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Privacy Policy
Last modified: May 25, 2018 

Jetway, Inc., dba NexTravel (“Nextravel,” "Company" or "We") respects your privacy and is committed to protecting it through our compliance with this Privacy Policy. 

NexTravel attaches great importance to protecting your personal data. Updates in this Privacy Policy account for data protection legal changes (including EU General Data Protection Regulation or “GDPR”) and a goal in mind to make things more transparent and clear.

Capitalized terms used but not defined in this Privacy Policy have the meanings ascribed to them in the Terms of Service for the use of the Website (“Site”) or Services. We also have added some definitions for terms that are not commonly used and a simple navigation tool to make your privacy with NexTravel easier to understand.

This Privacy Policy was written in English (US) and may be translated to other languages solely for the convenience of our Site Visitors. In all cases and specifically if a potential conflict between versions arises, the English version of this Privacy Policy controls.

To Navigate:
  • (1) Applicability of this Privacy Policy
  • (2) Information We Collect and Receive
    • Our Cookie Policy
  • (3) How We Use Information
  • (4) Data Retention and Deletion
  • (5) How We Share and Disclose Information
    • Data Security
  • (6) Age Limitations
  • (7) Changes to this Privacy Policy
  • (8) International Data Transfers and Contractual Terms
  • (9) Data Protection Officer
  • (10) Identifying the Data Controller and Processor
  • (11) Your Rights
    • Consents and Opt out
  • (12) Contacting NexTravel

(1) Applicability of this Privacy Policy
NexTravel is committed to respecting and preserving your privacy. This privacy policy and agreement ("Privacy Policy") covers how NexTravel collects, uses, and treats personal information that you may provide through our Site or Services. By using the Site or Services, you agree to be bound by NexTravel’s Terms of Service and this Privacy Policy. The terms "you" and "your" refer to any visitor at our Site ("Site Visitors"), as well as to any visitors who engage in transactions over the Site (each a "Site Customer"). To the extent the Terms of Service conflict with the terms of this Privacy Policy, the terms of this Privacy Policy will control.

This Privacy Policy applies (i) to information you have consented to provide to us while using or visiting our Site and Services, including your driver’s license information, date of birth, gender, and passport number; (ii) information that is about you but individually does not identify you, such as travel preferences, credit card details, loyalty programs, and travel plans; (iii) about your internet connection, the equipment you use to access our Site and applications and usage details; and (iv) Personally Identifiable Information that you choose to provide to us via the Site, or that you provide to us as part of the process of registering online as a Site Customer.

(2) Information We Collect and Receive
NexTravel will not share Personally Identifiable Information you provide via the Site with any third party, other than as expressly disclosed in this policy. "Personally Identifiable Information" means information that identifies you, such as your name, mailing address, phone number, or email address. NexTravel collects information from you at different points as a Customer on our Site, and uses this information for registration, emergency, processing requests and transactions, informational notices, anonymous aggregate information, IP addresses, cookies, and computer configuration.

Registration Information
As a Site Visitor or a Site Customer, you may provide Personally Identifiable Information to us, in connection with requests for information, or for other reasons.

We may collect Personally Identifiable Information voluntarily provided by you when you contact us, sign up for our newsletter, create a user account, download materials, participate in promotional activities, or provide such information through other electronic means. We are committed to security and implement a variety of security measures to maintain the safety of your Personally Identifiable Information.

We may also collect certain non-Personally Identifiable Information, such as your computer’s IP address, browser information, cookie information, domain name, your geographic location, pages viewed, and the number of times viewed. We may also collect information about your use of the Site using third party tools such as Google Analytics, but only for the purpose of improving our Site, user experience, and our services. You may also voluntarily provide us with other non-Personally Identifiable Information, such as your affiliated company. Unless otherwise required by law, all non-Personally Identifiable Information is not used to personally identify you and is only used by us to improve the content and functionality of our Site.

Emergency Information
As a Site Customer, you may provide personal information, emergency contact information, and information to us, in connection with requests for information or for other reasons. This information is requested to help you, and designated emergency personnel, in the event of an emergency, and to configure and personalize your NexTravel device and/or experience.

Processing Requests and Transactions
When you make a request of us via our Site, NexTravel will use any Personally Identifiable Information that you provide in connection with that request for the purposes of processing and responding to that request. In each instance where you make a request under our Site, NexTravel will use the information you provide to us solely for the purpose of fulfilling your request.

Informational Notices, Newsletters and Bulletins
Periodically, NexTravel may choose to send newsletters, bulletins, marketing materials, or other information to you, and will use Personally Identifiable Information to send such communications. If NexTravel chooses to undertake such communications, you will have the ability to opt-out of receiving these communications as provided in the opt out links and information below, located in in Your Rights, Consents, and Opt out.

Anonymous, Aggregate Information
"Aggregate Information" is information that does not identify you, and may include statistical information concerning the number of transactions through our Site or services, and the pages on our Site that users visit most frequently. NexTravel uses Aggregate Information to analyze the effectiveness of our Site, to improve our services and our Site, and for other similar purposes. In addition, from time to time, NexTravel may undertake or commission statistical and other summary analyses of (i) the general behavior and characteristics of our Site Visitors, (ii) the effect of our programs on, and the behavior of our Site Visitors, and (iii) the general characteristics of visitors at our Site and participants in our services. NexTravel may share these analyses and Aggregate Information with third parties. Rest assured, though, that Aggregate Information provided to third parties will not allow anyone to identify you or determine anything personal about you.

IP Addresses
NexTravel may automatically receive and record information in our server logs from your browser, including your IP address (the Internet address of your PC), your computer's name, the type and version of your web browser, referrer addresses and other generally accepted log information. NexTravel may also record page views (hit counts) and other general statistical and tracking information, which will be aggregated with that of other users in order to understand how our Site is being used and improving the overall Site Customer or Site Visitor experience.

Cookies and our Cookie Policy
A cookie is a small amount of data, which often includes an anonymous unique identifier, which is sent to your browser from a Site's computers and stored on your computer's hard drive. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a Site upon a future visit. NexTravel may include cookies on our Site and use them to recognize you when you return to our Site. You may set your browser so that it does not accept cookies. Cookies must be enabled on your web browser, however, if you wish to access certain personalized features of our Services.

Computer Configuration
In order to determine whether your computer is supported by our system, NexTravel may collect certain anonymous information. This information includes, but may not be limited to, your operating system and browser, as well as the presence of any software that our Site may require to operate with your computer, or other third party software on your computer. This information is kept strictly confidential and is not shared with third parties, except as provided for in this Privacy Policy.

Extent of Information Collected
NexTravel does not collect any more Personally Identifiable Information than reasonably necessary to operate the Site, including its Site or Services, and to respond to your requests. If you do not consent to the collection of your Personally Identifiable Information you have the right to opt out at any time.

(3) How we Use your Information
We will not share Personally Identifiable Information you provide via the Site with any third party, other than as expressly disclosed in this policy. We may use your Personally Identifiable Information to: (a) personalize your experience (your information helps us to better respond to your individual needs); (b) improve our Site (we continually strive to improve our Site offerings based on the information and feedback we receive from you); (c) improve customer service (your information helps us to more effectively respond to your customer service requests, inquiries and support needs); (d) create and use email lists to send periodic emails to provide you with new product information, technical updates and information about support services; and (e) perform marketing surveys to better understand the needs of prospective clients and partners.

(4) Data Retention and Deletion
NexTravel will retain content and information submitted by Site Customers in accordance with a Site Customer’s instructions, including any applicable terms in the Site Customer purchase agreement and Site Customer’s use of Services functionality, and as required by applicable law. The deletion of Site Customer data and other use of the Site or Services by Site Customer may result in the deletion and/or de-identification of certain associated Site Visitor information. NexTravel may retain other Site Visitor information pertaining to you only as long as necessary for the purposes described in this Privacy Policy. This may include keeping your Site Visitor information after you have deactivated your account for a reasonable period of time needed for NexTravel to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) specific EU member state legal obligations, resolve disputes, and enforce our agreements.

(5) How we Share and Disclose Information
NexTravel uses and discloses Personally Identifiable Information only as detailed in this Privacy Policy. NexTravel will not otherwise disclose your Personally Identifiable Information to unaffiliated third parties without your expressed consent, except in the following limited circumstances: Site Vendors, Imminent Harm, Legal, Transfer of Site, and Data Security.

Site Vendors
NexTravel may employ other companies to perform functions on our behalf, such as (i) maintaining the Site, (ii) maintaining the server farm or farms that allow us to host your data, (iii) collecting information, (iv) responding to and sending electronic mail, or (vi) other functions necessary to our business. NexTravel may need to share your Personally Identifiable Information with these companies (collectively, "Site Vendors"). NexTravel will provide Site Vendors with only that information necessary to perform their functions, and NexTravel will not allow such Site Vendor to use your Personally Identifiable Information for any other purpose. With regards GDPR related compliance, you may request a list of current Site Vendors (or sub-processors) as well as be notified of any relevant sub-processing changes in accordance with Section 7 and Section 8 of this Privacy Policy.

Imminent Harm
NexTravel may reveal your Personally Identifiable Information to attorneys, private investigator organizations or law enforcement agencies if NexTravel reasonably believes (a) that you are in risk of harm from another, or (b) that you are harming or interfering (or will imminently harm or interfere) with others or violating (either intentionally or unintentionally) our Terms of Service or otherwise violating legal rights. Please note, however, that by specifying this exception from our privacy and data protection practices, NexTravel assumes no duty to monitor safety concerns on your behalf.

Legal
NexTravel will reveal your Personally Identifiable Information, to the extent we reasonably believe we are required to do so by law, or in the unlikely event we become involved in a dispute with you, and such information is necessary to support or defend our position. In addition, if we receive legal process calling for the disclosure of your Personally Identifiable Information we will attempt to notify you via the email address you supplied during registration within a reasonable amount of time before we respond to the request, unless such notification is not permitted.

Transfer of Site
NexTravel shall be entitled to transfer to a third party information it collects, including any Personally Identifiable Information, in connection with a sale or transfer of all or substantially all of the assets of the business entity responsible for the information under this Privacy Policy, provided the acquiring third party has agreed to safeguard your Personally Identifiable Information with protections that in all material respects are the same as or more protective than those set out in this Privacy Policy. You will be informed with electronic notice regarding such Transfer of Site and your information in the event such sale or transfer takes giving you an opportunity to review your options and opt out at that time.

Data Security
NexTravel has put in place security systems designed to prevent unauthorized access to or disclosure of information you provide to us, and NexTravel takes commercially reasonable steps to secure and safeguard this information.

In the event of a security breach, NexTravel will immediately notify you of any unauthorized access to your Site Customer information or Personally Identifiable information. NexTravel has incident management policies and procedures in place to handle such an event.

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology. Credit card information supplied through the Site is maintained in accordance with the Payment Card Industry Data Security Standard (PCI DSS). 

In connection with its provision of the Site or Services, NexTravel agrees to comply with laws or industry standards designed to protect Customer’s data by using its best efforts and state-of-the-art organizational and technical safeguards, including, without limitation, the Standard Contractual Clauses approved by the European Commission for data transfers to processors, PCI Standards, HIPAA requirements for business associates, as well as similar and other frameworks, to the extent such frameworks apply to any of data that NexTravel comes into contact with.  

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site or applications or certain of our Services, you are responsible for keeping this password confidential.

(6) Age Limitations
To the extent prohibited by applicable law, NexTravel does not allow use of our Services and Sites by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information at legal@NexTravel.com.

Privacy Protection for Children and Teens Our Site is not directed at children, and NexTravel will not accept or request Personally Identifiable Information from individuals NexTravel knows to be under 13. In accordance with the Children's Online Privacy Protection Act ("COPPA"), if NexTravel learns that a child under 13 has provided Personally Identifiable Information, NexTravel will either (a) delete this information from our databases, in accordance with our deletion policy; or (b) obtain verifiable parental consent, in accordance with COPPA.

(7) Changes to this Privacy Policy
Notification of Changes
If we make any material changes to this Privacy Policy related to how we treat Customer personal information, we will notify you by e-mail to the primary e-mail address specified in your account. The date the Privacy Policy was last revised is identified at the top of the page. For such material changes related to EU Site Customers and the GDPR (e.g. sub-processors), you will be notified prior to such proposed changes and receive a reasonable objection period. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address to receive such notifications.  With respect to Site Visitors, your use of our Site following any such change constitutes your agreement to follow and be bound by the Privacy Policy, as changed.

(8) International Data Transfers and Contractual Terms
NexTravel, its authorized partners, or affiliates will not store or transmit any personal data to third parties without your consent or agreement to use such services as incorporated, such as travel related third party vendors.  NexTravel only collects the minimum amount of data necessary to provide you with account servicing and functionality of our Site and Services. As an EU Site Customer, you have rights associated to our current sub-processor list as well as notification of any changes. For more information or an additional Data Protection Addendum (DPA) please contact legal@nextravel.com.

(9) Data Protection Officer
If you are a Site Customer or supervisory authority with questions about your data, privacy or our Privacy Policy and Terms of Service, you may email legal@nextravel.com and your inquiry will reach our Data Protection Officer and team.

(10) Identifying the Controller and Processor
NexTravel serves as a both a controller and processor of Customer personal data.  You’re your consent, NexTravel may need to process additional personal data if we provide ancillary services such as customer service through a direct business relationship with an applicable partner.  Whenever you purchase or obtain services or products from NexTravel directly, NexTravel will serve as the controller for that data, meaning that NexTravel will serve to store, protect and make decisions surrounding the use of your data.  Whenever you purchase or use NexTravel Services on behalf of third party users, NexTravel will be the processor of that data while you remain the controller. For more information or an additional Data Protection Addendum (DPA) please contact legal@nextravel.com.

(11) Your Rights, Consent, and Opt Out
Consent by Site Visitors
By accessing and using the NexTravel Site as a Site Visitor, you are acknowledging that you have read and understood this Privacy Policy and agree to be legally bound by it and any such notifications and opt ins as provided to you throughout the Site. If you do not agree with the terms of this Privacy Policy or such notifications, please refrain from using the Site.

Consent by Site Customers
For features on the Site that allow online transactions, Site Customers may knowingly submit contact information, and other information. When you register as a Site Customer via the Site, you will be prompted to click an "I Accept" button linked to this Privacy Policy. Clicking "I accept" confirms your agreement to be bound by both the Terms of Service and Privacy Policy.

Changing or Removing Information; Opting Out; Discretionary Account Information
To allow appropriate control or deletion of your Personally Identifiable Information or to get immediate access to our sub-processor list, or information you have provided to us via the Site, and/or to change or update discretionary information that you have previously submitted, please contact legal@nextravel.com.

Opt Out
If NexTravel chooses to send to you bulletins, updates, or other unsolicited communications that are marketing-related materials, NexTravel will provide you with the ability to decline - or "opt-out of" - receiving such communications. Instructions for opting-out will be provided if and when NexTravel determines to send you such a communication. Please understand that you will not be allowed to "opt-out" of formal notices concerning operation of this Site, and other legal notices.

Finally, in accordance with an Opt-Out, if you also request an account deletion with your Opt-Out, NexTravel will remove your name and all other Personally Identifiable Information from our databases compiled from the Site or Services. You may request account deletion or request your privacy preferences with us through your account portal or by emailing us at legal@nextravel.com.

Please understand, however that, if you request deletion or limitation of your information, you will be unable to utilize associated features of the Site and any associated services with your previous Site Customer or Site Visitor information. You may not remove de-identified or Aggregate Information from our databases. At times, we may not accommodate a request to change or delete information if we reasonably believe the change would violate applicable conflicting law (e.g. what is required by a specific EU member state) or cause the information to be incorrect. For more information about GDPR related rights, your right to deletion and the right to be forgotten, please refer to Section 4’s Data Retention and Deletion in this Privacy Policy or email us at legal@nextravel.com for any assistance.

(12) Contacting us about your Privacy Rights
Your California Privacy Rights
California Civil Code Section § 1798.83 permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to support@nextravel.com or write us at: NexTravel, 221 Kearny Street, Suite 500, San Francisco, CA 94108. 

Contact Information
Please feel free to contact NexTravel if you have any questions about this Privacy Policy, NexTravel’s GDPR compliance, or if you are seeking to exercise any of or your statutory rights.

You may contact us by email or mail: 

General Questions: support@nextravel.com
GDPR and EU data privacy related questions: legal@nextravel.com

or

Jetway, Inc. dba NexTravel
Attn: Legal
221 Kearny St, Suite 500
San Francisco, CA, 94108
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