Effective Date: October 12, 2017

Thales InFlyt Experience is the inflight entertainment and Internet connectivity segment of Thales Avionics, Inc. (“Thales”). We respect your concerns about privacy and we understand that when you use our services you trust us with your information.

This Privacy Notice applies to the personal information we collect when you use our inflight entertainment and connectivity services. It describes what information we collect, why we collect it and what we do with it. We also describe the measures we take to protect the security of the information we collect and how our users and consumers can contact us about our privacy practices.

Thank you for using Thales InFlyt Experience. It is our pleasure to enhance your inflight experience.

Information we collect
We collect information to provide better services to all of our users. By using our products and services we obtain personal information (such as your name, address, email address and credit card number). For example, we may collect personal information when you purchase services, request information, submit comments or participate in some promotion, survey or other feature of the services, or otherwise communicate or interact with us. It is necessary for Thales to collect certain information about users of our services, including, but not limited to, account user name, IP address (local and public), session information, internet browsing history and other usage data. Some of this information may be provided to Thales by its service partners. Where possible, information will be stripped of personal identifiers, if any, and rendered anonymous. Other types of personal information we may collect include:

• Information we get from your use of our services. We collect information about the products and services that you use and how you use them, such as when you watch a movie, visit a website, or interact with our system. This information includes payment information such as payment card number, expiration date, authorization number or security code and billing address, as well as well as login information such as your user name and password information.

• Log Information from Server Logs. We collect information from server logs that indicate search queries and internet browsing history, device information such as device type and the media access control (MAC) address, device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.

• Automated collection methods. We may collect certain information by automated means such as cookies and web beacons. A “cookie” is a file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A web beacon, also known as an Internet tag, pixel tag or clear GIF, is a transparent graphic image placed on a web page or in an email, which indicates that a page or email has been viewed or that an email has been forwarded. In addition, a web beacon allows third parties to obtain information such as the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, the type of browser used to view the page, and the information in Cookies set by third parties. Through these automated collection methods we obtain “clickstream data,” which is a log of the links and other content on which a visitor clicks while browsing a website. As a website visitor clicks through a website, a record of the action may be collected and stored. We may link certain data elements we have collected through automated means, such as your browser information, with other information we have obtained about you. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our inflight entertainment services.

How we use the information we collect
We use the information we collect to provide, maintain, protect and improve our services, to develop new services, and to protect Thales and the users of our products and services. We may also use this information to develop enhanced insights of user behavior and to otherwise provide analytical value to the airline industry. To the extent necessary for management of our product and services offerings and for statistical purposes, Thales may retain the information we collect for a limited period of time, after which time the information will be discarded or destroyed. Where possible, any such retained information will be stripped of personal identifiers, if any, and rendered anonymous. Additional potential uses include the following:

• to provide, manage and operate Thales inflight entertainment products and services;
• to process payments in connection with the use of Thales products and services;
• to process requests for refunds received in connection with the use of Thales products and;
• to evaluate and improve Thales inflight entertainment services and business offerings (including developing new products and services), enhancing and improving Thales services, managing communications; and otherwise analyzing Thales products;
• to provide content personalization services relating to the use of Thales inflight entertainment products and services;
• to provide a comprehensive and cumulative summary and report of how airline passengers have interacted with Thales inflight entertainment products and services during a given flight, including passenger behavior inside third-party applications.
• to verify the identities of the users of Thales inflight entertainment products and services for purposes of delivering Thales inflight entertainment products and services or to protect against fraud and other unlawful activity, claims and other liabilities arising from the use of Thales inflight entertainment products and services;
• to provide third party products and services associated or connected with Thales inflight products and services (e.g. apps);
• to customize the use of the services relating the use of Thales inflight entertainment products;
• to deliver content tailored to users interests and in the manner in which users use Thales services and inflight entertainment products;
• to use for maintenance of the inflight entertainment system maintenance alerts and for other inflight entertainment system maintenance related purposes;
• to encrypt Inflight passenger data;
• to anonymize or tokenize Inflight passenger data;
• for research purposes, data and business analytic purposes, or other market and consumer research, trend analysis, and financial analysis purposes;
• for marketing and commercial purposes;
• for accounting and auditing functions;
• for information security testing and investigation purposes, including but not limited to, information security prevention, information security event correlation, information security event detection and information security event response; and to otherwise enhance the experience of airline passengers.

We also may use the information we collect in other ways for which we provide specific notice at the time of collection. In addition, we use information collected through cookies, web beacons, web server logs and other automated means for purposes such as (i) customizing our users’ use of our services; (ii) delivering content tailored to our users’ interests and the manner in which our users use our services; and (iii) managing our services and other aspects of our business. To the extent required by applicable law, we will obtain your consent before collecting information by automated means using cookies or similar methods. We may also use third-party web analytics services to analyze the information we collect.

If we decide to use personal information in a manner different from that stated at the time it was collected, we will notify affected individuals by e-mail. Individuals can choose whether or not to allow us to use information related to them in this new manner. If we do not receive permission, we will use the information in accordance with the privacy notice under which the information was collected.

Information we share
We may share your personal information with the airlines on whose planes our services are available and with our partners and with third parties we believe may offer products or services of interest to you. We also may share personal information with service providers who perform services on our behalf based on our instructions. We do not authorize these service providers to use or disclose the information except as necessary to perform services on our behalf or to comply with legal requirements. Examples of these service providers include entities that process credit card payments, provide satellite Internet services and that provide airline frequent flyer services. We may share data with third parties that has been depersonalized or anonymized, examples of which include aggregated user statistics, depersonalized demographic information and depersonalized usage information.

We also reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation). Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with this Privacy Notice. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.

In addition, we may disclose information about you as follows:
1. if we are required to do so by law or legal process;
2. to law enforcement authorities or other government officials;
3. when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss,
4. when we believe disclosure is necessary or appropriate to prevent harm to the rights, property or safety of our users or the public;
5. In connection with an investigation of suspected or actual fraudulent or illegal activity.
6. In connection with the enforcement of the applicable Terms of Service, including investigation of potential violations.

Your rights and choices
We offer you certain choices in connection with the personal information we collect from you, such as how we use the information and how we communicate with you. Whenever you use our services, we strive to provide you with access to your personal information. If that information is wrong, we’ll work with you to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. When updating your personal information, we may ask you to verify your identity before we can act on your request. We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup systems).

To update your preferences or to submit a request, please contact us as indicated in the “How to Contact Us” section of this Privacy Notice.

Data Transfers
We may transfer the personal information we collect about you to countries other than the country in which the information originally was collected, including to the United States. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will protect that information as described in this Privacy Notice. We may transfer your personal information to the U.S. in conjunction with the payment process and for other purposes indicated in this Privacy Notice. In addition, system components used to provide our services may be sent to the U.S. for repair or refurbishment. These components, which may have the capability of storing personal information, are subject to a deletion process following receipt by Thales in the U.S. By submitting your personal information through your use of our services, you indicate your consent to the transfer of your personal information outside the country in which it was collected. In the event Thales is purchased or is otherwise separated from the Thales group of companies, the personal information we collect about you will be one of the transferred assets.

How we protect personal information
We maintain administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, please know that we cannot provide an encrypted communication channel between the Wi-Fi point and your device following access. Thales recommends the use of secure virtual private network protocols and disabling file-sharing to increase your security.

Links to other websites
Thales InFlyt Experience services may provide links to other websites for your convenience and information. These websites may operate independently from us. Linked sites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites you visit are not owned or controlled by us, we are not responsible for the sites’ content, any use of the sites, or the privacy practices of the sites.

Children
We do not intentionally gather personal information about users who are under the age of 13. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will make reasonable efforts to delete such information from our records.

Do Not Track
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a user’s browser.

Updates to our Privacy Notice
This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post a notice of the revision date on our Privacy Notice to notify you that a revision will be implemented and the date that the revision will be effective.

How to contact us
If you have any questions or comments about this Privacy Notice, if you would like us to update information we have about you or your preferences or if you would like to exercise your rights as indicated in the “Your Rights and Choices” section of this Privacy Notice, please contact us by email at PrivacyTeam@us.Thalesgroup.com. You also may write to:

Thales InFlyt Experience
58 Discovery Drive
Irvine, CA 92618-3105, U.S.A.
Attention: Legal Department Privacy team

Consent to processing
By using our services you agree to the terms of this Privacy Notice and you expressly consent to the processing of your personal information according to this Privacy Notice.