• Flyer Club, INC (hereinafter “Flyer Club”) recognizes the importance of the privacy of its users and also of maintaining the confidentiality of the information provided by its users as a responsible data controller and data processor.
• This Privacy Policy provides for the practices for handling and securing user's Personal Information (defined hereunder) by Flyer Club and its subsidiaries and affiliates.
• This Privacy Policy is applicable to any person (‘User’) who purchases, intends to purchase, or inquire about any product(s) or service(s) made available by Flyer Club through any of Flyer Club’s customer interface channels including its website, mobile site, mobile app & offline channels including call centers and offices (collectively referred herein as "Services").
• For the purpose of this Privacy Policy, wherever the context so requires "you" or "your" shall mean User and the term "we", "us", "our" shall mean Flyer Club. For the purpose of this Privacy Policy, www.flyer-club.com means the website(s), mobile site(s) and mobile app(s) (Collectively referred to as “Site”).
• By using or accessing the Site or other Services, the User hereby agrees with the terms of this Privacy Policy and the contents herein. If you disagree with this Privacy Policy please do not use or access our Site or other Services.
• This Privacy Policy does not apply to any website(s), mobile sites, and mobile apps of third parties, even if their websites/products are linked to our Site. Users should take note that information and privacy practices of Flyer Club’s business partners, advertisers, sponsors, or other sites to which Flyer Club provides hyperlink(s), may be materially different from this Privacy Policy. Accordingly, it is recommended that you review the privacy statements and policies of any such third parties with whom they interact.
• This Privacy Policy is an integral part of your User Agreement with Flyer Club and all capitalized terms used, but not otherwise defined herein, shall have the respective meanings as known to the common man.

Protecting your Personal Information is one of our top priorities. In this manner, we lawfully collect information while acting honorably, discreetly, and with great certainty.

What is the reason for the privacy statement we have provided below? The objective is actually a clearly stated one that will appropriately represent how our organization gathers and manages customer personal data, while also discussing any other data consumers supply through various platforms when they purchase a good or service or sign up for our newsletter.

• This statement's objective is to let you know the measures we take to appropriately protect your personal data
• By using one of our platforms, you hereby agree to our Terms.
• We do not intend to knowingly collect information from children.

Personal Information we collect and use:

“Personal Information” is data that can fairly be used to contact you, identify you, relate to you, characterize you, or be linked directly or indirectly to you is referred to as "Personal Information." There is no discernible difference between "Personal Information" and "personal data" for the purposes of this Policy

We may collect, use and transfer the following types of personal data:

1. Identity Data: Which comprises a person's first and last names, a username or other unique identifier, their marital status, their title, their date of birth, their photos, their social security number, their job title, their vehicle registration number(s), their age, and their gender;

2. Contact Data: Which includes billing address, delivery address, personal email, and phone numbers;

3. Booking data: For example, each traveller's name, frequent flyer information, passport number and expiry date, redress control number, the nation of citizenship, booking reference number, and itinerary, which may include the name of the airline or carrier, hotel or vessel, port of destination, port of arrival, date and time of departure and/or check-in, date and time of arrival and/or check-out, meal preferences, luggage information, and layover or transfer information;

4. Financial Data: Which includes payment details such as card details or bank names;

5. Transaction Data: This contains your payments to us, the goods and Services you have purchased from us, as well as the activities you have engaged in;

6. Technical Data: Including any information that is automatically gathered from any device that accesses the Site or our Services. Such data may comprise, but not be limited to: your device's IP address, login information, browser type and version, time zone offset settings, geolocation, CPU, screen resolution, device memory, installed fonts, draw canvas logic, browser plug-in types and versions, operating system and platform, full "Uniform Resource Locators," clickstream to, through, and from the Site (including date and time), and other technology on the decentralized internet;

7. Profile Data: This contains your username and password, any orders or purchases you've made, your likes and preferences, comments and survey answers, as well as any items you've looked at or searched for; page response times, download issues, the duration of visits to specific pages, and page interaction data (such as scrolling, clicking, moving the mouse cursor over areas of the page, and how you navigated away from it);

8. Usage Data: Which includes information about how you use the Site, products, and Services;

9. Marketing and Communications Data: It includes your preferences for how you want to communicate with us and our third parties as well as how you want to receive advertisements from us;

10. Information that can include: Search history, IP address, screen resolution, the browser that was used, operating system, access times, and referring URL. We may also get information about your mobile device, its settings, and your location if you're using one;

11. Customer support information: We will record any questions, complaints, or other details you may send to our support team when you contact our customer support Services;

12. Any other information you provide to us.

• We assume the duty to gather, handle, and maintain your personal data securely only when you assure us that all the information is true and accurate to you.
• You warrant that you have the power to provide us with this information and to allow us to use the information in accordance with this Privacy Policy when you send any Personal Information pertaining to other individuals to us or to our service providers in connection with the Services.
• The provision of the above personal data, where requested, is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations except when we rely on consent as a legitimate basis for processing and or our legitimate interest. Without it, we may not be able to provide you with all the requested Services. It is important that all the personal data you give us is correct and accurate. This includes, by way of example only, ensuring that we have your correct contact (including email) details at all times.
• In case we have to collect your personal data according to law or under the terms and conditions of a contract with you (customer), and you don't provide the requested data, we can't finish the contract that we have or are trying to enter into with you. Therefore, we might need to cancel a service. However, in these types of situations, we will keep you informed.

At this time, the methods we and our third-party service provider use to collect your personal data are:

The Personal Information you give to us: Directly from you, we obtain your Personal Information. For instance, when you register, make travel arrangements, or get in touch with our customer care, you provide us with your Personal Information

We have the passive ability to collect some Personal Information. How does this happen?

When you visit our Site, you give us permission to collect certain information about yourself. In addition, when you are using our Site, cookies and other similar technologies can help us automatically collect technical data about your equipment, navigation actions, and patterns. See the cookies section of this Privacy Policy for further information.

Voice Calls: For contractual reasons, quality control, analytics, staff training, and/or to protect us in the event of a legal dispute, we may record or monitor calls to and from our Customer Support Team. We will handle any Personal Information we learn about you during the call in accordance with this Privacy Policy.

From Other Sources: To the extent authorized by applicable law, we may get your Personal Information from additional sources, such as public databases, joint marketing partners, social media platforms (including from users with whom you are friends or othe rwise connected), and other third parties.

Automatic Information: We may, when you visit our Site, automatically gather certain information about your computer. For instance, we keep track of your referring website, IP address, and web browser type (such as Firefox, Safari, or Internet Explorer). We might also compile data about your online behavior, including the trips and activities you view and the reservations you make. We gather this data automatically in order to personalize your user experience and safeguard against fraud. Also listed below are cookies and other technologies.

You can opt-out of this communication at any time by contacting us via phone or email.

We may use your Personal Information for the following purposes:

• To complete and fulfil your booking or purchase, including the processing of your payment, communicating with you regarding your booking or purchase, and offering you related customer service. This is done in order to establish and maintain the contractual relationship for the provision of the product and/or service that you have requested. You may get information about how we provide the Service, as well as any clarifications or assistance, via email, phone, SMS, recorded calls, or other similar technologies. To authenticate your account credentials and identify you, as necessary to log you into the Services and ensure the security of your account
• To communicate with you regarding your account or usage of our Services and/or functionality (for example: to send administrative information to you, such as details about the Services and updates to our terms and policies); to address your questions and requests, such as by sending you newsletters or following up on your comments and questions; and to perform other customer service tasks.
• For contractual reasons, quality control, analytics, staff training, and/or to protect us in the event of a legal dispute, we may record or monitor calls to and from our Customer Support Team.
• To send you marketing messages via email, phone, mail, SMS, or other comparable electronic communication about goods and Services.
• To enable you to access message boards, chat, profile pages, and other Services where you can submit content and resources (including our Social Media Pages). Please be aware that any information you reveal or upload through these Services will become public information and might be seen by those who frequent the Site and the general public.
• To improve your experience with the Services (please see the Cookies section of this Privacy Policy for further information). To show products and offers, marketing notifications, and advertising that are specifically suited to you based on your usage of our Site, products, Services, and other websites that are collected by cookies.
• To provide Services and information to travel partners, such as providing user feedback and usage details.
• For our business purposes, such as data analysis, market research, audits, developing new products, fraud monitoring, and prevention, to protect against, investigate, and deter fraudulent, unauthorized, or illegal activity.
• To comply with our policies, procedures, and legal obligations, including complying with law enforcement or government authority requests, addressing litigation-related issues, and exercising rights or obligations conferred by law.
• As otherwise consented to by you and as required or permitted by applicable law. If you give your consent to any further use of Personal Information, you can withdraw that consent at any time by contacting us using the details set out below.

As long as it serves the aforementioned goals and is legal to do so, we may contact you through electronic messaging, such as email, text message, or mobile push notification, to:

• Send you information relating to our products and Services: Booking confirmations and updates, technical notes and updates, security alerts, help requests, and administrative messages may all fall under this category.
• Send you marketing communications. In other instances, we might get in touch with you to let you know about giveaways, deals, prizes, forthcoming events, and other news on the goods and Services that we, our group companies, our travel partners, and other business partners offer.

Email Communications: Periodically, we might email you with details about your ostensible interests in travel or activities. We do this to make it simple for you to benefit from chances on our Site that have to do with travel or other things.

By clicking the "unsubscribe" link included in these emails, you can choose not to receive marketing and promotional emails from us in the future. In your account settings, if you have one, you can also choose not to receive marketing emails. Please be aware that we will still send you service-related messages, such as confirmations of any future bookings you place, even if you choose not to receive marketing emails from one or all of our Services.

Push Notifications (on Mobile Devices): You can use the settings on your mobile device to enable or turn off mobile push notifications from us.

SMS Message Service: In conjunction with the aforementioned goals, we may, with your permission, call, text, or use auto-disabled and prerecorded message calls at the mobile phone number you have provided to us.

You agree to receive recurrent autodialled marketing texts from or on behalf of our Company at the mobile number you have provided to opt-in by signing up for the SMS message service. You are aware that approval is not necessary for purchasing. Rates for messages and data may apply.

You can opt out of the SMS service at any time by simply replying "STOP" to any SMS message you get after signing up to receive messages online, in person, or via SMS. You won't get any more SMS texts from us after that. Even if you unsubscribe from our SMS service, we may still send you service-related SMS in relation to an existing booking. Simply sign up once more if you want to join, and we'll start sending you SMS messages once more.

You can simply reply "HELP" to the SMS message if you ever lose track of the terms that are supported. We will reply to your "HELP" SMS message with information on how to utilize our service as well as how to unsubscribe.

Any messages transmitted to you from us or to us from you may, as always, be subject to message and data fees. The user's interaction determines the frequency of messages. It is important to get in touch with your cellular operator if you have any questions about your text or data plan.

You represent that you are the account holder for the mobile telephone number(s) that you provide. You are responsible for notifying us immediately if you change your mobile telephone number. You may notify us of a number change by contacting us via email at info@flyer-club.com.

You consent to fully hold us harmless from any and all claims, costs, and losses resulting from or emerging under the Telephone Consumer Protection Act, as well as any other claims, costs, or losses that are connected to or result from your failure to notify us if you change your phone number.

For all questions about the SMS message service, you can contact us at:

Telephone: 888-564-9034

Email: info@flyer-club.com

In the event that we must share your information with a third party, we will do so in the following circumstances:

• only with your consent;
• if this action is strictly necessary to provide our Services;
• in the event that it is necessary to send information to a lawyer in order to begin the litigation resolution process;
• in the event that it is necessary to uphold the integrity and transparency of our business;

Additionally, our business partners may receive information regarding your personal data. Your Personal Information might be used by certain of these business partners for fraud detection, including an email address, to identify, stop, or otherwise handle fraud, security, or technical concerns. To determine the level of your satisfaction with our Services, we may also disclose your information by asking a partner to develop an application, questionnaire, etc. Your Personal Information might be used by some of these business partners to target you with online behavioral advertising or to provide you with Services or goods we think you'll find interesting. We might also disclose your information in other ways that were disclosed to you when we collected it. We could also provide anonymously

The Sites are based in the United States, and are directed to U.S. residents, and we process and store information in the U.S. If you are located outside the U.S., we and our service providers may transfer your information to, or store or access to your information in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We have adopted the appropriate security measures to avoid accidental loss, use or access to your personal data in an unauthorized manner, alteration or disclosure. In addition, we restrict access to your personal data only to those employees, agents, contractors, and other third parties who need to know the business. They will process your personal data only in accordance with our instructions and are subject to confidentiality.

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us via email at info@flyer-club.com.

We consider the quantity, nature, and vulnerability of the data as well as the purposes for which we process your Personal Information— even if we can achieve those purposes through other means—as well as the relevant legal, governmental tax, accounting, and other requirements in order to determine the necessary retention period for personal data.

What are Cookies?

Cookies and other similar technologies, such as local shared objects, flash cookies or pixels, are tools used by web servers to store and recover information about Site visitors, and also to ensure correct functioning of the Site.

Types of Cookies

Types of cookies depending on the organization managing them:

Own cookies: these cookies are sent to the user’s terminal from a computer or domain managed by the owner of the Site from which the service requested by the user is provided.

Third-party cookies: these cookies are sent to the user’s terminal from a computer or domain not managed by the owner of the Site from which the service requested by the user is provided, but by another organization that processes the data obtained through the cookies. In addition, if the cookies are installed from a computer or domain managed by the Site owner but the information collected by them is managed by a third party, they will also be considered third-party cookies.

Types of cookies according to their purpose:

Technical (strictly necessary) cookies: these are cookies that allow the user to browse a site, platform, or application and to use the different options or services thereon, including those that the editor uses to allow management and operation of the site and enable its functions and services. These include, for example, monitoring traffic and data communication, identifying the session, accessing restricted access areas, remembering the component elements of an order, carrying out the order purchase process, managing the payment, monitoring any fraud associated with the security of the service, dealing with an application for registration or participation in an event, counting the number of visits for the purposes of invoicing licenses for the software with which the service operates (website, platform or application), using security elements during browsing, storing content for the dissemination of videos or sound, enabling dynamic content (for example, animation to load a text or an image) or sharing content on social networks.

This category also includes, because of their technical nature, those cookies that allow the management, as efficiently as possible, of any advertising spaces that, as one more element of design or “layout” of the service offered to the user, the editor has included on a site, application or platform based on criteria such as the content edited, without compiling information about the users for other purposes, such as customizing this advertising content or other content.

Preference or functional cookies: these cookies are used to remember information so that the user can access the service with certain characteristics that differentiate his/her experience from that of other users such as, for example, the language, the number of results displayed when the user performs a search, the appearance or content of the service depending on the type of browser used by the user to access the service or the region from which he/she accesses the service, etc.

Analytics or performance cookies: these cookies allow the person or entity responsible for them to monitor and analyse the behaviour of users of the site with which they are associated, including quantifying the impacts of adverts. The information collected by this type of cookies is used to measure activity on the site, application or platform, in order to introduce improvements according to the analysis of the users’ data usage.

Behavioral advertising cookies (targeting cookies): these allow us to manage, as efficiently as possible, the advertising spaces on the site. These cookies store information on user behavior obtained through continuous observation of his/her browsing habits, allowing us to develop a specific profile to show the advertising adapted to that profile.

Geolocation cookies: these are used to find a user’s location when he/she requests a service. This cookie is anonymous and is used, for example, to offer you relevant information depending on the country where you are located.

Types of cookies according to the length of time they remain active:

Session cookies: these cookies are designed to collect and store data when the user accesses a website. They are generally used to store information that only needs to be kept for the provision of the service requested by the user on a single occasion (for example, a list of products bought) and disappear when the user logs off or ends the session.

Persistent cookies: with these cookies, the data continue to be stored in the terminal and may be accessed and processed for a period defined by the person/entity responsible for the cookie, which may range from a few minutes to several years.

HOW TO DISABLE COOKIES IN BROWSERS?

The user can, at any time, allow, block or delete the cookies installed on his/her device by changing the settings on the browser installed on his/her computer:

If you deactivate the cookies, it will not prevent you from browsing the website, but the use of some Services may be limited and, consequently, your browsing experience may be less satisfactory.

Below is an overview of the legal foundations we rely on to provide our Services to users in the European Union. Additionally, we have determined what your data subjects' rights are under EEA law and, if applicable, our legitimate interests.

Please take note that depending on the exact reason we are utilizing your data, we may process it for more than one legal basis. In the event that you require more information than what is provided below regarding the precise legal basis we are using to treat your personal data, please get in touch with us.

• To register you as a new customer.
• Type of data:
  1. Identity
  2. Contact
• Lawful basis for processing including the basis of legitimate interest:
  1. Performance of a contract with you.
• To process and deliver your order including:
  1. Manage payments, fees, and charges.
  2. Collect and recover money owed to us.
• Type of data:
  1. Identity
  2. Contact
  3. Financial
  4. Transaction
  5. Marketing and Communications
• Lawful basis for processing including the basis of legitimate interest:
  1. Performance of a contract with you.
  2. Necessary for our legitimate interests (to recover debts due to us).
• To manage our relationship with you which will include:
  1. Notifying you about changes to our terms or privacy policy.
  2. Asking you to leave a review or take a survey.
• Type of data:
  1. Identity
  2. Contact
  3. Profile
  4. Marketing and Communications
• Lawful basis for processing including the basis of legitimate interest:
  1. Performance of a contract with you
  2. Necessary to comply with a legal obligation.
  3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
• To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data).
• Type of data:
  1. Identity
  2. Contact
  3. Technical
• Lawful basis for processing including the basis of legitimate interest:
  1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganization or group restructuring exercise).
  2. Necessary to comply with a legal obligation.
• To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
• Type of data:
  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communications
  6. Technical
• Lawful basis for processing including the basis of legitimate interest:
  1. Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business, and to inform our marketing strategy).
• To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences.
• Type of data:
  1. Technical
  2. Usage
• Lawful basis for processing including the basis of legitimate interest:
  1. Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business, and to inform our marketing strategy).
• To make suggestions and recommendations to you about goods or services that may be of interest to you.
• Type of data:
  1. Identity
  2. Contact
  3. Technical
  4. Usage
  5. Profile
  6. Marketing and Communications
• Lawful basis for processing including the basis of legitimate interest:
  1. Necessary for our legitimate interests (to develop our products/services and grow our business).

1. You can ask for access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
2. Deletion of your personal data. This gives you the right to solicit us to delete or remove personal data from our system. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below). Note, in some cases when the legislation prohibits us to comply with your request, we will not delete or erase the data, anyway, you will be notified of that.
3. You can ask for the correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
4. The right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
5. Restriction of processing of your personal data. In the following cases:
   1. Establish the data's accuracy.
   2. Suspicions of illegal use of data.
   3. Hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
   4. Objections to our use of your data, at the same time we will verify whether we have superior legitimate motives of data usage
   5. Transfer of your personal data to you or to a third party.

Withdraw consent at any time where we are relying on consent to process your personal data.

In order to use any of the above-mentioned rights, you should contact us, and provide information to identify yourself, so we can be sure you are the entitled person to make the mentioned requests.

This privacy notice for California Residents supplements the information contained in our privacy policy above and applies solely to the personal data of users who reside in the State of California (“consumers” or “you”). We have included this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

Our Site collects information that identifies, relates to, describes, references is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). In particular, our Site has collected the following categories of Personal Information from its consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	[YES]
B. Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.	[YES]
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	[NO]
D. Commercial information.	Records of personal property, products or Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	[YES]
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	[NO]
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	[YES]
G. Geolocation data.	Physical location or movements.	[YES]
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	[NO]
I. Professional or employment-related information.	Current or past job history or performance evaluations.	[NO]
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	[NO]
K. Inferences drawn from other Personal Information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	[NO]
L. Equipment information.	Information about your internet connection, the equipment you use to access our Website, and usage details.	[YES]

Personal Information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.

Information excluded from the CCPA's scope, like:

• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
• Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

SALES OF PERSONAL INFORMATION

In the preceding twelve (12) months, Company has not sold Personal Information.

Your Rights and Choices:

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section de scribes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• Personal Information we collected about you.
• Sources for the Personal Information we collected about you
• Our purpose for collecting or selling that Personal Information.
• The third parties with whom we share that Personal Information.

Deletion Request Rights

Subject to certain limitations, you have the right to ask us to remove any of your personal information that we have acquired and kept about you. Unless an exception applies, we will remove (and instruct our service providers to delete) your Personal Information from our records once we receive and validate your genuine consumer request.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Debug products to identify and repair errors that impair existing intended functionality
• Comply with a legal obligation.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement if you previously provided informed consent.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
• provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative;

If we cannot validate your identity or authority to make the request and ensure the Personal Information corresponds to you, we will not be able to reply to your request or supply you with Personal Information. To confirm the requestor's identity or right to make the request, we shall only use the Personal Information contained in a verifiable consumer request.

Response Timing and Format

Within forty-five (45) days after receiving a valid customer request, we make an effort to respond. If we need longer time (up to 90 days), we will write to let you know why and for how long.

We will deliver our written response to that account if you have one with us. If you don't already have an account with us, you can choose whether to get our written response via mail or electronic delivery.

Any disclosures we make will only be for the twelve months prior to the consumer's verifiable request being received. If appropriate, we will additionally explain in our response why we are unable to fulfill a request. For requests for data portability, we will choose a format to deliver your Personal Information that is simple to use and should enable unhindered transmission of the data from one entity to another.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Do Not Sell My Personal Information

Our Company does not sell your Personal Information to third parties.

We do not provide any guarantee or warranty by us that your information will not be accessed or compromised by third parties, or that your information will be transmitted without unauthorized interception or modification, we will use all available security te chnologies to prevent unauthorized access to, use, or disclosure of your personally-identifying information. We may permanently delete or destroy any and all information at any time as determined by us.

Please be aware that our company's privacy policy is subject to modifications from time to time.

Additionally, it should be noted that our organization has no right to and will never limit your ability to have your Personal Information protected.

As a precaution, we will notify you in advance of any changes to our Site and post the date of the most recent update. You are deemed to have accepted modifications if you continue to use our Site after they have been posted.

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your information described above, your choices and rights regarding such use, or wish to exercise your rights, please do not hesitate to contact us.

Email: info@flyer-club.com

Contact: 888-564-9034

Last Update: December 5th 2022