Effective Date: [May 18, 2022]
OneAir (TWNH LLC) provides this Global Privacy Statement to describe OneAir’s practices in relation to the use of OneAir’s Web sites and the related applications, services, and programs offered by OneAir (collectively, the “Services”), as well as individuals’ choices regarding use, access and correction of personal information. This Global Privacy Statement applies to individuals who visit OneAirs’s Web Sites (“Visitors”) and customers that obtain and products and services (“Customers”).
Our privacy practices may vary among the countries and states in which we operate or in which you reside to reflect local practices and legal requirements.
1. PERSONAL DATA COLLECTED
Personal Data is any and all information that relates to you and identifies you as an individual. We collect Personal Data from you in two major ways:
information that you provide to us (such as name, billing address, email, etc.);
information about your use of the product (such as technical info like cookies, IP address, etc.).
OneAir only collects the least amount of data required to ensure that you have a delightful booking experience. We do not collect “extra” data that is unnecessary to providing you with a delightful booking experience, such as your age or gender.
2. INFORMATION THAT YOU PROVIDE
When you use the OneAir product, you voluntarily share some personal information with us. These are things like your name, telephone number and intended travel city and dates. If you make a booking with us, we’ll ask you to share some additional info such as your email address, billing address, payment details and the guests traveling with you.
You can choose which information you feel comfortable providing and which information you’d rather not share. However, there is some information that is required to be collected in order to complete a hotel booking. This includes, but is not limited to:
Information Required to Make a Booking
Full legal name of the person making the hotel reservation
Payment details to finalize a reservation, including credit card details or PayPal account, and billing address
An email address where a confirmation email and receipt can be sent
Information Collected From Use of OneAIr
Device Information: This is collected so that we understand the type of device or software you are using to interact with OneAir. This information includes things like Desktop of Mobile, Android or Apple, Chrome or Safari, etc. This information helps us better understand how users are engaging with us, and ensures we can provide full support for all devices. For more info on what data is shared, contact your device manufacturer or software provider.
Cookies and Log Data: These are used to record information about your session. This includes things like your IP address, the date and time of your searches and messages, and cookies or data provided to third-party analytics tools.This information helps us to better understand how you use our site, and what your preferences are.
Information Collected from Third Parties
Web beacons (also known as clear gifs, pixel tags or Web bugs) are tiny graphics with a unique identifier, similar in function to cookies, that are placed in the code of a web page. We use web beacons to monitor traffic patterns from one page to another, to deliver or communicate with cookies, to understand whether you have come to our site from an online advertisement displayed on a third-party website, and to improve site performance. We also may allow our service providers to use web beacons to track the visitor traffic and actions on our site. This helps us measure the effectiveness of our content and other offerings.
Other Sources: To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or information to help detect fraud and safety issues, from third party service providers and/or partners, and combine it with information we have about you.
3. THIRD-PARTY ADVERTISERS
OneAir does not share any Personal Information about you with these advertisers unless you give us specific permission to do so, separate from any permission you provide during a registration process.
As part of the registration process, we give you the choice to either receive advertisements, updates and promotions via e-mail.
If you choose to receive the above items we hope you will find them interesting and informative. In fact, we will use the information you tell us about your travel preferences and experiences to share customized advertisements, updates and promotions with you that include our recommendations to you about travel specials.
You should let us know if you do not want us to use your e-mail addresses to deliver to you: (1) our deals updates highlighting flight specials, promotions, and other travel opportunities available on our web site and/or sponsored by our travel service providers and advertisers; and/or (2) our monthly newsletter, when it becomes available, highlighting flight specials, promotions, contests, sweepstakes and other travel opportunities available on our site and/or sponsored by our travel service providers.
We use different methods, including an e-mail delivery and marketing company, to send the emails that you have agreed to receive.
Pixel tags and cookies may be used in those e-mail messages and at our website to help us measure the effectiveness of our advertising and to study how visitors use our site.
Should you no longer wish to receive our promotions, you may use the unsubscribe link included in any email message that we send you. If you are a registered member, you can also modify your choice at any time on the account profile page.
5. ON-LINE SURVEYS AND CONTESTS
We value your comments and opinions. From time to time, we will invite you, as a registered user of our site, to participate in online surveys, but the choice will be yours.
Each time you purchase, book or reserve travel services or accommodations through our site you may be asked for your feedback on your experience.
Your participation in these surveys is on an anonymous basis, unless we tell you up-front otherwise.
We may offer you the chance to win a variety of travel related prizes by sponsoring contests. You choose to participate in these contests or not. If you choose to participate in these contests, you will share certain of your Personal Information with us, like your full name, e-mail address and mailing address.
Participation in these contests may include participation in an on-line survey. We will only use your Personal Information to notify you if you win a contest.
6. TRAVELER PROFILE
OneAir combines your Personal Information into what we call your ‘Traveler Profile’.
We add the data about how you use our Website to your Traveler Profile. We may also collect information about you from outside sources and add it to your Traveler Profile, such as e-tickets or itineraries from airline companies.
We collect and use all of the information in your Traveler Profile to improve the quality of our service to you and your experience with us, and to otherwise fulfill the Purposes as applicable.
By way of example, we may use the combination of information in your Traveler Profile to (a) personalize the service we provide to you, (b) communicate with you about changes to your travel plans, service updates and new features or outages on our site, and (c) allocate the resources of our systems so that your experience with our site is as efficient as possible.
7. PAYMENT INFORMATION AND TRAVEL HISTORY
If you register with us, you will be able to book, reserve or purchase travel services or accommodations through our site.
To do so, you must provide payment information to us – for example, your credit card specifics like card number, expiration date, cardholder name and billing address.
We will add this payment information to your Traveler Profile.
We will keep a history of all your reservations, bookings and purchases of travel services and accommodations through our site in your Traveler Profile, unless you choose to edit your Traveler Profile as described below in this Policy (Changing/Removing Personal Information).
8. ITINERARY CHANGES & TRAVEL ALERTS
If you book, reserve or purchase travel services through our site, you will have the option to receive and/or have others receive last minute updates about your travel arrangements, such as changes in gate assignment or delays in departure or arrival time.
‘These ‘Travel Itinerary & Travel Alerts’ can be received by you or others of your choosing via email or text messages.
If you decide to direct a Travel Itinerary & Travel Alert to someone other than yourself, we will collect Personal Information about that other person that is necessary to send the requested Travel Itinerary & Travel Alert (i.e., that person’s name and phone number or e-mail address). You represent and warrant that any such person to whom you direct a Travel Itinerary & Travel Alert is a person with whom you have a personal or family relationship.
You will need to make sure that each of the other recipients of a Travel Itinerary & Travel Alert agrees, in advance, that you can disclose their Personal Information to us for this purpose, and you represent and warrant that you have such agreement prior to any such disclosure.
9. SHARING OF PERSONAL INFORMATION
Generally, we only disclose your Personal Information to those travel providers that you decide to make arrangements with through our site. For example, when you purchase an airline ticket or reserve a rental car or hotel room, we will provide the airline, car rental agency or hotel, as the case may be, with the Personal Information needed to process your transaction.
We use our reasonable efforts to ensure that these travel providers will also protect your Personal Information.
We contract with service providers to perform various functions necessary to operate our business – for example, to deliver tickets, ship items and process credit cards. We will share with these other companies only that Personal Information they require to fulfill your orders. These companies agree that they will not use or disclose that Personal Information for any other purpose.
Other than as explained in this Policy, we will not disclose any Personal Information we collect from you to others without your permission, except in certain limited circumstances, including: (a) to protect the security of our Website and our rights under our Terms and Conditions of Use; (b) to protect ourselves against liability; (c) in response to legal process, (d) if we believe in good faith that the law requires it; or (e) as required by governmental security regulations.
It should be remembered that should you choose to request certain services such as religious or special diet meals certain religious, or health information may be deduced by the travel provider and your permission is automatically granted to forward such information when you make such special requests.
Traveler’s information shared with travel providers may be communicated to countries security agencies under local legal requirements. For example, any travelers to/from the U.S. may have their data captured by the U.S. Homeland Security Agency, which can store it for up to 50 years, and may share such information with other U.S. Government Agencies.
10. CORPORATE TRAVEL
If you, or someone acting on your behalf, purchase(s) travel services or accommodations through our site and (a) you, or someone acting on your behalf, tell(s) us that your purchase is for corporate travel purposes either by indicating in the booking path that the purchase is for corporate travel or indicating that the credit card being used is a corporate credit card and (b) we have entered into an agreement with your corporation to provide data on the purchase of travel services or accommodations by the corporation’s personnel, we will provide your corporation with the Personal Information necessary for the corporation to track your corporate travel purchased on our site.
11. OTHER TRAVELERS
If you decide to book, reserve or purchase travel services or accommodations for other Travelers using your Traveler Profile, we will collect certain Personal Information about these other Travelers.
You will need to make sure that each of these other travelers agrees, in advance, that you can disclose their Personal Information to us. We will retain these other travelers Personal Information in your Traveller Profile.
12. HOW WE PROTECT YOUR INFORMATION
We are committed to safeguarding your information. For that reason, we employ security technology professionals and utilize industry standard security technology appropriate to the sensitivity of the applicable Personal Information. Only those employees who need access to Personal Information to fulfil their employment duties will have access to it.
13. PERSONAL DATA CHOICES YOU HAVE
The personal data that we collect is yours, and so you have choices available to you around what we collect and how it is used. Some of these choices can be communicated to OneAir (such as requesting access to or deletion of your information), and others should be communicated to other parties you engage with (such as in your phone settings for whether or not you share location information, etc.).
You can always choose not to provide personal information such as your name, phone number, email address, payment details, etc., however this may mean that you are unable to complete your flight or hotel booking.
Managing Your Information
You may access and update some of your information through your Account settings. If your account is tied to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app in the third party’s website. You are responsible for keeping your personal information up-to-date.
Rectification of Inaccurate or Incomplete Information
You have the right to ask us to correct inaccurate or incomplete personal information about you.
Data Access and Portability
In some jurisdictions, applicable law may entitle you to request certain copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
Data Retention and Erasure
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. In certain jurisdictions, you can request to have all your personal information deleted entirely.” Please note that if you request the erasure of your personal information:
We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a OneAir account for fraud or safety reasons, we may retain certain information from that account to prevent that Member from opening a new account in the future.
We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, OneAir may keep some of your information for tax, legal reporting and auditing obligations.
We may retain some copies of your information (e.g., log records) in our database, but they will be disassociated from personal identifiers.
Withdrawing Consent and Restriction of Processing
If we are processing your personal information based on your consent you may withdraw your consent at any time by changing your Account settings or by sending a communication to OneAir specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing pursuant (under Objection to Processing) and pending the verification whether the legitimate grounds of OneAir override your own.
Objection to Processing
In some jurisdictions, applicable law may entitle you to require OneAir not to process your personal information for certain specific purposes where such processing is based on legitimate interest. If you object to such processing OneAir will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing, or such processing is required for the establishment, exercise or defense of legal claims.
Filing a Request
To request access to, correction of, restriction of, or deletion of any of your personal data and information that we have collected, you can contact us at (email@example.com). We will respond to all inquiries within 72 hours.
14. CHILDREN AND MINORS
Under U.S. Federal Law (as reflected in the Children’s Online Privacy Protection Act), WE DO NOT COLLECT OR STORE ANY PERSONALLY IDENTIFIABLE INFORMATION FROM INDIVIDUALS THAT WE KNOW ARE UNDER THE AGE OF 13. If you wish further information concerning privacy policies in general, and concerning online social networking and safety, you should visit the following website: http://www.ftc.gov/privacy/index.html.
You must be at least the age of majority in the jurisdiction where you reside in order to register for or use the services available on our site.
OneAir staff are parents and OneAir believes that parents should play a central role in their child’s on-line activities and should monitor those activities to ensure that sites visited by their child, or minor, are respecting their child’s privacy.
15. PERSONAL DATA PROTECTION & INFORMATION SECURITY
The protection, security and confidential processing of your personal data is a major priority for OneAir. OneAir does not store credit card information and is PCI SAQ A compliant. We use industry standard 256 bit SSL encryption to store any sensitive data. Of course, any information or data transferred over the internet cannot be 100% guaranteed as safe, however we have implemented all industry standards and best practices to ensure that your data is secure, and to be alerted if this changes. Internally, only authorized staff members are permitted to access your personal information, and they only have access to the data that they need to perform their role. Any and all access of personal information is logged for security purposes.
16. CALIFORNIA PRIVACY RIGHTS
California law permits Members who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those third parties. See the “Contact Us” section for where to send such requests. OneAir does not share personal information with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your personal information to third parties for their direct marketing purposes by withholding consent.
Effective January 1, 2020, the California Consumer Privacy Act (CCPA) allows California residents, upon a verifiable consumer request, to request that a business that collects consumers’ personal information to give consumers access, in a portable and (if technically feasible) readily usable form, to the specific pieces and categories of personal information that the business has collected about the consumer, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the information was shared. California residents also have the right to submit a request for deletion of information under certain circumstances. Consistent with California law, if you choose to exercise your rights, we won’t charge you different prices or provide different quality of services unless those differences are related to your information. See here for information on data subject rights requests and how to submit a request. Please note that you must verify your identity and request before further action is taken. As a part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government government issued identification, and the authorized agent’s valid government issued identification.
17. UPDATES AND QUESTIONS
Once any changes are made, we will update the “Effective Date” at the top of this Policy. We encourage all users to check back on this policy frequently to stay updated on any potential changes.