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Privacy Policy

PRIVACY POLICY

We respect the importance of your personal information. This privacy policy (“Privacy Policy”) applies to your personal information that we collect thorugh or in connection with the operation of the in-flight internet connectivity service we operate (the “Service”). We want you to understand our Privacy Policy and, specifically, what information we gather in connection with the Service, how that information is used, with whom we share that information and what we do to protect it. We’re accountable for the protection of your personal information under our control and are committed to following this Privacy Policy and complying with the law. This Privacy Policy is not a contract between us and you.

In this Privacy Policy, “we,” “us” or “our” means Panasonic Avionics Corporation, a Delaware USA corporation based in California USA and “you” or “your” means a person who accesses or uses the Service (other capitalized terms used in this Privacy Policy but not defined here have the meaning provided in the Terms of Service (the “Terms”)).

Safe Harbor (for EU Residents).

Consistent with our commitment to protect personal privacy, we declare that we adhere to the Safe Harbor Principles embodied in the Safe Harbor Agreement concerning the transfer of personal data from the European Union (EU) to the United States of America effective November 1, 2000. If you are a EU resident, these Safe Harbor Principles [link to SHP—attached at end of this policy] apply.

What Categories Of Personal Information Do We Collect?

We collect information in order to provide the Services. Examples of the types of information we collect include:

  • Personal Information. Personal Information (or PII) is information that you provide to us that identifies you, for example, your name, address, email, telephone number, etc., or that can be used to identify you. Personal Information does not include information that is about you but from which you could not reasonably be identified. For purposes of this Privacy Policy, Personal Information does not include any personally identifiable data that you otherwise Transmit using the Service.
  • Sensitive Personal Information (for EU residents). Sensitive Personal Information is Personal Information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sexual activity. For purposes of this Privacy Policy, we will treat any Sensitive Personal Information received from a third party as required by the Safe Harbor Principles.
  • Contact Information. Contact Information is your name, email address and any other contact information that you provide us with in connection with creating or updating your Account.
  • Payment Information. Payment Information is the credit card, debit card or related banking information you provide us with to pay for the Service.
  • Network and Device Information. We may collect information about your mobile device and information that is necessary to provide you with the Service, such as a session ID token, source and destination addressing information, IP address, MAC address, the software you are using and related device and network information.
  • Feedback Information. You may volunteer, or we may ask for, information on your experience using the Service. At no time are you obliged to provide such information. Feedback Information includes comments, complaints, requests, suggestions or feedback sent by you to us regarding the Service.
  • User Data. User Data is all information and data that is not Personal Information that you access, send or receive when using the Service. User Data includes web browsing activity.
  • Location Data. We may collect data regarding your location while you are using the Service (more specifically, the location of the mobile device that is accessing the Service).

Persons under 18 Years of Age.

The Service is not directed towards persons under 18 years of age and we do not intentionally or knowingly collect Personal Information from persons under 18 years of age. If you allow a person under 18 years of age to use the Service, you should be aware that their Personal Information could be collected as described in this Privacy Policy and any Personal Information associated with his/her use will be treated as your own information under this Privacy Policy. Alternatively, you may contact us to have such PII deleted.

Parents/guardians should monitor their children’s use of the Service, including internet browsing and downloaded applications, to ensure that no information is being collected from their child without parental permission and that inappropriate Content is not being shared or accessed.

How Do We Collect Information?

We may collect information about you in a number of different ways, including:

  • what you provide to us.
  • from communications between you and us.
  • from public sources.
  • automatically in connection with your use of your mobile device and the Service.
  • from our service providers, including our roaming partners.

Collection of certain information is essential to the operation of the Service. Except where we are not required to do so under applicable law, we will obtain your consent before we collect other personal information.

How Do We Use This Information?

We may use the following information as described below:

  • Your Personal Information. We do not sell your Personal Information to third parties. Your Personal Information is only used and disclosed in connection with the operation of the Service, including to process payments, verify your identity, answer questions about your Account, troubleshoot problems, customize, measure and improve the Service, inform you about updates and changes to the Service, seek feedback, compare information for accuracy and enforce the Terms. We may share your Personal Information with the Host Airline and we and/or the Host Airline may use your Personal Information to personalize services and offers provided to you and for internal purposes, such as auditing, data analysis and research to improve services, customer communications and content.

When you use the Service, you give us your informed consent to collect, use and disclose your Personal Information in accordance with this Privacy Policy. Except where we are not required to do so under applicable law, we will notify you and obtain your consent before we disclose or use your Personal Information in any other way.

  • User Data. User Data that is associated with your Personal Information is only used and disclosed in connection with the operation of the Service, including to troubleshoot problems, customize, seek feedback, data analysis and research to measure and improve the Service, customer communications and content and enforce the Terms. User Data associated with your Personal Information will not otherwise be shared with third parties. User Data that is not associated with your Personal Information is treated as De-Personalized Information, see below.
  • Contact Information. Contact Information is used to to verify, process and charge for the Service and contact you regarding the Service. Contact Information is shared with our service providers, such as payment processors, as necessary to operate the Service.
  • Payment Information. Payment Information is used to confirm your identity and verify, process and charge for the Service. Payment Information is shared with our service providers, such as payment processors, as necessary to operate the Service.
  • Network and Device Information. Network and Device Information is used and disclosed in connection with the operation of the Service, including to troubleshoot problems, customize, and data analysis and research to measure and improve the Service and enforce the Terms.
  • Feedback Information. We may use Feedback Information in any manner and for any purpose without any obligation to account for such use or to compensate you for it. We reserve the right to utilize Feedback Information, on an anonymous basis, for marketing purposes, for instance by displaying selected comments on the Site, marketing materials or in other communications. We will not disclose any personally identifiable feedback information to third parties (other than third parties who are involved in providing the Service where such feedback relates to those providers) without your consent.
  • Passive Information. Passive Information is automatically generated. We only use Passive Information, on an aggregated basis, to provide you with better service or for statistical information.
  • Location Data. We may use information about your location to provide the Service or to customize Content presented to you. We also use location data to to troubleshoot problems, customize, seek feedback, data analysis and research to measure and improve the Service, customer communications and content and enforce the Terms
  • De-Personalized Information. We may collect information of any type, including User Data, anonymize that information, and use alone or with similar anonymized information obtained from other individuals (“De-Personalized Information”). No personally identifying information will be included in any De-Personalized Information. We may disclose De-Personalized Information Information to any third party and use it for any purpose we deem appripate in our sole discretion.
  • Other Parties’ Ability to Collect Personal Information. We do not authorize any third parties to collect PII about a User’s activities over time and across different sites when a User uses the Service.

You agree that we can, subject to applicable law, use your Personal Information to operate the Service (including sharing your Personal Information with the Host Airline and our service providers and/or agents, for example the third party banking organization or other providers of payment services and roaming partners you may use), conduct analysis and research; comply with legal requirements; prevent fraud or misuse of the Service; protect our rights or property or the safety of you or others; and send you communications regarding the Service. We may also disclose Personal Information if we believe in good faith that we are required to do so by law, or that doing so is necessary to comply with legal process, respond to requests from law enforcement or governmental agencies, respond to claims or to protect our rights.

Your Personal Information may be stored and processed in any country in which we or our affiliates or service providers maintain facilities. We reserve the right to transfer and store your Personal Information outside the country in which you reside. As we continue to develop our business, we might sell or buy subsidiaries or business units. In such transactions, as well as in the event we or substantially all of our assets are acquired by a third party, your Personal Information and User Data will generally be one of the transferred business assets. We reserve the right to include your Personal Information and User Data, collected as assets, in any such transfer to a third party. Additionally, your Personal Information and User Data could be disclosed as part of a bankruptcy involving us.

Can I obtain a copy of my Personal Information?

If you are a Subscriber, in most cases the Personal Information we have of yours will appear in your Account. To the extent required by applicable law, we will share other data we have about you. In the U.S., we are not generally required to release any records that are created and retained as part of the Service that are not Personal Information without a subpoena (unless otherwise required by law).

Can I correct my Personal Information?

If you are a Subscriber, in most cases, you can correct your Personal Information from your Account. If you are a User and there is any Personal Information of yours that is inaccurate, incomplete or out-of-date that you cannot correct, please contact us at customercare@panasonic.aero so that we can correct it.

Can I remove some or all of my Personal Information?

If you are a User, upon request, we will remove your Personal Information to the extent required under applicable law. However, the Service cannot operate without certain Personal Information and removal of such Personal Information may result in the termination of your Account or inability to access and use the Service.

What Categories Of Third Parties Do We Share Your Personal Information?

The categories of third parties with whom we may share your Personal Information, depending on the situation, include the Host Airline, our service providers and our roaming partners that you use.

Consent For Electronic Communications.

We use Contact Information to communicate with you regarding the Service. By providing Contact Information, you consent to receive such communications at such e-mail address and/or telephone number.

What Are Cookies And How Do We Use Them?

Cookies are pieces of information that we transfer to your computer or mobile device through a browser. Cookies we use do not contain any personally identifying information. We use Cookies to collect and store certain information about your Account. We may use both session Cookies (which expire when you close your web browser) and persistent Cookies (which stay on your device until you delete them).

We use cookies so that we can identify the mobile device being used and to reestablish service (auto-log-in). Cookies also enable us to gain information about your use of the Service and to enhance it to meet your preferences. These cookies persist until you delete them. We do not use web beacons. The Help option on the toolbar of most browsers will tell you how to prevent or limit the browser from accepting cookies, how to have the browser notify you when you receive a cookie, or how to disable cookies altogether.

You may access third party websites, online services or applications using the Service. The use of cookies, web beacons or similar technologies on such other websites, online services or applications is subject to any applicable privacy policies that they may have, not this Privacy Policy.

How We Treat “Do Not Track” Or Similar Signals.

Some browsers provide you with “do not track” options. Because there is not yet a common understanding of how to interpret the “do not track” signal, we do not currently respond to the browser “do not track” signals when you use the Service or interact with the Site

How Your Personal Information Is Protected.

We take physical, organizational and technical measures to protect the Personal Information you provide to us. We cannot guarantee the absolute security of our database, nor can we guarantee that any information supplied will not be intercepted while being transmitted over wireless networks or the Internet. An important aspect of protecting your Personal Information is the strength and security of your password. If you believe your password might have been compromised, change it immediately.

How Long Is Personal Information Kept?

We will retain your Personal Information for as long as is necessary to operate the Service; maintain records until they cannot be lawfully challenged and legal proceedings may no longer be pursued or as needed to operate the business; carry out marketing activities; comply with applicable law, regulatory requests and relevant orders from government authorities; and enforce or fulfill any of the other purposes detailed in, the Terms.

For California Residents: Your California Privacy Rights.

California Civil Code Section 1798 entitles California customers to request information concerning whether a business has disclosed Personal Information to any third parties for the third parties’ direct marketing purposes. As stated in this Privacy Policy, we will not sell or share your Personal Information with non-affiliated companies, other than the Host Airline, for their direct marketing purposes without your consent. California customers who wish to request further information about our compliance with this law or have questions or concerns about our privacy practices and policies may contact us as specified in the “How Can We Be Contacted” section below.

Can This Privacy Policy Be Modified?

We reserve the right to modify this Privacy Policy at any time. Use of the Service after we have published a modified Privacy Policy on the Site constitutes acceptance of such modified Privacy Policy.

How We Notify You Of Modifications.

We will publish the modified Privacy Policy on the Site. The modified Privacy Policy becomes effective upon publishing. If the modifications are material, we will provide more prominent notice as appropriate under the circumstances (for example, for a period of time following publication the icon or link to the Privacy Policy may be highlighted or include the word such as “modified,” “revised,” “updated” or similar).

How Can We Be Contacted? By mail at: Panasonic Avionics Corporation, Attn: Legal Department-WISP Privacy, 26200 Enterprise Way, Lake Forest, CA 92630 USA or by email at customercare@panasonic.aero.

Last revised: 30 September 2014. ©2014 Panasonic Avionics Corporation. All rights reserved.


 

Safe Harbor Principles (for EU Residents)

Consistent with our commitment to protect personal privacy, we declare that we adhere to the Safe Harbor Principles embodied in the Safe Harbor Agreement concerning the transfer of personal data from the European Union (EU) to the United States of America effective November 1, 2000. The U.S. Department of Commerce and the European Commission have agreed on the Safe Harbor Principles and related materials to enable U.S. companies to satisfy EU legal requirements for adequate protection of Personal Information transferred from the EU to the United States (www.export.gov/safeharbor/). The provisions of this Safe Harbor section apply to EU residents. If there is a conflict between the other provisions of this Privacy Policy and the Safe Harbor Principles, the Safe Harbor Principles will govern.

         Safe Harbor Privacy Principles

The usage of Personal Information conforms to the following Safe Harbor Privacy Principles as stated below under the heading of each principle.

                  Notice and Choice

To the extent permitted by the Safe Harbor Principles, we reserve the right to process Personal Information in the course of providing the Service to Users without the knowledge of the entities or individuals involved. If and when we collect Personal Information directly from individuals residing in the EU, we will inform them about the types of Personal Information we collect from them, the purposes for which we collect and use it and the types of non-agent third parties to which we disclose that information. We will also inform those individuals about the choices and means, if any, that we offer to limit the use or disclosure of their information.

Where we receive Personal Information from our subsidiaries, affiliates or other entities in the EU, we will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such Personal Information relates.

To the extent permitted by law, we will offer individuals the opportunity to choose (opt-out) whether their Personal Information is: (a) to be disclosed to a non-agent third party; or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

For Sensitive Personal Information, we will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

We will provide individuals with reasonable mechanisms to exercise their choices.

                  Disclosures and Onward Transfers

We have identified a privacy administrator who is responsible for training employees regarding the appropriate use of Personal Information and conducting regular self-assessment reviews to ensure full compliance with the Safe Harbor Principles. We will not disclose an individual's Personal Information to third parties, except when one or more of the following conditions is true:

  • we have the individual's permission to make the disclosure;
  • the disclosure is required by statute, government regulation or case law that creates explicit authorizations, provided that, in exercising any such authorization, we can demonstrate that its non-compliance with the Principles is limited to the extent necessary to meet the overriding legitimate interests furthered by such authorization;
  • the disclosure is required to meet national security, public interest, or law enforcement requirements;
  • the disclosure is reasonably related to the sale or disposition of all or part of our business;
  • the information in question is publicly available;
  • the disclosure is reasonably necessary for the establishment or defense of legal claims; or
  • the disclosure is to one of our related entities or to persons or entities providing services on our or the individual’s behalf (each, a “transferee”), consistent with the purpose for which the information was obtained, if the transferee, with respect to the information in question:
    • is subject to laws providing an adequate level of privacy protection;
    • has agreed in writing to provide an adequate level of privacy protection; or
    • subscribes to the Safe Harbor Principles.

Permitted transfers of information, whether to third parties or within our organization, include the transfer of data from one jurisdiction to another, including transfers to and from the United States.

                  Data Security

To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use and confidentiality of information, either for our own purposes or on behalf of our clients, customers and business partners, we have put in place and enforce appropriate physical, electronic, and administrative procedures to safeguard and secure the information that we process. However, we cannot guarantee the security of information on, or transmitted via, the Internet.

                  Data Integrity

We process Personal Information only in ways that are compatible with the purpose(s) for which it was collected or subsequently authorized by the individual. To the extent necessary for such purposes, we take reasonable steps to make sure that Personal Information is accurate, complete, current and otherwise reliable for its intended use.

                  Access and Correction

Upon request, individuals will be permitted to access any Personal Information we receive within a reasonable time period except in the circumstances as described below. If an individual becomes aware that Personal Information we maintain about that individual is inaccurate, or if an individual would like to update or review that individual’s Personal Information, the individual may contact us using the contact information in the Privacy Policy. In every case, we will take reasonable steps to permit individuals to correct, amend, or delete Personal Information that is demonstrated to be inaccurate. The individual seeking to access or amend such Personal Information will need to provide sufficient identifying information, such as name, address, billing statement, account user name, email address or other identifiers. We may request additional identifying information as a security precaution, including seeking assistance from a partner service provider to confirm an individual’s identity.

We may limit or deny access to Personal Information where the burden and expense of providing such access would be disproportionate to the risks to the individual’s privacy in the case in question, where the legitimate rights of persons other than the individual would be violated, or as otherwise permitted by the Safe Harbor Agreement. In some circumstances, we may charge a reasonable fee, where warranted, for access to Personal Information.

                  Enforcement and Dispute Resolution

We utilize a self-assessment approach to verify our compliance with this Privacy Policy. We periodically verify that this Privacy Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, accessible and in conformity with the Safe Harbor Principles. We retain a signed statement verifying our self-assessment and it will be made available upon request by individuals in the context of an investigation or complaint about non-compliance with this Privacy Policy.

We encourage interested persons to first raise any concerns about our implementation of this Privacy Policy using the contact information below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Privacy Policy.

Any claim arising out of or relating to our adherence to the Safe Harbor Principles, or the breach thereof, that cannot be resolved through our internal processes, will be settled by arbitration administered by the American Arbitration Association (“AAA”) in accordance with its applicable commercial rules. Any arbitrator will be either an attorney or retired judge having significant and recognized experience with, and knowledge of, privacy issues and information technology. The arbitration panel will apply California law, without regard to its conflict of laws principles, as well as the Safe Harbor Enforcement Principles issued by the U.S. Department of Commerce. In addition, the exclusive location for such arbitration will be Orange County, California. All decisions of the arbitration panel will be final and binding on the parties, which waive any right to appeal the arbitration award further, to the extent an appeal may be lawfully waived. We are also subject to the jurisdiction of the U.S. Federal Trade Commission and other U.S. and foreign government agencies.

Changes

We may change this Privacy Policy from time to time, consistent with the requirements of the Safe Harbor Principles or the United States Department of Commerce. We will post any revised privacy policy in our relevant work places, train relevant employees about such changes and how to comply with them, and will publish any amended privacy policy on the Site.

Information Subject To Other Policies Or Standards

We are committed to following the Safe Harbor Principles for all Personal Information within the scope of the Safe Harbor Agreement. Certain Personal Information, however, is subject to our policies that may differ in some respects from the provisions of this Privacy Policy. Personal Information subject to such additional policies includes Personal Information obtained from or relating to a customer airline or business partner that is subject to the terms of any privacy notice or agreement with such customer or business partner, as well as any applicable laws.

Last revised: 30 September 2014. ©2014 Panasonic Avionics Corporation. All rights reserved.

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