Privacy policy

Introduction

Welcome to Air Cahana, operated by Flyshare, Inc. (“Cahana”, "we",or "us"). This Privacy Policy is meant to help you understand how we collect, use and share information to operate, improve, develop and help protect our services. This includes how we collect and process your personal information such as when you visit our sites or use our services, when you interact with us via our call centers, customer support service including live chats and e-mail communications, social media channels, when you interact with us at airports or private or semi-private air terminals, or on board our aircraft, and when you interact with us on other online and offline services we provide (together, the "Services"). This Privacy Policy applies to our Services except where otherwise noted.

Why this matters

Please be sure to read this entire PrivacyPolicy before using or submitting information through the Services. By using orsubmitting information through the Services, you are agreeing to thecollection, transfer, manipulation, processing, storage, disclosure and otheruses of your personal data as described in this Privacy Policy and to be boundby the terms of this Privacy Policy.

What personal information we collect

The personal information that we process about you broadly falls into the following categories:

  • Information that you provide to us. We collect personal data from you when you interactwith our Services. Here is the data that we collect:

    • Demographic Data. Account Information: such as your name, address (including zip code),email, zip code, date of birth and phone number that you provide to us, for example, when you register for any Cahana Services, subscribe for Cahana marketing, or purchase a Cahana ticket.

    • Personal Records. Purchase Information: Payment information (such as your credit card number), order details, delivery information (such as shipping and delivery address) that you provide when you purchase any Cahana Services.

    • Sensitive Personal Information. Your account log-in, debit card or credit card number,and your password allowing access to your account.

    • Account Registration. User Profile Information: Any information that you provide to us in connection with your Cahana "User Profile", such as demographic data listed above, user name, and any additional information you choose to provide to enhance your use of the Services, including your weight, height, gender, general location, tags, image or avatar.

    • Contentand Context. User Generated: Any content or material you publish or post such as hashtags, photos or videos on our Services.

    • Feedback and Support. Communications Information: Any details of your communications/interactions with us, including when you call, email, live chat, video call or text with our customer or technical support teams or communicate with us via social media channels or community forums. We may record customer and technical support calls for training and monitoring purposes and to help resolve customer issues. We will tell you before recording and, where required by applicable laws, obtain your consent for the collection of these recordings. We collect and use this data based upon our business need to receive and act upon your feedback or issues.

    • Surveys. Survey and Review Information: Any information you voluntarily provide to us (or otherwise publish) in connection with a survey you complete or review / testimonial you provide about Flyshare goods and/or Services. We may collect this information to understand your opinions, better market our services and to collect relevant information about our business.

    • Promotions. Promotions: Any information that you provide to us in connection with any promotions we run.

    • Other Information. Other User Information: Any other information that you may provide to us in connection with your use of Cahana Services or other contact that you have with the Cahana team.

  • Information that we collect automatically. Some of this information may be collected using Cookies and Similar Technologies as described below.

    • Information generated through use of the Services.

    • Information from your device. Device Data: Information from and about the device you use when you use our Services (whether your desktop or mobile, including IP address, identifiers, type, mobile carrier, browser type and language, location (see below) and operating system. Usage Data: We may also collect information about how your device interacts with our Services, such as the content you access, pages and sites visited before and after you reach the Services, the date and time of your use, the amount of time spent on the Services, and other actions taken through use of the Services such as preferences.

    • Location Information. Depending on how you use the Services and your device settings,type and connectivity, we may collect location-based information including yourIP address, GPS location, city, county, zip code and region and your smartdevice’s proximity to “beacons”, Bluetooth networks and/or other proximitysystems. You will have the ability to opt-in or out of our collection of location information by selecting the location and Bluetooth settings in your device but this may affect your ability to use certain location dependent Services (such as track your run functionality).

  • Information we collect fromother sources

    • Other Applications. If you access our Services through a third party application, such as the Apple App Store or Google Play App Store (together with any similar applications, "App Stores") or Social Networking Sites("SNS") such as Instagram, Twitter or Facebook, we may collect information about you from that Third-Party application that you have made public via your privacy settings. This may include: your name, your SNS userID, your App Store user name, location, sex, birth date, email, profile picture and your contacts on the SNS.

    • Security. Security and Safety: We may collect certain information in order to protect and verify your informationand our Services. This may include Device IP, Location, and other identifiers with a third party application to ensure your safety and the security of your account.

    • Other Sources. We may receive information about you from other sources to supplement information provided by you. The supplemental information allows us to enhanceour ability to provide you with information about our business, products and Services and to provide you with any marketing communications that you have provided your consent to receive. Please see Your Rights below for how to unsubscribe.

How we use personal information

We use your information for the following purposes:

  • To provide you with the Services
  • To communicate with you
  • To send you marketing
  • For Service improvement purposes
  • For quality assurance and training purposes
  • For personalisation and advertising
  • To ensure the security and integrity of our Services
  • To comply with any applicable law and/or regulations
  • For any other lawful business purpose
  • To provide you with the Services. Cahana uses data to operate, improve, maintain and personalize our Services. We use data to:

    • Verify your identity, set upand maintain your account;

    • Process payments;

    • Maintainour services and operations.

  • To communicate with you. Supporting and communicating to you when you require it such as for:

    • Administrative matters (such as account management, updates to terms, or system maintenance);

    • To provide you with information about our Services;

    • To respond to any questions, comments or requests you have about our Services.

  • To send you marketing. Cahana uses data to market its Services, which may include:

    • Contacting you by phone, email, postal mail, push notifications, in-app messages or SMS with information about news, offers, products, promotions, events, contests and/or Services that might be of interest to you, as permitted by applicable law. This may include various usage data to send marketing communications that are personalised. Please see Your Rights below for how to unsubscribe.

  • For Service improvement purposes. Cahana works everyday to improve your experience by using data:

    • Including monitoring and measuring your use of our Services, to understand how they are being used and how they can be improved;

    • Financial analysis and analytics to understand billing, pricing and other financial matters that can be improved.

  • For quality assurance and training purposes. Cahana puts customers first and we use data to further that value by:

    • Monitoring communications and interactions with you to ensure the quality of our customer and technical support services, appropriate training of our people and to resolve your complaints. We will provide notice and consent options for monitoring of communications as required by applicable law.

  • For personalization and advertising. Cahana uses data for personalization and advertising that may include:

    • Providing you with a personalized and tailored Service, to serve you with Cahana advertising on third party properties;

    • To serve you with relevant advertising and content on our Services;

    • We may contract with third-party advertising companies and social media companies to display ads on their service. These companies may use cookies and similar technologies to track your activity, the information collected by these third parties in this manner is subject to that third party’s own privacy policies. We may also use aggregated information from these sources for creating similar audiences in order to better target advertisements on their networks to potential consumers who appear to have shared characteristics. See our Cookie Policy and Your Rights;

    • Understanding and assessing the effectiveness of our ads displayed;

    • To provide recommendations to you based on our inferences about your preferences and practices.

  • To ensure the security and integrity of our Services. Providing a safe and secure environment is key to providing a responsible platform and we do this by using data to:

    • Detect and combat any abuse or any harmful activity, fraud, spam, and illegal activity affecting our Services such as using personal identifiers, user profile, data usage, and other types of data to detect fraud, authentication or other harmful activity;

    • Monitor CCTV images, the prevention & detection of crime and for the health and safety of individuals on Cahana premises and aircraft.

  • To comply with any applicable law and/or regulations, legal proceedings.

    • We use data to investigate disputes or claims related to our Services.

    • Incertain circumstances, we may be obligated to use your information to respond to legal, government or regulatory requests.

  • Forany other lawful business purpose.

    • Including any incidental business purpose related to or in connection with any of the above, or for any other purpose disclosed to you at the point at which we collect your personal information.

Who we share your personal information with

We do not share your personal information or your sensitive personal information.

Who we sell your personal information to

We do not sell your personal information or your sensitive personal information.

Cookies and similar tracking technologies

We use cookies and similar tracking technologies such as pixel tags/web beacons and social media widgets (collectively "Cookies") to collect and use personal information about you, including for analytics purposes and to serve you interest-based advertising. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookies Policy.

Please also note that you may opt out and we honor certain technologies broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC) depending on the state you are in. This occurs on the browsers and/or browser extensions that support such a signal. This request will be linked to your browser identifier only.

International data transfers

Your personal information may be transferred to, processed and stored in countries other than the country in which you are resident, including the United States, Australia, Canada, the European Union and UK. The recipients of such information may be located in any country where Cahana has a place of business and additional territories where our suppliers and partners may transfer data, details of which can be provided upon request.

We take appropriate safeguards to protect your personal information in accordance with this Privacy Policy specifically in relation to any international transfer. This includes implementing an intra-group data sharing agreement that includes safeguards and protections for any use of your personal information by our group entities and incorporates the European Commission's Standard Contractual Clauses, which require all group companies to protect relevant information in accordance with European Union and UK data protection laws.

We have implemented similar appropriate safeguards and comply with applicable legal requirements when transferring Personal Information to countries such as utilizing Binding Corporate Rules, standard contractual clauses, and other data transfer mechanisms and/or rely on the European Commission adequacy decisions for certain countries outside of the European Economic Area should it be applicable with our third party service providers and partners. Further details can be provided upon request.

Your rights

You have the following rights:

  • Right to correction. You can have your information corrected if it is inaccurate.

  • Right to opt-out ofautomated decision making. You can say no to your information being used to make automated inferences, such profiling fortargeted, behavioral advertisement online.

  • Right to know about automated decision making, You can request access to and knowledge about how automated decision technologies work and what their probable outcomes are.

  • Right to limit use of sensitive personal information. You can ask us to restrict our use of sensitive personal information.

  • Right to delete. You can ask us to delete your information and ask us to instruct third parties to delete your information

  • Right to know. You have the right to request that we disclose to you the following about your information:

    • The specific information that we collect;

    • The categories of information that we collect;

    • The categories of sources from which we may collect your information;

    • The business purposes for collecting or sharing your information;

    • The categories of information we may disclose for business purposes; and

  • Right to opt-out. You have the right to opt out of sharing and selling your information. Note: Flyshare does not share or sell your information or your sensitive personal information.

  • Right to data portability. You have the right to request to have your information transported to other businesses or organizations.

You may exercise any of your rights listed above by using the details provided under Contact Us. We will not discriminate against you for exercising your rights above. Except as described in this policy or provided for under applicable privacy laws, there is no charge to exercise of your rights above.

Please also be advised that we continue to maintain some of your personal data where permitted by law, and that such information has not been deleted from Cahana systems. We retain your personal information where it is necessary for us to:

  • Complete the transaction for which the personal information was collected, provide a service that you have requested, or reasonably anticipated with in the context of our ongoing business relationship, or otherwise perform a contract between you and Cahana;

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;

  • Debug to identify and repair errors that impair existing intended functionality;

  • Comply with a legal obligation, existing warrant, litigation hold.

Please note that if you delete your account this will result in the deletion of your Cahana account and all associated information.

We will also confirm your identity before acting on your requests. We may not be able to respond to your request or provide you with personal data if we cannot verify your identity, or the authority to make the request on someone else’s behalf.

Consent

If we have collected and process your personal information with your consent (including any sensitive or special category data), then you can withdraw your consent at any time by using the details provided under Contact Us.

Direct marketing

We may send marketing communications for purposes disclosed to you (including as specified in section 2 above) and, where required by applicable law, with your consent. You can unsubscribe from direct marketing at any time by contacting us using the details provided under the Contact Us. We will process your request within a reasonable time after receipt, in accordance with applicable laws. Unsubscribe options are provided in electronic marketing communications as required by applicable law.

Email, SMS and Telephone. You can unsubscribe from email communications at any time. To stop receiving our promotional emails, follow the unsubscribe instructions in the email messages you receive from us, or contact us using the details provided under the Contact Us. We will process your request as soon as practicable after receipt, in accordance with applicable laws. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding Cahana and our Services and, to the extent permitted by law, you will not be able to opt-out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy). If you opt in, you will receive text messages from Cahana. “Cahana Account” text messages are non-promotional messages from Cahana alerting you to important information, like the details of your delivery, failed subscription payments and other alerts related to your Cahana subscription or purchases. To opt-out of receiving “Cahana Account” text messages, text STOP to the number from which you received the message. We will send you one final message to confirm that you have been unsubscribed and will process your request within a reasonable time after receipt, in accordance with applicable laws. If you experience any issues with text messages from Cahana, contact us using the details provided under the Contact Us. Carriers are not liable for delayed or undelivered messages. Message frequency varies. Message and data rates may apply.

We maintain “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within the timescales required by law.

Push Notifications. If you opt-in on your device, Cahana may occasionally send you push notifications through our Apps with updates, achievements and other notices that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your device.

"DoNot Track" / Global privacy control

Do Not Track ("DNT") is a privacy preference that users can set incertain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that, because there has been no agreed industry standard, we do not respond to or honor DNT signals or similar “do not track” mechanisms transmitted by web browsers.

Please note you may opt out, and we honor, certain technologies broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC) depending on the state you reside in. This occurson the browsers and/or browser extensions that support such a signal. This request will be linked to your browser identifier only.

Data retention

Cahana retains the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws. CCTV images are retained for at least 7 days. When we are no longer required to retain the personal information as described above, we will destroy, erase, or de-identify it. Legal requirements, however, may require us to retain some or all of the personal information we hold for a period of time that is longer than that for which we might otherwise hold it.

Security of your information

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. We maintain commercially reasonable administrative, technical and physical safeguards (which vary depending on the sensitivity of the personal information) designed to protect against unauthorized use, disclosure or access of personal information.

Legal basis for processing

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned, applicable laws and the specific context in which we collect it.

However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you (such as to provide our Services), (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

If we ask you to provide personal information to comply with a legal require mentor to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatoryor not (as well as of the possible consequences if you do not provide your personal information).

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Services, to communicate with you as necessary to provide our Services to you, and for our legitimate commercial interests such as responding to your queries, improving our products and Services, undertaking marketing, or detecting and preventing illegal activities. We may have other legitimate interests and we will make clear to you at the relevant time what those legitimate interests are. If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, you can contact us using the details provided under the Contact Us section below.

How to contact us

If you have any questions about our privacy practices, this Privacy Policy or would like to contact us or our Data Protection Officer, you can do so by email at legal@aircahana.com.

You can also complain to a data protection authority about our collection and use of your personal information if you feel that Flyshare has not acted in accordance with applicable laws. For more information, please contact your local data protection authority.

Updates to our privacy policy

We reserve the right to modify, revise, or otherwise amend this Privacy Policy at any time and in any manner. Any new version of this Notice will be posted at www.aircahana.com.