Privacy policy

Last Updated: September 16, 2023

1. INTRODUCTION

This Privacy Policy describes the privacy practices of Flights365 and in connection with our website https://corporate.flights365.com and any other website or mobile app that we own or control and which posts or links to this Privacy Policy (collectively, the “Websites”), and any online or offline interactions you may have with Flights365 related to our products and services (together, the “Services”). This Privacy Policy also describes the rights and choices available to individuals with respect to their information.

We wish to remind you that this Privacy Policy applies to personal information that we process in connection with our Services. It does not apply to any links to third parties’ websites and/or services, such as third-party applications, that you may encounter when you use our Services. We encourage you to carefully familiarize yourself with privacy policies applicable to any websites and/or services operated by third parties. Please be aware that we are not responsible for the privacy practices of any third parties.

2. OUR CORPORATE TRAVEL SERVICES AND TRAVELER DATA

Please see our Product Privacy Statement for a description of our privacy practices in relation to our corporate travel management services.

Typically, our customers are employers who use our services to facilitate corporate travel and events, and other employee travel. Our use of personal information for travel services is governed by our customer agreements and privacy policies that our customers may make available to their employees.

3. INFORMATION WE COLLECT

Information you provide to us. Personal information you provide to us through the Services or otherwise includes:

Business and personal contact information, such as your first and last name, email and mailing addresses, phone number, professional title, and company name.
Demographic information, such as your city, state, country of residence, postal code, and age.
The content you choose to upload to the Websites, such as text comments you may leave on our blog.
Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
Usage information, such as information about how you use the Services and interact with us, including information associated with any content you upload to the Websites or otherwise submit to us, and information you provide when you use any interactive features of the Services.
Marketing information, such as your preferences for receiving communications about our activities and publications, and details about how you engage with our communications
Information included in your job application, such as professional credentials and skills, educational and work history, and other information of the type that may be included in your resume.

Cookies and other information are collected by automated means. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Services. The information that may be collected automatically includes your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; and information about your use of and actions on the Services, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access. Our service providers and business partners may collect this type of information over time and across third‐party websites and mobile applications. On our Websites, this information is collected using cookies, browser web storage (also known as locally stored objects, or “LSOs”), web beacons, and similar technologies, and our emails may also contain web beacons.

Finally, we may periodically conduct surveys. Participation in any Flights365 survey is completely voluntary. Flights365 takes the information received from individuals responding to surveys and combines (or aggregates) it with the responses of other individuals to create broader, generic responses to the survey questions.

4. THE PURPOSES FOR WHICH WE USE PERSONAL INFORMATION

We use personal information for the following purposes:

To operate the Services, including to provide, develop, and improve our Services, provide information about our products and services, communicate with you about the Services (including by sending you announcements, updates, security alerts, and support and administrative messages), understand your needs and interests, and personalize your experience with the Services and our communications, provide support and maintenance for the Services, and respond to your requests, questions, and feedback.
For research and development, including to develop new products and services, including by studying user demographics and use of the Services (such as through market research).
For recruiting purposes, including managing our recruiting and processing employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics.
To send you Flights365-related marketing and promotional communications as permitted by law. You will have the ability to opt out of our marketing and promotional communications as described in the Opt out of marketing section below.
To display advertisements. We work with advertising partners to display advertisements on the Service or elsewhere online. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Services or your activity elsewhere online. Please see the Targeted online advertising section below to learn more about your choices in connection with advertisements.
As we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal processes, such as responding to subpoenas or requests from government authorities.
As we believe necessary or appropriate to (a) protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Services; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
As otherwise described when we specifically ask for your consent to collect, use, or share your personal information, such as when required by law.
To create anonymous, aggregated, or de‐identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated, or de‐identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated, or de‐identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.

5. HOW WE DISCLOSE PII

We may disclose the personal information we collect to the following categories of recipients:

Service providers, including third party companies and individuals that provide services on our behalf or help us operate the Services (such as customer support, hosting, analytics, email delivery, marketing, and database management services). These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy and are prohibited from using or disclosing your information for any other purpose.
Other users of the Services and the public, through functionality we provide that enables you to disclose personal information to other users of the Services or the public. For instance, you may be able to submit content to the Services (such as comments, reviews, surveys, blogs, photos, and videos), and we will display your name along with the content you submit. We do not control how other users or third parties use any personal information that you make available to other users or the public.
Professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.
Law enforcement, government authorities, and private parties as we believe necessary or appropriate to (a) protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
Third parties in connection with a business transfer, in which we may sell, transfer, or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

6. YOUR RIGHTS AND CHOICES

All users have the following rights and choices available to them with respect to the personal information we hold about them. Users who are located in the European Union can find additional information about their rights below.

Access or update your information. If you would like to access, update or correct the personal information we hold about you, please submit a request to privacy@flights365.com.

Opt out of receiving electronic direct marketing communications from us. You may opt out of marketing‐related emails by following the opt‐out or unsubscribe instructions at the bottom of the respective email. You may continue to receive service‐related and other non‐marketing emails.

Cookies and browser web storage. We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Service and third-party websites.

Targeted online advertising. Some of the business partners that collect information about users’ activities on or through the Service may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive the Services by designating it as required at the time of collection or through other appropriate means.

7. SECURITY

Flights365 maintains commercially reasonable administrative, technical, and physical safeguards designed to (i) protect the security and confidentiality of personal information; (ii) identify, assess, and protect against any reasonably foreseeable internal and external threats, risks, or hazards to the security or integrity of personal information; and (iii) protect against unauthorized access to or use of personal information. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

8. INTERNATIONAL DATA TRANSFERS

We are headquartered in the United States and have service providers in other countries, your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country. To protect such information, transfers will be made as permitted by applicable law, including where necessary being subject to appropriate contractual clauses.

9. CHILDREN

The Services are not directed to children under the age of 13, and we do not knowingly collect information from children under the age of 13 on the Websites. If a parent or guardian becomes aware that his or her child has provided us with personal information through the Websites, please contact us. We will delete such information from our files as soon as reasonably practicable.

10. CHANGES TO THE PRIVACY POLICY

Ovation reserves the right to revise, amend, or modify this Privacy Policy at any time and in any manner. You can tell when changes have been made to the Privacy Policy by referring to the “Last Updated” legend on top of this page.

11. CONTACT US

Should you have any questions or concerns regarding this Privacy Policy, please contact us by email at: privacy@flights365.com, or write to us at:

Flights365
Attn: Privacy
666 Third Avenue, Floor 4
New York, NY 10017

NOTICE TO EUROPEAN USERS

The information provided in this “Notice to European Users” section applies only to individuals in Europe.

12. LEGAL BASES FOR PROCESSING

Processing purpose Details regarding each processing purpose listed below are provided in the section above titled “How we use your personal information”	Legal basis
To operate the Services	Processing is necessary to perform the contract governing our provision of the Service or to take steps that you request prior to signing up for the Service. If we have not entered into a contract with you, we process your personal information based on our legitimate interest in providing the Service you access and request.
For research and development To manage our recruiting and process employment applications To send you marketing communications To display advertisements For compliance, fraud prevention, and safety To create anonymous data	These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
To comply with the law	Processing is necessary to comply with our legal obligations.
With your consent	Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Service.

13. SENSITIVE PERSONAL INFORMATION

We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services, or otherwise to us.

If you provide us with any sensitive personal information when you use the Services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through the Services.

14. RETENTION

We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have otherwise collected about you, we will dissociate such information from the information attached to your content. In some circumstances, we may anonymize your personal information (so that it can no longer be associated with you), in which case we may use this information indefinitely without further notice to you.

15. YOUR RIGHTS

European data protection laws give you certain rights regarding your personal information. If you are located within the European Union, you may ask us to take the following actions in relation to your personal information that we hold:

Provide you with information about our processing of your personal information and give you access to your personal information.
Update or correct inaccuracies in your personal information.
Delete your personal information.
Transfer a machine‐readable copy of your personal information to you or a third party of your choice.
Restrict the processing of your personal information.
Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

You may submit these requests by email to privacy@flights365.com. We may request additional information from you to help us confirm your identity and process your request.

Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.