Privacy Policy

USA

Effective Date: March 6, 2019

You have arrived at www.AirModo.com(the “Web Site“), which is owned and operated by United States Aviation Underwriters, Inc. (“USAU“). Throughout this Privacy Policy the words ” we,” “us,” and “our” refer to the USAU and its affiliates, and the words “you” and “your” refer to the user visiting the Web Site and your organization. This Privacy Policy applies to information that we collect at the Web Site or any mobile applications (collectively, the “Services“) and our handling of such information. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of the Services (unless otherwise stated below). Please review our Terms of Use, which governs your use of the Services.

By accessing and using the Services, you consent to our Privacy Policy, our Terms of Use and our collection, use and sharing of your information and data, and other activities, as described below.

1. What Information Do the Services Collect?

(a) Information You Provide to Us

Personal Information. We may ask you to provide us with your personally identifiable information, which is information about you as an identifiable individual, such as your first and last name, telephone number, [policy number, claims information, credit card], physical mailing address, e-mail address, and pilot certificate number, IP address, device identification, as well as other types of information that, alone or in combination with other information could be used to identify you (“Personal Information“). We may collect this Personal Information through various forms and in various places on the Services including account registration forms, contact us forms, or when you otherwise interact with the Services.

[The Services may offer you the ability to use Facebook or ‎other social media services (collectively, ” Social Media“) in conjunction with certain Services. ‎When you access the Services through your Social Media accounts, we may, depending on your privacy settings with the Social Media in question, have access to information that you have ‎provided to the Social Media platform. We may use this information for the purposes described ‎in this Policy or at the time the information was collected. If you associate your ‎Social Media account with your account and authorize us, through that service, to have access to this information, you ‎agree that we may collect, use and store the information provided by Social Media services as ‎described in this Policy.]

(b) Information Collected or Stored As You Access and Use the Web Site

In addition to any Personal Information or other information that you choose to submit to us via the Services, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Services (“Usage Information“). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device“) whenever you visit or interact with the Services. Unless otherwise required by applicable law, to the extent we associate Usage Information with your Personal Information that we collect directly from you on through the Services, we will treat it as Personal Information.

This Usage Information may include:

· your IP address, Unique Device Identifier (UDID) or other unique identifier (“Device Identifier“). A Device Identifier is a number that is automatically assigned to your Device used to access the Services, and our computers identify your Device by its Device Identifier;

· your Device functionality (including browser, operating system, hardware, mobile network information);

· the URL that referred you to the Web Site;

· the areas within the Services that you visit and your activities there, including remembering you and your preferences;

· if you have enabled such functionality on your Device, your Device location;

· certain other Device data, including the time of day, and location data.

Tracking Technologies. As set out in greater detail below, we may use various methods and technologies to store or collect Usage Information (” Tracking Technologies“). Tracking Technologies may collect information about your activities on your Device, such as the pages you have viewed and the actions you have taken while using the web. These Tracking Technologies include the following:

Cookies. A cookie is a data file placed on a Device when it is used to visit a web site and are generally of one of two types. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Tracking cookies remain longer and help in understanding how you use the Service and the web, and can be used to help enhance your user experience by customizing content. Cookies may remain on your Device for an extended period of time. If you use your browser’s method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked and as a result some features and functionalities of the Service may not work. A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage.

Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included on the Service’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. When the page or message is loaded, these technologies request a small clear image from the server of the party that embedded the beacon, thereby indicating to that party that the page or message was loaded. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Services, to monitor how users navigate the Services, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with a web site, such as the links you click on. The code is temporarily downloaded onto your Device from a web server or a third-party service provider, is active only while you are connected to the relevent site, and is deactivated or deleted thereafter.

Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification, is known as browser fingerprinting.

ETag, or Entity Tag. An ETag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.

Recognition Technologies. Recognition technologies are technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices in the same user).

Purposes for Using Tracking Technologies. We may use Tracking Technologies for a variety of purposes, including:

Strictly Necessary. We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access the Services, including cookies required to prevent fraudulent activity and improve security.

Performance‑Related. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Services, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Services.

Functionality‑Related. We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Services, including identifying you when you visit the Services or keeping track of your specified preferences, including in terms of the presentation of content on the Services.

Targeting‑Related. We may use Tracking Technologies to deliver content relevant to your interests on the Services and third‑party sites based on how you interact with our content. This includes using Tracking Technologies to understand the usefulness to you of the content that has been delivered to you.

Tracking Technologies Choices and Consent.

We obtain your consent to our information storage or collection Tracking Technologies by providing you with transparent information in our Privacy Policy and providing you with the opportunity to make a choice to disable cookies as set forth above, or as discussed below with respect to third party tracking. Please note that use of the above technologies for other purposes, such as to prevent fraud or ensure the security of the site, is a condition of use of the site..

Third Party Tracking and “Do Not Track.”

There may be other Tracking Technologies now and later devised and used by us in connection with the Services. Further, third parties may use Tracking Technologies in connection with the Services, which may include the collection of information about your online activities over time and across third-party web sites or online services. While we contractually require any third parties that may use Tracking Technologies on our site to use such technologies only in compliance with applicable privacy laws, and/or for the purposes set out in this privacy policy, we cannot monitor the use of all such Tracking Technologies and we are not responsible for them. You consent, however, to potentially encountering third-party Tracking Technologies in connection with use of the Services and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties. Also, various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.

(c) Information Third Parties Provide About You

We may, from time to time, supplement the information we collect directly from you on the Services with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you. To the extent we combine non-personal information we receive from those sources with Personal Information we collect on the Services, it will be treated as Personal Information and we will apply this Privacy Policy to such combined information. In no other circumstances do our statements under this Privacy Policy apply to information we receive about you from third parties, even if they have used our technology to collect it and share it with us.

(d) Interactions with Third-Party Sites

The Services may include functionality that allows certain kinds of interactions between the Services and a third-party web site or application, as described below. The use of this functionality may involve the third-party operator providing certain information, including Personal Information, to us. If we offer and you choose to use this functionality to access or use the Services, the third-party site or application may send Personal Information about you to us. If so, we will then treat it as Personal Information under this Privacy Policy, since we are collecting it as a result of your accessing of, and interaction on, the Services. In addition, we may provide third-party sites’ interfaces or links on the Services to facilitate you sending a communication from the Services. These third parties may retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy Policy. USAU may not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you are using their services and not our Services and they, not we, are responsible for their practices. You should review the applicable third-party privacy policies before using such third-party tools on the Services.

2. How Do We Use the Information Collected?

Generally. We may use your Personal Information and Usage Information that we collect about you: (1) to provide you with information or services or process transactions that you have requested or agreed to receive, including to send you electronic newsletters, or to provide you with special offers or promotional materials on behalf of us or third parties; (2) to enable you to participate in a variety of the Service features; (3) to process any inquiry, including verifying your information is active and valid; (4) to improve the Services or create new service offerings, to customize your experience using the Services, or to serve you specific content that is most relevant to you; (5) to contact you with regard to your use of any of the Services and, in our discretion, changes to the Services and/or any of the Service’s policies; (6) for internal business purposes to better understand our customer needs, provide the Services and generally manage our business and operations; and (7) for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.

Contact Us. Please note that information submitted to the Services via a “contact us” or other similar customer inquiry function may not receive a response. We will not use the information provided by you in a customer inquiry communication to contact you for marketing purposes unrelated to your request unless you agree otherwise.

3. How and When Do We Share Information with Third Parties?

We may share non-Personal Information, such as aggregated user statistics, with third parties. We may share your Device Identifiers with third parties providing services on our behalf, along with data related to you and your activities. We do not share your Personal Information with third parties for those third parties’ own direct marketing purposes unless we have obtained your prior consent to such sharing at the time you provide your Personal Information, or as otherwise permitted by law. If we de-identify data about you (i.e. remove certain data such that the remaining dataset could not reasonably be associated with you as an individual), it is not treated as Personal Information by us, and we may share it with others freely. In addition, we may share the information we have collected about you, including Personal Information, as may be separately disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy. USAU may also disclose your information as follows:

(a) When You Request Information From or Provide Information to Third Parties . You may be presented with an option on the Services to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties.

(b) Third Parties Providing Services on Our Behalf. We may use third-party vendors to perform certain services on behalf of us or the Services, such as hosting the Services, designing and/or operating the Services’ features, tracking the Services’ activities and analytics, and enabling us to send you special offers or perform other administrative services. On a need-to-know basis, we may provide these vendors with access to user information, including Device Identifiers and Personal Information, solely to carry out the services they are performing for you or for us. Third-party analytics and online advertising providers may set and access their own Tracking Technologies on your Device when you use our Services. They may also collect or have access to information about you relating to your activities on other web sites, potentially including Personal Information, about you. We are not responsible for those third party technologies or activities arising out of them, nor are we responsible for the effectiveness of or compliance with any third parties’ opt-out options.

(c) To Protect the Rights of the Company and Others. To the fullest extent permitted by applicable law, we may also disclose your information if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of USAU or third parties (including through the enforcement of this Privacy Policy, our Terms of Use, and other applicable agreements and policies); or (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders). To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest requests for such disclosures, all without notice to you.

(d) Affiliates and Business Transfer. We may share your Personal Information with our parent, subsidiaries and affiliates, on a need to know basis, where they require such data to assist us in providing you with the Services

(e) Business Transfer.

. We may share or transfer your Personal Information where reasonably required in the context of a sale, merger or amalgamation of all or part of our business or the insurance of securitization of our assets. In any such case, the recipient parties will be contractually required to keep the information confidential and use it only for the purposes of the transaction, or proposed transaction, in question. In the event a business transaction is affected, assignees or successors of USAU or our business or assets, or those of our affiliated entities, may use and disclose Personal Information only for the purposes as set out this Privacy Policy, unless further consent is obtained.

4. Do Third-Party Content or Links To Third-Party Sites Appear on the Web Site?

The Services may contain content that is supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when the Services are served to you. In addition, when you are using the Services you may be directed to other services that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their services and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. For example, if you “click” on a link, the “click” may take you off the Services onto a different site. These other sites may associate their Tracking Technologies with you, independently collect data about you, including Personal Information, and may or may not have their own published privacy policies. We encourage you to note when you leave the Services and to review the third-party privacy policies of all third-party websites and exercise caution in connection with them.

5. Your California Privacy Rights

Under California’s “Shine the Light” law, California residents who provide personally ‎identifiable information in connection with purchasing products or services may request a ‎disclosure of what personally identifiable information, if any, we have shared with other ‎businesses for their own direct marketing purposes. Such a request may be made by sending an e-‎mail message to privacy@AirModo.com with “Request for California Privacy Information” ‎in the subject line of the message. In response to such a request, we will provide information as ‎required by the California law for the previous calendar year concerning such other businesses ‎and the categories of personally identifiable information, if any, that we have shared with them.‎

6. How Do I Change My Information and Communications Preferences?

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information. Subject to limitations under applicable privacy law, the Services may allow you to review, correct or update Personal Information you have provided, and you may provide updates and changes by contacting us at [contact@AirModo.com] If you request updates or changes to provided Personal Information, we will make good faith efforts to make the requested changes in our records as soon as reasonably practicable (but, as required or permitted by law, we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons such as record retention policies or regulatory requirement .. When you edit your Personal Information or change your preferences on the Services, information that you remove may persist internally for USAU’s administrative purposes, as permitted by applicable law.

You may cancel or modify our e-mail marketing communications you receive from us by following the instructions contained within our promotional e-mails. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of e-mails the opt-out will be so limited. Please note that we reserve the right to send you certain communications relating to your use of our Service, such as administrative and service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications.

7. What About Transfer of Information to the United States?

The Services are operated in the United States. If you are located outside of the United States, please be aware that information we collect through the Web site, including Personal Information, will be transferred to, and processed, stored and used in the United States, but USAU may also access and use, but not store, such information, including Personal Information, from locations outside of the United States. The data protection laws in the United States, or in these other locations from which we may access data, may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the under the laws of the countries in which your Personal Information may be stored, processed or accessed. By using the Services or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States, and access from other countries, as set forth in this Privacy Policy.

8. What Should Parents Know About Children?

We understand the importance of protecting children’s privacy in the interactive world. We are a general audience service and do not use the Services to knowingly collect personal information from children under the age of thirteen (13), including personal information that requires parental notice and consent under the Children’s Online Privacy Protection Act (” COPPA“) without such parental consent. If you are a child under 13 years of age, you are not permitted to use the Site and should not send any information about yourself to us through the Services.

In the event that we become aware that we have collected personal information from any child, we will dispose of that information in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under the age of 13 has provided us with personal information without COPPA-required consent, please contact us at privacy@AirModo.com

9. What About Security?

We endeavor to incorporate commercially reasonable safeguards to help protect and secure your Personal Information. No data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information, however, can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Services and provide us with your information at your own risk.

10. What About Changes to the Privacy Policy?

We reserve the right to change this Privacy Policy at any time. Any changes will be effective immediately upon the posting of the revised Privacy Policy and your use of the Services indicates your consent to the privacy policy posted at the time of use. Where we do update the policy, we will include the date of the last revision at the top of the document. You should review this policy periodically to ensure you are aware of any such changes. We will not, however, use your previously collected Personal Information in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

11. Contact Us

If you have any questions about the Privacy Policy or practices described in it, you should contact us in the following ways: If you would like to request access to the Personal Information that USAU holds about you, or if you have any questions about this Privacy Policy, our privacy practices or the manner in which your Personal Information has been collected, used or disclosed, please contact us at:

Postal Mail: [125 Broad Street, 6th Floor, New York, NY 10004] ;

By e-mail privacy@AirModo.com.

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Canada

Effective Date: March 6, 2019

You have arrived at www.AirModo.com(the “Web Site”), which is owned and operated by United States Aviation Underwriters, Inc. (“USAU”). Throughout this Privacy Policy the words “we,” “us,” and “our” refer to the USAU and its affiliates, and the words “you” and “your” refer to the user visiting the Web Site and your organization. This Privacy Policy applies to information that we collect at the Web Site or any mobile applications (collectively, the “Services”) and our handling of such information. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of the Services (unless otherwise stated below). Please review our Terms of Use, which governs your use of the Services.

By accessing and using the Services, you consent to our Privacy Policy, our Terms of Use and our collection, use and sharing of your information and data, and other activities, as described below.

1. What Information Do the Services Collect?

(a) Information You Provide to Us

Personal Information. We may ask you to provide us with your personally identifiable information, which is information about you as an identifiable individual, such as your first and last name, telephone number, [policy number, claims information, credit card], physical mailing address, e-mail address, and pilot certificate number, IP address, device identification, as well as other types of information that, alone or in combination with other information could be used to identify you (“Personal Information”). We may collect this Personal Information through various forms and in various places on the Services including account registration forms, contact us forms, or when you otherwise interact with the Services.

[The Services may offer you the ability to use Facebook or ‎other social media services (collectively, “Social Media”) in conjunction with certain Services. ‎When you access the Services through your Social Media accounts, we may, depending on your privacy settings with the Social Media in question, have access to information that you have ‎provided to the Social Media platform. We may use this information for the purposes described ‎in this Policy or at the time the information was collected. If you associate your ‎Social Media account with your account and authorize us, through that service, to have access to this information, you ‎agree that we may collect, use and store the information provided by Social Media services as ‎described in this Policy.]

(b) Information Collected or Stored As You Access and Use the Web Site

In addition to any Personal Information or other information that you choose to submit to us via the Services, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Services (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with the Services. Unless otherwise required by applicable law, to the extent we associate Usage Information with your Personal Information that we collect directly from you on through the Services, we will treat it as Personal Information.

This Usage Information may include:

  • your IP address, Unique Device Identifier (UDID) or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Services, and our computers identify your Device by its Device Identifier;
  • your Device functionality (including browser, operating system, hardware, mobile network information);
  • the URL that referred you to the Web Site;
  • the areas within the Services that you visit and your activities there, including remembering you and your preferences;
  • if you have enabled such functionality on your Device, your Device location;
  • your Device characteristics; and
  • certain other Device data, including the time of day, and location data among other information.

Tracking Technologies. As set out in greater detail below, we may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may  collect information about your activities on your Device, such as the pages you have viewed and the actions you have taken while using the web. These Tracking Technologies include the following:

Cookies. A cookie is a data file placed on a Device when it is used to visit a web site, and are generally of one of two types. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Tracking cookies remain longer and help in understanding how you use the Service and the web, and can be used to help enhance your user experience by customizing content. Cookies may remain on your Device for an extended period of time. If you use your browser’s method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked and as a result some features and functionalities of the Service may not work.  A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage.

Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included on the Service’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. When the page or message is loaded, these technologies request a small clear image from the server of the party that embedded the beacon, thereby indicating to that party that the page or message was loaded.  Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Services, to monitor how users navigate the Services, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with a web site, such as the links you click on. The code is temporarily downloaded onto your Device from a web server or a third-party service provider, is active only while you are connected to the relevent site, and is deactivated or deleted thereafter.

Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification, is known as browser fingerprinting.

ETag, or Entity Tag. An ETag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.

Recognition Technologies. Recognition technologies are technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices in the same user).

Purposes for Using Tracking Technologies. We may use Tracking Technologies for a variety of purposes, including:

Strictly Necessary. We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access the Services, including cookies required to prevent fraudulent activity and improve security.

Performance‑Related. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Services, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Services.

Functionality‑Related. We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Services, including identifying you when you visit the Services or keeping track of your specified preferences, including in terms of the presentation of content on the Services.

Targeting‑Related. We may use Tracking Technologies to deliver content relevant to your interests on the Services and third‑party sites based on how you interact with our content. This includes using Tracking Technologies to understand the usefulness to you of the content that has been delivered to you.

Tracking Technologies Choices and Consent.

We obtain your consent to our information storage or collection Tracking Technologies by providing you with transparent information in our Privacy Policy and providing you with the opportunity to make a choice to disable cookies as set forth above, or as discussed below with respect to third party tracking. Please note that we are not required to obtain your consent to the information collection Tracking Technologies identified above that are strictly necessary.

We are giving you detailed notice of the Tracking Technologies and your limited choices regarding them so that your consent is meaningfully informed.

Third Party Tracking and “Do Not Track.”

There may be other Tracking Technologies now and later devised and used by us in connection with the Services. Further, third parties may use Tracking Technologies in connection with the Services, which may include the collection of information about your online activities over time and across third-party web sites or online services. While we contractually require any third parties that may use Tracking Technologies on our site to use such technologies only in compliance with applicable privacy laws, and/or for the purposes set out in this privacy policy, we cannot monitor the use of all suchTracking Technologies and we are not responsible for them. You consent, however, to potentially encountering third-party Tracking Technologies in connection with use of the Services and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties. Also, various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.

(c) Information Third Parties Provide About You

We may, from time to time, supplement the information we collect directly from you on the Services with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you. To the extent we combine non-personal information we receive from those sources with Personal Information we collect on the Services, it will be treated as Personal Information and we will apply this Privacy Policy to such combined information. In no other circumstances do our statements under this Privacy Policy apply to information we receive about you from third parties, even if they have used our technology to collect it and share it with us.

(d) Interactions with Third-Party Sites

The Services may include functionality that allows certain kinds of interactions between the Services and a third-party web site or application, as described below. The use of this functionality may involve the third-party operator providing certain information, including Personal Information, to us. If we offer and you choose to use this functionality to access or use the Services, the third-party site or application may send Personal Information about you to us. If so, we will then treat it as Personal Information under this Privacy Policy, since we are collecting it as a result of your accessing of, and interaction on, the Services. In addition, we may provide third-party sites’ interfaces or links on the Services to facilitate you sending a communication from the Services. These third parties may retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy Policy. USAU may not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you are using their services and not our Services and they, not we, are responsible for their practices. You should review the applicable third-party privacy policies before using such third-party tools on the Services.

2. How Do We Use the Information Collected?

Generally. We may use your Personal Information and Usage Information that we collect about you: (1) to provide you with information or services or process transactions that you have requested or agreed to receive, including to send you electronic newsletters, or to provide you with special offers or promotional materials on behalf of us or third parties; (2) to enable you to participate in a variety of the Service features; (3) to process any inquiry, including verifying your information is active and valid; (4) to improve the Services or create new service offerings, to customize your experience using the Services, or to serve you specific content that is most relevant to you; (5) to contact you with regard to your use of any of the Services and, in our discretion, changes to the Services and/or any of the Service’s policies; (6) for internal business purposes to better understand our customer needs, provide the Services and generally manage our business and operations; and (7) for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.

Contact Us. Please note that information submitted to the Services via a “contact us” or other similar customer inquiry function may not receive a response. We will not use the information provided by you in a customer inquiry communication to contact you for marketing purposes unrelated to your request unless you agree otherwise.

3. How and When Do We Share Information with Third Parties?

We may share non-Personal Information, such as aggregated user statistics, with third parties. We may share your Device Identifiers with third parties providing services on our behalf,  along with data related to you and your activities. We do not share your Personal Information with third parties for those third parties’ own direct marketing purposes unless we have obtained your prior consent to such sharing at the time you provide your Personal Information, or as otherwise permitted by law. If we de-identify data about you (i.e. remove certain data such that the remaining dataset could not reasonably be associated with you as an individual), it is not treated as Personal Information by us, and we may share it with others freely. In addition, we may share the information we have collected about you, including Personal Information, as may be separately disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy. USAU may also disclose your information as follows:

(a) When You Request Information From or Provide Information to Third Parties. You may be presented with an option on the Services to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties.

(b) Third Parties Providing Services on Our Behalf. We may use third-party vendors to perform certain services on behalf of us or the Services, such as hosting the Services, designing and/or operating the Services’ features, tracking the Services’ activities and analytics, and enabling us to send you special offers or perform other administrative services. On a need-to-know basis, we may provide these vendors with access to user information, including Device Identifiers and Personal Information, solely to carry out the services they are performing for you or for us. Third-party analytics and online advertising providers may set and access their own Tracking Technologies on your Device when you use our Services.  They may also collect or have access to information about you relating to your activities on other web sites, potentially including Personal Information, about you. We are not responsible for those third party technologies or activities arising out of them, nor are we responsible for the effectiveness of or compliance with any third parties’ opt-out options.

(c) To Protect the Rights of the Company and Others. To the fullest extent permitted by applicable law, we may also disclose your information if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of USAU or third parties (including through the enforcement of this Privacy Policy, our Terms of Use, and other applicable agreements and policies); or (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders). To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest requests for such disclosures, all without notice to you.

(d) Affiliates and Business Transfer. We may share your Personal Information with our parent, subsidiaries and affiliates, on a need to know basis, where they require such data to assist us in providing you with the Services

(e) Business Transfer.

. We may share or transfer your Personal Information where reasonably required in the context of a sale, merger or amalgamation of all or part of our business or the insurance of securitization of our assets.  In any such case, the recipient parties will be contractually required to keep the information confidential and use it only for the purposes of the transaction, or proposed transaction, in question. In the event a business transaction is affected, assignees or successors of USAU or our business or assets, or those of our affiliated entities, may use and disclose Personal Information only for the purposes as set out this Privacy Policy, unless further consent is obtained.

4. Do Third-Party Content or Links To Third-Party Sites Appear on the Web Site?

The Services may contain content that is supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when the Services are served to you. In addition, when you are using the Services you may be directed to other services that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their services and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. For example, if you “click” on a link, the “click” may take you off the Services onto a different site. These other sites may associate their Tracking Technologies with you, independently collect data about you, including Personal Information, and may or may not have their own published privacy policies. We encourage you to note when you leave the Services and to review the third-party privacy policies of all third-party websites and exercise caution in connection with them.

5. Your California Privacy Rights

Under California’s “Shine the Light” law, California residents who provide personally ‎identifiable information in connection with purchasing products or services may request a ‎disclosure of what personally identifiable information, if any, we have shared with other ‎businesses for their own direct marketing purposes. Such a request may be made by sending an e-‎mail message to contact@AirModo.com with “Request for California Privacy Information” ‎in the subject line of the message. In response to such a request, we will provide information as ‎required by the California law for the previous calendar year concerning such other businesses ‎and the categories of personally identifiable information, if any, that we have shared with them.‎

6. How Do I Change My Information and Communications Preferences?

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information.  Subject to limitations under applicable privacy law, the Services may allow you to review, correct or update Personal Information you have provided, and you may provide updates and changes by contacting us at contact@AirModo.com  If you request updates or changes to provided Personal Information, we will make good faith efforts to make the requested changes in our records as soon as reasonably practicable (but, as required or permitted by law,we may retain prior information as business records).  Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons such as record retention policies or regulatory requirement . When you edit your Personal Information or change your preferences on the Services, information that you remove may persist internally for USAU’s administrative purposes, as permitted by applicable law. 

You may cancel or modify our e-mail marketing communications you receive from us by following the instructions contained within our promotional e-mails.  This will not affect subsequent subscriptions and if your opt-out is limited to certain types of e-mails the opt-out will be so limited.  Please note that we reserve the right to send you certain communications relating to your use of our Service, such as administrative and service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications. 

7. What About Transfer of Information to the United States?

The Services are operated in the United States.  If you are located outside of the United States, please be aware that information we collect through the Web site, including Personal Information, will be transferred to, and processed, stored and used in the United States, but USAU may also access and use, but not store, such information, including Personal Information, from locations outside of the United States. The data protection laws in the United States, or in these other locations from which we may access data, may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the under the laws of the countries in which your Personal Information may be stored, processed or accessed. By using the Services or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States, and access from other countries, as set forth in this Privacy Policy.

8. What Should Parents Know About Children?

We understand the importance of protecting children’s privacy in the interactive world. We are a general audience service and do not use the Services to knowingly collect personal information from children under the age of thirteen (13), including personal information that requires parental notice and consent under the Children’s Online Privacy Protection Act (“COPPA”) without such parental consent. If you are a child under 13 years of age, you are not permitted to use the Site and should not send any information about yourself to us through the Services.

In the event that we become aware that we have collected personal information from any child, we will dispose of that information in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under the age of 13 has provided us with personal information without COPPA-required consent, please contact us at contact@AirModo.com

9. What About Security?

We endeavor to incorporate commercially reasonable safeguards to help protect and secure your Personal Information. No data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information, however, can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Services and provide us with your information at your own risk.

10. What About Changes to the Privacy Policy?

We reserve the right to change this Privacy Policy at any time. Any changes will be effective immediately upon the posting of the revised Privacy Policy and your use of the Services indicates your consent to the privacy policy posted at the time of use. Where we do update the policy, we will include the date of the last revision at the top of the document.  You should review this policy periodically to ensure you are aware of any such changes. We will not, however, use your previously collected Personal Information in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

11. Contact Us

If you have any questions about the Privacy Policy or practices described in it, you should contact us in the following ways: If you would like to request access to the Personal Information that USAU holds about you, or if you have any questions about this Privacy Policy, our privacy practices or the manner in which your Personal Information has been collected, used or disclosed, please contact us at:

Postal Mail: [125 Broad Street, 6th Floor, New York, NY 10004];

By e-mail privacy@AirModo.com.

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