Privacy Policy

LEGAL FRAMEWORK INTEGRATION

This Privacy Policy is part of our comprehensive legal framework and should be read in conjunction with:

• Terms of Use: Governing all service relationships and binding agreements
• Legal Disclaimer: Important limitations and service disclaimers across all service categories
• Post-Issuance Restrictions: Governing operational limitations and procedures after service confirmation

This policy should also be read in conjunction with all applicable restrictions or disclaimers published by Flyer Club, Inc.

For complete understanding of your rights and obligations regarding all our luxury services, please review all documents in our legal framework available at flyer-club.com.

Flyer Club, Inc. ("we," "us," or "our") is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our luxury travel and lifestyle services, visit our website at flyer-club.com, or interact with us through any channel.

This Privacy Policy applies to all services provided by Flyer Club, Inc., including flight bookings, hotel accommodations, luxury villa rentals, private jet arrangements, ground transportation, entertainment bookings, and lifestyle concierge services.

By using our services, you consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy and as outlined in our Terms of Use.

WHAT PERSONAL INFORMATION WE COLLECT

Information You Provide Directly

Travel and Booking Information:

• Full name, date of birth, and gender
• Passport and travel document information
• Contact information (address, phone, email)
• Payment and billing information
• Travel preferences and special requirements
• Emergency contact information

Flight Services Information:

• Airline preferences and frequent flyer numbers
• Seat preferences and special assistance needs
• Meal preferences and dietary restrictions
• Baggage requirements and special handling needs

Hotel and Accommodation Information:

• Room preferences and special requests
• Loyalty program memberships
• Accessibility requirements
• Guest preferences and amenities

Luxury Villa Information:

• Property preferences and requirements
• Guest count and special arrangements
• Staff service preferences
• Event and celebration planning details

Private Jet Services Information:

• Aircraft preferences and requirements
• Passenger manifest information
• Catering and amenity preferences
• Ground handling requirements

Ground Transportation Information:

• Vehicle preferences and requirements
• Pickup and destination details
• Special assistance needs
• Chauffeur service preferences

Entertainment and Lifestyle Information:

• Event and experience preferences
• Venue and artist preferences
• Dietary restrictions and accessibility needs
• Personal shopping and styling preferences
• Wellness and spa service preferences

Information We Collect Automatically

Website and Platform Usage:

• IP address and device information
• Browser type and operating system
• Pages visited and time spent on our website
• Search queries and booking patterns
• Cookies and similar tracking technologies

Communication Records:

• Phone call recordings (with consent)
• Email correspondence
• Chat and messaging interactions
• Customer service communications

Information from Third Parties

Service Provider Information:

• Booking confirmations and updates
• Service delivery information
• Loyalty program data
• Travel disruption notifications

Payment Processor Information:

• Transaction verification data
• Fraud prevention information
• Payment method validation

HOW WE USE PERSONAL INFORMATION

Service Delivery and Management

We use your personal information to:

• Process and manage your luxury service bookings
• Coordinate with airlines, hotels, villa operators, aircraft operators, transportation providers, entertainment venues, and lifestyle service providers
• Provide customer support and assistance
• Send booking confirmations and travel updates
• Manage your account and preferences

Personalization and Enhancement

We use your information to:

• Personalize your travel and lifestyle experiences
• Recommend services based on your preferences
• Customize our website and communications
• Improve our service offerings
• Develop new luxury services and experiences

Business Operations

We use your information for:

• Payment processing and billing
• Fraud prevention and security
• Legal compliance and regulatory requirements
• Business analytics and reporting
• Marketing and promotional activities (with consent)

Communication and Support

We use your information to:

• Respond to your inquiries and requests
• Provide customer service and support
• Send service-related notifications
• Communicate about account changes or updates
• Conduct satisfaction surveys and feedback collection

HOW WE SHARE PERSONAL INFORMATION

Service Providers and Partners

We share your information with:

Airlines and Aviation Partners:

• Flight booking and ticketing information
• Passenger details for security and regulatory compliance
• Special assistance and meal preferences
• Frequent flyer program information

Hotel and Accommodation Partners:

• Guest information for reservations
• Room preferences and special requests
• Loyalty program details
• Payment and billing information

Luxury Villa Operators:

• Guest details and preferences
• Property requirements and arrangements
• Staff service coordination
• Event planning information

Private Jet Operators:

• Passenger manifest information
• Aircraft preferences and requirements
• Catering and amenity arrangements
• Ground handling coordination

Ground Transportation Providers:

• Passenger details and preferences
• Pickup and destination information
• Vehicle requirements and special needs
• Chauffeur service arrangements

Entertainment and Lifestyle Providers:

• Guest information for bookings
• Event and experience preferences
• Dietary restrictions and accessibility needs
• Personal service arrangements

Business Partners and Affiliates

We may share information with:

• Trusted business partners who assist in service delivery
• Affiliated companies within our corporate family
• Technology providers who support our operations
• Marketing partners (with your consent)

Legal and Regulatory Requirements

We may disclose information when required by:

• Legal process or court orders
• Government agencies and regulatory authorities
• Law enforcement investigations
• National security requirements
• Compliance with international travel regulations

Business Transactions

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity, subject to the same privacy protections.

DATA RETENTION AND STORAGE

Retention Periods

We retain your personal information for different periods based on the type of information and business requirements:

• Active Account Information: Retained while your account is active and for a reasonable period thereafter
• Booking and Transaction Records: Retained for up to 7 years for business and legal purposes
• Communication Records: Retained for up to 3 years for customer service and quality purposes
• Marketing Information: Retained until you opt out or withdraw consent

Secure Storage

Your personal information is stored on secure servers with appropriate technical and organizational safeguards. We use industry-standard encryption and security measures to protect your data.

International Transfers

Your information may be transferred to and processed in countries other than your country of residence, including the United States. We ensure appropriate safeguards are in place for international transfers.

YOUR RIGHTS IN RESPECT OF PERSONAL INFORMATION

Access and Correction

You have the right to:

• Access the personal information we hold about you
• Request correction of inaccurate or incomplete information
• Update your account information and preferences
• Request a copy of your personal information

Data Portability and Deletion

You may request to:

• Receive your personal information in a portable format
• Delete your personal information (subject to legal and business requirements)
• Restrict processing of your personal information in certain circumstances

Marketing and Communications

You can:

• Opt out of marketing communications at any time
• Update your communication preferences
• Withdraw consent for marketing activities
• Continue to receive service-related communications

Exercising Your Rights

To exercise your privacy rights, please contact us at:

• Email: privacy@flyer-club.com
• Phone: +1 844-447-0007
• Mail: Privacy Officer, Flyer Club, Inc., 1603 Capitol Avenue, Suite 413 #B102, Cheyenne, WY 82001

We will respond to your requests within a reasonable timeframe and may require verification of your identity.

COOKIES AND TRACKING TECHNOLOGIES

Types of Cookies We Use

Essential Cookies: Required for website functionality and security

Performance Cookies: Help us understand how you use our website

Functionality Cookies: Remember your preferences and settings

Marketing Cookies: Used to deliver relevant advertisements (with consent)

Cookie Management

You can control cookies through your browser settings, but disabling certain cookies may affect website functionality. Our website includes cookie management tools to help you control your preferences.

Third-Party Tracking

We may use third-party analytics and marketing tools that place cookies on your device. These tools are subject to their own privacy policies.

SECURITY MEASURES

Technical Safeguards

We implement robust security measures including:

• Encryption of sensitive data in transit and at rest
• Secure server infrastructure and network protection
• Regular security assessments and updates
• Access controls and authentication systems

Organizational Safeguards

Our security practices include:

• Employee training on privacy and security
• Limited access to personal information on a need-to-know basis
• Regular security audits and compliance reviews
• Incident response and breach notification procedures

Payment Security

Payment information is processed through secure, PCI-compliant payment processors. We do not store complete payment card information on our systems.

CHILDREN'S PRIVACY

Our services are not directed to children under 13 years of age. We do not knowingly collect personal information from children under 13. If we become aware that we have collected information from a child under 13, we will take steps to delete such information.

For travel bookings involving minors, we collect information necessary for travel arrangements and safety, with appropriate parental or guardian consent.

INTERNATIONAL PRIVACY LAWS

GDPR Compliance (European Union)

For EU residents, we comply with the General Data Protection Regulation (GDPR) and provide additional rights including:

• Legal basis for processing your information
• Enhanced consent mechanisms
• Data protection officer contact information
• Right to lodge complaints with supervisory authorities

CCPA Compliance (California)

For California residents, we comply with the California Consumer Privacy Act (CCPA) and provide additional rights including:

• Right to know what personal information is collected
• Right to delete personal information
• Right to opt out of sale of personal information
• Right to non-discrimination for exercising privacy rights

Other Jurisdictions

We comply with applicable privacy laws in all jurisdictions where we operate and may provide additional rights and protections as required by local law.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or legal requirements. Material changes will be communicated through:

• Email notification to registered users
• Prominent notice on our website at flyer-club.com
• Updated effective date at the top of this policy

Continued use of our services after notification of changes constitutes acceptance of the updated Privacy Policy.

THIRD-PARTY WEBSITES AND SERVICES

Our website may contain links to third-party websites and services. This Privacy Policy does not apply to third-party sites, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party sites you visit.

Service Providers may have their own privacy policies governing their collection and use of your information. We encourage you to review these policies when interacting with Service Providers.