CCPA - iFLY Holdings, Inc CCPA - iFLY Holdings, Inc

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Effective Date: January 1, 2023

 

iFLY respects your privacy and is committed to complying with the relevant privacy laws and regulations in the jurisdictions in which we operate. iFLY’s California Consumer Rights Page provides additional information about our commitment to respecting your personal information, including ways for you to access and delete that information.

 

This California Privacy Notice (“Notice”) is provided by SkyGroup Investments, LLC and our affiliates and subsidiaries (“iFLY,” “Company,” “us,” “we,” or “our”) pursuant to the California Consumer Privacy Act (as amended, the “CCPA”), a state law intended to enhance privacy rights and Consumer protection for residents of California. This Notice applies to your use of our websites (including www.iflyworld.com) and to other information we collect online and offline (together, our “Services”), regardless of how you access or use the Services, and supplements iFLY’s Privacy Policy. In the event of a conflict between any other iFLY policy, statement, or notice and this Notice, this Notice will prevail as to California “Consumers” (California residents) and their rights under the CCPA. Capitalized terms defined in the CCPA that are used in this Notice shall have the same meaning as in the CCPA. Unless otherwise noted, the disclosures contained within this Notice cover our activities in the prior 12 months from the Effective Date as well as our current practices.

 

This Notice applies to Consumers that use our Services. If you are a current employee of iFLY, you may view your California notice by logging into UKG. If you are an applicant of iFLY please visit your California applicant notice.

 

HOW AND WHY WE COLLECT YOUR PERSONAL INFORMATION

 

Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. Personal Information does not include information that is publicly available, Deidentified, or Aggregated.

 

We Collect the categories of Personal Information about California Consumers that are indicated in the chart below. Note that the specific pieces of Personal Information we Collect about you may vary depending on the nature of your interactions with us and may not include all of the examples listed.

 

Category of Personal Information or Sensitive Personal Information 

Business Purposes for Collection, Use, and Disclosure

1. Identifiers: such as name, postal address, phone number, IP address, unique personal identifier(s), username and password for our Service, and email address.

We collect, use, and disclose this Personal Information in order to:

  • enhance your experience with our Services by remembering your log-in status and viewing preferences from a previous use of our Services;
  • respond to your requests;
  • manage web traffic;
  • engage in marketing, send relevant discounts and administer surveys, rewards, and promotions;
  • prevent, detect, and investigate fraud, security breaches, and potentially prohibited or illegal activities;
  • securely process transactions;
  • receive feedback;
  • enforce our Terms and Conditions; and
  • comply with applicable laws and regulations.

2. Personal Records: such as name, postal address, phone number, email address, and financial information

We collect, use, and disclose this Personal Information in order to:

  • enhance your experience with our Services by remembering your log-in status and viewing preferences from a previous use of our Services;
  • respond to your requests;
  • manage web traffic;
  • engage in marketing, send relevant discounts and administer surveys, rewards, and promotions;
  • prevent, detect, and investigate fraud, security breaches, and potentially prohibited or illegal activities;
  • securely process transactions;
  • receive feedback;
  • enforce our Terms and Conditions; and
  • comply with applicable laws and regulations.

3. Customer characteristics of protected classifications under California or federal law: such as birth date, veteran status, and gender.

We collect, use, and disclose this Personal Information in order to:

  • personalize your experience by providing content through our Services, including targeted advertising that we believe may be of most interest to you;
  • deliver content relevant to your interests on our Services and on other websites and mobile apps; and
  • verify your identity.

4. Customer Account Details / Commercial Information: such as purchase history or tendencies and information from surveys, flight details, interests, purchase channel (online or retail), promotions, and the contents of your communications with us via phone or email.

We collect, use, and disclose this Personal Information in order to:

  • personalize your experience by providing content through our Services, including advertising that we believe may be of most interest to you;
  • deliver content relevant to your interests on our Services and other websites and mobile apps;
  • improve our products and Services;
  • administer surveys, rewards, and promotions;
  • provide a safe, secure, efficient, and customized experience; and 
  • enhance Consumer experiences.

5. Internet or Other Electronic Network Activity Information: such as browser type, operating system, internet or mobile network provider, website access time, duration of visit, referring website address, browsing and search history on our websites, information regarding your interactions with our website, advertisements, social media pages, and emails

We collect, use, and disclose this Personal Information in order to:

  • enhance your experience with our Services by remembering your log-in status and viewing preferences from a previous use of our Services;
  • personalize your experience by providing content through our Services, including targeted advertising that we believe may be of most interest to you;
  • deliver content relevant to your interests on our Services and third-party websites and mobile apps;
  • improve our products and Services;
  • administer surveys, rewards, and promotions;
  • determine your location; 
  • manage web traffic;
  • detect and prevent potentially illegal acts, violations of our policies, fraud, and/or data security breaches; and
  • guide decisions about iFLY’s products, websites, applications, Services, tools, and communications.

6. Geolocation Data: such as your physical location based on information you provide directly or inferred from your IP address

We collect, use, and disclose this Personal Information in order to:

  • determine which iFLY location is closest to you to ensure you can find the most convenient location; 
  • provide you relevant offers or promotions; and 
  • improve your experience with our Services.

7. Sensory Data: such as audio recordings of customer service calls and CCTV footage

We collect, use, and disclose this Personal Information in order to:

  • research and resolve issues and improve your experience with our Services.

9. Inferences from Personal Information Collected: such as Consumer profiles reflecting preferences and predispositions 

We collect, use, and disclose this Personal Information in order to:

  • personalize your experience by providing content through our Services, including targeted advertising that we believe may be of most interest to you;
  • understand your preferences;
  • deliver content relevant to your interests on our Services and third-party websites;
  • improve our products and Services; and
  • administer surveys, rewards, and promotions. 

 

We may also collect Personal Information about you that does not directly fit within one of the categories defined by the CCPA. For example, we may collect the contents of communications you send to us when you interact with us on social media or other websites.

 

We may also collect, use, and disclose your Personal Information as required or permitted by applicable law and reserve the right to convert, or permit others to convert, your Personal Information into Deidentified data or Aggregated Consumer Information.

 

All of the categories of Personal Information described in the above chart may also be disclosed to:

 

  • provide our Services; 
  • help detect and prevent potentially illegal acts, violations of our policies, fraud, and/or data security breaches;
  • process payments;
  • personalize or enhance your experience with our Services, including to deploy targeted advertising that we believe may be of most interest to you;
    • assess promotional effectiveness and deliver content relevant to your interests;  
    • troubleshoot and improve our Services;
    • provide customer service;
    • give you information about your account;
    • manage your purchases;
  • deliver marketing communications;
  • generate analytics and understand our customers; 
  • inform marketing practices;
  • customer support; and
  • improve our products and Services.

 

Categories of Recipients with whom Personal Information is Disclosed

 

We disclose Personal Information to: 

 

  • affiliates;
  • business partners;
  • franchisees; 
  • Service Providers that process Personal Information on our behalf; and
  • other vendors including those that facilitate interest-based advertising and other advertising and marketing services. 

 

We may also disclose your Personal Information to other parties at your request. 

 

Sensitive Personal Information

 

We Collect the following categories of Sensitive Personal Information about California Consumers: 

 

  • Health data directly from you in order to ensure you can safely participate in, our Services.

 

SOURCES OF PERSONAL INFORMATION

 

We may collect Personal Information directly from you in the following circumstances: 

 

  • when you provide us information online, through electronic forms, over the phone, or through paper documents; 
  • automatically through our websites via cookies and other tracking technologies; 
  • from our Service Providers, vendors and suppliers, our affiliates, or other individuals and businesses; 
  • from third-party sources, such as data providers; and 
  • from public sources of data, such as government databases. 

 

More detail on the ways in which we collect Personal Information can be found in our Privacy Policy.

 

RETENTION OF PERSONAL INFORMATION 

 

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information (which includes the categories of Personal Information set forth in the charts and sections above) for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, obligations, or as necessary to resolve disputes. To determine the appropriate retention period for Personal Information, we consider applicable legal requirements, the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information, and whether we can achieve those purposes through other means. For certain types of Personal Information, we will only maintain it for a limited duration. 

 

SELLING AND SHARING OF PERSONAL INFORMATION 

 

We may Sell or Share the below categories of Personal Information with third parties for cross-context behavioral advertising. We offer you the ability to opt-out of these disclosures as set forth in the “Opt Out” section below.

 

  • Identifiers – for advertising purposes with advertisers and analytics providers.
  • Internet or other electronic network activity information – for advertising purposes and analytics providers.
  • Geolocation data – for advertising purposes and analytics providers.

 

SUBMITTING REQUESTS RELATING TO YOUR PERSONAL INFORMATION

 

The CCPA gives California Consumers certain rights:

 

Right to know about Personal Information Collected, disclosed, Shared, or Sold. You have the right to know about your Personal Information that we are currently maintaining and have Collected and disclosed in the 12-month period prior to the date you submit your request. You also have the right to obtain a transportable copy of such Personal Information.

 

Requests of this nature may be made no more than twice in a 12-month period. Please note that we retain Personal Information for various time periods in accordance with applicable law and our internal recordkeeping policies and procedures.

 

Right to Know. California Consumers have the right to request more information regarding the following: 

 

  1. The categories of Personal Information we have collected about you;
  2. The categories of sources from which the Personal Information was collected;
  3. Our business or commercial purposes for collecting, selling, or sharing your Personal Information;
  4. The categories of third parties to which we disclosed your Personal Information;
  5. The categories of Personal Information we sold or shared about you and the categories of third parties to which each category of Personal Information was sold or shared;
  6. The categories of Personal Information we disclosed about you for a business purpose and the categories of persons to which it was disclosed; and
  7. The specific pieces of Personal Information we have collected about you. 

 

Right to Request Deletion of Your Personal Information. California Consumers also have the right to request that we delete Personal Information collected or maintained by us. Following receipt of a verifiable request to delete, we will let you know what Personal Information we can delete from our records. We will also notify our Service Providers about your request to delete. If we cannot delete all of your Personal Information, we will let you know why. 

 

Right to Opt-out of the “Sale” or “Sharing” of Your Personal Information. California Consumers have the right to opt-out of the “Sale” or “Sharing” of their Personal Information in the context of cookies or other tracking technologies. You can learn how to exercise choices regarding these technologies by following the instructions in the Opt-Out Rights section below. To opt out of types of cookie-based Sales or Sharing, please click the “Do Not Sell or Share My Personal Information” link in the footer of our website.

 

You may also opt out of the Sale or Sharing of your Personal Information via cookies or tracking technologies through an opt-out preference signal. In order to process your request through an opt-out preference signal, you must use a browser supporting the preference signal. If you choose to use an opt-out preference signal, you will need to turn it on for each browser and each device you use.

 

Right to Correct Inaccurate Information. If you believe that any of the Personal Information we maintain about you is inaccurate, you may submit a request for us to correct that information. Upon receipt of a verifiable request to correct inaccurate Personal Information, we will use commercially reasonable efforts to correct the information as you direct. 

 

Right to Limit Use and Disclosure of Your Sensitive Personal Information. We do not use Sensitive Personal Information for the purpose of inferring characteristics about you, or for any other reasons besides the permitted Business Purposes. For this reason, we do not treat the Sensitive Personal Information we Collect as subject to a limit use of Sensitive Personal Information request and, therefore, we do not offer a way for you to submit such a request.

 

Rights Related to Automated Decision-making and Profiling. You have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects. We do not profile in a manner that would result in legal or similarly significant effects and as such do not offer this right.

 

Right to Non-Discrimination for the Exercise of Your Privacy Rights. We will not discriminate against you if you choose to exercise any of the privacy rights described above.

 

Exercise Those Rights. You may submit CCPA requests to iFLY by filling out the webformhereor by calling us toll-free at1-888-675-0188. 

 

Please note: before we can fulfill your request, we must be able to verify your identity. We will ask you to provide your email and will use a verification link pushed out through email or will otherwise attempt to verify that we have a record of you in our systems. If we cannot verify your identity, we may not be able to fulfill your request. 

 

You may authorize an agent to make CCPA-related requests on your behalf. To fulfill requests made by authorized agents, you must provide iFLY with enough information such that we can verify the authority of the agent.

 

SHINE THE LIGHT

 

California’s “Shine the Light” law permits California customers to request certain details about how their personal information is shared with third parties, and in some cases affiliates, if personal information is shared for those third parties’ or affiliates’ own direct marketing purposes. We do not share personal information with third parties or affiliates for those third parties’ or affiliates’ own direct marketing purposes. Californians may request information about our compliance with this law by contacting us at  ccpa@iflyworld.com or by sending a letter to:

 

13265 N US Highway 183, Suite A

 

Austin, TX 78750

 

Attention: Legal Counsel.  

 

Any such request must include “California Shine the Light Request” in the first line of the description and include your name, street address, city, state, and ZIP code.  Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address or mail address.

 

Additionally, “Shine the Light” rights and CCPA rights are established under different laws and must be exercised separately.

 

CHANGES TO THIS NOTICE

 

From time to time, we may update this Notice and indicate changes by updating the “Effective Date” date at the top of the Notice.

 

Your use of iFLY’s Services after any update to this Notice will constitute your acceptance of the changes. To the extent any provision of this Notice is found by a court of competent jurisdiction to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

 

CONTACT US

 

For more information regarding your California privacy rights, you may contact us at 1-888-675-0188 or email us at ccpa@iflyworld.com.  You may also write to us at: 13265 N US Highway 183, Suite A, Austin, TX 78750 (Attention: Legal Counsel).

 

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