AIRBLE AVIATION INC.
Effective Date: [January 1, 2023]
OUR COMMITMENT TO PRIVACY
At Airble Aviation Inc. (“Airble”, “we” or “us”, which reference includes our subsidiaries and affiliates), we respect the privacy of our customers, their guests and any other person (collectively, “you”) who uses our mobile, tablet and other smart device applications and application program interfaces (collectively, our “Platform”). We are committed to protecting security, confidentiality and privacy of all personal information that is provided to us.
SCOPE OF POLICY
This Policy applies to our collection, use and disclosure of your personal information. However, this Policy does not impose any limits on the collection, use or disclosure of business contact information or certain publicly available information and applies only to information relating to individuals and therefore does not apply to companies, partnerships, trusts, associations and other commercial or corporate entities. This Policy is subject to the provisions of applicable privacy laws and does not replace or over-ride those laws.
We may make changes to this Policy from time to time to reflect changes in our legal or contractual obligations, or in the manner in which we deal with your personal information. These changes will be incorporated into a revised Policy. A link to any revised Policy will be available on our Platform, and may also be accessed on our website at https://airble.com/legal/privacy. It is your responsibility to check the Policy as linked or on our website to review changes to this Policy.
If you are a resident of the United States, the provisions of this Policy will be subject to the applicable laws and regulations concerning privacy in your jurisdiction of residence. This Policy does not attempt to set forth the detailed privacy laws of applicable US jurisdictions and therefore we recommend that you consult with your own legal advisors if you wish to better understand the particular federal, state or local US privacy laws that may be of application and to which this Policy will be subject.
We have designated a Privacy Officer who is responsible for our compliance with this Policy. The contact information for our Privacy Officer is as follows:
Airble Aviation Inc.
303-5360 Airport Rd South
Richmond, BC, V7B 1B4, Canada
Attn: Privacy Officer
Tel: +1.604.279.8999 Ext. 104302
E-mail: [email protected]
For the purpose of this Policy, “personal information” is any information that, by itself or in combination with other information, is reasonably capable of being linked to a specific individual or household (other than the person's business title or business contact information used or disclosed for the purpose of business communications). Personal information does not include anonymous or non-personal information (i.e., information that cannot be associated with or tracked to a specific individual).
COLLECTION OF INFORMATION
We may collect some or all of the following information from you directly TO THE EXTENT REQUIRED BY US, THE APPLICABLE AIR CARRIER (“Carrier”) AND/OR BY LAW to enable you to use our Platform; create, maintain and operate an account on the Platform; or make a booking with the Carrier through our Platform:
your name, age and gender;
your home address, home and mobile telephone numbers and personal e-mail addresses;
payment or banking information (including related payment verification information);
biographical information, such as household data, preferences, and demographic information;
if required of us by the Carrier in order to confirm a booking with it, citizenship and residency status and/or details of your identification and travel documents, such as driver's licenses, passports, visas and so forth;
information about how you interact with the services available on the Platform, including information regarding your selections of products and services offered on our platform, access dates and times, pages viewed, and so forth;
information about the devices you use to access our Platform and services; and
any other personal information you choose to provide to us, including your feedback.
Airble may also collect personal information about you from our Carriers and their associated and affiliated entities as well as regulatory agencies and governmental authorities, to the extent permitted under applicable laws and for the purposes stated in this Policy.
In addition to the foregoing, Carriers may require you to submit certain other personal information in relation to the services you wish to purchase, such as your height, weight and details of any medical or physical conditions, subject to applicable laws and regulations. Such information may be required by the Carrier in order to ensure your health, safety and comfort, and to determine your eligibility to participate in certain activities such as sky-diving or hot air ballooning. Although such information may be submitted through our Platform while making a booking, such information is collected by Carriers and Airble is not responsible for storing or managing such personal information, nor is Airble responsible for compliance by Carriers with applicable laws and regulations.
Airble will not collect any biometric information from you. However, a Carrier, or a third party including a government agency, an airport operator or a security agency (such as the Canadian Air Transport Security Authority or the Transportation Safety Administration) may collect biometric information from Users in relation to or in the course of the services you purchase. Any such collection will be subject to applicable laws and regulations and the policies and procedures of such Carrier or third party.
INFORMATION RELATED TO PLATFORM USE
At any time that you visit or use our Platform, we or our vendors and suppliers may gather certain non-personally identifiable information regarding your use of our Platform. Subject to applicable laws and regulations, such information may include the type and version of your browser; the operating system, hardware version, device settings, file and software names and types, battery and signal strength, and device identifiers of the device you use to access the Platform; device location, including specific geographic locations, such as through GPS, GLONASS, Bluetooth, or wireless or WiFi signals; your service provider, your IP address, pages visited and requests made, and day and time of connection and any search engine you may have used to locate our site.
The information is collected on an aggregated basis for statistical purposes only and at no time is your identity revealed. We use this information to help diagnose problems with our server, administer the Platform, and compile broad statistical data. In addition, we gather certain navigational information about where you go on our Platform to help us continually improve the user experience and tailor our Platform to the needs of our users. The amount of information that is sent by your web browser or by third-party vendors depends on the browser and settings you use, including your cookie settings.
To help us ensure that our Platform contains content that is useful to our customers and potential customers, we may use certain tools on our website that allow us to review anonymous data regarding the gender, age and interests of Platform users and customize the Platform to better reflect our users needs. This information is not collected in a personally-identifiable format and we cannot identify what information is about you.
The Platform can be accessed on a mobile device such as a tablet or a smartphone by way of the Airble App or a version of the Airble website that is optimized for use browsing on mobile devices. You can enable location services on your mobile device to use the Airble App and the mobile version of the Airble website to determine availability of air and tour services near your location. You can also enable push notifications on your mobile device to allow Airble to send you push notifications related to your inquiries, bookings and reservations. You can also allow the Platform to access to your location data or contact details in order to provide services you request. Information about how to change settings and manage the sharing of data can be found in the user manual of your mobile device.
You may opt out of cross device tracking through the privacy settings on your account or on the Airble App, or by changing the cookie settings in your browser.
Some cookies allow us to make it easier for you to navigate our Platform, while others are used to enable a faster log-in process, support the security and performance of the Platform, or allow us to track activity and usage, understand how users interact with the Platform, identify and resolve bugs and errors, optimize performance, and securely operate the Platform.
Some of these cookies may be operated by third party companies who may collect device and usage data through the Platform in order to provide us with reports and metrics that help us to evaluate and improve performance and user experiences.
THIRD-PARTY CONTENT (e.g., social media links): Some of the content on our Platform may include links or applications made available by third parties, which could include social media buttons or links that allow you to access third party content or websites or share content or links to our Platform through the relevant third-party applications. These third-party applications themselves may facilitate the collection of personal information by those third parties, through your interaction with the applications. We are not responsible for, and do not accept any liability in relation to the technical operation of these applications or the collection and use practices of the relevant third parties. Please visit the relevant third-party websites to understand their privacy practices and the options they may make available to you in relation to their collection of your personal information.
DISCLOSURE OF PERSONAL INFORMATION
We may disclose your personal information to the Carriers and their associated and affiliated entities in order to enable the Carrier to carry out the air services and carry out or cause to be carried out any related tour operated services, communicate with you as required, for payment purposes or for legal reasons, as well as to our Agents (see below) and insurers and our other business partners, affiliates and vendors and suppliers, relevant governmental agencies and statutory authorities, law enforcement agencies or other persons where disclosure is authorized by law. While Airble, by contract or otherwise, will use reasonable efforts to restrict the purpose of use of your personal information by Carriers and Agents, to the extent Airble shares your personal information with Carriers, Agents and other third parties as set forth in this Policy, it cannot control nor is it responsible for the use of that personal information by the Carriers, Agents and any such third parties.
We collect and use your personal information for the following purposes:
to authenticate your identity;
to protect and ensure the confidentiality of your account information and to safeguard our business interests;
for administering and monitoring compliance with contracts for the sale and purchase of services through our Platform and maintaining accurate customer records;
to process payments and collect debts owed to us or to any Carrier, subject to applicable laws and regulations;
to communicate with you regarding your inquiries and bookings and for customer notifications regarding your bookings and account information;
for customer support, including directing your questions to the appropriate contact and investigating and addressing your concerns;
to establish, develop and maintain our relationship with you by personalizing your interaction with us and our Platform, remembering your interests and preferences and providing you with a customized shopping experience, tailoring our marketing efforts to your needs and preferences and providing you with information and offers for other products and services, including those offered by or through Carriers or third parties, that may be of interest to you;
to improve our products, services and Platform, including by seeking feedback from you in the form of customer surveys and market research studies;
to communicate with you regarding our products, services, promotions, offers, incentives and marketing initiatives;
to better understand how users access and use our website, in order to improve our website and to respond to user preferences;
at your request, to share your booking information with other potential users identified by you;
to comply with legal and regulatory requirements;
to share with applicable Carriers and third parties, such as payment processors, in respect of your bookings, the services provided to you and your payments to us and/or to the Carriers;
to share information with our affiliates and subsidiaries (if applicable) as required to enable them to carry out their obligations concerning your bookings; and
to perform internal operations necessary to provide our services, to monitor and analyze use and activity trends and for testing, research, analysis and product development.
We also use your personal information to endeavor to protect you, us and our Carriers and their associated and affiliated entities from fraud and error and to safeguard our business interests, to collect debts owed to us and to comply with our contractual and legal duties and obligations.
The above collections, uses and disclosures are a necessary part of your relationship with us. By providing such personal information to us, you consent to us using and disclosing that information for those purposes.
We may also collect, use and disclose your personal information to offer additional or alternate products and services to you, and we may add your personal information to customer lists for this purpose. You may instruct us to refrain from using or sharing your personal information in this way by providing written notification to our Privacy Officer. We will not refuse you access to any product or service merely because you have instructed us to stop using your personal information in this manner.
When collected personal information is to be used for a purpose not previously identified, we will identify the new purpose to you and obtain your consent prior to using your personal information for such new purpose, unless such use is authorized or required by law.
We may use aggregated, non-identifiable information about our customers for promotional, advertising, research and other commercial purposes, and we may use, license and sell such aggregated data as we see fit. We will not sell your personal information to third parties.
We may transfer your personal information across national borders to fulfil any of the above purposes (including, for example, for air services that include flights outside of Canada) and to comply with applicable local laws. You may contact our Privacy Officer to obtain information about our policies and practices regarding our transfer of personal information outside of Canada, or to ask questions about the collection, use, disclosure or storage of personal information by us or our service providers.
Subject to the terms of this Policy concerning our allowable collection, use and disclosure of personal information, we will obtain your consent to collect, use or disclose personal information except where we are authorized or required by law to do so without consent. For example, we may collect, use or disclose personal information without your knowledge or consent where:
the information is publicly available, as defined by statute or regulation;
we are obtaining legal advice;
we reasonably expect that obtaining consent would compromise an investigation or proceeding; or
where we are required to do so pursuant to applicable laws and regulations, a court order, valid subpoena or other legally binding directive.
Your consent can be express, implied or given through an authorized representative. Consent may be provided orally, in writing, electronically, through inaction (such as when you fail to notify us that you do not wish your personal information collected/used/disclosed for various purposes after you have received notice of those purposes) or otherwise.
You may withdraw consent at any time, subject to legal, contractual and other restrictions, provided that you give reasonable notice of withdrawal of consent to us. If you withdraw your consent by notifying us in writing, we will inform you of the likely consequences of the withdrawal of consent, which may include our inability to provide certain services in respect of which that information is necessary.
As used in this Policy, an “authorized representative” of a User is an individual who has been expressly authorized in writing by the User to represent or act for the User and a copy of such authorization has been provided to Airble. Notwithstanding the foregoing, (i) if a User is a corporation or a body corporate, each of its officers and directors, and (ii) if a User is a partnership, each of its partners (or in case of a limited partnership, its general partner), is deemed to be an authorized representative of such User without any requirement for a written authorization.
The Platform is not directed at, marketed to, nor intended for, individuals under 18 years of age. No one under the age of 18 is permitted to provide any information on or through the Platform. If you are under 18 years of age, DO NOT: use or provide any information on or through the Platform; use any of the Platform's features; use any interactive or public commenting feature on the Platform; and/or provide any information about yourself to Airble. Airble does not and will not knowingly collect any information, including personal information, from any person under 18 years of age and Airble will take prompt steps to delete any such information if it is inadvertently received. If Airble learns that it has received personal information from any person under 18 years of age, Airble will delete that information. If you believe a minor may have uploaded or posted information through the Platform without authorization, and such information is publicly available, or if you believe Airble might otherwise have information from or about any person under 18 years of age, please contact our Privacy Officer.
RETENTION AND DESTRUCTION PERSONAL INFORMATION
We will only retain your personal information to fulfil the purposes for which it was collected and for complying with any legal, tax, accounting, or reporting requirements. We will cease to retain your personal information, or anonymize your personal information such that it can no longer identify you, when we reasonably determine that such personal information or its further processing is no longer required to for the purpose for which it was collected. We will retain registration, account profile, transactions, purchases and payment information submitted by or collected from a User for as long as a User maintains an account on the Platform. Users may request deletion of their account at any time through the profile settings in the Platform or by contacting Airble's Privacy Officer. Upon receipt of such request, we will delete the User's account data other than any personal information that is required to be retained for complying with our legal, tax, accounting, reporting, insurance, litigation, or other regulatory requirements. Such information will be retained for a maximum period of 7 years or such longer period required under applicable laws and regulations. In certain circumstances, we may be unable to delete a User's account (for example, if there is an outstanding credit on the account or due to an unresolved dispute). Upon resolution of the issue, we will delete the account as described above.
We will take due care when destroying personal information so as to prevent unauthorized access to the information.
THIRD PARTY SERVICE PROVIDERS
We may retain agents, subcontractors, vendors or suppliers (each, and “Agent”) from time to time in relation to our business. If we require an Agent or other third party to deal with your personal information, we will notify the Agent or third party of the terms of this Policy and require it to adhere to the Policy and to comply with all applicable privacy laws concerning your personal information. We will not provide to an Agent or third party any more of your personal information of which we have knowledge than is reasonably necessary and we will use all reasonable commercial efforts to cause such information to be returned to us or destroyed by the Agent or other third party once the purpose for which it was given is completed.
We will make reasonable commercial efforts to ensure that personal information we are using or disclosing is accurate and complete. If you believe that a record of your personal information is inaccurate or incomplete, you may request in writing that we correct the record. If we refuse to make the requested change, we will give you written reasons for that decision and will explain your further options. If appropriate, we will send the amended information to third parties to whom the information has been disclosed.
When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, we will annotate the personal information under our control with a note that the correction was requested but not made.
SAFEGUARDING PERSONAL INFORMATION
We use industry standard administrative, technical, and physical data security measures to protect the personal information in our custody or control against unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. We will require, through contractual or other reasonable means, a comparable level of personal information protection be implemented by our Agents and the Carriers.
Confidentiality and security are not assured when information is transmitted through e-mail or other wireless communication. We will not be responsible for any loss or damage suffered as a result of a breach of security and/or confidentiality when you transmit information to us by e-mail or other wireless communication or when we or you transmit such information to our Agents and Carriers. Please notify our Privacy Officer in writing if you do not want Airble to communicate with you through these means.
You have a right to access your personal information held by us. If you request access, then after we authenticate your identity, we will provide you with your personal information under our control (unless prohibited by applicable law). We will also give you information about how that information is being used and a description of the organizations to whom that information has been disclosed. We may charge you a reasonable fee for doing so. We will make a reasonable effort to make the information available within 30 days of receiving a written request or provide written notice where additional time is required to fulfil the request.
In some situations, we may not be able to provide access to certain personal information (e.g., if disclosure would reveal personal information about another individual, the personal information is protected by solicitor/client or attorney/client privilege, the information was collected for the purposes of an investigation or where disclosure of the information would reveal confidential commercial information that could harm the competitive position of Airble). We may also be prevented by law from providing access to certain personal information.
Where an access request is refused, we will notify you in writing, document the reasons for refusal and outline further steps that may be available to you.
We will, on request, provide information regarding our complaints procedure. Any inquiries, complaints or questions regarding this Policy should be directed in writing to Airble's Privacy Officer at the postal address or e-mail address included on page 1 of this Policy.