Avianis Systems, LLC Privacy Policy

Effective August 1, 2022

In this privacy policy (the Privacy Policy), we describe the information, including personal information, that Avianis Systems, LLC (Avianis), a Wheels Up company, collects about you and our use and disclosure of that information. Unless stated otherwise, this Privacy Policy applies to information that we collect on our website and our mobile application (collectively, our Sites), when you use our services available through our Sites and offline, such as when you contact or interact with us (collectively, our Services). If you use our Services as a registered user of our Subscription Services (as defined below), please see our notice directed to users of our Subscription Services. Please note that depending on your relationship with us, our use of your information may be governed by additional terms, such as those set forth in your master services, software subscription, or other agreement. If there is a conflict between your agreement and this Privacy Policy pertaining to your personal information, then your agreement will govern with regard to that particular conflict.

Please note that this Privacy Policy pertains only to Avianis Systems, LLC. If you use products or services provided by another Wheels Up company, or visit other websites or applications operated by a Wheels Up company, please review the policies made available by such other Wheels Up company(ies).

When you use the Services, whether as a guest or registered user, your use will be subject to this Privacy Policy, which is incorporated into and forms a part of the Terms of Service. Where permitted by applicable law, any disputes regarding our use, disclosure, or other processing of your information, including your personal information, will be subject to the dispute resolution form of the Terms of Service.

This Privacy Policy may change from time to time. If we make material changes to the manner in which we use, disclose or otherwise process your personal information, we will endeavor to notify you by noting on the Site that the Privacy Policy is new or by emailing you at the last known email address on record (if you have registered with us).

1.           Information We Collect About You and How We Collect It

We collect information, including personal information, about you, including, information that we collect directly from you, from other persons, and automatically as you use our Sites and our Services.

1.1.            Information We Collect Directly From You: The scope of information, including personal information, that we collect from you varies based on your interaction with our Sites and Services. We collect information from you as follows:

(a)                Account creation/update: when you create an account with us, we collect the following information: name, contact information (such as phone, email, postal and physical mailing address, and company information). Depending on the type of account you have with us, you may have the option of storing additional items relevant to your account, such as identification information (e.g., passport number, country of citizenship).

(b)               Log into your account/take action within your account: we collect your log on credentials and any information regarding your use of our Services once logged in, such as date and time of your particular log in.

(c)                Contact us: such as to report a problem with our Services or to make a request.

(d)               Chat with us: certain of our Sites provide you with the opportunity to chat with us.

(e)                Provide us with general information: Complete a survey or questionnaire or ask for a demonstration of our Services.

(f)                 Sign Up for Email Marketing: we collect your name and email address if you sign up to request email advertising from us.

1.2.            Information We Collect from Other Persons: We also collect information, including personal information, about you from other persons:

(a)                Your employer: If your employer has purchased Subscription Services from us, your employer may provide us with a list of persons authorized to use the Subscription Services. Your employer typically provides us with names and business contact information. More information about how we use data in conjunction with our Subscription Services (defined below) is set forth in the section Information we Collect as a Service Provider.

(b)               Third party integrations. Our Subscription Services permit customers to connect authorized third-party service providers to the customers instance of our Subscription Services. If your employer connected such third parties to its instance of our Subscription Services, we may collect information about you from those connected third parties.

1.3.            Information We Collect Automatically: We automatically collect certain information about you when you use our Services and Subscription Services. We collect this information through our service providers, which include operating systems and platforms, internet service providers, and data analytics providers. The type of information that we collect varies on the settings on your browser, the particular Site, your App, and your interactions with our Services, and may include: information about your equipment, browsing actions and patterns, such as the date/time you visit/log into our Services, the pages you visit, the length of time on each page, our IP address, device ID, device type, location information (collected, e.g., through our analytics providers). Our service providers also may track your behavior through links that you click on our Sites. See the section below titled Cookies and Tracking for more information. If you are logged into our Subscription Services, we may associate certain of this automatically collected information with your account, for example, for trouble-shooting purposes, and to assist us in determining how users use our Services, but we do not typically associate this information with the personal information that we collect about you.

2.           How We Use Your Information

We use your information, including personal information, for the following purposes:

2.1.            To provide our Services to you and for other Transactional Purposes: to provide our Services to you. For example, to facilitate your access to our Subscription Services.

2.2.            Communicate with You: to communicate with you, respond to your inquiries, and for other customer services purposes. This may include contacting you regarding your customer support or other requests.

2.3.            Marketing/Advertising: for marketing purposes, including, as permitted by applicable law, to provide you with special offers, promotions, news, and newsletters; to contact you about products we think may interest you, including products offered by our affiliated entities; to administer contests, promotions, and other offers; and for other marketing, advertising, and promotional purposes. Where permitted by applicable law, our communications may include information about Avianis or any other entity within the Wheels Up family that we think may be of interest to you. Our marketing communications with you may include communications via postal mail and email. We, and our service providers, also use your information to determine the success of our advertising campaigns, regardless of the marketing and advertising channel.

2.4.            Administration: for administrative purposes, including to manage access to and security of our Sites and Services, and to facilitate proper functioning of our Services; to help us better understand how our customers access and use our Services, including the pages viewed, ad impressions clicked, or other Site activity; to maintain security and operability of our Sites (including for debugging purposes); to provide reports to prospective partners, service providers, regulators, and others; to implement and maintain security, anti-piracy, fraud prevention, and other services designed to protect you and us; to enforce this Privacy Policy, our Terms of Service, and other policies.

2.5.            Research and development/Analytical purposes: for research and development purposes, including to improve our Services, products, and customer experience; to understand what parts of our Sites are most popular or to improve upon such Sites; to understand our customer demographics; and for other research and analytical purposes.

2.6.            Legal compliance: to comply with applicable legal or regulatory obligations, including to respond to a subpoena or court order; to cooperate with law enforcement or other governmental investigations; and as part of legal proceedings.

2.7.            Protection of us and others: where we believe it is necessary to protect us and others, including, without limitation to detect, prevent, and respond to fraud, security incidents, or other issues where we believe it is appropriate to protect us and others.

3.           Disclosure of Your Information

We disclose your information, including your personal information, as set forth in this Privacy Policy and as we may notify you from time to time.

3.1.            To our affiliates and subsidiaries: we may share anonymized data (e.g., data that is not personal data and data that cannot be traced back or linked to a customer) with our affiliates and subsidiaries.

3.2.            Analytics Providers/Advertisers: as set forth above, we share information with analytics providers to assist us in evaluating the use of our Site, App, and Services. Often the information that we share is collected from you through cookies and other tracking technologies on our Sites.

3.3.            Regulatory Entities: certain flights flown using our Services are flown pursuant to FAR Part 135, which requires disclosure of the name of all persons on a flight to the operator performing the flight, and customers who use our Subscription Services may therefore be required to furnish passenger data, such as name and date of birth, or passport information, to comply with national and international security requirements for governing bodies. Additionally, our customers may be required to furnish passenger data, such as name and date of birth, or passport information, to comply with national and international security requirements or governing bodies. We would only release information to governmental entities as required by law.

3.4.            Ground Transportation: if we process this information as part of our Services, it may also be necessary for tour customer provide names of persons on a flight to third parties providing services related to a flight such as ground transportation at your request.

3.5.            Service Providers: we provide your information to service providers to assist in providing our Services to you. These providers are entities that host our websites and data, assist us with marketing and advertising and determining the success of our marketing and advertising, assist us with customer services (such as the chat function on our Site), assist us with debugging or fine tuning our Services, and provide analytics about our Site, App, and Services, including Subscription Services.

3.6.            Other governmental agencies, law enforcement, or companies: to assist us with fraud prevention, governmental or other investigations, and as we believe necessary to protect our own rights or the rights, property, or safety of Avianis, its subsidiaries and affiliates, its employees, its customers or the public. To comply with any court order, law or legal process, including to respond to any government, law enforcement or regulatory request. We may do so when: (i) permitted or required by law; (ii) trying to protect against or prevent actual or potential fraud or unauthorized transactions; (iii) investigating fraud which has already taken place; or (iv) otherwise cooperating with a governmental investigation.

3.7.            Aggregate and De-Identified Information: we may disclose aggregate and de-identified information about our customers for marketing, advertising, or research purposes.

We also disclose your information, including your personal information, in the following circumstances. The recipients will vary based on the basis for the disclosure and include: governmental agencies, law enforcement, customers, Avianis affiliates and subsidiaries, advisors, and other entities where such disclosure is required and/or permitted by applicable law:

3.8.            In a business transaction: In the event of a potential or actual business transaction, and to evaluate such a transaction, including a merger, divestiture, restructuring, reorganization, disclosure or some or all of our assets, dissolution, or other sale or transfer of some or all of our assets, we may share your information with a buyer/potential buyer, legal, tax, and other advisors, and other persons in connection with the transaction.

3.9.            Investigations and compliance with legal obligations: To investigate or comply with legal requirements arising from a cybersecurity incident. To enforce or apply our Terms of Service and other agreements or policies, including for billing and collection purposes.

We do not share personal information that we collect from you with third parties for their own direct marketing purposes.

4.           Our Collection and Use of Your Information as a Service Provider When You Use Our Subscription Services

If you are a user of the Avianis software as a service application or the related mobile application (collectively, the Subscription Services), we use the data collected through the Subscription Services for the purposes of providing the requested services to our customers in our capacity as a service provider. Our customer determines the scope of information that you will upload to the Subscription Services. We use, disclose, and process the data that you (or your employer, as the case may be) upload to the Subscription Services in our capacity as a service provider, and, where applicable, as set forth in the contract governing your use of the Subscription Services. Please also note: if you or your employer choose to integrate with authorized third-party service providers through the Subscription Services, we will exchange data with the service provider at your direction. Our customer, which may be your employer, determines what integrations to use and the scope of data exchanged through the Subscription Services.

5.           Cookies and Other Tracking Technologies

We and our service providers use cookies and other mechanisms, including session replay tracking, to track information about your use of our Services, to record sessions for later playback. We do not typically associate this information with the personal information that we collect about you, nor do we attempt to identify you as a natural person through this information. To modify your cookie preferences, please modify your browser settings. Please also see our Cookie Policy.

5.1.            Cookies. We or our service providers may use cookies to track visitor activity on our Sites and through our Subscription Services. A cookie is a text file that a website transfers to your device for record-keeping purposes. We or our service providers may use cookies to track user activities on our Services, such as the web pages you view and time you spend on our Services. The help section on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Services who disable cookies may not be able to browse certain areas of the Services.

5.2.            Clear GIFs, Pixel Tags and Other Technologies. Clear GIFs are tiny graphics with a unique identifier, similar in functionality to cookies, which are embedded invisibly on web pages. We or our service providers may use clear GIFs (also known as web beacons, web bugs, pixel tags, or action tags, among other names), in connection with our Services to perform functions like tracking the activities of visitors to our Services, helping us manage content, and compiling statistics about usage of our Services. We or our service providers may also use clear GIFs in emails to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

5.3.            Embedded Scripts. We may use embedded scripts, which is code designed to collect information about how visitors interact with a website, such as the website that linked them to our Site.

5.4.            Analytics. We use service providers, such as Microsofts Azure Application Insights, a feature of Azure Monitor, to evaluate the use of our Sites. We or our service providers use automated devices and applications to evaluate use of Services, including our Subscription Services. We use these tools to help us improve our services, performance, and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Azures privacy practices, please review the Privacy in Azure materials at https://azure.microsoft.com/en-us/overview/trusted-cloud/privacy/.

6.           Do Not Track

Currently, our systems do not recognize browser do-not-track requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).

7.           Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. If you do not wish to have your e-mail address and other contact information used by Wheels Up to promote our products or services, you may contact usprivacy@wheelsup.com, if you are resident in the United States, or globalprivacy@wheelsup.com, if you are resident in any other country, to opt out of receiving such services and in some locations we will not promote out products or services to you unless you have opted in to receiving such services. If we have sent you a promotional e-mail, you may also click on the opt-out link at the bottom of the email and follow the opt out directions. This opt-out does not apply to information that you provide to us as a result of a product or service purchase, program registration, product service experience or other transactions initiated by you.

8.           Accessing and Correcting Your Information

Where applicable law provides you with the right, you may contact usprivacy@wheelsup.com, if you are resident in the United States, or globalprivacy@wheelsup.com, if you are resident in any other country, you have the option to delete or correct your personal information, or to opt out of certain uses of your personal information, however this may impact your ability to use certain features of the Services or maintain an online account. In addition, account holders may review and edit certain personal information by logging into the Subscription Services and visiting your account profile page.

9.           Data Security

We have implemented commercially reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. Unfortunately, the transmission of information via the internet and mobile devices is not completely secure and we cannot guarantee the security of your personal information transmitted to or through the Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

The safety and security of your information also depends on you. You are responsible for keeping your password(s) confidential. We ask you not to share your password with anyone.

10.      Childrens Personal Information

The Services are not intended for children under 16. We do not knowingly collect or solicit personal information directly from children or knowingly allow such persons to register. If you believe that we might have collected personal information from a child under 16, please contact us at usprivacy@wheelsup.com, if you are resident in the United States, or globalprivacy@wheelsup.com, if you are resident in any other country.

11.      Links

The Services may contain links to websites that we do not control or maintain. We are not responsible for the privacy practices of any such website. If you follow a link from the Services to another website or application, that website or application's privacy policies will govern any information that website or application collects about you.

12.      Additional Information For Non-US Users of our Services, including our Subscription Services

We maintain servers and systems in the United States of America and other countries. Information that we obtain from or about you in connection with your use of the Services, including our Subscription Services, will be collected, processed, stored, disclosed and disposed of in the United States and Switzerland and may be transferred from your country of residence to the United States or Switzerland, which may not be deemed to have the same level of protection as your home country. If you are a user outside of the United States or Switzerland, you acknowledge and agree that we may collect and use your information as discussed in this Privacy Policy, outside your resident jurisdiction.

In certain jurisdictions, you may have the following additional rights, and we have obligations, with respect to your personal information. If you are a resident of a Member State of the European Economic Area ("EEA") or the United Kingdom, please see the Additional Information for EEA and UK Users section below.

12.1.        Access: you may have the right to request a copy of the information that we hold about you, information about the ways in which that information is being used and ‎‎a description of the individuals and organizations to whom that information has been disclosed. We ‎‎will respond to such requests as required by applicable law‎.

12.2.        Rectification: you may have the right to request that we correct data that we hold about you that is inaccurate or incomplete. In most cases, we rely on you to ensure that your information is current, ‎‎complete and accurate.‎ If you demonstrate that personal information about you is inaccurate or incomplete, we will amend the ‎‎information as required by applicable law.

12.3.        Withdrawal of Consent: if you have provided express consent to use your personal information, you have the right to withdraw that consent at any time. However, if you withdraw consent, you may no longer be able to use the Services.

If you wish to exercise any of these rights, please contact globalprivacy@wheelsup.com.

13.      Additional Information for EEA and UK Users

13.1.        Controller, EU Representative, UK Representative

Avianis is usually the data processor when you use our Subscription Services, for other Services Avianis is the data controller. Avianis is headquartered in the United States at 601 W. 26th Street, Suite 900, New York, NY 10001 and can be contacted at legal@wheelsup.com.

13.2.        Legal Basis of Processing

We collect your information as a data controller when we have a legal basis to do so. When you use our Subscription Services, we use the information that you upload in our capacity as a data processor, not a data controller. The following legal bases pertain to our collection of data:

(a)                Our use of your personal information is in our legitimate interest as a commercial organization (for example in order to make improvements to our products and services and to provide you with information you request); you have a right to object to processing as explained in the Legal Rights of EEA/UK Users section below;

This is the legal basis for the following purposes (for details on the purposes please see How We Use Your Information and Disclosure of Your Information): (i) Communicate with You if we have not entered into a contract and if communication is not necessary to enter into a contract with you (legitimate interest in responding to your questions/requests); (ii) Marketing/Advertising (legitimate interest in presenting and offering our Services); (iii) Anonymization/de-identification of your personal information (legitimate interest in anonymizing data and using anonymized data for marketing, product improvement, advertising, research); (iv) Administration (legitimate interests in ensuring the security and proper functionality of our platform, in understanding how our Sites are used, in improving our Sites and Services, and in ensuring that our policies and Terms of Service are complied with); (v) Research and development/Analytical purposes (legitimate interest in improving our Services, products and customer experience and in understanding how and by whom the Sites are used); (vi) Protection of us and others (legitimate interest in establishing, exercising and defending against legal claims and safeguarding our and others rights and safety); (vii) Legal compliance where the legal obligation stems from non-EEA law (if you are in the EEA) or non-UK law (if you are in UK) (legitimate interest in complying with legal obligations), (viii) in the event of a potential or actual business transaction, and to evaluate such transaction (legitimate interest in managing and utilizing our business/assets);

(b)               Our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (for example, to provide you with Services or fulfill your purchase of a product or service)

This is the legal basis for the following purposes (for details on the purposes please see How We Use Your Information and Disclosure of Your Information): (i) To provide our Services to you and for other Transactional Purposes; (ii) Communicate with You; (iii) Administration to the extent it is related to the contractual relationship with you;

(c)                Our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have (for example, where we are required to disclose personal information to a court or tax authority)

This is the legal basis for the following purposes (for details on the purposes please see How We Use Your Information and Disclosure of Your Information): Legal compliance;

(d)               Our use of your personal information is in accordance with your consent (for example, when you consent to sharing your personal information with another party for their own marketing)

This is the legal basis for the following purposes (for details on the purposes please see How We Use Your Information and Disclosure of Your Information): Marketing/Advertising; Research and development/Analytical purposes;

(e)                Our use is necessary to protect your vital interests (for the health safety of our customers)

This is the legal basis for the following purposes (for details on the purposes please see How We Use Your Information and Disclosure of Your Information): Protection of us and others;

If you would like to find out more about the legal bases on which we process personal information, please contact us using the details below

13.3.        Storage Periods Regarding Personal Data

We retain your personal information for as long as necessary to provide our services to you, to fulfil the purposes described in this policy and/or our business purposes, or as required by law or regulation.

Exceptionally, we may store personal data longer, should this be necessary for the establishment, exercise or defense of legal claims. In such case, the processing of affected personal data will be limited to said purpose

13.4.        Cookies and other Tracking Technologies

We will store Cookies and other mechanisms to track information about your use of our Services, which are not strictly necessary to provide you with Services you have requested, on your device and access such cookies and other mechanisms stored on your device only on the basis of your voluntary consent. You can modify or withdraw your consent at any time with effect for the future by following the instructions in our Cookie Policy

13.5.        Legal Rights of EEA/UK Users

Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, when we act as a data controller, EEA and UK individuals have certain right regarding their personal information:

(a)                Right to access, correct, and delete your personal information.

You have the right to request access to the personal information that we hold about you, in particular access to information on (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controllers identity; (d) the categories of personal data concerned, (e) the envisaged period for which the personal data will be stored or the criteria to determine that period and (d) the entities or categories of entities to whom your personal information may be transferred.

(b)               You also have the right to request that we delete your information.

We are not required to comply with your request to erase personal information, in particular, if the processing of your personal information is necessary for compliance with a legal obligation or for the establishment, exercise, or defense of legal claims.

(c)                Right to restrict the processing of your personal information.

You have the right to restrict the use of your personal information when (i) you contest the accuracy of the data until we were able to verify the accuracy; (ii) their use is unlawful but you do not want us to erase the data; (iii) we no longer need the personal information for the relevant purposes, but you require it for the establishment, exercise, or defense of legal claims; or (iv) you have objected to Our personal information use where such use is justified on our legitimate interests and we must verify as to whether we have a compelling interest to continue to use your data. We can continue to use your personal information following a request for restriction, where:

                                                                              (i)            We have your consent; or

                                                                            (ii)            to establish, exercise or defend legal claims; or

                                                                          (iii)            to protect the rights of another natural or legal person.

(d)               Right to data portability.

To the extent that we process your information that you have provided directly to us: (i) based on your consent or under a contract; and (ii) through automated means, you have the right to receive such personal information in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller (where this is technically feasible).

(e)                Right to object.

You have the right to object to the processing of your personal information: You can object to any processing of your personal information which has our legitimate interests as its legal basis at any time based on grounds relating to your particular situation. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms. We may continue processing your personal information if we demonstrate such compelling legitimate interests or if this is necessary for the establishment, exercise or defense of legal claims.

Where we process personal information for direct marketing purposes, you shall have the right to object at any time to the processing of your personal information for such purpose. Where you object to the processing for direct marketing purposes, we shall no longer process the information for such purpose.

(f)                 Right to withdraw consent.

Where processing of your personal information is based on your consent, you have the right to withdraw such consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

(g)                Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction.

You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the EEA.

(h)               Right to lodge a complaint with your local supervisory authority.

You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

13.6.        Legal Basis of Processing

How to Exercise Your Rights: If you would like to exercise any of the rights described above, please send us a request at legal@wheelsup.com. In your message, please indicate the right you would like to exercise and the information that you would like to access, review, correct, or delete. We may ask you for additional information to confirm your identity and for security purposes before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. We may not always be able to fully address your request, for example if it would affect the duty of confidentiality we owe to others or if we are legally entitled to deal with the request in a different way.

14.      Additional Information for California Residents

In this section, we provide additional information to California residents about how we handle their personal information, as required under California privacy laws including the California Consumer Privacy Act (CCPA). This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information that is exempt under the CCPA.

14.1.        Categories of Personal Information Under the CCPA (last updated 7 March 2022)

While our collection, use and disclosure of personal information varies based upon our relationship and interactions with you, in this section we describe, generally, how we have collected and disclosed personal information about consumers in the prior 12 months (from the Last Updated date above).

14.2.        Categories of Personal Information Collected and Disclosed.

The table below identifies the categories of personal information (as defined by the CCPA) we have collected about consumers, as well as how we have disclosed such information for a business purpose. For more information about the business and commercial purposes for which we collect, use and disclose personal information, please see the How We Use Your Information and the Disclosures of Your Information sections above. The section below does not include information that you provide to us in our capacity as a processor or a service provider when we operate our Subscription Services.

Personal Information Collected

Do We Disclose this Information?

Categories of Other Entities to Whom We May Disclose this Information

Categories

Description

 

 

Identifiers

Includes direct identifiers, such as name, alias user ID, username, account number or unique personal identifier; email address, phone number, address and other contact information; IP address and other online identifiers; and other similar identifiers.

YES

   service providers

   advisors and agents

   government entities and law enforcement

   affiliates and subsidiaries

   advertising networks

   data analytics providers

   internet service providers

   operating systems and platforms

   business customer/client

Customer Records

Includes personal information, such as name, account name, user ID, contact information, education and employment information, account number. For example, this may include information collected when a customer seeks information about our products and services.

YES

   service providers

   advisors and agents

   government entities and law enforcement

   affiliates and subsidiaries

   advertising networks

   data analytics providers

   internet service providers

   operating systems and platforms

   business customer/client

Commercial Information

Includes records of products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.

YES

   service providers

   advisors and agents

   government entities and law enforcement

   affiliates and subsidiaries

   data analytics providers

   internet service providers

   operating systems and platforms

   business customer/client

Usage Data

Includes browsing history, clickstream data, search history, access logs and other usage data and information regarding an individuals interaction with our websites and mobile apps.

YES

   service providers

   advisors and agents

   government entities and law enforcement

   affiliates and subsidiaries

   data analytics providers

   internet service providers

   operating systems and platforms

   business customer/client

Professional Information

Includes professional and employment-related information (such as current and former employer(s) and position(s), business contact information and professional memberships).

YES

   service providers

   advisors and agents

   government entities and law enforcement

   our affiliates and subsidiaries

   data analytics providers

   internet service providers

   operating systems and platforms

   business customer/client

Inferences

Includes inferences drawn from other personal information that we collect to create a profile reflecting an individuals preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities or aptitudes. For example, we may analyze personal information in order to identify the offers and information that may be most relevant to customers, so that we can better reach them with relevant offers and ads.

YES

   service providers

   advisors and agents

   government entities and law enforcement

   our affiliates and subsidiaries

   advertising networks

   data analytics providers

   social networks

   internet service providers

   operating systems and platforms

   data brokers

   business customer/client

 

 

14.3.                    Sources of Personal Information.

As described above in the Information We Collect About You and How We Collect It, we collect personal information from the following sources:

        directly from the individual

        data analytics providers

        internet service providers

        operating systems and platforms

        business customers

14.4.                    Rights of California Residents.

Our services are provided to business customers. As a result, we typically collect limited personal information, including business contact information and information obtained through our website. With the exception of the right to non-discrimination, the following rights do not apply to the personal information that we collect and use within the context of providing services to you or your employer.

(a)                Do-not-sell (opt-out): to opt-out of our sale of their personal information. We do not sell personal information about California consumers, including those we have actual knowledge are younger than 16.

(b)               Right of deletion: to request deletion of their personal information that we have collected about them and to have such personal information deleted (without charge), subject to certain exceptions.

(c)                Right to know: with respect to the personal information we have collected about them in the prior 12 months, to require that we disclose the following to them (up to twice per year and subject to certain exemptions):

                                                                              (i)            categories of personal information collected;

                                                                            (ii)            categories of sources of personal information;

                                                                          (iii)            categories of personal information about them we have disclosed for a business purpose or sold;

                                                                          (iv)            categories of third parties to whom we have sold or disclosed for a business purpose their personal information;

                                                                            (v)            the business or commercial purposes for collecting or selling their personal information; and

                                                                          (vi)            a copy of the specific pieces of personal information we have collected about them.

(d)               Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.

14.5.                    Submitting CCPA Requests.

California residents may submit CCPA requests:

(a)                Email: usprivacy@wheelsup.com

(b)                Avianis Privacy Information Request Form

When you submit a request to know or a request to delete, we will verify your identity by matching the information provided by you with the information we have in our records with the information submitted in your form/email.

In some cases, we may request additional information to verify your identity or where necessary to process your request. If we are unable to adequately verify your identity (or your agents authority to submit the request in your behalf), we will notify you, or your agent, as applicable.

Authorized agents may initiate a request on behalf of another individual by submitting an email along with proof of their authority or through the webform. If submitting through webform, the agent must follow the instructions necessary to demonstrate authority. Authorized agents must provide proof of their authorization; we also may require that the consumer directly verify its identity and the authority of the authorized agent/

14.6.                    Financial Incentives.

We do not offer financial incentives as defined under the CCPA.

15.            Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, please contact us at legal@wheelsup.com.

Service Provider:

Avianis Systems, LLC
601 W. 26th Street, Suite 900
New York, NY 10001

Designated Agent:

Legal Department
Avianis Systems, LLC
601 W. 26th Street, Suite 900
New York, NY 10001
Phone: 855-359-8760
Email: 
legal@wheelsup.com