Effective date: March 15, 2019
As noted in the Terms, we do not knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact us at email@example.com.
U.S. Privacy Shield
Privacy Shield Principles:
- Accountability for Onward Transfer
- Data Integrity and Purpose Limitation
What Information does Freebird Collect?
Information You Provide to Us
We receive and store any information you knowingly provide to us. For example, through the registration process and/or by making a purchase using our Services, we may collect Personal Information such as:
- Email address
- Phone number
- Department of Homeland Security Redress Control Number (if applicable)
- Known Traveler Number (if applicable)
- IP Address and other online identifiers
- Information about all of your interactions with the Site (“Usage Data”) and how the Site is performing (“Analytics Data”).
- Usage Data includes information regarding any interaction you have with the Site, such as which functionalities are used and the frequency of use (e.g., pages visited, actions taken, data entered). See “Information Collected Automatically” section below.
We may communicate with you if you have provided us the means to do so. For example, if you have given us your email address, we may send you promotional email offers on behalf of other businesses, or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us. This confirmation helps us make our communications with you more interesting and improve our services. If you do not want to receive communications from us, please indicate your preference by contacting us at firstname.lastname@example.org.
Information Collected Automatically
Whenever you interact with our Services, we (or one of our partners) automatically receive and record information on our server logs from your browser or device, which may include keystrokes based on your interaction with our website, your IP address, device identification, “cookie” information, the type of browser and/or device you are using to access our Services, and the page or feature you requested. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, or you can opt-out of some automatic data collection features, but this may prevent you from taking advantage of some of the features of the Services.
We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services – for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible.
To the extent we log your session when interacting with our Site, we only review the collected information, including any Personal Information that may be visible to us as a result of your recorded session, internally to better learn how our users interact with the website and to improve the design and functionality of our website.
Information Collected From Other Websites and Do Not Track Policy
Will Freebird Share Any of the Personal Information it Receives?
Information that’s been de-identified. We may de-identify your Personal Information so that you are not identified as an individual, and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage or de-identified information to a partner (or allow a partner to collect such information) in a manner that would easily identify you as an individual person.
Advertisers: We may allow advertisers and/or merchant partners (“Advertisers”) to choose the demographic information of users who will see their advertisements and/or promotional offers and you agree that we may provide any of the information we have collected from you in non-personally identifiable form to an Advertiser, in order for that Advertiser to select the appropriate audience for those advertisements and/or offers. For example, we might use the fact you are located in Boston to show you ads or offers for Boston businesses, but we will not tell such businesses who you are. Or, we might allow Advertisers to display their ads to users with similar usage patterns to yours, but we will not disclose usage information to Advertisers except in aggregate form, and not in a manner that would identify you personally. Note that if an advertiser asks us to show an ad to a certain audience or audience segment and you respond to that ad, the advertiser may conclude that you fit the description of the audience they were trying to reach.
We may deliver a file to you through the Services (known as a “web beacon”) from an ad network. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser or device must request these advertisements and web beacons from the ad network’s servers, these companies can view, edit, or set their own cookies, just as if you had requested a web page from their site.
Affiliated Businesses: In certain situations, businesses or third party websites we are affiliated or partner with (e.g., Intermediaries, travel agents, airlines) may sell or provide products or services to you through or in connection with the Services (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business’ or websites’ policies.
Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you; for example, we may use a payment processing company to receive and process your credit card transactions for us. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.
Business Transfers: We may choose to buy or sell assets, and may share and/or transfer customer information in connection with the evaluation of and entry into such 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, Personal Information could be one of the assets transferred to or acquired by a third party.
Protection of Company and Others: We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with law or court order; enforce or apply our Terms and other agreements; or protect the rights, property, or safety of Company, our employees, our users, or others.
Is Personal Information about me secure?
We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. We are committed to providing a service that follows generally accepted and professionally standard security procedures. Any portion of the Freebird Site that collects sensitive Personal Information, uses industry-standard TLS encryption. Any data storage mechanism housing Personal Information uses AES-256 data encryption.
International Transfer And Storage Of Information Collected
We primarily store information collected from you within the European Economic Area, and the United States. By default, Freebird hosts in the U.S. region, but at the customer’s request, we can host in various other regions, including within the EU, Asia and Latin America, which varies based on each unique customer circumstances. To facilitate our global operations, we may transfer and access such personal information from around the world, including from other countries in which Freebird has operations. We use applicable, approved information transfer mechanisms where required, such as EU Standard Contractual Clauses (SCCs), or the EU - U.S. Privacy Shield.
What Personal Information can I access?
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: email@example.com.
What choices do I have?
You can always opt not to disclose information to us, but keep in mind some Personal Information may be needed to take advantage of some of our features. You have the right to choose (opt out) whether your personal data is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by you. If you wish to opt out, all you need to do is contact us at firstname.lastname@example.org. Applicable law allows certain exceptions to your ability to opt out, such as where we are parties to a contract that is still being performed, where law requires us to maintain information, or otherwise. Where applicable law permits us to retain and continue to use such information and we do so, we will do so only to the extent permitted or required by law. If you contact us to opt out, we will explain the options available and comply with your request as required by the Principles and applicable law. We may use any de-identified aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. If you would like to request access to, correct or delete the Personal Information which we hold, please send us an email at email@example.com.
Accountability For Onward Transfer
As Controller: When we transfer personal data to a third party acting as a controller, we comply with the Notice and Choice Principles in the ways stated above. We also enter into contracts third-party controllers that provide that such data may only be processed for limited and specified purposes consistent with the consent provided by the individual and that the third party controller will provide the same level of protection as Freebird and will notify us if the third party makes a determination that it can no longer meet this obligation. Those contracts provide that, when such a determination is made, the third party controller ceases processing or takes other reasonable and appropriate steps to remediate.
As Agent: Where we transfer personal data to a third party acting as an agent, (i) we transfer such data only for limited and specified purposes; (ii) we require (usually by contract) at least the same level of privacy protection as is required by the Privacy Shield Principles; (iii) we take reasonable and appropriate steps to ensure that the agent effectively processes the personal data transferred in a manner consistent with the organization’s obligations under the Privacy Shield Principles; (iv) we require the agent to notify us if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles; (v) upon notice, including under (iv), we take reasonable and appropriate steps to stop and remediate unauthorized processing; and (vi) we will provide a summary or a representative copy of the relevant privacy provisions of our contract with that agent to the Department of Commerce upon request.
What if I have questions about this policy?
If you have any questions or concerns regarding our privacy policies, please send us a detailed message to firstname.lastname@example.org, and we will try to resolve your concerns.
Recourse And Enforcement
If you have cause for recourse, the section describes how to contact us or make a complaint, the complaint and recourse methods available to you and the enforcement powers to which we are subject.
In compliance with the Privacy Shield Principles, Freebird commits to resolve complaints about our collection or use your personal information. European Union, UK, and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Freebird at:
488 Green Street, Cambridge, MA 02139
Data Protection Officer
If you have an unresolved complaint, Freebird has committed and signed on to the JAMS EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield ADR (JAMSADR), an alternative dispute resolution provider located in the United States. If you do not receive a timely acknowledgement of your complaint from Freebird, or if we have not resolved your complaint, please contact or visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield ADR are provided at no cost to you. Meditations will be conducted pursuant to JAMS International Mediation Rules unless the parties have specified a different set of Rules or Procedures. Freebird is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). European Union and Swiss individuals have the possibility, under certain conditions, to invoke binding arbitration.