Aeroplan Identity Verification Privacy Notice
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Aeroplan Instant Verification Privacy Notice

This notice explains how Aeroplan and its service provider, Persona Identities Inc. (“Persona”), handle your personal information, including biometric information, in connection with Aeroplan’s identity verification and fraud prevention service (“Instant Verification”).  

Instant Verification is based on facial biometrics, which are measurements of your facial features extracted using facial recognition technology. This service is available to members aged 18 and older. For non-biometric options for verifying your identity, see section 5.

1. How Instant Verification works

If you consent by pressing the “consent and continue” button:

  1. You will be guided to use your mobile device to take photos of your passport, driver’s license, NEXUS card or other accepted and valid government ID (“government ID”), as well as a live selfie.
  2. You will be asked to upload the photos of your government ID and then your selfie.
  3. Persona will validate the authenticity of your government ID and confirm that the information on it matches your Aeroplan member information.
  4. If the government ID is authentic and matches your Aeroplan member information, Persona will use facial recognition technology to analyze and measure the facial features in the government ID image and your selfie. This creates unique numerical representations called faceprints, which are biometric information. Persona then compares these faceprints to see if they match.
  5. If the faceprints match, your identity is verified. If your faceprints do not match, your identity is not considered verified. This decision is based solely on the automated processing of information.
  6. Your faceprints and other personal information used for Instant Verification will be retained for a reasonable period no longer than one year (subject to any legal requirement), to prevent and detect related fraud.
  7. 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.
  8. You can find more information on Persona’s privacy policy.

2. Personal information used for Instant Verification

  1. Government ID: photos of the ID and the information they contain, excluding data restricted by law where you live
  2. Selfie: a live-captured image of your face
  3. Faceprints: facial biometrics information created from the facial images in your government ID and selfie
  4. Aeroplan Member Information: member number, name, address and date of birth
  5. Technical and connection information such as: IP address, device OS, device type, browser type, general geolocation data.

    This information is used to verify your identity and to determine the authenticity of your government ID, and to 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. Protection of personal information collected and used for Instant Verification

Persona and its subcontractors process the personal information collected and used for Instant Verification 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 your biometric information, although Persona may be paid for its services.

Aeroplan and Persona will not disclose your biometric information unless you 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).

Your 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 you live. This means your 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 Instant Verification is protected by physical, technological and organizational security measures. For example, your biometric information (faceprints) is irreversibly hashed before storage and the originals destroyed. Your other 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 your information is monitored and limited to authorized personnel who need it to perform their duties in connection with Instant Verification. At the end of the retention period, all personal information, including hashed faceprints, is destroyed.

4. Non-biometric options for verifying your identity

Alternatively, your identity is verified if one of the following applies to you:

  1. You fly or have already flown on two Air Canada, Air Canada Rouge or Air Canada Express operated flights on two separate bookings within the last five years.

Air Canada verifies your identity in person when checking your government ID at boarding.

or

  1. You are the primary holder of an Aeroplan credit card linked to and bearing the same name as your own Aeroplan Account

We rely on the verification made by the bank that issues the card.

or

  1. You present your proof of identity in person to an Air Canada representative at one of the following airports: Montreal Trudeau (YUL); Chicago O’Hare (ORD) or Charles de Gaulle (Paris-CDG).

Find more information on non-biometric options for identity verification

5. More Information

For more information on how Aeroplan handles your personal information, consult the Aeroplan Privacy Policy

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.