Privacy Notice

PLEASE READ THIS PRIVACY NOTICE CAREFULLY.

OTG Experience, LLC, a Delaware limited liability company (together with its affiliates, “OTG” and also referred to herein as “we”, “us”, “our” and similar terms), operates certain websites, mobile apps, web-based applications, and kiosks or other devices (collectively, the “Programs”) that reference this OTG Privacy Notice (this “Privacy Notice”).

FOR ACCOUNT HOLDERS, THIS PRIVACY NOTICE IS ALSO INCORPORATED INTO AND MADE A PART OF OUR TERMS OF USE AGREEMENT.

We Reserve the Right to Modify this Privacy Notice. The effective date of the Privacy Notice is forth above. We reserve the right to modify this Privacy Notice at any time by posting amended terms or otherwise notifying you of changes to this Privacy Notice. Your continued use after such amendment indicates your acceptance of the amended Privacy Notice. IF YOU DO NOT AGREE TO CHANGES TO THIS PRIVACY NOTICE, YOU MUST STOP USING THE PROGRAMS AFTER THE EFFECTIVE DATE OF SUCH CHANGES. You should check this Privacy Notice periodically for modifications by referencing the effective date posted above. We will not materially change our policies and practices to make them less protective of Personal Information collected in the past without the consent of affected users.

• Personal Information in General. In some cases, we may request specific permission to collect Personal Information from you. By “Personal Information we mean information that can identify or reasonably be linked to you.
• Types and Sources of Personal Information.
• Order Data. In order to place an order through the Programs, you may be required to provide Personal Information, such as your name, seat location for delivery, payment method (from available options), email address or phone number. We refer to Personal Information provided in connection with an order as “Order Data.” We do not store payment method data in a manner that would permit purchases with the information. We use a third-party payment processor who is responsible for processing payments using your payment method in a secure manner. OTG is not responsible for the information practices of this third-party payment processor, and the third-party processor’s use of your credit card number or other Personal Information is governed by the payment processor’s own privacy notice and the Payment Card Industry Data Security Standard promulgated and enforced by payment card issuers.
• Registration Data. We reserve the right to require you to register or create an account with OTG in order to receive certain benefits, offers or services. In order to register or create an account with OTG, you may be required to provide Personal Information such as your name, location of residence, email address or phone number. We refer to Personal Information provided in connection with registration or account creation as “Registration Data.”
• Account Data. If you choose to scan your boarding pass, otherwise voluntarily provide us with your flight information and/or seek to use your airline’s frequent flyer points or miles or other rewards program, we may offer you certain products and services (e.g., pay with miles) and participation in certain programs based on the account associated with your airline frequent flyer or other rewards program number. In such a case, we may obtain certain Personal Information about you directly from the airline and rewards provider and may combine it with other Personal Information collected directly from you as described in this Privacy Notice. In these cases, all information associated with your airline frequent flyer or other rewards program number is or may be Personal Information. We refer to this type of Personal Information as “Account Data.”
• Location Data. We may collect Personal Information about your location when using the Programs by using mobile device location based tracking methods. Location based tracking uses methods that include GPS, wireless networks, cell towers, Wi-Fi access points, and other sensors, such as gyroscopes, accelerometers, and compasses. Your mobile device may include settings to disable the Programs’ access to your location. Please check your device and/or operating system instructions for availability and details. Note, however, that failure to opt-in to, or later opting-out of, the collection of location information will result in limitations in our ability to provide our full range of services using location-based features.
• Social Media Data. We may receive Personal Information about you if you interact with our social media accounts. If you post text, photos or videos to our social media accounts, the text, photos or videos may identify you or others. This is Personal Information and will be used and disclosed by OTG in accordance with this Privacy Notice. The Personal Information will also be subject to the applicable social media company’s privacy policy. Accordingly, please do not submit text, photos or videos if you do not wish OTG or the applicable social media company to collect, use, and disclose such Personal Information.
• Third Party Authentication. When you use a third-party account, such as Google, Apple or Amazon (each, an “Authentication Provider”), to log in to our Services, we may collect information about that Authentication Provider account and share information with that Authentication Provider as described in the connection process. This collected information may include, but is not limited to, your name, email address, and demographic information from your profile. You acknowledge and agree that OTG is not responsible for the data collection or use practices of any such connected Authentication Provider. You should read each Authentication Provider’s privacy policy before connecting that Authentication Provider account.
• User Experience Data. We also collect user experience recordings, which reproduce your interactions with the Programs, including mouse movements, page scrolling, information you type (including Personal Information), screen taps, and other actions you take while using the Programs. Recordings may include technical and usage data, as well as visual representations of actions you take while using the Programs. We use these recordings to help us understand how users interact with our Programs and to design a better user experience for you.
• You may also choose to communicate with us through email, text message, via the Programs, via telephone, in writing, or through any other means. We may collect all information, including Personal Information, in or about these communications.
• In general, most of the Personal Information collected will be in the form of Registration Data, Order Data, and/or Account Data (as defined above). In most instances, we will not collect any Personal Information from you unless you voluntarily submit such information to us. In most instances, you are not required to provide us with any Personal Information to use or access the Programs. However, if you choose not to provide certain Personal Information, you may not be able to make purchases or receive certain products offers or services.
• Consolidating the Information We Collect. We may combine any of the information described in this Privacy Notice, including Personal Information we collect directly from you or from Outside Contractors, with information collected automatically through your use of the Programs, including Personal Information and Non-Identified Information (described below), for any of the purposes described in this Privacy Notice. In the event that we link any Non-Identified Information with Personal Information, we will treat such information as Personal Information in accordance with this Privacy Notice.

• to establish and verify the identity of users;
• to open, maintain, administer, and service users’ accounts or memberships;
• to respond to inquiries and fulfill requests and otherwise provide our services, including fulfilling purchase and service orders placed though use of the Programs;
• to personalize users’ experience, including, without limitation, collecting and storing order preferences and user behavioral information for future use;
• to communicate with users or Outside Contractors regarding orders (e.g., sending electronic receipts of purchases via email or text message), account creation (e.g., welcome email), to confirm user options and preferences, or in order to provide or offer services, or deliver electronic newsletters and other information or news about services or the Programs;
• to promote products and services on our behalf and on behalf of Outside Contractors, including by sending promotional text messages and emails on our behalf or on behalf of our Outside Contractors, which promotions may be targeted based on your use of the Programs; and
• for other related business purposes, such as data analysis, audits, developing new products, improving the Programs, identifying usage trends, determining the effectiveness of promotional campaigns, and maintaining the security and integrity of our systems.

When you use or access any of the Programs, we and our Outside Contractors may also collect information about you, your mobile device, and your use of the Programs that does not identify you, such as demographic information (e.g., age, profession or gender), anonymous device, advertising and other identifiers that cannot reasonably be connected to your identity, and information about the date and time you used the Programs, the pages you accessed while using the Programs, and the Internet addresses of the websites (e.g. URL) you visited that were linked to the Programs (collectively, “Non-Identified Information”). We and our Outside Contractors also collect Non-Identified Information from or about the mobile phones or other mobile devices where you install or access the Programs, depending on the permissions you have granted.

To learn more about how we and our Outside Contractors collect Non-Identified Information, please see our Cookie Notice.

• Disclosure to Our Affiliates. We may disclose your Personal Information to our Affiliates. For the purpose of this Privacy Notice, “Affiliates” means any person or entity which directly or indirectly controls, is controlled by, or is under common control with us, whether by ownership or otherwise. Any Personal Information relating to you that we provide to our Affiliates will be treated by those Affiliates in accordance with this Privacy Notice.
• Disclosure to Airline Partners. We may share Personal Information obtained from Registration Data, Order Data, or Account Data (e.g., from and after boarding pass scanning) with our airline partners, and we may allow our airline partners to use such data for their other applications or services. The Personal Information we share may include the type of payment method a customer uses to pay for products or services purchased through use of the Programs.
• Disclosure to Our Outside Contractors. We may contract with business partners (such as an airline or rewards provider), vendors or suppliers (collectively, “Outside Contractors”) to participate in or provide specific services related to the Programs (e.g., internet access, payment processing, advertising, etc.) and to offer or provide retail products and services through use of the Programs. These Outside Contractors may sometimes have limited access to Personal Information collected by the Programs, including your Personal Information, in the course of providing products or services to you and/or us. Access to your Personal Information by these Outside Contractors is limited to the information reasonably necessary in order for the Outside Contractors to perform their limited function.
• Disclosure to Online Tool Providers. We may also disclose Personal Information and Non-Identified Information to Online Tool Providers. By “Online Tool Provider” we mean a licensor of software that we include in, or use with, the Programs, including an API or SDK, that provides a specialized function or service to us and that requires the transmission of Personal Information and/or Non-Identified Information to the Online Tool Provider. Online Tool Providers may have the right to use Personal Information and Non-Identified Information about you for their own business purposes. Use and disclosure of Personal Information and Non-Identified Information by an Online Tool Provider is described in its privacy policy. See the Cookies and Automatic Information Collection section for more information.
• Advertisers. We may partner with advertisers to provide you with special offers, or to advertise products or services to you. If you redeem or respond to an offer, we may provide your Personal Information to the advertising partner, including your name, email address, gender, and year of birth. If you answer questions or fill out surveys from an advertiser, we may share Personal Information with that advertiser. The advertising partner’s privacy policy will govern their use of your Personal Information, which may include marketing of other products or services to you. You should read each advertiser’s privacy policy before providing Personal Information to that advertiser.
• Sharing of Aggregate Non-Identified Information. Some of your Non-Identified Information may be shared as a part of a larger set of statistics, but that information will not be sufficient to permit the recipient to identify you. For instance, we may provide Non-Identified Information to Outside Contractors regarding the number of unique users who use the Programs, the demographic breakdown of the users of the Programs, or the activities that users of the Programs engage in while using the Programs. The Outside Contractors to which we may provide this information may include potential or actual advertisers, providers of advertising services (including website tracking services), airlines, sponsors, licensees, researchers, and other similar parties.
• Disclosure in Limited Circumstances. Notwithstanding the foregoing, we may also use and disclose Personal Information outside the normal use of the Programs in the following limited circumstances: (i) if we are required to do so by law, (ii) if we have the good faith belief that such action is necessary to conform to applicable laws or comply with legal process served on us (e.g., to comply with a search warrant, subpoena, or court order), (iii) to respond to requests from public or government authorities, (iv) to detect, prevent or otherwise address fraud, security or technical issues, (v) to enforce our terms and conditions, (vi) to prevent a crime or protect national security, or (vii) to protect you or the rights or property of a third party or another user of the Programs.
• Acquisition, Sale, Reorganization, or Bankruptcy of the Business. As we continue to develop the Programs and our businesses, we might acquire other business entities or assets or sell, license, or transfer business entities or assets to third parties. In such transactions, customer information, including Personal Information, generally is one of the assets acquired or transferred. Also, we may transfer information, including your Personal Information, to a third party in the event of a sale, merger, transfer of all or substantially all of our assets, a controlling interest in us is acquired, or in the unlikely event of a bankruptcy, liquidation, or receivership of our business. We will use commercially reasonable efforts to notify you of such transfer, for example via email or by posting notice on our website.

• Cookies. Cookies are pieces of information that a web site saves to a device or a computer’s hard disk. Cookies may include Personal Information or Non-Identified Information, and do identify a user’s device. Most web browsers are initially set up to accept cookies. We reserve the right to use cookies in accordance with our Cookie Notice. Advertisers and other Outside Contractors that display ads in or on the Programs may also use cookies, however, we do not have access to the information obtained from cookies issued from other sites.
• Pixels. A pixel, tag or web beacon is a small, usually-transparent image or script placed on a web page that allows the operator of that image or script, which may be the operator of the website you visit or a third party, to read or write a Cookie.
• Online Tool Providers. Our Online Tool Providers may collect information automatically, in which case Personal Information and Non-Identified Information it receives are subject to the Online Tool Providers’ privacy policy. Some Online Tool Providers may allow you to opt out of certain collection and/or uses of your information. We use the following Online Tool Providers: [ Google Analytics, Microblink, Elavon Converge ].

The Programs are directed toward and designed for use by persons aged thirteen (13) years or older. IF YOU ARE UNDER THE AGE OF THIRTEEN (13), YOU CANNOT USE THE PROGRAMS. Our policy is that we do not knowingly collect, use, or disclose Personal Information about visitors under 13 years of age.

Transparency and Choice. We may use third-party service providers that collect information for interest-based advertising purposes (advertisements that are tailored to your likely interests, based on categories in which you have shown an interest). To learn more about these third parties and the choices they offer users, please visit the Network Advertising Initiative’s choices page at http://www.networkadvertising.org/choices or the Digital Advertising Alliance’s choices page at http://www.aboutads.info/choices. If you are reading this Privacy Notice from a mobile device, you can learn more about the DAA's mobile choices program here or at http://www.aboutads.info/appchoices.

We support the development and implementation of a standard "do not track" browser feature that provides customers with control over the collection and use of information about their web-browsing activities. Once a standardized "do not track" feature is released, we intend to adhere to the browser settings accordingly.

You can opt out of receiving marketing messages in the notification preference section of your account profile, by clicking on the “unsubscribe” link in an e-mail, or by replying to a text message with the word “STOP.” Please note that it may take up to ten (10) business days for an email unsubscribe opt-out request to be processed. Also, even if you opt out of messages, we may continue to send you certain account-related messages, such as notices about your account and confirmations of transactions you have requested.

If you have an objection to the use of your Personal Information as described in this Privacy Notice, you may file a complaint by sending an email to privacy@otgexp.com. We will attempt to accommodate your objection or complaint, but you understand that, to the extent you object to our processing of Personal Information that is necessary for us to provide the Programs to you, certain features and functionalities of the Programs may no longer be available to you. Nothing in this Privacy Notice prejudices your rights to file a complaint with the Office of the Privacy Commissioner of Canada, and/or with any other applicable data protection authorities.

The Programs are controlled, operated and intended to be used from within the United States and Canada only. We make no representation that the Programs are appropriate for use outside the United States or Canada, or that access to and use of the Programs in accordance with this Privacy Notice complies with the laws of any other jurisdiction. Those who choose to access or interact with the Programs from outside the United States or Canada do so of their own free will and hereby consent to the transfer of their Personal Information to the United States as described in this Privacy Notice.