GOGO BUSINESS AVIATION BROADBAND™ NETWORK SERVICES
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.
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.
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:
|Type of Cookies
||Purpose of Use
||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 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.
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 email@example.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
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.
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 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
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.
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
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.
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.
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