User’s consent to the collection and handling of User’s data;
  • When the purpose for the collection and handling of User’s data has been fulfilled; or
  • When Visa’s business permanently closes.

H. CHANGES TO PRIVACY POLICY

Visa may amend this Privacy Policy from time to time in its sole and absolute discretion. The terms governing use, collection and storage of personal information will be the terms prevailing at the time when such personal information is submitted or provided in any other way to Visa by the User. If Visa makes material changes in the Privacy Policy, Users registered at the time of such changes will be notified by Visa posting an announcement on the first screen of the Registration Site or sending such Users an email. Users are bound by any changes to the Privacy Policy when they provide any personal information through the Registration Site after such changes have been first notified.

I. QUESTIONS AND CONCERNS

1. Users who have any questions or concerns regarding this Privacy Policy may send their queries via email to:

(a) For specific queries relating to the Upgrade Program or to a User’s own account, (including access to own personal information or revocation of consent to collection of personal information), please email to APoffers@visa.com

(b) For general inquiries on privacy, please email to privacy@visa.com or write to us at P.O. Box 194607, San Francisco, CA 94119-4607 Attention: Global Privacy Office.

(c) For any inquiries relating to Hilton Honors’s collection or use of personal information, please email Hilton Honors directly at customer_privacy@hilton.com or send queries by postal mail to Hilton Customer Privacy Department, 7930 Jones Branch Drive, McLean, VA 22102, USA.

2. Visa will make every effort to resolve your concerns. Please allow at least 5 working days for us to provide a response.

J. GOVERNING LAW AND JURISDICTION

This Privacy Policy is governed by the laws of Singapore. All Users agree to submit to the jurisdiction of the courts of Singapore over any dispute arising from or in connection with this Privacy Policy.

I consent to the collection and use of my personal information (including location information under Section A(5)) in accordance with the Privacy Policy.
I consent to the transfer of my personal information to third parties in accordance with the Privacy Policy.
I consent to the transfer of my personal information abroad in accordance with the Privacy Policy.