Last updated June 23, 2015
INFORMATION COLLECTED BY THE GOGO SERVICE
Personal Information You Provide to Us
By using the Gogo Service or the Gogo Application, you may choose to provide information that could reasonably be used to contact you or to identify you personally (e.g., your name, mailing or billing address, telephone number, or email address, email preferences, and, for users accessing the Service on certain operating system platforms, your Gogo password and hint question (collectively, "Personal Information")). For example, we may collect Personal Information when you register to use the Gogo Application.
As a convenience for you, the Gogo Application will request access to the contact list on your mobile device. We do not use that contact information for our own purposes.
The commercial and business aviation airlines or aircraft owners/operators on whose planes the Gogo Service is available for use do not collect any information through your use of the Gogo Service. However, as noted below, we may share Personal Information of Gogo customers with commercial passenger airlines. We may also share Personal Information of Gogo Business customers with business aviation airlines or aircraft owners/operators for billing and collection purposes.
Information Collected by Automated Means
We and/or our authorized service providers may receive such information and use it to operate and improve the Gogo Service and the Gogo Application, deliver services and content, and for billing and collection purposes. We may also share Usage Information of Gogo Business customers with business aviation airlines or aircraft owners/operators for billing and collection purposes.
In order to provide you with certain limited availability, in-flight features, such as the ability to use your smartphone or other device to connect to your mobile service provider and thereby use your cellular service on certain flights, we need to obtain your SIM, IMSI, IMEI, ICC-ID, MDN, MIN, MEID, mobile telephone number, or similar device or mobile service identifier. If you register for the Gogo Service, you expressly agree that we may access and use such identifiers in order to facilitate your ability to connect to your mobile service provider and obtain a cellular connection. We will collect these identifiers from you automatically if possible, or obtain them with your assistance if automatic collection is not feasible.
HOW WE USE THE INFORMATION COLLECTED
We may use your Personal Information to send you electronic newsletters or promotional emails, unless you have requested not to receive such promotional communications from us. We may also use your Personal Information to send you Gogo Service-related communications, for which you may opt out if you terminate your account.
To the extent that certain information that we collect as part of any talking features constitutes customer proprietary network information (“CPNI”), Gogo complies with applicable law governing CPNI.
INFORMATION WE SHARE
In order to provide the Services efficiently, carry out your requests, and provide you with offers and advertisements tailored to your interests, we may also disclose Personal Information to the airline partner on whose plane you have accessed the Services.
For Gogo Business aviation passengers: we may disclose your Personal Information to our business aviation airline or aircraft owner/operator partners for billing and collection purposes.
Third Parties Providing Services On Our Behalf.
In order to provide the Gogo Service, carry out your requests, make various features, services and materials available to you through the Gogo Service, and respond to your inquiries, we may share your Personal Information with third parties that perform functions on our behalf (or on behalf of our partners), such as (a) companies or individuals that: host or operate parts of the Gogo Service, analyze data, provide customer service, or manage payments; (b) advertisers; and (c) sponsors or other third parties that participate in or administer our promotions or provide marketing or promotional assistance. In such cases, such third parties are not entitled to use this information for any other purpose.
Your Agreement To Have Your Personal Information Shared.
Law Enforcement Compliance.
We may be required by law, or by law enforcement officers acting under the color of law, to record some or all of your communications on or through the Gogo Service. We may, and you hereby authorize us to, disclose your Personal Information (including your account information) or any non-Personal Information if required by law or by law enforcement officers acting under the color of law, or if we believe in good faith that such disclosure is necessary to: (a) comply with relevant laws or to respond to subpoenas or warrants served on us; or (b) protect or defend the rights, property, or safety of us, you, other users, or third parties (especially in emergency situations).
INFORMATION WE RECEIVE FROM THIRD PARTIES
We may receive information about you from third
parties. For example, if you are on another website and you opt in to receive
information from us, that website will forward to us your e-mail address and other
information about you so that we may contact you as requested. You may also
choose to participate in a third party application or feature (such as one of
our Facebook or Twitter applications or a similar application or feature on a
third party web site) through which you allow us to collect and share (or the
third party to collect and share) information about you, including Personal
Information. In addition, we may receive information about you if other users
of a third party web site give us access to their profiles and you are one of
their “connections” or information about you is otherwise accessible through
your “connections” web page, profile page, or similar page on a social
networking or other third party web site or interactive service.
YOUR ACCESS AND CHOICES
We offer you choices regarding the collection, use, and sharing of your Personal Information. You can stop all collection of information by the Gogo Service by uninstalling the Gogo Application through the standard uninstall process offered through your mobile device. When you receive promotional communications from us, you may indicate a preference to stop receiving further promotional communications from us and you will have the opportunity to "opt-out" by following the unsubscribe instructions provided in the promotional email. In addition:
If you wish to verify, correct, update or delete any of the Personal Information provided to us, you may do so by contacting us at firstname.lastname@example.org (for Gogo commercial passenger airline customers) or email@example.com (for individuals aboard aircraft owned/operated by Gogo Business’s business aviation customers).
In accordance with our routine record keeping, we may delete certain records that contain Personal Information you have submitted through the Gogo Service or the Gogo Application. Please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). You should be aware that it is not always possible to completely remove or delete all of your information from our databases without some residual data remaining in our archives because of backups and other reasons.
ADVERTISING; HOW TO OPT-OUT
For Gogo commercial airline passengers: We license technology to serve advertisements on the Gogo Service. In addition, we may use third-party analytics vendors to evaluate and provide us with information about the use of the Gogo Service. We do not share Personal Information with these third parties, but ad network providers, the advertisers, the sponsors, and/or analytics service providers may set and access their own cookies, pixel tags and similar technologies on your mobile device, and they may otherwise collect or have access to information about you, including Usage Information. We and our network advertisers may target advertisements for products and services in which you might be interested based on your use of the Gogo Service. We may use a variety of companies to serve advertisements.
If you prefer to not receive targeted advertising, you can opt out of some network advertising programs that use your information. To do so please visit the Digital Advertising Alliance (DAA) Opt-Out Page: http://www.aboutads.info/choices/. Please note that even if you choose to remove your information (opt out), you will still see advertisements while you are browsing online. However the advertisements you see may be less relevant to you and your interests. Additionally, many network advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. The DAA Opt-Out Page provides a tool that identifies its member companies that have cookies on your browser and provides links to those companies.
LINKS TO THIRD PARTY SITES
HOW WE PROTECT PERSONAL INFORMATION
We use Secure Sockets Layer (SSL) and Transport Layer Security (TLS protocols) to provide connectivity for the Gogo Service and the Gogo Application. Although we take reasonable steps to protect your security, please be aware that we cannot ensure or warrant the security of any information you transmit to us, and you use the Gogo Service and the Gogo Application and provide us with your information at your own risk.
CONSENT TO PROCESSING AND TRANSFER OF INFORMATION
If you are a user who resides outside the United States, please be aware that information we collect may be transferred to and processed in the United States. By using the Gogo Service or the Gogo Application, or providing us with any information, you consent to the collection, processing, maintenance and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to, those in the country where you reside and/or are a citizen.
We do not intentionally gather Personal Information about users who are under the age of 13. If we become aware that we have unknowingly collected Personal Information from a child under the age of 13, of if a parent or guardian contacts us concerning information a child under his or her responsibility has provided us without his or her consent, we will make reasonable efforts to delete such information from our records within a reasonable time.
HOW TO CONTACT US