Privacy Policy

Privacy Policy

GOGO BUSINESS AVIATION BROADBAND™ NETWORK SERVICES

Gogo Business Aviation Business Aviation Services LLC and its subsidiaries, Affiliates (as defined below), web site developers and other promotional partners (“Gogo Business Aviation", “us” or “we") respect concerns about privacy and value our relationship with our customers, aircraft owners, and aircraft operators. This privacy policy (the “Privacy Policy") is intended to inform our customers and those using their services about 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”), the Gogo Dash mobile application (“App”), through the Gogo Biz, SwiftBroadband and Iridium services, and any other websites, apps or online services that link to this policy (collectively with the Sites and the App, the “Services”), whether accessed via computer, mobile device or other technology.

Please read this Privacy Policy carefully, because by using the Services, users are acknowledging that they understand and agree to the terms of this Privacy Policy. In addition, please review our Terms of Use Agreement, which governs use of the Services by aircraft owners, aircraft operators and other users and any content submitted to the Sites.

 

Information Collected Through Our Services

Users who reside outside of the United States should note that their information may be transferred to, stored, and processed in the United States.  In certain circumstances, foreign courts, law enforcement agencies or regulatory agencies may be entitled to access personal information without notice.  By submitting Personal Information (as defined below), users agree to this transfer, storing or processing 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 a user resides and/or is a citizen. 

 

Personal Information Provided to Us

Aircraft owners and operators will, when signing up for Services, and users may, by using the Services, be required to provide information that could reasonably be used to contact them, or to identify them personally, or that otherwise relates to them as an individual (such as a user’s name, email address, or username and password for an Account (collectively, “Personal Information”)). Note that as described below, we also collect certain information that is not Personal Information when our Sites and Services are used on an aircraft owner or operator’s flight.

Please note that this Privacy Policy does not exempt you from any obligations you may incur should you collect individuals’ Personal Information or Usage Data (as defined below), including for example as part of your use of the App.
 

Information Collected by Automated Means

Whenever users utilize the Services, Gogo Business Aviation, as well as our service providers, may use a variety of technologies that automatically or passively collect information about the Services, users’ interactions with the Services and the aircraft on which the Services are provided (“Usage Information”). Usage Information may include, among other things: (i) computer or device-related information such as browser type, operating system, the page served and the time; (ii) Site-related information such as the pages users visit, how long they stay on each page and preceding page views (iii) content-related information such as the type of content being transmitted (e.g., video content); and (iv) flight-related information such as origin and destination information, aircraft location, including altitude, longitude and latitude information, and speed (“Flight Information).  We may also collect technical information about use of the Services, including, among other things, orders, equipment installs, inventory, historical data usage in flight, and invoicing information. Usage Information collected from the Sites helps up to keep the Sites fresh and interesting to our visitors and to tailor content to a visitor’s interests.  Usage Information does not generally identify specific individuals, but if Gogo Business Aviation associates it with a specific and identifiable person, Gogo Business Aviation treats it as Personal Information. We may collect Usage Information that is generated or captured during interactions with the Services or Gogo Business Aviation that may be viewed by customers, dealers, or OEMS, including, but not limited to, information about Gogo Business Aviation equipment installed on aircrafts, order information and online ordering tools, flight characterization, information currently contained in CCDS, online RMA, quality management tools and technical references.


Call Detail Records and Customer Proprietary Network Information

In connection with our voice services, we may collect call detail records (“CDR”), which may include information about numbers called, when they are called, and the length of those calls. We may also collect Customer Proprietary Network Information (“CPNI”), which includes the time, date, duration and destination number of each call, as well as the particular services used on an aircraft owner or operator’s aircraft.
 

Device Identifiers

In the course of collecting Usage Information, Gogo Business Aviation also automatically collects users’ IP address, MAC Address or other unique identifiers (“Device Identifier”) for the computer, mobile device, Wi-Fi card, technology or other device (collectively, “Device”) used to access the Services. A Device Identifier is a number that is automatically assigned to a Device when it is used to access a web site or its servers, and our computers identify the Device by its Device Identifier. When users use the App or visit the Sites, for example, we may view Device Identifiers. Users of certain Services may also be able to view Device Identifiers of others connected to the same network.  We use this information to provide the Services, collect Flight Information, and to enhance the Services, and we may associate Device Identifiers with 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 Devices or user Accounts. We may use both session Cookies (which expire once a user closes his or her web browser) and persistent Cookies (which stay on a computer until deleted). 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 users are recognized when moving from page to page within the Sites and that any information they have entered is remembered. Users can choose not to accept session Cookies by changing the settings in their browser. Session Cookies expire once a user closes his or her web browser.
Persistent Cookies Persistent Cookies help the Sites remember user’ information and settings when they visit them in the future. This results in faster and more convenient access.
Features of the Service made possible by persistent Cookies include: authentication, language selection, theme selection, menu preferences, internal site bookmarks or favorites, among others. Cookies may enhance the online experience by saving preferences while users are visiting a particular Site.
Persistent Cookies also allow us to select which of our advertisements or offers are most likely to appeal to a user and display them while that user is using the Services.

We currently use a third party ad network to serve Cookies.
Eternal, unless deleted by the user.

If a user would prefer not to accept cookies, most browsers will allow him or her to: (i) change browser settings to notify the user when he or she receives a cookie, which lets them choose whether or not to accept it; (ii) to disable existing cookies; or (iii) to set the browser to automatically reject any cookies.

Start with these sites to learn more about browser privacy controls:

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

Users can also learn more about Cookies by visiting www.allaboutcookies.org, which includes additional useful information on Cookies and how to block Cookies using different types of browsers.  For more information on advertising using Cookies and how to opt-out of advertising Cookies specifically, please see Advertising; How To Opt-out below.

Please be aware that if cookies are disabled or rejected, some features and Services may not work properly because we may not be able to recognize and associate them with a user’s Gogo Business Aviation Account.

 

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 users, which we will use to collect information regarding users’ interaction with such content and ads. A web beacon is a transparent graphic image placed on a web page or in an email, which indicates that a page or email has been viewed or that an email has been forwarded. In addition, a web beacon allows 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 third parties. A web beacon may also tell the browser to get content from another server.
 


Network Information for App

When a user uses the App, we may automatically collect other network information, including but not limited to network or service availability, networks viewed or searched for, other devices connected to a network, app response times, download errors, length of visits to certain pages, app interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the App.

How We Use the Information Collected

We use information we collect about and from aircraft owners and operators and users for a variety of business purposes, including, for example, to: provide the Services, respond to requests that users make, improve the Services and offer additional services, and to better tailor content, advertisements, offers and the features, performance, and support of the Services; and for purposes disclosed at the time a user or aircraft owner or operator provides Personal Information or otherwise with the user’s consent or the aircraft owner or operator’s consent. We may use transcripts of user e-mail conversations with our customer service agents for support, training, and improvements to our Services. If a user provides feedback to us, we may use and disclose such feedback for any purpose, provided we do not associate such feedback with the user’s Personal Information.

We may use Personal Information to send electronic newsletters or promotional emails, unless or aircraft operator or owner has requested not to receive such promotional communications from us or doing so would be prohibited by applicable law. Users and aircraft owners or operators can opt-out of receiving further promotional messages from us by following the unsubscribe instructions provided in the promotional email they receive or by contacting us directly at bacustomerservice@gogoair.com. We may use Personal Information to send Service-related communications, for which aircraft owners or operators, and users may opt-out if they terminate their Account.

To the extent that certain information that we collect in providing the Services constitutes CPNI, Gogo Business Aviation complies with applicable law governing CPNI.

 

Information We Share

Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent, or share Personal Information, CDR, or CPNI with third parties, unless the aircraft owner or operator, authorizes us to do so. We may share Usage Information or Device Identifiers with the owners or operators of the aircrafts on which the Services are available. We may also share non-Personal Information, such as anonymous, statistical or aggregate information (in a form that does not contain data fields that can reasonably be used to identify users) and certain Usage Information, including Flight Information, with third parties. In addition, we may share information as disclosed at or before the time the user provides the 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 requests, to make various features, services and materials available through the Services, and to respond to inquiries, we may share Personal Information or Usage Information, including Device Identifiers and Flight Information, with third parties that perform functions on our behalf (or on behalf of our partners), such as: (a) companies or individuals that: host or operate our Sites or App; analyze data; provide customer service; manage payments; (b) advertisers; and (c) sponsors or other third parties that participate in or administer our promotions or provide marketing or promotional assistance.

 

Agreement To Have Personal Information Shared. 

While using the Services, users 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 information with a third party while using the Services. If a user agrees to have his or her Personal Information shared, such Personal Information will be disclosed to the third party and 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 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.

 

Business Transfers.  

If our company or our assets related to this Privacy Policy are acquired by another company, Personal Information, and any other information that we have collected about the aircraft owners or operators or 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 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 the communications on or through the Services. We may, and you and users hereby authorize us to, disclose Personal Information and other information including user communications through the Services, if required by applicable law or by law enforcement officers acting under the color of applicable law, or if we believe in good faith that such disclosure is necessary to: (a) comply with relevant laws or to respond to subpoenas or warrants served on us; or (b) to protect or defend the rights, property, or safety of Gogo Business Aviation, you, users, or third parties (especially in emergency situations).

 

Information We Receive from Third Parties

Gogo Business Aviation may receive information about aircraft owners or operators, and users from third parties. For example, if a user is on another website and opts-in to receive information from Gogo Business Aviation, that website will forward to us the user’s email address and other information so that we may contact the user as requested. Users may also choose to participate in 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 users allow us to collect and share (or the third party to collect and share) information, including Personal Information. In addition, we may receive information about a user if other users of a third party web site give us access to their profiles and the user is one of their “connections” or information the user is otherwise accessible through his or her connections” web page, profile page, or similar page on a social networking or other third party web site or interactive service.

We may also supplement the information we collect through the Services with other information from third parties in order to enhance our ability to provide service, tailor our content, and to offer opportunities to purchase products or services that we believe may be of interest.  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 Policy to any Personal Information received, unless we have disclosed otherwise.

We may match the information we receive about users from third parties with the information we collect ourselves to enhance the experience with the Services and to select which of our advertisements or offers are most likely to appeal to a user and display them while that user is utilizing the Services.
 

Access and Choices 

We offer choices regarding the collection, use, and sharing of Personal Information. For example, if an individual  receives promotional emails from us, her or she may indicate a preference to stop receiving further promotional communications from us and will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the promotional email received or by contacting us directly at bacustomerservice@gogoair.com or by accessing our email preference page at HYPERLINK. Gogo Business Aviation does not charge for this opt-out service, and the opt-out request will be processed within 30 days of the date on which we receive it. Regardless of the indicated email preferences, we may send 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.

To verify, correct or update any of the Personal Information provided to us, edit it in the Account page or by contacting us at the above email address. Please note that unless stated otherwise, we may send any corrected or updated Personal Information to every organization to which the relevant Personal Information has been disclosed in accordance with this Privacy Policy.  In accordance with our routine record keeping, we may delete certain records that contain Personal Information submitted through the Services.  Please note that we may be required (by applicable 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 the deletion request only after we have fulfilled such requirements). Be aware that it is not always possible to completely remove or delete all information from our databases without some residual data remaining in our archives because of backups and other reasons.

 

Online Advertising; How to Opt-out

Gogo Business Aviation licenses technology to serve advertisements on its own Sites and within its content as that content is served across the Internet. In addition, Gogo Business Aviation may use 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 Devices and they may otherwise collect or have access to information about users, including Usage Information, which they may collect over time and across different websites following a users’ visit to our services.  We and our network advertisers may target advertisements for products and services in which users might be interested based on their use of the Services, visits to the Sites and other websites. We may use a variety of companies to serve advertisements.

We do not currently respond to web browser “do not track” signals or other mechanisms that provide a method to opt out of the collection of information across the networks of websites and online services in which we participate.  If we do so in the future, we will describe how we do so in this Privacy Policy.  Visit the following website, www.allaboutdnt.org, for more information on this developing area.

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

 

Links to Other Sites 

Our provision of links to other websites or locations is for convenience and does not signify our endorsement of such other websites or location or its contents.  We have no control over, do not review and cannot be responsible for these outside websites or their content.  These other websites may send their own Cookies to a 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 Policy do not apply to these outside websites.  Users 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).

 

How We Protect Personal Information

The connection through which users access many of the Services is an SSL-encrypted link. However, if a user has VPN, Gogo Business Aviation recommends using that channel for greater security. SSL-encrypted websites or pages, typically indicated by “https” in the address field and a “lock” icon, can also generally be accessed through the Gogo Business Aviation Services. Users should be aware, however, that data packets from un-encrypted Wi-Fi connections can be captured by technically advanced means when they are transmitted between a user’s Device and the Wi-Fi access point. Users should therefore take precautions to lower their security risks. Gogo Business Aviation recommends that users follow good security practices, such as ensuring that file-sharing is not enabled while accessing the Internet from an un-encrypted public network and that laptops have firewall and other protection against malware. Gogo Business Aviation recommends that sensitive or private information should not be accessed via or transmitted over an unencrypted connection. While Gogo Business Aviation takes steps to provide reasonable security for Personal Information, and employs physical, technical, and administrative safeguards to protect such information, we cannot ensure or warrant the security of any information transmitted to us, users utlilize the Services and provide us with information at their own risk.
 

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.
 

Updates to Our Privacy Policy 

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

How to Contact Us

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

Modified 7/17/2017