This notice explains how Aeroplan and its service provider, Persona Identities Inc. (“Persona”), handles a minor’s personal information, including their government-issued ID or document, to verify that document and validate a request, and otherwise detect and prevent fraud (“Identity Verification for Minors”).
Only the parent or legal guardian of an Aeroplan Member aged 17 or younger (the “minor”) may complete the Identity Verification for Minors process and consent to the collection and use (including storage and deletion) of personal information needed for that purpose.
1. How Identity Verification for Minors works
If you check the checkbox to confirm that you are the parent or legal guardian of the minor and that you consent to the collection and use of both the minor’s personal information and your own as described in this notice, then:
- You will be guided to use your mobile device to take photos of the minor’s valid government photo ID. For example: passport, driver’s license or NEXUS card (“government ID”).
- You will be asked to upload the photo of the minor’s government ID.
- Persona will verify the authenticity of the minor’s government ID and confirm that the information on it matches the minor’s Aeroplan Member information.
- If the minor’s government ID, and other information are satisfactory, the minor’s request will be met. If not, the request is declined. This decision is based solely on the automated processing of information. To seek a review of this decision, see section 3.
- The minor’s government-issued ID, and other personal information used for Identity Verification for Minors will be retained for a reasonable period no longer than one year (subject to any legal requirement), to prevent and detect related fraud.
- Where applicable, you can withdraw your consent by contacting our Principal Privacy Officer (see section 6 below). If you withdraw your consent, Aeroplan may still retain and use some of your personal information as permitted or required by law, including to comply with legal obligations, to prevent fraud, and to establish, exercise or defend against legal claims.
2. Personal information used for Identity Verification for Minors
- Minor’s government ID: photos of the ID and the information it contains, excluding data restricted by law where the minor lives
- Minor’s Aeroplan Member Information: member number, name, address and date of birth
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Technical and connection information such as: IP address, device OS, device type, browser type, general geolocation data.
This information is used to verify the authenticity of the minor’s government ID so as to verify their identity and otherwise prevent and detect fraud related to Aeroplan accounts. It will be retained for a reasonable period no longer than one year, or for a longer period if required by law, after which it is destroyed.
3. Requesting Assistance
You will be able to request assistance during the automated process if you are unable to complete Identity Verification for Minors or would like a review of a decision that their identity was not considered verified.
4. Protection of personal information collected and used for Identity Verification
Aeroplan through Persona uses the minor’s government ID exclusively for purposes of Identity Verification for Minors.
Persona and its subcontractors process the personal information collected and used for Identity Verification for Minors only on Aeroplan’s instructions. They may not disclose it or use it for their own business or commercial purposes. Neither Aeroplan nor Persona may sell, lease, trade, or otherwise profit from the minor’s information, although Persona may be paid for its services.
Aeroplan and Persona will not disclose the minor’s information without consent or if the disclosure is required by law (for example, in response to a valid legal process such as a court order or warrant).
The minor’s personal information will be handled by Persona and its subcontractors in Canada and in the United States of America, possibly outside the province or state where the minor lives. This means their information may be subject to the laws of these jurisdictions, which may permit access by courts, law enforcement or other governmental authorities.
Persona and its subcontractors are contractually bound to meet stringent data protection requirements. All information used for Identity Verification for Minors is protected by physical, technological and organizational security measures. For example, the minor’s personal information is also encrypted in transit and at rest, and the systems that process it are subject to a vulnerability management program. Access to personal information is monitored and limited to authorized personnel who need it to perform their duties in connection with Identity Verification for Minors. At the end of the retention period, all personal information is destroyed.
5. More Information
If you have concerns or further questions or wish to withdraw your consent, make a formal access or correction request or terminate your Aeroplan membership, please contact our Principal Privacy Officer using the contact information below.
Email: AeroplanPrivacy@aircanada.ca
Address:
Aeroplan Principal Privacy Officer
P.O. Box 23000
Station Pointe-Claire-Dorval
Pointe-Claire, QC H9Y 1K2
Please note that we will need to take reasonable steps to validate your identity prior to disclosing any personal information via the above communication channels.