AerPass will not sell, rent, or trade your Personal Information. AerPass will only transfer your Personal Information at your request, and with your consent, for use by third parties to verify your identity or group eligibility, and as required for the provision of our Services and the prevention of fraud. AerPass has built rigorous security and privacy requirements into our technology from inception. We are an ethical steward of your Personal Information and are committed to supporting the following principles:
This Privacy Policy describes how AerPass and its affiliates, including Military Connect (collectively “AerPass”) collect, use and disclose certain information, including your Personal Information, both online and offline, and the choices you can make about that information. We respect your concerns about privacy, and value our relationship with each of our users. It is for this reason that AerPass will never sell, rent, or trade your Personal Information, and why we take measures to safeguard your Personal Information as we work to become the most trusted Personal Identity Network on Earth.
This Privacy Policy is designed to help you understand (i) what information we collect from visitors to our websites or through our marketing channels; (ii) how we use such information at AerPass, and (iii) the choices you have associated with that information. Additional privacy policy information specific to the Military Connect program can be found here, and for the purposes set forth in this privacy policy will be deemed to be fully included herein and fully applicable to all members of the Military Connect program. Should any of the terms of the Military Connect program privacy policy conflict with the terms set forth herein the Military Connect program privacy policy shall be deemed controlling, but only for Military Connect program members and only with respect to information specifically governed by the program privacy policy.
When we refer to “AerPass,” “we,” “our,” or “us” in this policy, we are referring to AerPass, and its subsidiaries and affiliates, as the “controller” (and/or a “business” under the CCPA) or the equivalent legal construct under applicable law of the information we process when you visit our websites and/or we interact with you through our marketing channels for business purposes. This Privacy Policy covers the digital properties listed herein. When we refer to “personal information”in this policy, we are referring to personal data, personally identifiable information, or the equivalent of each under applicable law.
It is important to note that where AerPass handles personal information on behalf of or at the direction of its customers through their use of our Services, AerPass is the “processor” (and/or “service provider” under the CCPA) or the equivalent legal construct under applicable law of that data and AerPass’ use, processing, and handling of such data is done pursuant to the written instructions of its customers in the form of the Terms of Service, Data Processing Addendum, and/or any similar written agreement between the parties. In these cases, our use of information collected through our Service shall be limited to the purpose of providing and operating the Services for our customers. As used herein, the “Service(s)” refers to the applications, services, and websites (marketing and product) provided by AerPass. AerPass may, from time-to-time, introduce new products and services. To the extent that any new products and/or services affect this Privacy Policy, we will notify you as further described in Section 8 below.
If you have any questions about this privacy policy or our practices, please contact us. If you are in the European Union, you may contact our Data Protection Officer through this same email address.
We collect several different types of information, including:
Customer Account and Registration Data: This includes information you provide to create your account with us or register for events, webinars, surveys, etc. and may include, first and last name, billing information, a passcode and a valid email address.
Service Data (including Session and Usage data): When you visit our websites and use our Services, we receive information either voluntarily entered by you or others (for example, schedules, attendee info, etc.), or passively logged by the website or Service itself, (for example, duration of session, use of webcams, connection information, etc.). We may also collect usage and log data about how the Services are accessed and used, including information about the device you are using to access the Services, IP addresses, location information, language settings, what operating system you are using, unique device identifiers and other diagnostic data to help us support and improve upon the Services.
Third Party Data: We may receive information about you from other sources, including publicly available databases or from third parties from whom we have purchased data, and combine this data with information we already have about you. We may also receive information from other affiliated companies that are a part of our corporate group. This third-party data is obtained for our legitimate business interests and helps us to update, expand and analyze our records, identify new prospects for marketing, and provide products and services that may be of interest to you.
Location Information: We collect your location-based information for the purpose of providing and supporting the Service and for fraud prevention and security monitoring. If you wish to opt-out of the collection and use of your collection information, you may do so by disabling location services on your mobile device.
Device Information: When you use our online and mobile Services, we may automatically collect information about the type of device you use, for example, the operating system version or the device identifier (or"UDID").
AerPass may access and use the data we collect as necessary: (a) to provide and operate Services; (b) to address and respond to service, security, and customer support issues; (c) to detect, prevent, or otherwise address fraud, security, unlawful, or technical issues; (d) as required by law; (e) to fulfill our contracts; (f) to improve and enhance the Services; and/or (g) to provide analysis or valuable information back to our customers and users.
Some specific examples of how we use the information:
AerPass also collects and stores meeting attendee information to fulfill our obligation to our customers and provide the Services. With their consent or under their instructions, we may also directly provide product and other AerPass related information to attendees. AerPass will retain your information, under a lawful basis, as long as your account with us is active, to comply with our legal obligations, to resolve disputes, and enforce our agreements.
If you wish to cancel your account or for us to stop providing you Services, or if we hold personal information about you and you want it to be removed from our database or de-activated, please contact us here.
AerPass continuously improves its websites and Services through the use of various third-party web analytics tools, which help AerPass understand how its visitors use its websites, desktop tools, and mobile applications, what they like and dislike, and where they may have run into problems which need to be addressed.
Geolocation and Other Data:
We may utilize precise Geolocation data but only if you specifically opt-in to or permit collection of that data in connection with a particular Service. We also use information such as IP addresses to determine the general geographic locations areas of our visitors. The web beacons used in conjunction with these web analytics tools may gather data such as what browser or operating system a person uses, as well as, domain names, MIME types, and what content, products and services are reviewed or downloaded when visiting or registering for Services at one of our websites or using one of our mobile applications.
Google Analytics:
We use Google Analytics as described in “How Google uses data when you use our partners' sites or apps.” You can prevent your data from being used byGoogle Analytics on websites by installing the Google Analytics opt-out browser add-on. We also employ IP address masking, a technique used to truncate IP addresses collected by Google Analytics and store them in an abbreviated form to prevent them from being traced back to individual users. Portions of our website may also use Google Analytics for Display Advertisers including DoubleClick or Dynamic Remarketing which provide interest-based ads based on your visit to this or other websites. You can use Ads Settings to manage the Google ads you see and opt-out of interest-based ads. You can opt-out of use of this information as described below.
Tracking Technologies:
AerPass and our partners use cookies and similar tracking technologies to track user traffic patterns and hold certain registration information. Other tracking technologies used are beacons, tags and scripts to collect and track information and to improve and analyze our Services. If you wish to not have the information these technologies collect used for the purpose of serving you targeted ads, you may opt-out here, or if located in the EuropeanUnion, click here. The Help Menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. You can still review the website if you choose to set your browser to refuse all cookies; however, you must enable cookies to establish an account and to install the Services.
Examples of Cookies We Use:
Mobile Analytics:
We use mobile analytics software to allow us to better understand the functionality of our mobile software on your mobile device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.
Social Media:
Our sites include social media features, such as Facebook, Google and Twitter “share” buttons. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These services will also authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign-up form or provide feedback. Your interactions with these features are governed by the PrivacyPolicy of the third-party company providing them.
Ensuring your privacy is important to us. We do not share your personal information with third parties except as described in this Privacy Policy. We may share your personal information with: (a) third party service providers; (b) business partners; (c) affiliated companies within our corporate structure; and (d) as needed for legal purposes. Third-party service providers have access to personal information only as needed to perform their functions and they must process the personal information in accordance with this Privacy Policy. These transfers to subsequent third parties are covered by appropriate transfer agreements such as the EU Model Clauses.
Examples of how we may share information with service providers include:
Examples of how we may disclose data for legal reasons include:
AerPass may need to communicate with you for a variety of different reasons, including:
We only retain a limited amount of personal data, under an appropriate and lawful basis, for as long as needed for the business purposes for which they were collected or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. After that time frame, we delete or anonymize the data according to our data retention policies and/or procedures.
Our customers can always review, update or change personal information from within their account or by contacting us. AerPass will also, when you request, provide you with information about the types of information we process about you and whether we hold, or process on behalf of a third party, any of your personal information. You may have the right to a copy of your personal information in machine-readable format.
You can also ask about:
Finally, you can ask us: (a) not to collect or use your personal information for certain purposes; (b) to delete your personal information; or (c) to provide your personal information to a third party.
To make any of these requests, please contact us at https://support.aerpass.com/contactus which allows you to make a request online or through a phone call.
We may also collect information on behalf of our customers, to provide the Services, and we may not have a direct relationship with the individuals whose personal data is processed. If you are a customer or end-user of one of our customers, please contact them (as the data controller or legal equivalent) directly with any of these requests.
Depending on which laws apply to your personal information, we may only be able to fulfill some of the above requests for you. If you make a request and we have a justified lawful reason to maintain your information (e.g., legal and audit purposes), we will explain your legal rights, the reason we are maintaining such information and, if applicable, any recourse you may have.
We will respond to your request without undue delay, but in any event within thirty (30) days. We reserve the right to take reasonable steps to verify your identity prior to granting access or processing changes or corrections.
If you wish to no longer receive marketing communications from us, you can opt-out of marketing by clicking on the unsubscribe link on any marketing email you receive.
You may also have the right to complain to a regulatory authority. If you have a question or complaint, we ask that you please contact us first. If you are in the EU and we are unable to resolve your complaint, you may complain to the Data Protection Authority in your home country.
AerPass follows generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. However, no security measure is perfect. We recommend safeguarding your passcode, as it is one of the easiest ways you can manage the security of your own account – remember that if you lose control over your passcode, you may lose control over your personal information.
AerPass is headquartered in the United States of America and maintains a global infrastructure. Information that we collect and maintain may be transferred to, or controlled and processed in, the United States and/or other countries around the world. Although these countries may have different data protection laws to the laws of your country, we will protect the privacy and security of personal information we collect in accordance with this Privacy Policy, regardless of where it is processed or stored. Where AerPass processes European Union personal information outside of the European Union in countries not declared to have adequate protections, it does so in compliance with Chapter 5 of the GDPR (e.g., under the E.U.-US and Swiss Privacy Shield Framework(s) and/or Standard Contractual Clauses) and applicable law.
Additionally, the California Consumer Privacy Act, or CCPA, which took effect on January 1, 2020, is intended to provide California residents with expanded rights to access, delete and control their personal information. Any terms defined in the CCPA have the same meaning when used in this Privacy Policy.
For personal information collected by us during the preceding twelve(12) months that is not otherwise subject to an exception, California residents have the right to access and delete their personal information. We will not discriminate against those who exercise their rights. Specifically, if you exercise your rights, we will not deny you access to our Services, charge you different prices for Services or provide you a different level or quality of Services.
The CCPA additionally requires businesses to provide or make available certain disclosures in the event a party sells your personal information to third parties, however because AerPass does not receive any personal information as consideration for any Services or other items provided or performed by AerPass, these disclosures do not apply. AerPass does not collect, retain, share or use any personal information except as necessary for a business purpose pursuant to a written contract (i.e., to provide and operate the Services) and subject to the restrictions specified in Section 1798.140 (v) of the CCPA. Additionally, AerPass refrains from taking any action that would cause any transfers of personal information that qualify as "selling personal information" under the CCPA or other similar applicable privacy laws.
California residents may exercise the rights specified in this Privacy Policy or request information from us regarding whether we share certain categories of your personal information with third parties by contacting privacy@aerpass.com.
Residents of the State of California, under California Civil Code § 1798.83, have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed personal information during the preceding year for direct marketing purposes. Alternatively, the law provides that if the company has a privacy policy that gives either an opt-out or opt-in choice for use of your personal information by third parties (such as advertisers) for marketing purposes, the company may instead provide you with information on how to exercise your disclosure choice options.
AerPass qualifies for the alternative option. We have a comprehensive privacy statement and provide you with details on how you may either opt-out or opt-in to the use of your personal information by third parties for direct marketing purposes. Therefore, we are not required to maintain or disclose a list of the third parties that received your personal information for marketing purposes during the preceding year.
AerPass’ webpages are intended for general audiences – we do not seek through this site to gather personal data from or about persons that are thirteen (13) years of age or younger. If you inform us or we otherwise become aware that we have unintentionally received personal information from an individual under the age of thirteen (13), we will delete this information from our records.
We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes that have a substantive and adverse impact on your privacy, we will provide notice on this website and notify you by email (sent to the e-mail address specified in your account) for your approval prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
If you have any other questions about this policy please contact AerPass Privacy Team, or call +1 720 306 5058.
