California Online Privacy Protection Act
According to CalOPPA we agree to the following:
Users can visit our site anonymously
Users are able to change their personal information:
- By logging in to their account
How does our site handle do not track signals?
We honor do not track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.
Does our site allow third party behavioral tracking?
It's also important to note that we allow third party behavioral tracking
COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under 13, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation's consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online. We do not specifically market to children under 13.
Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify the users via email
- Within 7 business days
We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.
CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
- Send information, respond to inquiries, and/or other requests or questions.
- Process orders and to send information and updates pertaining to orders
To be in accordance with CANSPAM we agree to the following:
- NOT use false, or misleading subjects or email addresses
- Identify the message as an advertisement in some reasonable way
- Include the physical address of our business or site headquarters
- Monitor third party email marketing services for compliance, if one is used.
- Honor opt-out/unsubscribe requests quickly
- Allow users to unsubscribe by using the link at the bottom of each email
If at any time you would like to unsubscribe from receiving future emails, you can
- Follow the instructions at the bottom of each email.
and we will promptly remove you from ALL correspondence.
Privacy Notice – California Residents
This Notice explains how TN collects, uses, shares and stores your personal information and other data when you use the Network Services, and how you can exercise certain rights you have in connection with your privacy and personal information. Any personal information that TN collects will be treated as set forth below.
This Notice is effective as of: 4th January, 2021.
For ease of reference, you may click on any of the following links to jump to one of the sections addressed below:
- Scope of this Notice
- Changes to this Notice
- Information TN May Collect
- How TN Gathers Information
- How TN Uses Information
- Processing by Service Providers
- Your Rights and Choices
- Securing Personal Information
- Children’s Privacy
- Contact Information
Scope of this Notice
This Notice covers only the Network Services identified above and is only applicable if you reside in California. This Notice does not apply to visitors, users and others who provide information to us through our Network Services but do not reside in California, and this Notice does not apply to information which you may send us by other means. Other TN websites, locations, products or services, whether online or offline, may have their own specific privacy policies or notices which apply instead of this Notice, and you should consult those accordingly.
The Site may contain links to external websites and other online locations, including those embedded in third-party advertisements or sponsor information, that are not controlled by TN. TN is not responsible for the privacy practices and data collection policies for any third-party services. You should consult the privacy policies or notices of those third-party services for details about how they handle your personal information.
Changes to this Notice
TN reserves the right to make changes to this Notice at any time. Since this Notice may change over time as we modify or expand our Network Services, we suggest you check back from time to time to understand how we treat your information. Our Notice’s effective date will always be set forth at the beginning and end of the Notice. Any changes will be immediately incorporated into this Notice, and will be prospective only. We will not make any changes that have retroactive effect unless legally required to do so.
Any change to this Notice is effective immediately. Your continued use of the Network Services after any changes are made to this Notice constitutes your acceptance of the changes. If any changes are unacceptable to you, you should cease all use of the Network Services.
Information TN May Collect
Personal information (“Personal Information”) is generally defined as information that, alone or in combination with other information, could identify, relate to, describe, reference, be reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. The information we collect includes certain kinds of Personal Information. Personal Information can include, but is not limited to, your name, mailing/billing address(es), telephone number, email address, username and password, IP address or other device information, browsing or search history, credit/debit card number or other financial information, professional or employment-related information, office address and other business information, demographic information, visitor preferences, biometric information such as fingerprints, precise location information, or any other type of information that, directly or indirectly, is reasonably capable of being associated with you.
When using the Network Services, the Personal Information we may collect includes contact information/identifiers such as the following:
- Consumer name;
- Home postal address and/or office postal address;
- Telephone number;
- E-mail address;
- Alias, unique personal identifier, or other online identifier or account name (e.g., social media handle);
- Signature and physical characteristics or description;
- Passport number, driver’s license or state identification card number, insurance policy number.
To access parts of the Network Services, you may need to provide us with account information, such as the following:
- Date of birth;
- Username and password;
- Known traveler numbers; and
- Information collected from voluntary interviews and/or customer surveys.
For certain Network Services, we may request that you furnish Personal Information including payment information, such as a credit or debit card number or other payment account information.
TN may also collect Personal Information that is categorized by California law and/or federal law as protected classification characteristics, including a consumer’s:
- Medical conditions such as a physical or mental disability (collected in order to set up boarding and disembarking assistance system);
- Marital Status;
- Gender; and
- Veteran or military status;
When you visit the Site, we may automatically collect certain Internet or other network activity information about your computer, browser or device, including potential Personal Information and other data about your web browser, such as a consumer’s:
- Social media credentials;
- Internet or other electronic network activity information, including, but not limited to, IP address, browsing history, search history, and information regarding a consumer’s interaction with an internet web sites visited before or after TN’s website, application, or advertisement;
- Geolocation information;
- Information collected from voice calls;
- TN may collect device information using technologies such as cookies, which are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how you may be able to disable cookies, visit http://www.allaboutcookies.org.
Finally, TN may also collect commercial information that may include a consumer’s history using TN’s air carrier services:
- Travel history (locations, dates of travel, etc.);
- The cost of the flights taken by the consumer;
- The methods of payment; and
- Other purchasing or consuming histories or tendencies.
Importantly, information that is publically available from government records or de-identified or aggregate consumer information is not considered Personal Information under the CCPA.
How TN Gathers Information
TN may collect Personal Information when you visit TN’s site or use its Network Services, including to book flights, create a frequent flier account (Club Tiare), submit questions or comments, subscribe to any communications from us, or when you otherwise voluntarily provide it to us in any interaction you may have with TN and its Network Services.
Other data, such as device information that may include Personal Information to the extent such data are reasonably capable of identifying you, could be collected in an automated manner whenever you visit or use the Network Services. For example, when you access or use the Network Services, we and third parties that may provide certain functionality on the Network Services, such as social media or advertising networks, may engage, receive, collect, and store certain online identifiers through automatic data collection tools including cookies, pixel tags, web beacons, embedded web links, and similar technology. These technologies may collect information including, but not limited to, your IP address, browser type, the date and time that you use the Network Services, number of clicks, and information about your mobile device.
By using TN’s Network Services, you are authorizing us to gather and retain data, including Personal Information, related to TN’s provision of the Network Services.
TN may also receive Personal Information from third parties that interact with TN in connection with the services TN performs, such as travel agents, online travel agencies, loyalty program partners, and our airline partners.
How TN Uses Information
Depending on the nature of your interaction with us, TN may use your Personal Information and other data to:
• Administer and secure your frequent flier account;
• Maintain proper business records, organizational records and other relevant records;
• Respond to your questions, comments or other messages;
• Send you TN newsletters or other updates with information or advertising relating to our services;
• Process payment information related to your use of any TN services;
• Analyze market trends;
• Improve customer and passenger experiences when utilizing TN’s air carrier services;
• Prepare boarding and disembarking assistance;
• Checking passengers into the TN’s system prior to a flight’s departure;
• Allowing passengers to access TN’s Private Suite;
• Contact you if there are issues with information or content that you provided through the Network Services;
• Provide ongoing technical support related to the Site and other Network Services;
• Communicate with you regarding additional uses of your Personal Information beyond the scope of this list and this Notice;
• Improve the content and general administration of the Network Services;
• Perform internal operations related to the Network Services (e.g., fraud prevention);
• Troubleshoot software issues and operational problems with the Network Services;
• Conduct data analysis and testing;
• Monitor usage of the Network Services;
• Manage and protect TN’s property and the property of its passengers;
• To prevent and detect crime;
• Protect the health and safety of TN’s customers and employees;
• Fulfill U.S. and foreign regulatory requirements to collect certain passenger information and disclose such information to government agencies for purposes including, but not limited to security, immigration, and health concerns; and
• Respond to any law enforcement requests, as required by applicable law, court order, or governmental regulations, and to resolve any legal disputes.
Processing by Service Providers
Except as noted herein, TN does not share or sell your Personal Information with any person or entity outside of TN.
We may disclose certain portions of your Personal Information to service providers or third parties as necessary to fulfill the anticipated purposes for which you provided the Personal Information.
We may share any information, including Personal Information, that we receive with third parties, which include vendors and service providers retained as necessary to fulfill the purposes for which you provided such information in connection with the TN’s air carrier services. For example, we may provide contact information such as your name, address, email address or phone number to shipping/mail and email service providers to send you products, newsletters, and other materials you order or request.
We provide your Personal Information for a business purpose to the following categories of third parties: (i) service providers, (ii) our affiliate and partner airlines, and (iii) third parties to which you authorize TN to disclose your personal information in connection with the services you purchase from TN.
The Network Services may allow you to share information, including Personal Information, with third-party services and social networking websites, such as Facebook. We do not share your Personal Information with these social media providers unless you direct the Network Services to do so. Their use of the information will be governed by their privacy policies, and you may be able to modify your privacy settings on these entities. Please consult these third parties’ privacy policies before using their platforms to make sure you are comfortable with the level of sharing.
In the preceding 12 months, we have disclosed the following categories of Personal Information listed above to third parties to provide our air carrier services to our customers and passengers: (1) Contact Information; (2) Account Information; (3) Payment Information; (4) Protected Classification Characteristics; (5) Internet or Other Network Activity Information; and (6) History Using TN’s Air Carrier Services.
We may also disclose your Personal Information to other service providers and for other purposes with your permission, or for one or more of the following purposes:
• Assist our service providers prepare boarding and disembarking assistance to those passengers who need such assistance;
• Allow our service providers to check-in and screen our passenger prior to boarding;
• To carry out our obligations and enforce our rights arising from any contracts related to your use of the TN’s air carrier services, including for billing and collections;
• As necessary or appropriate to protect TN’s rights, property or safety, our passengers, employees, visitors or others;
• To respond to law enforcement requests and as required by applicable law, subpoena, court order, other legal process or governmental regulations;
• As otherwise described to you at or before the point when we collect your Personal Information; or
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or to transfer some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.
By providing to TN the Personal Information and other data referenced above, you agree that TN may use and share such Personal Information and other data in accordance with the terms of this Notice. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice and obtaining your consent to the new processing activities. If you do not opt-in, your information will continue to be used in a manner that is consistent with the version of this Notice under which it was collected, or the information will be deleted.
TN does not knowingly collect or sell the Personal Information of minors under 16 years of age.
Your Rights and Choices
As a California resident, you have the following rights with regard to TN’s collection, use and sharing of your Personal Information on or through the Network Services:
- The right to request details about what Personal Information we collect, use, disclose or sell about you;
- The right to request the deletion of Personal Information we have collected or maintain about you;
- If applicable, the right to opt-out of any sale of your Personal Information; and
- The right not to receive discriminatory treatment by TN, in terms of the services, products and prices offered on or through our Network Services, because you exercised these rights regarding the collection, use and sharing of your Personal Information.
If you would like to request the ability to access, review, edit, delete or have us properly dispose of any of the Personal Information that TN collected about you, if you would like to opt-out of receiving further information from TN, or limit what we share, or if you otherwise wish TN to cease using your Personal Information in the manners specified in this Notice (subject to any applicable legal exceptions), you can do so by emailing us at firstname.lastname@example.org or by calling us at 888-964-0275.
You may be able to opt-out of TN sharing your Personal Information with the entities identified in this Notice by contacting us using the information above, unless the sharing of your Personal Information is necessary to perform one of the following business purposes: to count ad impressions and evaluate their effectiveness; to detect, protect against, and prosecute security incidents; to debug or troubleshoot functional errors that may arise with the Network Services; to complete short-term tasks related to an existing interaction you have with TN; to maintain or service your account; to process payments and fulfill orders or other transactions you authorize; to verify your customer information; and to ensure the safety and quality of the Network Services.
Any removal of content by TN does not ensure or guarantee complete or comprehensive removal in all places. The content may have been shared or reposted by other parties, or federal or state law may require maintenance of the content or information. TN will do its best to accommodate your request, but we cannot guarantee we can remove all Personal Information from the specified uses. Therefore, please be as specific as possible in your request. If the request relates to information that TN needs to make certain Network Services function properly for you, you may not be able to use those Network Services properly moving forward. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise to perform a contract we entered into with you;
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
3. Debug products to identify and repair errors that impair existing intended functionality;
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546);
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
8. Comply with a legal obligation; or
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
TN reserves the right to maintain proper records as required by law, or for otherwise legitimate business purposes to the extent permitted by law, even if such records contain your Personal Information.
You may grant an authorized agent written permission to submit requests regarding your Personal Information, but we may deny authorized agent requests absent proof that you authorized such agent to act on your behalf, or if we are unable to verify your identity.
TN is required to verify the identity of any person or entity that requests the disclosure or deletion of Personal Information. If you have a password-protected account with us, we will use our existing authentication procedures to verify your identity. For most other requests, TN will ask you to provide information that matches at least two pieces of Personal Information we store about you before responding to your request. If you would like to request the specific pieces of your Personal Information that TN has collected, or if you would like us to delete highly sensitive information, you will need to match at least three pieces of information we store about you, and you must provide a signed declaration under penalty of perjury that you are the consumer whose Personal Information you are requesting.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
If you would like to opt out of receiving promotional emails from TN, please follow the opt-out instructions at the bottom of the email or send TN a detailed email at email@example.com.
Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of Personal Information the business shares with third parties for those third parties' direct marketing purposes and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To exercise your rights, you may make one request each year by emailing us at firstname.lastname@example.org.
Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. To learn more about other ways to possibly opt-out of certain kinds of targeted advertising, visit the Network Advertising Initiative website and the Digital Advertising Alliance website. Options you select are browser- and device-specific, and there is no guarantee that these industry-provided opt-out tools will prevent all targeted advertising.
Securing Personal Information
TN takes the issue of protecting your Personal Information seriously, but you should exercise discretion in what information you disclose and/or transmit through the Site. TN cannot guarantee that information sent over the internet is fully secure. The transmitted information may be intercepted by others before it reaches TN. If you are concerned about sending information to TN over the Internet, please send the information by mail or call us to make other arrangements. TN is not responsible for the security of information sent over the Internet.
TN retains collected information for a reasonable amount of time in order to fulfill the stated purpose for why the information was collected. TN also retain collected information connected to business records for periods of time required by law. If TN determines that collected information is no longer needed, it will delete such information. Our collection times will be consistent with applicable law.
The Networks Services are intended for individuals 16 years of age and older located in the United States.
The Network Services are not directed at, marketed to, nor intended for, individuals under 16 years of age. However, Personal Information concerning persons under the age of 16 may be collected from their parents or guardians, in which case the information is used by TN solely for business purposes. Moreover, TN does not sell any Personal Information of any individual.
Questions about this Notice, the Network Services, or your other interactions with TN, please contact TN at:
TN intends to strictly enforce this Notice. If you believe there has been some violation of this Notice, please contact us.
This Notice was last updated on 4th January, 2021.