Last Updated: August 9, 2024

This Privacy Policy applies to the processing of personal information by Revaire Inc. (“Revaire,” “we,” “us,” or “our”) including on our website available at www.revaire.club, our mobile application and our other online or offline offerings which link to, or are otherwise subject to, this Privacy Policy (collectively, the “Services”).

1. UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time in our sole discretion. If we do, we’ll let you know by posting the updated Privacy Policy on our website, and/or we may also send other communications.

2. PERSONAL INFORMATION WE COLLECT

We collect personal information that you provide to us (as an applicant, a member or a website visitor) about yourself and your guests, personal information we collect automatically when you use the Services, and personal information from third-party sources, as described below.

A. Personal Information You Provide to Us Directly

We may collect personal information that you provide to us about you and your guests.

·   Account and Reservation Information. We may collect personal information in connection with the application, creation or administration of your member account and any reservations you make. This personal information may include, but is not limited to, your name, email address, phone number, and other information you store with your account such as your dietary preferences.  We may also collect some of this information about any of your guests.

·   Purchases. We may collect personal information and details associated with your purchases, including payment information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).

·   Your Communications with Us. We, and our service providers, may collect the information you communicate to us, such as through email or our web chat tool. 

·   Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.

·   Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.

·   Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

·   Job Applications. If you apply for a job with us, we will collect any personal information you provide in connection with your application, such as your contact information and CV.

B. Personal Information Collected Automatically

We may collect personal information automatically when you use the Services. 

·   Device Information. We may collect personal information about your device, such as your Internet protocol (IP) address, user settings, cookie identifiers, other unique identifiers, browser or device information, Internet service provider, and location information (including, as applicable, approximate location derived from IP address and precise geo-location information). 

·   Usage Information. We may collect personal information about your use of the Services, such as the pages that you visit, items that you search for, the types of content you interact with, information about the links you click, the frequency and duration of your activities, and other information about how you use the Services.

·   Cookie Policy (and Other Technologies). We, as well as third parties, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect personal information through your use of the Services.

o   Cookies. Cookies are small text files stored in device browsers.

o   Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects personal information about use of or engagement with the Services. The use of a pixel tag allows us to record, for example, that a user has visited, a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

C. Personal Information Collected from Third Parties

We may collect personal information about you from third parties.  For example, if you access the Services using a Third-Party Service (defined below), we may collect personal information about you from that Third-Party Service that you have made available via your privacy settings. In addition, users of the Services may upload or otherwise provide personal information about others.

o   Google API Integrations. In order to provide the Services we receive information from Google APIs, subject to user consent.  Revaire's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. Information received from Google APIs is not shared with any third-party AI models. 

3. HOW WE USE PERSONAL INFORMATION

We use personal information for a variety of business purposes, including to provide the Services, for administrative purposes, and to provide you with marketing materials, as described below.

A. Provide the Services

We use personal information to fulfill our contract with you and provide the Services, such as:

·   Managing your information;

·   Purchasing shares of an aircraft for a charter flight;

·   Chartering an entire aircraft for a flight;

·   Providing access to certain areas, functionalities, and features of the Services;

·   Answering requests for support;

·   Communicating with you;

·       Sharing personal information with third parties as needed to provide the Services;

·   Processing your financial information and other payment methods for products and Services purchased;

·   Processing applications if you apply for a job we post on our Services; and

·   Allowing you to register for events.

·   Reviewing membership applications to make membership decisions

B. Administrative Purposes

We use personal information for various administrative purposes, such as:

·   Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;

·   Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

·   Carrying out analytics;

·   Measuring interest and engagement in the Services;

·   Improving, upgrading, or enhancing the Services;

·   Developing new products and services;

·   Creating de-identified and/or aggregated information. If we create or receive de-identified information, we will not attempt to reidentify such information, unless permitted by, or required to comply with, applicable laws;

·   Ensuring internal quality control and safety;

·   Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy;

·   Debugging to identify and repair errors with the Services;

·   Auditing relating to interactions, transactions, and other compliance activities;

·   Enforcing our agreements and policies; and

·   Carrying out activities that are required to comply with our legal obligations.

C. Marketing

We may use personal information to tailor and provide you with marketing and other content. We may provide you with these materials as permitted by applicable law.  If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.

D. With Your Consent or Direction

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information, with your consent, or as otherwise directed by you.

E. Automated Decision Making

We may engage in automated decision making.  Revaire’s processing of your personal information will not result in a decision based solely on automated processing that has a legal or other similarly significant effect on you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making.  If you have questions about our automated decision making, you may contact us as set forth in “Contact Us” below.

4. HOW WE DISCLOSE PERSONAL INFORMATION

We disclose personal information to third parties for a variety of business purposes, including to provide the Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide the Services

We may disclose any of the personal information we collect to the categories of third parties described below.

·   Service Providers. We may disclose personal information to third-party service providers that assist us with the provision of the Services. This may include, but is not limited to, service providers that provide us with hosting, customer service, analytics, marketing services, IT support, and related services. In addition, personal information and chat communications may be disclosed to service providers that help provide our chat features.

Some of the service providers we may use include:

o   Google Analytics. For more information about how Google uses your personal information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your personal information, please click here.

·   Third-Party Services You Share or Interact With. The Services may link to or allow you to interface, interact, share information with, direct us to share information with, access and/or use third-party websites, applications, services, products, and technology (each a “Third-Party Service”).

Any personal information shared with a Third-Party Service will be subject to the Third- Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.

·   Business Partners and Investors. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.

Once your personal information is shared with our business partner, it will also be subject to our business partner’s privacy policy. We are not responsible for the processing of personal information by our business partners. 

We may also share aggregated, de-identified or pseudonymized personal information with investors or potential investors.

·   Affiliates. We may share your personal information with our corporate affiliates. 

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction.

D. Disclosure Regarding Sensitive Personal Information 

To the extent we use and disclose sensitive personal information, we do so for the following purposes:

·   To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.

·   To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, and/or confidentiality of stored or transmitted personal information.

·   To resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for those actions.

·   To ensure the safety of natural persons.

·   For short-term, transient use. For example, Revaire will watch your inbox for commercial flight reservations and only scan for flight-related emails. We only store flight details, we never store your emails, and Revaire staff will never have access to your inbox.

·   Maintaining or servicing accounts, providing customer service, processing, or fulfilling purchases and transactions, verifying customer information, processing payments, and providing analytic services or providing similar services.

·   For purposes that do not infer characteristics about individuals.

5. YOUR PRIVACY CHOICES AND RIGHTS 

Your Privacy Choices. The privacy choices you may have about your personal information are described below.

·   Email Communications. If you receive an unwanted email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails. We may also send you certain non-promotional communications regarding us and the Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to this Privacy Policy).

·   Text Messages. If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in “Contact Us” below. 

·   Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device. To request deletion of your account, please use the standard deletion functionality available via the Services, or contact us using the information set forth in “Contact Us” below. Please note that even if you delete your account, certain information, such as previous bookings, may be retained for legal and compliance purposes.

·   “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

·   Cookies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Services may not work properly. 

Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of certain tracking on some mobile applications by following the instructions for Android, iOS, and others. 

The online advertising industry also provides mechanisms that may allow you to opt out of receiving targeted ads from organizations that participate in self-regulatory programs. To learn more, visit the Network Advertising Initiative, the Digital Advertising Alliance, and the European Digital Advertising Alliance.

Please note you must separately opt out in each browser and on each device.

6. SECURITY

We implement reasonable and appropriate physical, technical, and administrative controls to protect your personal information from unauthorized access, use or disclosure, and monitor such controls to help minimize risks from any security threats, including encryption of sensitive and confidential information. We also ensure that any service provider, processor, or sub-processor processing your personal information on our behalf contractually commits to appropriate security measures to ensure the protection of your personal information during the entire lifecycle of processing activities.

7. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live.

8. CHILDREN’S PERSONAL INFORMATION

Our website and mobile application are not directed to children under 16 (or other age as required by local law outside the United States), and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has uploaded personal information to the Services in violation of applicable law, you may contact us as described in “Contact Us” below.

9. THIRD-PARTY WEBSITES/APPLICATIONS

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

10. CONTACT US

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at: privacy@revaire.club.