Luggage Lifeline Privacy Policy

 

Effective Date: September 12, 2023

Last Updated: May 02, 2024

 

This Privacy Policy explains how Luggage Lifeline collects, uses, discloses, stores, and protects personal information when you visit our website, purchase or register for our service, contact us, or use our lost baggage logistics support service.

 

Luggage Lifeline is a brand of the Kennedy Circle group of companies. In this Privacy Policy, “Luggage Lifeline,” “we,” “us,” and “our” mean Kennedy Circle, its affiliates, and service providers acting on its behalf.

 

This Privacy Policy is intended to comply with applicable privacy laws, including, where applicable, Delaware privacy laws, other U.S. state privacy laws, and U.K./European privacy requirements.

 

1. What We Do

 

Luggage Lifeline provides a logistics planning, sourcing, coordination, and delivery service for travelers whose checked luggage does not arrive at their destination. We are not an insurance company and do not sell insurance. We use personal information to determine eligibility, arrange service, source replacement travel essentials, communicate with customers, process payments, and coordinate delivery to a hotel, villa, cruise port, or other approved place of stay.

 

2. Personal Information We Collect

 

We may collect the following categories of personal information:

 

A. Contact and Identity Information

 

This may include your name, email address, phone number, billing address, country of residence, and the customer name listed on the checkout form.

 

B. Travel and Booking Information

 

This may include your flight details, destination country, travel dates, airline, arrival airport, hotel or accommodation address, booking reference, and information confirming that your purchase applies to one eligible flight within the applicable service period.

 

C. Lost Baggage Claim Information

 

If your luggage is delayed or lost, we may collect your Property Irregularity Report number, airline file reference number, baggage claim information, airline communications, and related details needed to evaluate and coordinate your service request.

 

D. Sizing and Preference Information

 

To source replacement essentials, we may collect clothing sizes, shoe size, bathing suit size, preferred fit, gendered or non-gendered clothing preferences, basic style preferences, and other practical information needed to assemble a replacement essentials suitcase.

 

E. Delivery and Accommodation Information

 

This may include your hotel name, room number if necessary, villa address, cruise port details, local phone number, delivery instructions, and the name of a person authorized to receive delivery.

 

F. Payment and Transaction Information

 

We may collect transaction amount, purchase date, payment status, refund status, and limited payment details. We do not intentionally store full credit card numbers. Payment card information is processed by our payment processor.

 

G. Communications

 

We may collect messages, emails, forms, chat transcripts, call notes, customer support records, and feedback you provide.

 

H. Website, Device, and Advertising Information

 

When you use our website, we may collect IP address, device type, browser type, operating system, pages viewed, referring pages, approximate location, cookie identifiers, advertising identifiers, and analytics data.

 

I. Sensitive Information

 

We do not ask for sensitive information unless it is reasonably necessary for the service or you choose to provide it. For example, if you voluntarily tell us about a disability, medical need, allergy, mobility limitation, or special delivery requirement, we may use that information only to support your requested service. Please do not provide sensitive information unless it is necessary for us to assist you.

 

3. How We Collect Information

 

We collect information:

 

1. directly from you when you complete checkout, submit a registration form, contact us, or request service;

2. from your travel companion or authorized representative, if they contact us on your behalf;

3. from airlines, baggage service desks, delivery partners, hotels, sourcing partners, or travel providers when needed to verify or perform the service;

4. from payment processors and fraud prevention providers;

5. automatically through cookies, analytics tools, advertising pixels, and similar technologies; and

6. from publicly available or commercially available sources where permitted by law.

 

4. How We Use Personal Information

 

We may use personal information for the following purposes:

 

1. to process purchases and confirm customer eligibility;

2. to register the customer and applicable flight;

3. to verify that the purchase applies to the named customer and eligible trip;

4. to respond to lost baggage service requests;

5. to review PIR numbers, file reference numbers, and baggage claim details;

6. to source replacement travel essentials;

7. to arrange delivery to your approved accommodation or destination location;

8. to communicate with you by email, phone, SMS, messaging service, or other contact method;

9. to provide customer support;

10. to process refunds where applicable;

11. to prevent fraud, misuse, abuse, or unauthorized claims;

12. to improve our website, service, operations, and customer experience;

13. to conduct analytics and measure advertising performance;

14. to market our services, subject to your rights and choices;

15. to comply with legal, tax, accounting, regulatory, and law enforcement obligations;

16. to enforce our Terms of Service and other agreements; and

17. to protect the rights, safety, and property of Luggage Lifeline, our customers, partners, and others.

 

5. Lawful Basis for U.K. and European Users

 

Where U.K. GDPR, EU GDPR, or similar laws apply, we rely on one or more of the following lawful bases:

 

Contract

 

We process personal information to provide the service you purchased or requested, including registration, service eligibility, sourcing, delivery, customer support, and refunds.

 

Legitimate Interests

 

We process information for legitimate business interests, including fraud prevention, service improvement, analytics, customer communications, business administration, security, and limited marketing, provided those interests are not overridden by your rights.

 

Consent

 

We rely on consent where required, including for certain cookies, direct marketing, sensitive information, or optional information you choose to provide.

 

Legal Obligation

 

We process information when necessary to comply with tax, accounting, legal, regulatory, or law enforcement obligations.

 

Vital Interests

 

In rare cases, we may process information to protect someone’s vital interests, such as in an emergency affecting safety or wellbeing.

 

6. How We Share Personal Information

 

We may share personal information with the following categories of recipients:

 

A. Sourcing and Logistics Partners

 

We may share information with local partners who source clothing, toiletries, travel essentials, luggage, or other replacement items, and with delivery partners who deliver those items.

 

B. Hotels, Accommodation Providers, and Travel Partners

 

We may share delivery details with hotels, villas, cruise operators, concierge desks, airport representatives, or other destination contacts when needed to complete delivery.

 

C. Airlines and Baggage Claim Providers

 

We may communicate with airlines, baggage service desks, baggage handling companies, or related providers to verify baggage delay details or coordinate service.

 

D. Payment Processors

 

We share payment and transaction information with payment processors to process purchases, refunds, chargebacks, and fraud checks.

 

E. Technology and Business Service Providers

 

We may share information with website hosts, cloud storage providers, customer support tools, email providers, analytics providers, CRM systems, fraud prevention vendors, professional advisors, and other operational service providers.

 

F. Advertising and Analytics Partners

 

We may use advertising and analytics services to measure website traffic, understand customer interest, and show ads to potential customers. These partners may collect cookie identifiers, device information, IP address, browsing activity, and similar data.

 

G. Affiliates

 

We may share information with companies in the Kennedy Circle group of companies for administration, operations, customer support, compliance, reporting, and service improvement.

 

H. Legal and Safety Recipients

 

We may disclose information when required or permitted by law, including to courts, regulators, law enforcement, tax authorities, professional advisors, insurers, or parties involved in a dispute.

 

I. Business Transaction Parties

 

If we are involved in a merger, acquisition, financing, restructuring, sale of assets, bankruptcy, or similar transaction, personal information may be disclosed or transferred as part of that transaction.

 

We do not sell your personal information for money. However, certain advertising or analytics activities may be considered “targeted advertising,” “sharing,” or a “sale” under some privacy laws. You may opt out as described below.

 

7. Cookies, Analytics, and Advertising

 

We may use cookies, pixels, tags, software development kits, local storage, and similar technologies to:

 

1. operate the website;

2. remember your preferences;

3. analyze website traffic and user behavior;

4. measure advertising performance;

5. prevent fraud and protect security; and

6. deliver or measure ads.

 

Where required by law, we will ask for your consent before placing non-essential cookies. You can manage cookies through your browser settings and, where available, through our cookie banner or privacy choices link.

 

8. Your Privacy Choices

 

Depending on where you live, you may have the right to:

 

1. confirm whether we process your personal information;

2. access your personal information;

3. correct inaccurate personal information;

4. delete personal information;

5. obtain a copy of personal information in a portable format;

6. request a list or categories of third parties to whom information has been disclosed;

7. opt out of targeted advertising;

8. opt out of the sale or sharing of personal information;

9. opt out of certain profiling or automated decision-making;

10. withdraw consent where processing is based on consent;

11. object to or restrict certain processing; and

12. appeal a decision we make about your privacy request.

 

To exercise your rights, contact us at:

 

Email: info@luggagelifeline.com

 

Privacy Choices Link: [Insert “Your Privacy Choices” or “Do Not Sell or Share My Personal Information” link]

 

We may need to verify your identity before responding to certain requests. We will not require you to create a new account to exercise your privacy rights, but we may ask for information reasonably necessary to verify the request.

 

9. Delaware Privacy Rights

 

If you are a Delaware resident and the Delaware Personal Data Privacy Act applies to us, you may have the right to:

 

1. confirm whether we process your personal data;

2. access your personal data;

3. correct inaccuracies in your personal data;

4. delete personal data provided by or obtained about you;

5. obtain a portable copy of your personal data;

6. obtain a list or categories of third parties to whom we disclosed your personal data;

7. opt out of targeted advertising;

8. opt out of the sale of personal data; and

9. opt out of profiling in furtherance of solely automated decisions that produce legal or similarly significant effects.

 

We will respond to Delaware consumer requests within the time required by law. If we deny your request, you may appeal by contacting us at info@luggagelifeline.com

and writing “Privacy Appeal” in the subject line.

 

If your appeal is denied, you may contact the Delaware Department of Justice regarding your concern. The Delaware Department of Justice has identified privacy@delaware.gov as the contact email for privacy complaints.

 

We honor valid opt-out preference signals where required by law, including browser-based or device-based universal opt-out mechanisms that communicate a consumer’s choice to opt out of targeted advertising or sale of personal data.

 

10. California and Other U.S. State Privacy Rights

 

Residents of certain U.S. states may have additional privacy rights. Where applicable, we will provide those rights as required by law, including rights to access, delete, correct, opt out of sale or sharing, opt out of targeted advertising, limit certain uses of sensitive information, and appeal certain privacy request decisions.

 

To exercise these rights, use the contact methods listed in this Privacy Policy.

 

11. U.K. and European Privacy Rights

 

If U.K. GDPR, EU GDPR, or similar laws apply to you, you may have the right to:

 

1. access your personal data;

2. correct inaccurate or incomplete personal data;

3. request deletion of your personal data;

4. restrict processing;

5. object to processing based on legitimate interests;

6. object to direct marketing;

7. request data portability;

8. withdraw consent at any time where processing is based on consent; and

9. lodge a complaint with a supervisory authority.

 

If you are in the United Kingdom, you may contact the Information Commissioner’s Office. If you are in the European Economic Area, you may contact your local data protection authority.

 

12. International Transfers

 

Luggage Lifeline is operated by a Delaware limited liability company, and we may process personal information in the United States and other countries where we, our affiliates, or our service providers operate.

 

If you are located outside the United States, your personal information may be transferred to countries that may not provide the same level of data protection as your home country. Where required, we use appropriate safeguards, such as contractual protections, data processing agreements, transfer terms, consent, necessity for contract performance, or other lawful transfer mechanisms.

 

13. Data Retention

 

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the service, complete deliveries, support customers, process refunds, prevent fraud, comply with legal and tax obligations, resolve disputes, and enforce agreements.

 

Our retention periods may vary depending on the type of information. For example:

 

1. customer account, registration, and purchase records may be retained for legal, tax, accounting, and service history purposes;

2. lost baggage claim records may be retained for service verification, dispute resolution, and fraud prevention;

3. delivery records may be retained to confirm completion of service;

4. marketing records may be retained until you opt out or until no longer needed;

5. cookie and analytics data may be retained according to the settings of the relevant analytics or advertising provider; and

6. sensitive information, if collected, will be retained only as long as reasonably necessary for the specific purpose for which it was provided, unless a longer period is required by law.

 

14. Data Security

 

We use reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure.

 

No method of transmission or storage is completely secure. We cannot guarantee absolute security, but we work to protect personal information in a manner appropriate to the nature of the information and the risks involved.

 

15. Children’s Privacy

 

Our service is intended for adults and is not directed to children under 18. We do not knowingly collect personal information from children under 13.

 

If we learn that we have collected personal information from a child in a way that violates applicable law, we will take appropriate steps to delete it or obtain required parental consent.

 

We do not knowingly sell personal information or process personal information for targeted advertising where we know the consumer is under 18, unless legally valid consent has been obtained.

 

16. Marketing Communications

 

We may send service-related messages, including purchase confirmations, registration reminders, service updates, delivery updates, and customer support communications.

 

We may also send marketing communications where permitted by law. You may opt out of marketing emails by using the unsubscribe link in the email or contacting us. Even if you opt out of marketing, we may still send non-marketing messages related to purchases, service requests, legal notices, safety, or account administration.

 

17. Automated Decision-Making

 

We do not use solely automated decision-making to make decisions that produce legal or similarly significant effects about you. We may use automated tools to help detect fraud, manage advertising, route customer requests, or improve operations, but important service decisions are subject to human review where appropriate.

 

18. Third-Party Websites and Services

 

Our website may link to third-party websites, payment processors, airline sites, hotel sites, social media platforms, or other services that we do not control. Their privacy practices are governed by their own privacy policies. We are not responsible for the privacy or security practices of third parties.

 

19. Accessibility

 

We aim to make this Privacy Policy reasonably accessible. If you need this Privacy Policy in another format, please contact us at info@luggagelifeline.com.

 

20. Changes to This Privacy Policy

 

We may update this Privacy Policy from time to time. When we do, we will update the “Last Updated” date above. If we make material changes, we may provide additional notice, such as by posting a notice on our website or contacting you directly where required by law.

 

21. Contact Us

 

If you have questions about this Privacy Policy or wish to exercise your privacy rights, contact us at:

 

Luggage Lifeline

A brand of the Kennedy Circle group of companies

 

Email: info@luggagelifeline.com

 

For privacy rights requests, please include your name, email address, country or state of residence, and the nature of your request. Please do not include unnecessary sensitive information in your request.