GOGO BUSINESS AVIATION BROADBAND™ NETWORK SERVICES
This policy is for users of our services. If you are a prospective, current, or former employee, please see the privacy notice on our careers page.
Information Collected through our Services
We collect Personal Data about you from a variety of sources, including from you directly (e.g. when you contact us or sign up for an account), information we generate about you in the course of our relationship with you (e.g. data collected from cookies and other similar technologies. We may be required by law to collect certain personal data about you or because of any contractual relationship we have with you. Failure to provide this information may prevent or delay the fulfillment of these obligations.
Aircraft owners and operators will, when signing up for Services, and users may, by using the Services, be required to provide name, mailing or billing address, telephone number, or email address, email preferences, password for your Account and password hint question, and a complete set of credit card data that enables us to receive your payment (including your credit card authorization number).
Information Collected by Automated Means
Whenever using the Services, we may use a variety of technologies that automatically or passively collect information about the Services, users’ interactions with the Services and the aircraft on which the Services are provided (“Usage Information”). Usage Information may include, among other things: (i) computer or device-related information such as browser type, operating system, and device identifiers (IP address, MAC Address or other unique identifier for the computer, mobile device, Wi-Fi card, technology or other device you use to access the Services)l; (ii) Site-related information such as the pages users visit, how long they stay on each page and preceding page views (iii) content-related information such as the type of content being transmitted (e.g., video content); and (iv) flight-related information such as origin and destination information, aircraft location, including altitude, longitude and latitude information, and speed (“Flight Information”). We may also collect technical information about use of the Services, including, among other things, orders, aircraft equipment installs, inventory, historical data usage in flight, and invoicing information. Usage Information collected from the Sites helps up to keep the Sites fresh and interesting to our visitors and to tailor content to a visitor’s interests. Usage Information does not generally identify specific individuals, but if Gogo Business Aviation associates it with a specific and identifiable person, Gogo Business Aviation treats it as Personal Information. We may collect Usage Information that is generated or captured during interactions with the Services or Gogo Business Aviation that may be viewed by customers, dealers, or OEMS, including, but not limited to, information about Gogo Business Aviation equipment installed on aircrafts, order information and online ordering tools, flight characterization, information currently contained in CCDS, online RMA, quality management tools and technical references.
Call Detail Records and Customer Proprietary Network Information
As a telecommunications provider, while providing our voice services, we may collect call detail records (“CDR”), which may include information about numbers called, when they are called, and the length of those calls. We may also collect Customer Proprietary Network Information (“CPNI”), which includes the time, date, duration and destination number of each call, as well as the services used on an aircraft owner or operator’s aircraft.
Type of Cookies, Purpose of Use and Duration
Session Cookies: Session Cookies ensure that users are recognized when moving from page to page within the Sites and that any information they have entered is remembered. Users can choose not to accept session Cookies by changing the settings in their browser. Session Cookies expire once a user closes his or her web browser.
Persistent Cookies: Persistent Cookies help the Sites remember user’ information and settings when they visit them in the future. This results in faster and more convenient access.
Features of the Service made possible by persistent Cookies include authentication, language selection, theme selection, menu preferences, internal site bookmarks or favorites, among others. Cookies may enhance the online experience by saving preferences while users are visiting a Site.
Persistent Cookies also allow us to select which of our advertisements or offers are most likely to appeal to a user and display them while that user is using the Services.
We currently use an external party ad network to serve Cookies. Eternal, unless deleted by the user.
If a user would prefer not to accept cookies, most browsers will allow him or her to: (i) change browser settings to notify the user when he or she receives a cookie, which lets them choose whether or not to accept it; (ii) to disable existing cookies; or (iii) to set the browser to automatically reject any cookies.
Start with these sites to learn more about browser privacy controls:
Additionally, Firefox and Chrome have extensive repositories of add-ons that can help enhance control over privacy.
Users can also learn more about Cookies by visiting www.allaboutcookies.org, which includes additional useful information on Cookies and how to block Cookies using different types of browsers. For more information on advertising using Cookies and how to opt-out of advertising Cookies specifically, please see Advertising; How To Opt-out below.
Please be aware that if cookies are disabled or rejected, some features and Services may not work properly because we may not be able to recognize and associate them with a user’s Gogo Business Aviation Account.
We may also include web beacons (also known as Internet tags, pixel tags, tracking beacons and clear GIFs) with the content and ads that we deliver to users, which we will use to collect information regarding users’ interaction with such content and ads. A web beacon is a transparent graphic image placed on a web page or in an email, which indicates that a page or email has been viewed or that an email has been forwarded. In addition, a web beacon allows external parties to obtain information such as the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, the type of browser used to view the page, and the information in cookies set by external parties. A web beacon may also tell the browser to get content from another server.
Network Information for App
When a user uses the App, we may automatically collect other network information, including but not limited to network or service availability, networks viewed or searched for, other devices connected to a network, app response times, download errors, length of visits to certain pages, app interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the App.
How We Use the Information Collected
We use information we collect about and from aircraft owners and operators and users for a variety of business purposes, including, for example, to: provide the Services, respond to requests that users make, improve the Services and offer additional services, and to better tailor content, advertisements, offers and the features, performance, and support of the Services; and for purposes disclosed at the time a user or aircraft owner or operator provides Personal Information or otherwise with the user’s consent or the aircraft owner or operator’s consent. We may use transcripts of user e-mail conversations with our customer service agents for support, training, and improvements to our Services. If a user provides feedback to us, we may use and disclose such feedback for any purpose, provided we do not associate such feedback with the user’s Personal Information.
If you submit a request to us concerning your Personal Information, we will use the information we have to help verify your identity before we can complete your request. Similarly, we use such data to fulfill any orders or requests that you make to us in the course of our business with you. In providing our products, we will always use your Personal Information to ensure system security and anti-fraud systems are working and to prevent and contain any such issues.
We may use your Personal Information for marketing and to send you advertising materials, electronic newsletters, or promotional emails about our products and services. Users and aircraft owners or operators can opt-out of receiving further promotional messages from us by following the unsubscribe instructions provided in the promotional email they receive, by selecting to opt-out in our preference center or by contacting us directly at firstname.lastname@example.org. We may use Personal Information to send Service-related communications, for which aircraft owners or operators, and users may opt-out if they terminate their Account.
To the extent that certain information that we collect in providing the Services constitutes CPNI, Gogo Business Aviation complies with applicable law governing CPNI.
Information We Share
We may share your Personal Data with external parties under the following circumstances:
External Parties Providing Services On Our Behalf. In order to provide the Services, carry out requests, to make various features, services and materials available through the Services, and to respond to inquiries, we may share Personal Information or Usage Information, including Device Identifiers and Flight Information, with external parties that perform functions on our behalf (or on behalf of our partners), such as: (a) companies or individuals that: host or operate our Sites or App; analyze data; provide customer service; manage payments; (b) advertisers; and (c) sponsors or other external parties that participate in or administer our promotions or provide marketing or promotional assistance.
Law Enforcement Compliance. We may be required by law, or by law enforcement officers acting under the color of law, to record some or all communications on or through the Services. We may, and you and users hereby authorize us to, disclose Personal Information and other information including user communications through the Services, if required by applicable law or by law enforcement officers acting under the color of applicable law, or if we believe in good faith that such disclosure is necessary to: (a) comply with relevant laws or to respond to subpoenas or warrants served on us; or (b) to protect or defend the rights, property, or safety of Gogo Business Aviation, you, users, or external parties (especially in emergency situations).
Information We Receive from External Parties
Using multiple data sources, we derive your airline, tail number, origin, destination and flight number of the flight when you access the Services. If you choose to opt in, non-Gogo websites will forward your contact data and external party applications/sites (such as Facebook and Twitter) will share your personal data with us. We may also obtain data about you from persons you are connected to on social media sites. For example, if a user is on another website and opts-in to receive information from Gogo Business Aviation, that website will forward to us the user’s email address and other information so that we may contact the user as requested. Users may also choose to participate in an external party application or feature (such as one of our Facebook or Twitter applications or a similar application or feature on an external party web site) through which users allow us to collect and share (or the external party to collect and share) information, including Personal Information. In addition, we may receive information about a user if other users of an external party web site give us access to their profiles and the user is one of their “connections” or information the user is otherwise accessible through his or her connections” web page, profile page, or similar page on a social networking or other external party web site or interactive service.
We may match the information we receive about users from external parties with the information we collect ourselves to enhance the experience with the Services and to select which of our advertisements or offers are most likely to appeal to a user and display them while that user is utilizing the Services.
Purposes for the Processing of Personal Data; Legal Basis
We process your Personal Data on the following legal bases, and for the following purposes:
We do not use your Personal Data for any automated decision making covered by Articles 22(1) and (4) of Regulation (EU) 2016/679.
Gogo may retain your Personal Data both during and after the time you are our customer, but we won’t keep it longer than needed. The amount of time we keep it depends on the type of Personal Data and the purpose for processing. For example, we may need it for regulatory compliance, to maintain our internal financial or transactional records, to communicate with you about our relationship, or in cooperation with law enforcement agency requests.
Access and Choices
Under current privacy laws, you have the right to:
We will not discriminate against you because you exercised any of these rights.
For questions about the collection of Personal Data by Gogo, or to exercise the right to access, correct, update, or delete such data or object, for legitimate purposes, to the processing of Personal Data for which Gogo is the data controller, as provided under applicable law, please click here. You may also exercise these rights by emailing us at email@example.com, calling our customer care line +1 303.301.3278, or emailing our customer care team at firstname.lastname@example.org.
We may take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the personal information and whether you have an account with us.
You may designate an authorized agent to make a request under the CCPA on your behalf. When submitting the request, please ensure the authorized agent identifies himself/herself/itself as an authorized agent.
There may be cases where restrictions on the amount of data that can be disclosed to data subjects under applicable law (for example, if that would necessarily involve disclosing data about another person). Gogo is permitted to withhold some types of Personal Data in certain circumstances, subject to applicable local law requirements. If there is a dispute, please contact the Gogo privacy officer at email@example.com. In addition, data subjects have the right to lodge a complaint with a supervisory authority. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based external party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Right to Withdraw Consent
To the extent you have provided consent for certain personal data processing activities, you may withdraw such consent at any time using the options available within this notice.
Online Advertising; How to Opt-out
Gogo Business Aviation licenses technology to serve advertisements on its own Sites and within its content as that content is served across the Internet. In addition, Gogo Business Aviation may use external party analytics vendors to evaluate and provide us with information about the use of the Services and viewing of our content. We do not share Personal Information with these external parties, but ad network providers, the advertisers, the sponsors, and/or analytics service providers may set and access their own Cookies, pixel tags and similar technologies on Devices and they may otherwise collect or have access to information about users, including Usage Information, which they may collect over time and across different websites following a users’ visit to our services. We and our network advertisers may target advertisements for products and services in which users might be interested based on their use of the Services, visits to the Sites and other websites. We may use a variety of companies to serve advertisements.
If a user prefers to not receive targeted advertising, he or she can opt-out of some network advertising programs that use their information. To do so, please visit the Digital Advertising Alliance (DAA) Opt-Out Page: http://www.aboutads.info/choices. Please note that even if a user chooses to remove information (opt-out), the user will still see advertisements while browsing online. Additionally, many network advertising programs allow users to view and manage the interest categories they have compiled from online browsing activities. These interest categories help determine the types of targeted advertisements that will be delivered. The DAA Opt-Out Page provides a tool that identifies its member companies that have Cookies on a browser and provides links to those companies.
Links to Other Sites
Our provision of links to other websites or locations is for convenience and does not signify our endorsement of such other websites or location or its contents. We have no control over, do not review and cannot be responsible for these outside websites, their content, or their data collection.
How We Protect Personal Information
The connection through which users access many of the Services is an SSL-encrypted link. However, if a user has VPN, Gogo Business Aviation recommends using that channel for greater security. SSL-encrypted websites or pages, typically indicated by “https” in the address field and a “lock” icon, can also generally be accessed through the Gogo Business Aviation Services. Users should be aware, however, that data packets from un-encrypted Wi-Fi connections can be captured by technically advanced means when they are transmitted between a user’s Device and the Wi-Fi access point. Users should therefore take precautions to lower their security risks. Gogo Business Aviation recommends that users follow good security practices, such as ensuring that file-sharing is not enabled while accessing the Internet from an un-encrypted public network and that laptops have firewall and other protection against malware. Gogo Business Aviation recommends that sensitive or private information should not be accessed via or transmitted over an unencrypted connection. While Gogo Business Aviation takes steps to provide reasonable security for Personal Information, and employs physical, technical, and administrative safeguards to protect such information, we cannot ensure or warrant the security of any information transmitted to us, users utilize the Services and provide us with information at their own risk.
Transfer of Personal Data
Personal Data collected by Gogo may be stored or processed in the United States or in any other country where Gogo or its affiliates, subsidiaries, or external party service providers maintain facilities. EU data subjects who provide Personal Data to Gogo acknowledge the processing and transfer of that data to the United States and around the world. Gogo will execute agreements with external parties for the transfer of personal data outside of the EU. These agreements may use European Commission-approved Standard Contract Clauses and/or employ additional or alternative appropriate safeguards. For more information on the appropriate safeguards in place and to obtain a copy of such safeguards, please contact us at firstname.lastname@example.org.
We do not intentionally gather Personal Information about Users who are under the age of 16. If we become aware that we have unknowingly collected Personal Information from a child under the age of 16, we will make reasonable efforts to delete such information from our records.
Compliance with the California Consumer Privacy Act (CCPA)
In addition to the notice provided above, the following notice applies to California residents.
We have collected the following personal information from our users over the past 12 months. What information we collect varies depending on how you interact with us and our services.
Changes to this Notice
We may modify or update this privacy notice from time to time. If we make any revisions that materially change the ways in which we process your Personal Data, we will notify you of these changes before applying them to that Personal Data.
How to Contact Us
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