Last Updated: May 17, 2021
Avelo Airlines (“Avelo,” “we,” “us,” or “our”) and its service providers may collect or receive the types of information described below in connection with your access to and use of our Site.
Categories of Personal Information We Collect
We may collect the following categories of Personal Information, which is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information” or “Personal Data”):
- Identifiers: Identifiers such as: a real name, alias, postal address, email address, or other similar identifiers.
- Customer Records: Any of the following types of information: bank account number, credit card number, debit card number, signature, telephone number, and any other financial information.
- Commercial Information: Commercial information, including records of Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Technical Identifiers: Cookies and online identifier (discussed in further detail below), device identifiers, and internet protocol address (“IP Address”).
- Internet Activity. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
- Geolocation Data. Information which can be used to identify your location.
- Inferences. Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- Job Applicant Data. Information regarding your employment and education history, transcript, writing samples, and references as necessary to consider your job application for open positions.
This Policy does not apply to any Personal Information that is publicly available.
Categories of Sources of Personal Information We Collect and How We Collect It
We may collect all categories of Personal Information listed above from the following categories of sources:
- Information that you voluntarily provide to us, for example, your contact information and payment information.
- Information that we collect through your use of our Site and App, for example, account activity, data collected by the servers used to operate our Site and App (e.g., IP addresses), data collected by cookies, and data collected by analytics and advertising services.
Information That You Voluntarily Provide to Us
Account Information. To create an online account, you will need to submit your name and email address and you may be required to select and answer security questions.
Order & Payment Information. Purchases of Services using our Site and App must be made by credit or debit card. All credit and debit card information is provided directly to our third-party payment processors. We do not directly access, handle, or store your credit or debit card information. To make a purchase on our Site or App, you will need to submit your name and your credit or debit card type, number, expiration date, security code and billing address.
If you purchase our Services or sign up or otherwise opt in to receive promotions or other communications from us, you will need to submit your email address. You may also provide your physical address. We may use this information to provide you with promotional and other electronic communications. You may opt out of receiving promotional emails from us at any time by following the unsubscribe instructions contained in the applicable email and you may opt out of receiving hard copy mailings from us by contacting us using the contact information provided below under “Contact Us.” We may use third-party email and mail providers to deliver these communications to you.
Categories of Information that We Collect Through Your Use of Our Site or App
IP Addresses, Location Data, and Related Data. When you visit or use our Site or App, we may automatically collect certain information from your device. Under certain applicable laws, a, this information may be considered Personal Information or Personal Data under applicable data protection laws. Specifically, the servers used to operate and provide the Site and App may collect data pertaining to you and the equipment, software, and communication methods you use to access the Internet and the Site, including Internet protocol (“IP”) addresses assigned to the computers and other devices from where you access the Internet, your Internet service provider (ISP), your device ID number, your approximate geographic location, your browser type, the pages you access on the Site, the websites you access before and after visiting the Site, the length of time you spend on the Site, date and time stamps, and clickstream data. Avelo may use this information to administer the Site and its servers, to generate statistical information, to monitor and analyze Site traffic and usage patterns, to serve personalized advertising, to monitor and prevent fraud, to investigate complaints and violations of our policies, and to improve the Site’s content and the Services, materials, and other content that we describe or make available through the Site. We may combine this information with other Personal Information and information obtained from third parties for the purposes discussed below. The suppliers that we use to provide the Site may collect information about your visits to the Site and other websites. Some of this information may be collected using cookies and similar tracking technologies as explained further below under “Cookies.”
- Operationally necessary. These are cookies that are required for the operation of our Site or App. For example, these cookies are required to identify irregular website behavior, prevent fraudulent activity, and improve security. They also allow users of our Site or App to make use of its functions, for example, shopping carts, saved search, and similar functions. Without these cookies, websites that you have requested cannot be provided.
- Functionality related. These cookies allow us to offer you enhanced functionality when accessing or using our Site or App. This may include remembering choices you make, remembering your username, preferences, or settings, remembering if you reacted to something on or through the Site so that you are not asked to do it again, remembering if you have used any feature of the Site or App before, restricting the number of times you are shown a particular advertisement, remembering your location, and enabling social media components. As described above, you may disable functional cookies, but if you do so then various functions of the Site or App may be unavailable to you or may not work the way you want them to.
- Performance related. These cookies assess the performance of the Site, including as part of our analytic practices to help us understand how visitors use and interact with the Site, for example, which pages on our website users visit most often. These cookies also enable us to personalize content and remember your preferences (e.g., your choice of language, country, or region). These cookies help us improve the way our websites work and provide a better, personalized user experience. Some of our performance-related cookies are managed for us by third parties.
- Advertising or targeted related. These cookies record your visits to our Site or App, the pages you have visited on our websites, and the links you have clicked. They are used to gather information about your browsing habits and remember that you have visited a particular website. Avelo and its third-party advertising platforms or networks may use this information to make our Site or App, its content, and advertisements displayed on our websites more relevant to your interests (this is sometimes called “behavioral” or “targeted” advertising and is further discussed below). These types of cookies are also used to limit the number of times you see an advertisement and to help measure the effectiveness of advertising campaigns. To find out more about interest-based ads and your choices, please visit the Digital Advertising Alliance, the Network Advertising Initiative, the Interactive Advertising Bureau (IAB) Europe, http://www.allaboutcookies.org, and http://www.youronlinechoices.com.
Advertising Networks, Personalized Advertising, Remarketing, and Retargeting. From time to time, we may use or participate in advertising networks and related advertising services that are managed and provided by third-party advertising servers, advertising agencies, technology vendors, and research firms, including, as discussed below, Google Ads. These services collect information about your visits to and interactions with the Site, App and other websites and will use that information to target advertisements for goods and services. The information collected may be associated with your Personal Information. These targeted advertisements may appear on the Site, App or on other websites. Advertising networks often gather data about consumers who view advertisements to make inferences about a consumer’s interests and preferences, which enables their computers to deliver advertisements directly targeted to the consumer’s specific interests. This practice is often referred to as “online behavioral advertising.” For example, a third-party advertising network might collect the type of Internet browser you use, the type of computer operating system you use, the domain name of a website you visit, whether or not you visit specific pages of our Site and other websites, the location of your Internet service provider, the date and time of a visit to a website, and other interactions between you and a website.
We use Google Ads, an online advertising service provided by Google, to serve ads on our behalf across the Internet and sometimes on our Site or App. Google uses your Internet searches, cookies, and similar identifiers (e.g., pixel tags) to collect information about your visits to the Site and your interaction with our Services to generate targeted advertisements to you on other websites that you visit across the Internet. To opt out of remarketing advertising provided through Google, to customize your ad preferences, or to limit Google’s collection or use this information, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of our Site or App.
To change your preferences with respect to certain online ads and to obtain more information about third-party ad networks and online behavioral advertising, please visit the National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Please remember that changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads from time to time.
Social Media. The Site or App may allow you to connect to and share information with various social media platforms, for example, Facebook. These features may require us to implement cookies, plug-ins, and application protocol interfaces (APIs) provided by those social media platforms to facilitate those communications and features. We may share information that you provide us or that we may collect about your use of the Site or App with those platforms and that information will be subject to their privacy policies. We encourage you to review those platforms’ privacy policies: see Facebook’s Data Policy. In addition, by choosing to use any third-party social media platform or choosing to share content or communications with any social media platform, you allow us to share information with the designated social media platform. We cannot control any policies or terms of such third-party platform. As a result, we cannot be responsible for any use of your information or content by a third-party platform, which you use at your own risk.
The Site or App may also use the advertising services and networks offered by those social media platforms to deliver advertising content. Use of these services requires social media platforms to implement cookies or pixel tags to deliver ads to you while you are logged into the platform.
If you do not wish a social media platform to collect information relating to you via the Site or App, we suggest that you: (a) hide social media platform plug-ins using an ad blocker; (b) always log off completely from the social media platform before visiting other websites and delete all related cookies; and(c) where the option is made available by the social media platform, disable the advertising services and networks operated by that platform.
Avelo is active on social media, including Facebook. You have the opportunity to comment on those social media platforms regarding us and the Services we offer. Avelo reserves the right to post on its websites and social media pages any comments or content that you post on our social media pages.
Purpose for Collecting Personal Information
How We Use and Share Personal Information
Purpose Collected. We will use and share your Personal Information for the purpose for which it was collected, for example, to process your purchase of air transportation and services, in connection with your account and payment, and to provide you with information and communications that you request. If you purchase Services through our Site or App, we will use Personal Information to communicate with you regarding your order. In accordance with your preferences, your location information will be used to add location information to your account, if applicable, and to understand where our users are located. If you contact us for support or assistance in using the Site, we may use Personal Information to determine whether or not your system meets the minimum requirements needed to access and use the Site and otherwise to contact you regarding your request.
Sharing Personal Information with Other Third Parties. We do not rent, license, or sell Personal Information to any third parties.
Aggregate Data. We may aggregate Personal Information to create aggregate data on Site and App users, which describes users as a group but does not reveal the identity of individual users. We may use aggregate data to understand users’ needs, to determine user demographics and usage patterns, to determine what kinds of Services we can provide, and to improve and enrich our Services and our Site and App.
Evaluation and Improvement of the Site and App. We may use Personal Information: to analyze, develop, and improve the content, materials and Services that we make available through our Site and App and their functionality; to inform marketing and communication plans and strategies; to evaluate user needs and customize content, promotional emails, and your browsing experience; and for other legitimate and lawful business purposes.
To Protect Avelo and Others. We may share your Personal Information with law enforcement, regulatory authorities, courts with competent jurisdictions, emergency services, and other necessary third parties for legal, protection, security, and safety purposes, including: (a) to comply with laws or regulatory requirements and to respond to lawful requests and legal process; (b) to report or collect debts owed; (c) to protect the rights and property of Avelo, its agents and customers, and others, including to enforce our agreements, policies, and terms and to protect our network and physical assets; and (d) to protect the safety of our crewmembers, agents, customers and any other person.
Business Transactions. We may choose to buy or sell assets from time to time. We may share Personal Information in connection with the evaluation of those transactions. We may transfer Personal Information if we enter into those transactions. Also, if we (or our assets) are acquired or if we go out of business, enter bankruptcy, or go through some other change of control or reorganization, Personal Information and aggregate data could be one of the assets transferred to or acquired by a third party.
TSA Secure Flight Screening
The Transportation Security Administration (“TSA”) requires us to request, and you to provide, your full name, date of birth, and gender for the purpose of watch list screening, under the authority of 49 U.S.C. section 114, the Intelligence Reform and Terrorism Prevention Act of 2004 and 49 C.F.R parts 1540 and 1560. You may also provide your redress number, if available. Failure to provide your full name, date of birth, and gender may result in denial of transport or denial of authority to enter the boarding area. TSA may share information you provide with law enforcement or intelligence agencies or others under its published system of records notice. For more on TSA privacy policies, or to review the system of records notice and the privacy impact assessment, please see the TSA website at www.tsa.gov.
International Transfers of Your Personal Information
Avelo does not guarantee that loss, misuse, or alteration of Personal Information will not occur, but we have a variety of technical and organizational security measures in place to help protect against the loss, misuse, and alteration of Personal Information under our control. Specifically, on our shopping cart and payment pages, Secure Socket Layers technology is used to encrypt information passed between your browser and our systems. While we are focused on the security of your Personal Information and follow strict standards, processes and procedures that are designed to protect your Personal Information, you must remember that the Internet is a global communications vehicle open to threats, viruses and intrusions from others and so we cannot promise, and you should not expect, that we will be able to protect your personal information at all times and in all circumstances.
How Long We Retain Your Personal Information
For Personal Information that we process on behalf of our customers, we will retain that Personal Information in accordance with the terms of our agreement with them, subject to applicable law.
Opt-Out of Marketing Communications.
You may opt out of marketing communications we send you at any time by clicking on the “unsubscribe” or “opt out” link in the marketing e-mails we send you. To opt out of other forms of marketing, such as postal marketing or telemarketing, if applicable, then please contact us using the contact information provided below under “Contact Us.”
Categories of Personal Information Disclosed for a Business Purpose
In the last 12 months we shared the following categories of Personal Information for our Business Purposes: Identifiers, Customer Records, Commercial Information, Internet Activity, Geolocation Data and Inferences. See the section above titled “Categories of Personal Information We Collect” for more detail on the type of Personal Information in each category. A “Business Purpose” means the use of Personal Information for use of Avelo or its service provider’s operational purposes. Examples include auditing related to a current interaction with the consumer and concurrent transactions, protecting/detecting security incidents, and performing services including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
Access by Children
The Site and App are not directed at children under 13 years of age. Other than information required to complete a booking, Avelo does not knowingly collect or use information from children under 13 through the Site or App. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us at email@example.com and we will use commercially reasonable efforts to delete that information.
Limitation of Liability
Notice to Certain U.S. State Residents
Certain U.S. states may provide for additional disclosure to and/or rights for their residents under state-specific privacy laws, which may not apply to you or only apply in certain circumstances. To the extent such laws apply, Avelo will comply with applicable law.
We currently do not honor “do not track” requests.