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Data Protection Policy

1. INTRODUCTION

As part of our responsibilities to be fully compliant with all rules and regulations where we operate and offer our services, Premier Destination Services Inc. or an affiliate of Premier Destination Services Inc. (together, “Premier” or “Premier Affiliates”), are committed to international compliance with data protection laws.

Ensuring data protection is pivotal not only to our service offering and reputation, but most importantly for building and developing trustworthy partnerships with businesses and customers alike.Daniel Wing

This policy (“Policy”) sets out our commitment to comply with all rules and regulations under all applicable data protection laws, including transparency. It provides the necessary framework conditions and ensures the proper level of data protection for cross-border data transmission among the Premier Affiliates (as defined below), staff, consultants and/or contractors.

The Executive Committee and Compliance Committee (as defined below), responsible for ensuring that we comply with all legal obligations, have approved this policy. It sets out the rules and steps to take or actions to carry out whenever we obtain, store, use, delete and/or destroy Personal Data (as defined below).

2. POLICY SCOPE & APPLICATION

We process Personal Data of Individuals (as defined below) such as staff, consultants and/or contractors, and customers only for specific purposes, including but not limited to pre-authorized services.

This processing is regulated by data protection laws, rules and regulations where we operate and from May 2018 the European Union’s General Data Protection Regulation (“GDPR”).

Premier is not registered as a Data Controller/Processor with any regulatory body and/or authority; however, we take data privacy and protection obligations extremely seriously- including the different data managing roles we may play- and are fully committed to be compliant with GDPR and other legislation where we operate.

This Policy applies to all our staff, consultants and/or contractors/agents, and other third parties authorized by us who use or process any Personal Data pertaining or related to us and/or our service offering. In countries where the data of legal entities is protected to the same extent as Personal Data, this Policy will equally apply.

Premier Affiliates are not entitled to adopt regulations that deviate from this Policy. Additional data protection policies can be created in agreement with the Data Protection Officer (as defined below) and Compliance Committee only if required by applicable national laws.

Overall, the reason for enforcing this Policy is to make sure that all Personal Data handled by us and/or oue staff, consultants and/or contractors, is:

• Handled and processed in a lawful, fair and transparent manner;
• Handled and processed specifically, explicitly, legitimately and most important –exclusively- for the purposes of our service offering;
• Handled and processed not in a manner that is incompatible with those purposes;
• Handled and processed with proper care – including appropriate safeguards set out by us- accurate, up to date and limited scope to what is required; and
• Avoid keeping it longer than necessary other than for the purposes for which it is being processed.

3. POLICY DEFINITIONS

Definition of the following terms used throughout this Policy include:

• Consent: means the Individual has been fully informed of the intended purpose of processing Personal Data, and agrees for Premier (including but not limited to Premier Network –as defined below-, staff, consultants and/or contractors) to do so without pressure being exerted upon them. There must be some active communication between the Premier, the Data Controller and/or the Individual such as consent is given as part of completion of an on-line form, physical signing a form or in email format and a record of the consent should be retained;
• Data Controller: includes any individual, business partner, government authority or other body who (or which) decides what Personal Data Premier will process and for what purpose, and the means and guidelines for its use. Premier’s Data Controller role is limited to the data which it processes directly – including staff, consultants and/or contractors personal information;
• Data Processor: means any individual, business partner, contractor or third party, which processes Personal Data on Premier’s behalf and/or on Premier’s instructions (i.e. those within Premier’s supply chain network that provide a specific service);
• Data Protection Officer (“DPO”): is the person accountable for ensuring that Premier follows this Policy and complies with all data protection laws, including GDPR;
• Individual: includes all data subjects who Premier holds or otherwise process Personal Data on behalf of. All Individuals have legal rights in relation to their Personal Data as prescribed by law and as described in this Policy;
• Personal Data: entails any personal information relating to a living individual who is either identified or identifiable. It must be an individual and cannot be a company or a public body. Legal representatives of companies or organizations would, however, be individuals;
• Premier Affiliates comprises a group of entities affiliated with or controlled by Premier for purposes of Premier’s service offering;
• Processing means any activity and/or operation carried out by a Data Processor that involves Personal Data; and
• Special Categories of Personal Data include information deemed sensible about an individual, such as racial or ethnic origin; political opinions; religious beliefs; disabilities; health and medical records; genetic and biometric data; criminal records and sexual orientation. Premier will process this Personal Data only if required by law and/or under strict conditions.

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