Privacy Users Privacy Notice

We are committed to protecting the personal information of everyone we interact with. On this page, you can find our privacy policy for protecting and holding your personal data. We are an international company with offices around the globe and the privacy requirements among countries. This notice encompasses our general practices and if you have any specific questions not answered here, please contact us at privacyofficer@gogoair.com.

Last Updated: 28 June 2019

What personal data do you keep about vendors, contractors, or other external users?

When you participant in training with Gogo, we will ask you for additional contact and personal information to administer the essential HR and security functions necessary for your interaction with us. If you use our learning management system for training, then we collect your user activity and credentials to track your progress. This tracking is necessary to comply with our contractual and regulatory requirements when working with external users. Any personal data we collect is held to the same standard as our employee data. As each external user interaction is slightly different, we can provide you with further information on the processing of any personal information we collect upon request. Please email privacyofficer@gogoair.com. 

We use your personal data as described for business-related purposes. We also use your data to provide you with training and to assess your performance.

Any information we collect about you during your interaction follows the relevant law and we hold onto this information only if required by our compliance obligations. We use certain third-party providers to help us with our administrative functions.

We hold your personal data after you complete required training at Gogo for a period in accordance with our security certification and local legal requirements.

Our Legal Basis for Processing Your Data

We will only process your personal data where we have a legal basis for doing so. In each case, the legal basis will be one or more of the following:

  • To administer the business relationship and perform the contract that we may have with you or your employer (if applicable)
  • To comply with our legal obligations;
  • To fulfill our legitimate interests as a business; or
  • To process in conformance with your consent.

What are your rights?

You have the right to send us a request to access, correct, delete, or limit the use and disclosure of your personal data in our possession and we will respond in accordance with the applicable requirements. If we cannot complete your request due to legal restrictions or because we cannot locate your data, we will let you know. These services are provided free of charge.

If after you have contacted us, you still have any unresolved issues and you live in the European Union or Switzerland, then you may contact your local Data Protection Authority for more information. The local Data Protection Authorities are a public service provided at no cost to you. For more information, please visit http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

Is your data transferred internationally?

We are headquartered in the United States. Personal data may be accessed by us or transferred to the United States or to our affiliates elsewhere in the world. By providing us with personal data, you consent to this transfer. We will protect the privacy and security of your personal data according to this privacy statement, regardless of where it is processed or stored. However, by providing us personal data, you acknowledge that personal data stored or processed in the United States will be subject to the laws of the United States, including the ability of governments, courts or law enforcement or regulatory agencies of the United States to obtain disclosure of your personal data, and you consent to such activities.

We engage with various trusted service providers to better support our business. You can ask for a list of these providers by emailing privacyofficer@gogoair.com.

For the purposes of Regulation (EU) 2016/679 and applicable national implementing laws in your jurisdiction, we are a data controller with respect to your data.  Any personal data we collect is transferred in accordance with our agreements based on the Standard Contractual Clauses set out by the European Union.

If you have any inquiries about how we handle or transfer your personal data, please email privacyofficer@gogoair.com.

Security

We provide reasonable and appropriate physical, electronic, and procedural safeguards intended to maintain the confidentiality of the personal data we collect. While we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

Changes

Any changes to this notice will be posted here, along with the date of the last update.

Who can you contact to learn more?

If you have any questions regarding our privacy policy or our use of personal data, please email privacyofficer@gogoair.com. Gogo LLC
ATTN: Privacy Manager
Suite 1500
111 N Canal St.
Chicago IL 60606
USA