DCSIMG

Privacy & Cookie Policy

GOGO PRIVACY & COOKIE POLICY

Last updated March, 2014

Gogo LLC and its subsidiaries and affiliates, (“Gogo,” “us” or “we”) respect your concerns about privacy and value our relationship with you. This Privacy and Cookie Policy is intended to inform you of the types of information we collect, as well as our policies and practices regarding the collection, use and disclosure of that information through the web pages, tracking devices, interactive features, mobile applications, blogs and their respective contents at Gogo’s on-ground and in-flight URLs, including among others www.gogoair.com, custhelp.gogoinflight.com, mobile.gogoinflight.com, airborne.gogoinflight.com and blog.gogoair.com/node (collectively, “Gogo Domains”), in addition to our Twitter, Facebook and other social networking sites, and their respective contents (collectively, the “Sites”), and the Gogo services (collectively with the Sites, the “Services”), whether accessed via computer, mobile device or other technology.

 

QUICK GUIDE TO CONTENTS

  1. Information Collected through our Services

    The airlines on whose planes the Services are available do not collect any information through your use of the Services, but we may share certain types of information with such airlines, as described below. Please remember that this policy only covers your activities while on the Gogo Domains; to the extent you visit third party websites, including the websites of our airline partners, the privacy policies of those websites will govern. Users who reside outside of the United States should note that their information will be held and processed in the United States.

    Personal Information You Provide to Us

    By using the Services, you may choose to provide information that could reasonably be used to contact you, or to identify you personally, or that otherwise relates to your person (such as your 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 information that enables us to receive your payment (including your credit card authorization number) (collectively, “Personal Information”)). For example, Gogo may collect Personal Information when you register on the Sites, purchase Services, request information, submit comments or participate in some promotion, survey or other feature of the Sites, or otherwise communicate or interact with us. In addition, you may choose to provide contact information for friends you may wish us to contact. When you provide us information for these “refer a friend” messages, we use the information only to send the message you request. Please check that friends you refer are happy for us to contact them. The Sites may also ask you to provide other information about yourself, such as demographic information (gender, zip code, age, etc.) or certain information about your preferences, product use and interests.

    Information Collected by Automated Means

    Whenever you use the Services, Gogo, as well as any of our third-party advertisers and/or service providers, may use a variety of technologies that automatically or passively collect information about how the Services are accessed and used (“Usage Information”). Usage Information may include, among other things, browser type, operating system, the page served, the time, how many users visited the Sites, origin and destination information, flight information, subscriber status and the preceding page views. This statistical data provides us with information about the use of the Services, such as how many visitors visit a specific page on the Sites, how long they stay on that page, and which hyperlinks, if any, they “click” on. This information helps us to keep the Services fresh and interesting to our visitors and to tailor content to a visitor’s interests. Usage Information is generally non-identifying, but if Gogo associates it with you as a specific and identifiable person, Gogo treats it as Personal Information.

    Device Identifiers

    In the course of collecting Usage Information, Gogo also automatically collects your IP address, MAC Address or other unique identifier (“Device Identifier”) for the computer, mobile device, Wi-Fi card, technology or other device (collectively, “Device”) you use to access the Services. A Device Identifier is a number that is automatically assigned to your Device when you access a website or its servers, and our computers identify your Device by its Device Identifier. When you visit the Sites, we may view your Device Identifier. We use this information to determine the physical location of your Device, including origin, destination, flight route information, and longitude and latitude information. We also may use this information to enhance the Services and we may associate your Device Identifier with your Personal Information. The technologies used on the Services to collect Usage Information, including Device Identifiers, may include, without limitation:

    Cookies

    Cookies are data files placed on a Device when it is used to visit the Sites or access the Services (“Cookies”). We may use Cookies to collect and store certain information about your Account. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them). The types, use and duration of the Cookies used are as follows:

    Type of Cookies

    Purpose of Use

    Duration

    Session Cookies

    Session Cookies ensure that you are recognized when you move from page to page within the Sites and that any information you have entered is remembered. For example, session Cookies ensure that items placed in a shopping basket don’t disappear by the time you reach the checkout. You can choose not to accept session Cookies by changing the settings in your browser.

    Session Cookies expire once you close your web browser

    Persistent Cookies

    Persistent Cookies help the Sites remember your information and settings when you 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 your online experience by saving your preferences while you are visiting a particular Site.

    Persistent Cookies also allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are using the Services.

    We currently use a third party ad network to serve Cookies in the United States; and we may partner with third party ad networks to serve our Cookies in the European Union.

    Eternal, unless deleted by the user.

    If you would prefer not to accept Cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a Cookie, at which time you can choose whether or not to accept it; (ii) disable existing Cookies; or (iii) set your browser to automatically reject any Cookies. Start with these sites to learn more about your browser’s privacy controls:

    Additionally, Firefox and Chrome have extensive repositories of add-ons that can help enhance your control over your privacy.

    You 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 you disable or reject Cookies, some features and Services may not work properly because we may not be able to recognize and associate you with your Gogo Account.

    Web Beacons

    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 you, which we will use to collect information regarding your 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 third 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 the third party. A web beacon may also tell your browser to get content from another server.

  2. How We Use the Information Collected

    We use information we collect about and from you to: provide the Services to you, respond to requests that you make, improve the Services, and better tailor content, advertisements, offers and the features, performance and support of the Services; and for purposes disclosed at the time you provide your Personal Information or otherwise with your consent. We may use records of your e-chat sessions with our representatives for support, training and improvements to our Services. If you provide feedback to us, we may use and disclose such feedback for any purpose, provided we do not associate such feedback with your Personal Information.

    We may use your Personal Information to send you electronic newsletters or promotional emails, unless you have requested not to receive such promotional communications from us. You can opt-out of receiving further promotional messages from us by following the unsubscribe instructions provided in the promotional email you receive or by contacting us directly at customercare@gogoair.com. We may also use your Personal Information to send you Service-related communications unless or until such time as you terminate your Account.

  3. Information We Share

    Except as otherwise stated in this Privacy and Cookie Policy, we do not trade, rent, or share your Personal Information with third parties, unless you ask or authorize us to do so. We may share non-Personal Information, such as aggregate user statistics, demographic information and Usage Information with third parties. We may also share your information as disclosed at the time you provide your information, as set forth in this Privacy and Cookie Policy and in the following circumstances:

    Roaming Partners. Gogo has agreements in place with various companies (typically hotspot aggregators or telecommunications companies) (“Roaming Partners”) that provide the Services to their customers (“Roaming Partner Users”). If you are a Roaming Partner User, we may send to the applicable Roaming Partner: (a) the userID and password you submit to us when you sign in to use the Services in order to authenticate you and for security purposes; and (b) information regarding the times that you started and stopped use of the Services and bandwidth used.

    Airline Partners. In order to provide the Services efficiently, carry out your requests, and provide you with offers and advertisements tailored to your interests, we may also disclose Personal Information, such as your e-mail address, Device Identifier, and Usage Information to the airline partner on whose plane you have accessed the Services.

    Third Parties Providing Services On Our Behalf. In order to provide the Services, carry out your requests, make various features, services and materials available to you through the Services and respond to your inquiries, we may share your Personal Information or Usage Information with third parties that perform functions on our behalf, such as (a) companies or individuals that: host or operate our Sites; analyze data; provide customer service; or manage payments; (b) advertisers; and (c) sponsors or other third parties that participate in or administer our promotions or provide marketing or promotional assistance. In such cases, such third parties are not entitled to use this information for any other purpose.

    Your Agreement To Have Your Personal Information Shared. While using the Services, you may have the opportunity to opt-in to receive information and/or marketing offers from someone else or to otherwise consent to the sharing of your information with a third party, including companies who advertise their services via the Service. If you agree to have your Personal Information shared, your Personal Information will be disclosed to the third party and the Personal Information you disclose will be subject to the privacy policy and business practices of that third party.

    Affiliates. To facilitate our marketing and communications efforts, we may share some or all of your Personal Information with our Affiliates (“Affiliates” are parent companies, subsidiaries, joint ventures, or other companies under a common control), in which case we will require our Affiliates to honor this Privacy and Cookie Policy. If you are a California resident, you may ask us to refrain from sharing your information (whether collected online or offline) among our Affiliates for their marketing purposes, if the Affiliates are separate legal entities. Please tell us your preference by contacting us as indicated in the “How to Contact Us“ section of this Policy. We will comply with the applicable data privacy laws and direct marketing requirements in the relevant jurisdictions and may seek opt-in or opt-out consents as appropriate for the collection, use and transfer of personal information in accordance with the laws in the relevant jurisdictions.

    Business Transfers. If our company or our assets related to this Privacy and Cookie Policy are acquired by another company, your Personal Information, and any other information that we have collected about the users of the Services, may be disclosed to that company as part of the due diligence process and will be transferred to that company as one of the transferred assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use information you have provided through the Sites in a manner that is consistent with this Privacy and Cookie Policy. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.

    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 of your communications on or through the Services. We may, and you hereby authorize us to, disclose your Personal Information (including your Account Information) and your communications through the Services, if required by law or by law enforcement officers acting under the color of 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) protect or defend the rights, property, or safety of Gogo, you, other users, or third parties (especially in emergency situations).

  4. Information We Receive from Third Parties

    Gogo may receive information about you from third parties. For example, if you are on another website and you opt-in to receive information from Gogo, that website will forward to us your e-mail address and other information about you so that we may contact you as requested. You may also choose to participate in a third party application or feature (such as one of our Facebook or Twitter applications or a similar application or feature on a third party website) through which you allow us to collect and share (or the third party to collect and share) information about you, including Personal Information. In addition, we may receive information about you if other users of a third party web site give us access to their profiles and you are one of their “connections” or information about you is otherwise accessible through your “connections” web page, profile page or similar page on a social networking or other third party website or interactive service.

    We may also supplement the information we collect about you through the Services with other information from third parties in order to enhance our ability to serve you, to tailor our content to you and to offer you opportunities to purchase products or services that we believe may be of interest to you. Using multiple data sources, we derive your airline, tail number, origin, destination and flight number of the flight when you access the Services. We may combine the information we receive from these third parties with information we collect through the Services. In those cases, we will apply this Privacy and Cookie Policy to any Personal Information received, unless we have disclosed otherwise.

    We may match the information we receive about you from third parties with the information we collect from you ourselves in order to enhance your experience with the Services and to select which of our advertisements or offers are most likely to appeal to you and display them while you are using the Services.

  5. Consent to Processing and Transfer of Information

    By using the Services, you agree to the terms of this Privacy and Cookie Policy and you expressly consent to the processing of your Personal Information according to this Privacy and Cookie Policy. For human resources data we have agreed to cooperate with Data Protection Authorities.

    If you are a User who resides outside the United States, please be aware that information we collect will be transferred to and processed in the United States. By using the Services, or providing us with any information, you consent to the collection, processing, maintenance and transfer of such information in and to the United States and other applicable countries in which the privacy laws may not be as comprehensive as or equivalent to, those in the country where you reside and/or are a citizen.

    Gogo participates in the EU and Swiss Safe Harbor Framework as established by the U.S. Department of Commerce regarding the collection, use and retention of personal information from European Union member countries and Switzerland. Gogo has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement. To learn more about the Safe Harbor program, and to view our certification page, please visit http://www.export.gov/safeharbor/.

    In compliance with the EU and Swiss Safe Harbor Principles, Gogo commits to resolve complaints about your privacy and our collection of use of your personal information. European Union or Swiss citizens with inquiries or complaints regarding this Privacy and Cookie Policy should first contact Gogo at:

    Gogo LLC
    Attn: General Counsel
    1250 N. Arlington Heights Rd., Suite 500
    Itasca, IL 60413

  6. Your Access and Choices

    As part of our participation in the safe harbor we have agreed to TRUSTe dispute resolution for disputes relating to our compliance with the Safe Harbor Privacy Framework. If you have complaints regarding our compliance with the Safe Harbor you should first contact us (as provided above). If contacting us does not resolve your complaint, you may raise your complaint with TRUSTe by clicking here, fax to +1 415-520-3420, or mail to TRUSTe Safe Harbor Compliance Dept., click for mailing address. If you are faxing or mailing TRUSTe to lodge a complaint, you must include the following information: our name, the alleged privacy violation, your contact information, and whether you would like the particulars of your complaint shared with us. For information about TRUSTe or the operation of TRUSTe’s dispute resolution process, click here or request information for TRUSTe at any of the addresses listed above. The TRUSTe dispute resolution process shall be conducted in English.

    We offer you choices regarding the collection, use, and sharing of your Personal Information. When you receive promotional communications from us, you may indicate a preference to stop receiving further promotional communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the promotional email you receive or by contacting us directly at Customer Care customercare@gogoair.comgogoair.com. Gogo does not charge for this opt-out service, and your opt-out request will be processed within 30 days of the date on which we receive it.

    Regardless of your indicated email preferences, we may send you administrative emails regarding the Services, including, for example, purchase confirmation, account creation confirmation, and notices of updates to our Terms of Use Agreement or Privacy and Cookie Policy.

    If you wish to verify, correct, update or delete any of the Personal Information provided to us, you may do so by editing it in your Account page, or by contacting us at the above email address. Please note that unless you state otherwise, we may send any corrected or updated Personal Information to every organization to which your Personal Information has been disclosed in accordance with this Privacy and Cookie Policy. In accordance with our routine record keeping, we may delete certain records that contain Personal Information you have submitted through the Services. Please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). You should be aware that it is not always possible to completely remove or delete all of your information from our databases without some residual data remaining in our archives because of backups and other reasons.

    If you wish to withdraw or modify your consent to our collection, use or disclosure of the Personal Information provided to us, we reserve the right to terminate your Account or your continued use the Services if the withdrawal or modification of your consent would or could adversely affect our operations or the Services.

  7. Advertising; How to Opt-out

    Gogo licenses technology to serve advertisements on its own Sites and within its content as that content is served across the Internet. In addition, Gogo may use third 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 third 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 your Device and they may otherwise collect or have access to information about you, including Usage Information. We and our network advertisers may target advertisements for products and services in which you might be interested based on your use of the Services, visits to the Sites and other websites. We may use a variety of companies to serve advertisements.

    If you prefer to not receive targeted advertising, you can opt-out of some network advertising programs that use your information. To do so please visit the Digital Advertising Alliance (DAA) Opt-Out Page: http://www.aboutads.info/choices. European users can also go to http://www.youronlinechoices.com Please note that even if you choose to remove your information (opt-out), you will still see advertisements while you’re browsing online. Additionally, many network advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. The DAA Opt-Out Page provides a tool that identifies its member companies that have Cookies on your browser and provides links to those companies.

  8. Links to Other Sites

    Our provision of links to other websites or locations is for your 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 or their content. These other websites may send their own Cookies to your Device, may independently collect data or solicit Personal Information and may or may not have their own privacy policies. Please be aware that the terms of our Privacy and Cookie Policy do not apply to these outside websites. You should independently assess the authenticity of any website which appears to be or claims that it is one of our Sites (including those linked to through an email or social networking page).

  9. How We Protect Personal Information

    The connection through which you access the Services is an SSL-encrypted link. However, following such initial access, due to multiple users of our inflight Wi-Fi access point, Gogo does not provide an encrypted communication channel, such as Wired Equivalent Privacy (WEP), or Wi-Fi Protected Access (WPA2), between our in-flight Wi-F access point and your Device. Gogo does support secure Virtual Private Network (VPN) and Secure Shell (SSH) access. If you have VPN, Gogo recommends that you use secure VPN protocols 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 Services. You 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. You should therefore take precautions to lower your security risks. Gogo recommends that you 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 a personal firewall and other protections against malware. Gogo recommends that sensitive or private information should not be accessed via or transmitted over an un-encrypted connection. While Gogo takes reasonable steps to protect your security, please be aware that we cannot ensure or warrant the security of any information you transmit to us, and you use the Services and provide us with your information at your own risk.

  10. Children

    We do not intentionally gather Personal Information about Users who are under the age of 13. If we become aware that we have unknowingly collected Personal Information from a child under the age of 13, we will make reasonable efforts to delete such information from our records.

  11. How to Contact Us

    Should you have any questions, concerns or complaints regarding this Privacy and Cookie Policy, please contact us at customercare@gogoair.com.

  12. Updates to Our Privacy and Cookie Policy

    This Privacy and Cookie Policy and other information on the Sites may be updated periodically and without prior notice to you, and any changes will be effective immediately upon the posting of the revised Privacy and Cookie Policy on the Sites. However, we will use your Personal Information in a manner consistent with the Privacy and Cookie Policy in effect at the time you submitted the information, unless you consent to the new or revised notice. We will post a prominent notice on the Sites to notify you of any significant changes to our Privacy and Cookie Policy and indicate at the top of the notice when it was most recently updated.

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