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Privacy Policy

Updated March 1, 2024

 

This website is operated by Paws Airlines. The privacy of our users is essential to us, and therefore, we encourage all users to read this policy very carefully because it contains vital information. This privacy policy will inform you how we look after your data when you visit our website (regardless of where you visit it from) or by enquiring us. We will also tell you about your privacy rights and how the law protects you.

 

Purpose of this privacy policy

This privacy policy aims to inform you how Paws Airlines collects and processes your data, which we collect through your contact with us, including any data you may provide during our relationship with you as a client or potential client. The data may be collected using our website, through direct contact with our employees or authorized agents through telephone, email, social media, or any other legitimate means not explicitly identified here.

 

This website is not intended for children, and we do not knowingly collect data relating to children.

 

You must read this privacy policy and any other privacy policy or fair processing policy we may provide on specific occasions when we collect or process personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

 

Controller

Paws Airlines LLC is the controller and responsible for your data (collectively referred to as “ Paws Airlines,” “we,” “us,” or “our” in this privacy policy).

 

Contact details

For any questions you may have about this Privacy Policy or any issue regarding our use of your data, please get in touch with Paws Airlines by email at info@paws-air.com or by post at  Paws Airlines 801 Hangar Lane, Hangar #9, Nashville, TN 37217.

 

You can complain about data protection issues to the Information Commissioner’s Office (ICO), the USA regulator (www.ico.org). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please get in touch with us in the first instance.

 

Please inform us of changes.

We keep our privacy policy under regular review. This privacy policy was published on January 12024, and historical versions can be obtained by contacting us.

 

The personal data we hold about you must be accurate and current. Please keep us informed if your data changes during your relationship.

 

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking or enabling those links may allow third parties to collect or share your data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

 

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped as follows:

 

Identity Data includes first name, maiden name, last name, title, job title, username or similar identifier, potentially your business /company name, marital status, gender (where required), passport or ID number and photo.

Contact Data includes billing, postal, and email addresses and telephone numbers.

 

Financial Data includes bank account details and payment card details.

Travel Data includes information about your booking and travel itinerary and arrangements, revisions to booked arrangements, dietary requirements, special assistance that you may require, or other passengers traveling on your booking or connection with your travel itinerary, details of any travel, visa and work permit information where the authorities require this in any destination.

Medical Data includes details about any medical conditions or results that may be relevant to or affect your proposed journey and your ability to travel between countries.

 

Technical Data includes [internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology you use to access this website.

 

Usage Data includes information about how you use our website, products and services.

 

Profile Data includes your quote requests and flight bookings, interests, preferences, feedback and survey responses. 

 

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use, and share aggregate data, such as statistical or demographic data, for any purpose. Aggregated Data could be derived from your data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, suppose we combine or connect Aggregated Data with your data so that it can directly or indirectly identify you. In that case, we treat the combined data as personal data, which this privacy policy will use.

 

We may collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data, any information about criminal convictions and offenses) to perform the required services.

 

If you fail to provide personal data

Where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

 

How is your data collected?

We use different methods to collect data from and about you, including through:

Direct interactions. You may give us your Identity, Contact, Financial, Travel or Medical Data by filling in forms or corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

Ask for a quote for services; apply for our products or services; place an order for our services directly or through a third party; create an account on our website; subscribe to our service or publications; request marketing to be sent to you or using the Please give us feedback or contact us feature.

 

We have automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

 

Automatically collected information (including cookies and geolocation).

When you use our Services, we may receive technical information such as your browser type, the operating system you use, your geolocation, the name of your internet service provider, mobile advertising identifiers, and pages visited on our Services. American gets this information by using technologies, including cookies, web beacons, and mobile device geolocation, to provide and improve our Services and advertising across browsers and devices (also known as cross-device linking). We also use this information to verify that visitors meet the criteria required to process their requests and to report activity on our services. For example, we want to know how long the average user spends on our Services or which pages or features get the most attention. This technical information may be combined with personally identifiable information to personalize our Services and advertising to your interests, including across browsers and devices. For example, review a particular flight or destination but still need to complete a travel reservation. We may use this information to show you targeted advertising about similar flights or destinations on our Services or third-party websites. Some of this information may be shared with third parties, as described in the section titled “Information collected by third parties on our Services.”

Additionally, and with your specific consent where the law requires, Americans may combine the information we receive from you with other sources. This information may be used to provide offers and services specifically tailored to your interests by applicable laws.

 

When you use our Services, we and third parties on our Services may automatically receive information using tracking technologies such as cookies, web beacons, pixel tags, and similar technologies (collectively, “Cookies”). This information includes your browser type, IP address, type of operating system you use, the name of your internet service provider, mobile advertising identifiers, and pages visited on our Services.

 

Cookies and online advertising.

We use Cookies for various reasons, including to provide and improve our Services and advertising and to show you relevant advertising, including across browsers and devices (also known as cross-device linking). Some Cookies are necessary to keep our Services secure. Others make sure you get a high-quality experience and receive relevant advertising.

Some of our Services include social networks or other third-party plug-ins (such as Facebook’s "Like" button) that enable you to log in to certain Services, comment on content available on our Services, and share things you find on our Services with your social network. The providers of these plug-ins may be able to collect information about you even if you do not click on or otherwise interact with the plug-in or widget, regardless of whether you have an account or other relationship with these social networks and third parties. If you use social network tools or visit social networking sites, you should read their privacy disclosures to learn what information they collect, use, and share.

 

What is a cookie?

A cookie is a small text file (often including a unique identifier) sent to a user’s browser from a website’s computer and stored on a user’s computer’s hard drive, tablet, or mobile device. The cookie stores a small amount of data about your visit to the Services on your device. Some Cookies are “session cookies,” which expire at the end of the browser session and can capture your activities during the browser session. Other Cookies are “persistent cookies” that remain on your device for the period specified in the Cookie and can capture your settings or activities on multiple websites.

Cookies allow websites to recognize your browser or device while using our Services. Some Cookies also allow us to track your behavior when you use other entities’ services (e.g., websites or apps).

 

 

Biometric Data. You should be aware that facial recognition and biometric technology are used in some airports to facilitate passenger boarding.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

  • Technical Data from analytics providers such as Google based outside the US;

  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Thomas Reuters based inside and outside the US; and

  • Identity and contact data are from publicly available sources such as the USA's Companies House and the Electoral Register.

How we use your data

We will only use your data when the law allows us to. Most commonly, we will use your data in the following circumstances:

  • Where do we need to perform the contract we are about to enter into or have entered into with you?

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights, do not override those interests.

  • Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your data. However, we will get your permission before sending you third-party direct marketing communications via email or text. You can withdraw consent to marketing at any time by contacting us.

 

Purposes for which we will use your data

In a table format, we have described below all the ways we plan to use your data and which legal bases we rely on. We have also identified what our legitimate interests are where appropriate.

 

Note that we may process your data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please get in touch with us if you need details about the legal ground we rely on to process your data.

 

Marketing

We strive to provide you with choices regarding specific personal data uses, mainly marketing and advertising. We have established the following personal data control mechanisms.

 

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view of what we think you want or need or what may interest you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications if you have requested information or purchased broker services from us and have yet to opt out of receiving that marketing.

 

Opting out

You can ask us or third parties to stop sending you marketing messages by contacting us anytime. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us due to our provision of broker services to you.

 

Change of purpose

We will only use your data for the purposes we collected it unless we consider that we need to use it for another reason. That reason is compatible with the original purpose. If you wish to explain how the processing for the new purpose is compatible with the original purpose, please get in touch with us.

If we need to use your data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. Please note that we may process your data without your knowledge or consent in compliance with the above rules where this is required or permitted by law.

 

Disclosures of your data

We may share your data with the parties below for the purposes set out in the table Purposes for which we will use your data above.

 

External Third Parties will perform the required services.

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may use your data the same way as set out in this privacy policy. We require all third parties to respect your data's security and treat it by the law. We do not allow our third-party service providers to use your data for their purposes and only permit them to process it for specified purposes and by our instructions.

 

International transfers

We may need to share your data with third-party operators or other professional advisors with whom it is necessary to share your data to provide you with the services we have contracted with you. This may involve transferring your data outside the US.

Whenever we transfer your data out of the US, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your data to countries that have been deemed to provide an adequate level of protection for personal data. For further details, see American Commission: Adequacy of protecting personal data in non-EU countries.

  • Where we use certain service providers, we may use specific contracts approved by the American Commission, which give personal data the same protection it has in The USA. For further details, see American Commission: Model contracts for transferring personal data to third countries. 

  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to personal data shared between the USA and the US. For further details, see American Commission: EU-US Privacy Shield.

Please get in touch with us if you want further information on the specific mechanism we use when transferring your data out of the USA.

 

Data security

We have implemented appropriate security measures to prevent your data from being accidentally lost, used, accessed unauthorizedly, altered or disclosed. In addition, we limit access to your data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your data on our instructions and are subject to a duty of confidentiality.

 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

How long will you use my data?

We will only retain your data for as long as reasonably necessary to fulfill the purposes we collected it, including satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your data for a more extended period in case of a complaint or if we reasonably believe there is a prospect of litigation concerning our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your data, the purposes for which we process your data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances, you can ask us to delete your data: see your legal rights below for further information.

In some circumstances, we will anonymize your data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

 

Your legal rights

Under certain circumstances, you have rights under data protection laws about your data:

Request access to your data.

Request correction of your data.

Request the erasure of your data.

Object to processing of your data.

Request restriction of processing your data.

Request transfer of your data.

Right to withdraw consent.

If you wish to exercise any of the rights set out above, please get in touch with us.

No fee is usually required.

You will not have to pay a fee to access your data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may request specific information from you to help us confirm your identity and ensure your right to access your data (or to exercise any of your other rights). This security measure ensures that personal data is not disclosed to anyone who has no right to receive it. We may also contact you to ask you for further information about your request to speed up our response.

 

Time limit to respond

We respond to all legitimate requests within one month. Occasionally, it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

 

Glossary

 

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your data for our legitimate interests. We do not use your data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you regarding specific activities.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Complying with a legal obligation means processing your data where necessary for compliance with a legal obligation that we are subject to.

 

THIRD PARTIES

External Third Parties

Service providers act as processors based within the USA, providing IT and system administration services.

Third parties that provide travel assistance include companies that offer ground transportation services, ground handling, catering, customs and immigration authorities.

Professional advisers and aviation professionals acting as processors or joint controllers, including lawyers, bankers, auditors, insurers, aviation agents or brokers based both in the USA and outside the USA who provide consultancy, banking, legal, insurance and accounting services.

The air operators or carriers acting as processors are based both in the USA and outside the USA.

 

HM Revenue & Customs, regulators and other authorities based in the United Kingdom require reporting of processing activities in certain circumstances. Depending on the nature of the broker services we provide, the regulators or other authorities may be based both inside or outside the USA. Fraud prevention agencies or other providers of services utilized to detect or prevent fraud, ensuring compliance with anti-money laundering, bribery or corruption legislation, or otherwise assisting us in conducting necessary due diligence required of us by professional rules of conduct or other relevant laws.

 

YOUR LEGAL RIGHTS

You have the right to:

Request access to your data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request 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. However, we need to verify the accuracy of your new data.

Request the erasure of your data. This enables you to ask us to delete or remove personal data without a good reason for continuing to process it. You also have the right to ask us to delete or remove your data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.

Object to processing of your data where we rely on a legitimate interest (or those of a third party), and something about your particular situation makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your 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.

Request restriction of processing of your data. This enables you to ask us to suspend the processing of your data in the following scenarios:

If you want us to establish the data’s accuracy.

Where our use of the data is unlawful, but you do not want us to erase it.

You need us to hold the data even if we no longer require it, as you need it to establish, exercise or defend legal claims.

You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your data to you or a third party. We will provide you, or a third party you have chosen, your data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your data. However, this will not affect the lawfulness of any processing before you withdraw your consent. We may not provide certain products or services if you withdraw your consent. We will advise you if this is the case when you withdraw your consent.

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