Privacy Policy

GOGO BUSINESS AVIATION BROADBAND™ NETWORK SERVICE AND WEBSITE

Gogo Business Aviation Business Aviation Services LLC and its subsidiaries, affiliates, web site developers and other promotional partners (“Gogo Business Aviation“, “us” or “we“) respect your concerns about privacy and value our relationship with you. This privacy policy (the “Privacy 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 and their respective contents at the URLs: business.gogoair.com, and my.gogoair.com(collectively, the “Sites”), and through the Gogo Biz, SwiftBroadband and Iridium services (collectively with the Sites, the “Services”), whether accessed via computer, mobile device or other technology.

 

Please read this Privacy Policy carefully, because by using the Services, you are acknowledging that you understand and agree to the terms of this Privacy Policy. In addition, please review our Terms of Use Agreement, which governs your use of the Services and any content you submit to the Sites.

 

Information Collected On Our Sites

 

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 (such as your name, email address, username and password for your Account (collectively, “Personal Information”)).

 

Information Collected by Automated Means

Whenever you use the Services, Gogo Business Aviation, as well as our 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, in part, browser type, operating system, the page served, the time, and the preceding page views. This statistical data provides us with information about the use of the Sites. We may also collect technical information about use of the Services, including, in part, orders, equipment installs, inventory, historical data usage in flight, and invoicing information. Our customers and dealers may access this technical information, if authorized. Usage Information is generally nonidentifying, but if Gogo Business Aviation associates it with you as a specific and identifiable person, Gogo Business Aviation treats it as Personal Information. We may collect Usage Information that is generated or captured during your 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.

 

In connection with our voice services, we may collect call detail records (“CDR”), which may include information about the numbers you call, when you call them, 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 particular services you use.

 

Device Identifiers

In the course of collecting Usage Information, Gogo Business Aviation 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 web site 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 and understand from what regions of the world the visitors to the Sites come. We also may use this information to enhance the Sites and we may associate your Device Identifier with your Personal Information. The technologies used on the Sites 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. 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). 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. Cookies may enhance your online experience by saving your preferences while you are visiting a particular Site.

 

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, which lets you choose whether or not to accept it; (ii) to disable existing cookies; or (iii) to set your browser to automatically reject any cookies. However, please be aware that if you disable or reject cookies, some features and services on our Sites may not work properly because we may not be able to recognize and associate you with your Gogo Business Aviation 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.

 

How We Use the Information Collected

We use information we collect about and from you for a variety of business purposes, including, for example, to: provide the Services to you, respond to requests that you make, improve the Services, and to better tailor the content, advertisements, offers,] 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 transcripts of your e-mail conversations with our customer service agents 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 Service-related communications, for which you may opt out if you terminate your Account.

 

Information We Share

Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent, or share your Personal Information, CDR, or CPNI with third parties, unless you authorize us to do so. We may share Usage Information or Device Identifiers with the owners of the aircrafts on which the Services are available. We may also share non-Personal Information, such as aggregate user statistics, demographic information, and Usage Information with third parties. We may share your information as disclosed at the time you provide your information, as set forth in this Privacy Policy and in the following circumstances:

 

Third Parties Providing Services On Our Behalf. In order to provide the Services, carry out your requests, to make various features, services and materials available to you through the Sites, and to respond to your inquiries, we may share your Personal Information or Usage Information with third parties that perform functions on our behalf (or on behalf of our partners), such as companies or individuals that: host or operate our Sites; analyze data; provide customer service; manage payments; advertisers; sponsors or other third parties that participate in or administer our promotions or provide marketing or promotional assistance.

 

Your Agreement To Have Your Personal Information Shared. From time to time, we may offer you 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 while you use the Services. 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.

 

Business Transfers. 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 Policy. If our company or our assets related to this Privacy 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 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) to protect or defend the rights, property, or safety of Gogo Business Aviation, you, other users, or third parties (especially in emergency situations).

 

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 Notice.

 

Information We Receive from Third Parties

 

Gogo Business Aviation 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 Business Aviation, that website will forward to us your email address and other information about you so that we may contact you as requested. From time to time, 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 web site) 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 web site or interactive service.

 

From time to time, we may also supplement the information we collect about you through the Sites 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. We may combine the information we receive from these third parties with information we collect through the Sites. If this is the case, we will apply this Privacy Policy to any Personal Information received, unless we have disclosed otherwise.

 

Your Access and Choices

 

We offer you choices regarding the collection, use, and sharing of your Personal Information. If 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 “optout” by following the unsubscribe instructions provided in the promotional email you receive or by contacting us directly at bacustomerservice@gogoair.com. Gogo Business Aviation will not charge for this service, and your opt-out request will be processed within 30 days of the date on which we receive it. Despite 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 Policy.

 

If you wish to verify, correct or update 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. 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.

 

How We Protect Personal Information

 

The connection through which you access the Services is an SSL-encrypted link. However, if you have VPN, Gogo Business Aviation recommends that you use that channel for greater security. SSLencrypted 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. 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 Business Aviation 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 firewall and other protection against malware. Gogo Business Aviation recommends that sensitive or private information should not be accessed via or transmitted over an un-encrypted connection. Please be aware that 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 you transmit to us, and you use the Services and provide us with your information at your own risk.

 

Consent to Processing and Transfer of Information

 

By using the Services, you agree to the terms of this Privacy Policy and you expressly consent to the processing of your Personal Information according to this Privacy Policy.

 

If you are a User who resides outside the United States, please be aware that information we collect may 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 territories 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.

 

Children

 

The Services are not directed at Users who are under the age of 13, and we do not intentionally gather Personal Information such about Users. 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.

 

Updates to Our Privacy Policy

 

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

 

How to Contact Us

 

This Privacy 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 Policy on the Sites. However, we will use your Personal Information in a manner consistent with the Privacy 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 Policy and indicate at the top of the notice when it was most recently updated.

 

Modified 9/1/2014