Last updated: 16th September 2021
Additionally, if you use Fly Now Pay Later Credit, your non-public personal information will be subject to the Cross River Bank Privacy Notice and Fly Now Pay Later’s use of such information will be consistent with that privacy notice.
What type of information does Fly Now Pay Later collect?
Fly Now Pay Later collects two basic types of information from you in conjunction with your use of the Fly Now Pay Later Services (collectively, your “personal information”): (1) personally identifiable information; and (2) non-personally identifiable information.
Personally Identifiable Information is any information that can identify you.
- Examples include your name, e-mail address, telephone number, postal address, device identifiers, IP addresses, and financial account information that you provide, such as credit or debit card numbers.
- We may also collect personally identifiable information about you from third parties such as data vendors.
- Aggregate and/or de-identified information is not considered personally identifiable information.
Non-personally identifiable information is information that does not identify you directly, but may be linkable to you.
- Examples include demographic information and general location information.
How does Fly Now Pay Later Collect Information?
We collect information about you through:
- Your interactions with or use of the Fly Now Pay Later Services;
- Your contact with our customer support team;
- Third parties, such as data vendors;
- Through our websites, using cookies, Clear GIFs, web beacons, mobile application plug-ins and similar technologies.
Cookies are small files that are stored on your computer or device when you use the Fly Now Pay Later Services. Cookies record your preferences and the actions you take on your computer or device. We may also use web beacons and mobile application plug-ins, such as software development kits, application programming interfaces and similar technologies. We use these and other similar technologies for security, to monitor traffic, improve the Fly Now Pay Later Services, and make the Fly Now Pay Later Services easier to use and more relevant to you. We may also use these technologies to personalize your experience, deliver advertisements, and for research and marketing.
Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with the Fly Now Pay Later Services to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage.
How do we use the personal information we collect?
We may use your personal information to:
- Provide the Fly Now Pay Later Services and customer support
- Process transactions and send notices about your transactions
- Resolve disputes and collect payments and/or fees
- Verify the accuracy of and authenticate your information
- Detect, investigate and prevent potentially prohibited or illegal activities, such as fraud
- Communicate about accounts or transactions and send information about features and enhancements
- Contact you by phone, text (SMS) or email
- Communicate changes to our policies
- Personalize content and experiences, including providing recommendations based on your preferences
- Send offers or promotions for the Fly Now Pay Later Services
- Provide advertising, including advertising based on your use of the Fly Now Pay Later Services or third-party websites
- Perform statistical, demographic and marketing analyses of users of the Fly Now Pay Later Services and their purchasing patterns
- Conduct any other legitimate business activities not otherwise prohibited by law
How do we share personal information?
We may share your personally identifiable information with:
- Service providers and affiliates who help with our business operations, including but not limited to, fraud prevention, account maintenance, customer service, marketing and technology services
- Credit bureaus and collection agencies, as permitted by law
- Merchants you order your goods or services from using the Fly Now Pay Later Services
- Companies that we plan to merge with or be acquired by
- Third parties, including governmental authorities and law enforcement, to (i) protect or defend the legal rights, interests or property of Fly Now Pay Later and any related entity of Fly Now Pay Later; (ii) protect the safety and security of our customers or members of the public; (iii) protect against fraud; or (iv) comply with applicable law, subpoena or legal process.
- Other third parties with your consent or at your direction to do so.
- Third parties for any legitimate business purpose not otherwise prohibited by law
We will not share or sell any personally identifiable information about you to our affiliates or non-affiliated third parties for their marketing purposes unless you have provided consent, except as set forth in the Fly Now Pay Later Terms of Service.
How do we protect personal information?
Fly Now Pay Later uses reasonable security measures to protect your personal information from unauthorized access and use in compliance with applicable law. These measures include computer safeguards and encrypted, secured files and buildings. We also maintain other physical, technical, administrative, and procedural safeguards to protect personal information, and access to personal information is limited to the employees who require it for their job functions. Please be aware that despite our efforts, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
How can you restrict us from sharing your personal information?
Personally Identifiable Information: You may choose not to provide your personally identifiable information to us; however, you will not be able to use the Fly Now Pay Later Services.
You can also limit our use and sharing of your personal information in other ways, such as:
- You may unsubscribe from marketing emails, but we will still be permitted to contact you for servicing and account-related purposes by clicking the “Unsubscribe” link in the email footer or by contacting Fly Now Pay Later Customer Service.
- You can modify browser settings to decline cookies, but certain features of Fly Now Pay Later Services may not function properly or may be unavailable if you do. For more information on cookies and how to disable them, you can consult the information provided by the Interactive Advertising Bureau at www.allaboutcookies.org.
- For your mobile device, you can understand which third parties have currently enabled cookies on your mobile device and how to opt-out of some of those cookies by accessing the Network Advertising Initiative’s website at http://www.networkadvertising.org/mobile-choices from your mobile device. On your mobile device you may also select “Limit Ad Tracking” (on iOS devices) or “Opt out of Interest-Based Ads” (on Android). Even if you disable tracking, keep in mind that you may still receive interest-based advertising, including from third parties with whom your information had been previously disclosed and that you may still receive advertising from third parties, although such advertising may not be based on your interests and preferences.
- We use the information provided by Google Analytics to improve our Services. For more information regarding how Google collects, uses, and shares your information and how to opt out of certain uses please visit http://www.google.com/policies/privacy/partners/ and https://tools.google.com/dlpage/gaoptout.
The Fly Now Pay Later Services may contain links to third-party websites, including social media sites. By including a link to a third-party website, we do not endorse or recommend any products or services offered or information contained at the third-party website. Any access to and use of such linked websites is not governed by this policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites. If you decide to visit a third-party website via a link contained in or by the Fly Now Pay Later Services, you do so at your risk.
Children Under 13
Our products and services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.
If you are a resident of California, under 18 and a registered user of the Services, you may ask us to remove content or information that you have posted through the Services by contacting us on email@example.com. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.
Governing Law and Notice to Non-US Users
Accessing, Correcting or Deleting Your Information
You may request to access, correct, or delete any personal information that you have provided to us. You will not be permitted to examine the personal information of any other person or entity and may be required to provide us with personal information to verify your identity prior to accessing any records containing information about you. We may not accommodate a request to change or delete personal information if we believe doing so would violate any law or legal requirement or cause the information to be incorrect. To submit a request, email firstname.lastname@example.org.
Changes to this Policy
This policy is current as of the Last Updated date set forth above. We may change this policy from time to time, so please be sure to check back periodically. We will post any changes to this policy on the Fly Now Pay Later Services. If we make any changes to this policy that materially affect our practices with regard to the personal information we have previously collected from you, we will aim to provide you with notice in advance of such change by highlighting the change on our web site.
How can you contact Fly Now Pay Later?
f you have questions about the privacy aspects of our services or would like to make a complaint, please contact email@example.com.
Additional Options and Rights – California Residents Only
California provides consumers with additional rights as related to their personal information. Fly Now Pay Later will not discriminate against you because you exercise any of the rights as described in this section. These rights do not apply, however, to any non-public personal information that Fly Now Pay Later collects or discloses in providing a financial product or service.
|Categories of Data Collected, Sold, and Disclosed||Please see our Notice of California Consumer Data Collection and Sharing Practices.|
|Sale of Personal Information to Third Parties||You have the right to opt-out of the sale of some types of personal information. At present, Fly Now Pay Later does not sell personal information to third parties. Please note that your right to opt-out does not apply to our sharing of data with service providers, who are parties who are engaged to perform a function on our behalf and are contractually obligated to use the data only for that function. If our practices change in the future, we will provide you with the opportunity to opt-out before any such sale.
To opt out please email: firstname.lastname@example.org
|Access to Personal Information||You have the right to request from us access to personal information collected about you and information regarding the source of the data, the purposes for which we collected it, and the third parties and service providers with whom we shared it. To protect our customers’ personal information, we are required to verify your identify before we can take action on your request.
To submit a request, email email@example.com.
|Erasure of Personal Information||You have the right to request in certain circumstances that we delete any personal information that we have collected directly from you. To protect our customers’ personal information, we are required to verify your identify before we can take action on your request. We may have a reason under the law why we do not have to respond to your request, or respond to it in a more limited way than you anticipated. If we do, we will explain that to you in our response.
To submit a request, email firstname.lastname@example.org.
|Participation in Data Sharing for Financial Incentive||At this time, we do not offer consumers any financial incentives to share data with us. If that changes, we will seek your consent prior to sharing data.|
Notice of California Consumer Data Collection and Sharing Practices
The California Consumer Privacy Act (“CCPA”) requires us to disclose certain information about our data collection and sharing practices to California residents, and to align this information to certain categories of personal information as enumerated in the law:
- The specific pieces of personal information and the categories of personal information we have collected about consumers in the past 12 months.
- The business or commercial purpose for collecting that personal information.
- Whether we “sell” that category of information to third parties. An external party may be considered a third party in the below chart either because the purpose of sharing is not an enumerated business purpose under California law, or because our contract does not restrict them from using personal information for other purposes. To “sell” data means to sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.
- Whether we disclose that category of information to “service providers,” which are external parties that we engage for business purposes and is restricted from using personal information for any purpose that is not related to our engagement.
Fly Now Pay Later does not engage in the practice of providing data to third parties in return for a financial benefit to us.
As a California resident, you may be entitled to additional rights regarding the collection and sharing of your data described in this Policy.
The following table summarizes the personal information we collect or create and how we share with external parties. This table describes our practices generally; not all individual pieces of your personal information may be shared.
|Data Fields||Method of Collection||Purpose of Collection (in addition to the purposes listed below)||Shared with Service Providers|
|(A) Personal Identifiers||Name||Consumer provides when creating account or completing transaction||To provide advertisements and discounts for third party goods and services.||Yes|
|Phone Number||Consumer provides when creating account or completing transaction||Yes|
|Email Address||Consumer provides when creating account or completing transaction||To provide advertisements and discounts for third party goods and services.||Yes|
|Contact Address||Consumer provides when creating account or completing transaction||To provide advertisements and discounts for third party goods and services.||Yes|
|Account Number||We generate and assign to consumer account||To provide advertisements and discounts for third party goods and services.||Yes|
|Online Handle, user name or identifiers||Consumer creates when creating account||To provide advertisements and discounts for third party goods and services.||Yes|
|IP Address||Automatically when consumer visits website||To provide advertisements and discounts for third party goods and services.||Yes|
|(B) Additional Personal Identifiers||Credit/Debit card Number||Consumer provides when creating account||To provide advertisements and discounts for third party goods and services.||Yes|
|Age||Consumer provides date of birth when creating account||To provide advertisements and discounts for third party goods and services.||Yes|
|(D) Commercial Information||Actual and considered transactions are stored in consumer profile||To provide advertisements and discounts for third party goods and services.||Yes|
|(F) Internet or other electronic network activity information||Automatically when consumer visits website or uses the Services||To provide advertisements and discounts for third party goods and services.||Yes|
|(H) Audio, electronic, visual, thermal, olfactory, or similar information||Voice recordings||Telephone interactions with customer service may be recorded||Yes|
|Email and chat communications||Emails sent by consumer to any Fly Now Pay Later email address; chat communications with Fly Now Pay Later Customer Service; Emails accessed while enrolled in the Email Connect Service||Yes|
|(K) Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics||Inferences may be generated through a series of computer processes||To provide advertisements and discounts for third party goods and services.||Yes|
All listed categories of personal information are collected for the following business purposes (in addition to purposes included in the table above):
- To enable or effect, directly or indirectly, a commercial transaction involving the Fly Now Pay Later Services.
- Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
- Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
- Undertaking internal research for technological development and demonstration.
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Debugging to identify and repair errors that impair existing intended functionality.
All non-public personal information that we collect through a Fly Now Pay Later Credit account with Cross River Bank is subject to the following Consumer Privacy Notice:
|Facts||What does Cross River Bank do with your personal information?|
|Why?||Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share and protect your personal information. Please read this notice carefully to understand what we do.|
|What?||The types of personal information we collect and share depend on the product or service you have with us. This information can include:
When you are no longer our customer, we continue to share your information as described in this notice.
|How?||All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Cross River Bank chooses to share; and whether you can limit this sharing.|
|Reasons we can share your personal information||Does Cross River Bank share?||Can you limit this sharing?|
|For our everyday business purposes—such as to process your transactions, maintain your accounts, offer loans or lines of credit, offer other financial services, respond to court orders and legal investigations, or report to credit bureaus||Yes||No|
|For our marketing purposes—to offer our products and services to you||Yes||No|
|For joint marketing with other financial companies||Yes||No|
|For our affiliates’ everyday business purposes—information about your transactions and experiences||No||We don’t share|
|For our affiliates’ everyday business purposes—information about your creditworthiness||No||We don’t share|
|For nonaffiliates to market to you||No||We don’t share|
|Questions?||Call toll-free 1-877-55CRB55 or go to
www.crossriverbank.com. You may also email your request to email@example.com.
What we do
|How does Cross River Bank protect my personal information?||To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
We also maintain other physical, electronic and procedural safeguards to protect this information and we limit access to information to those employees for whom access is appropriate.
|How does Cross River Bank collect my personal information?||We collect your personal information, for example, when you
We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.
|Why can’t I limit all sharing?||Federal law gives you the right to limit only
State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.
|Affiliates||Companies related by common ownership or control. They can be financial and nonfinancial companies.
|Nonaffiliates||Companies not related by common ownership or control. They can be financial and nonfinancial companies.
|Joint marketing||A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
Other important information
Special Notice For State Residents
For Alaska, Illinois, Maryland and North Dakota Customers. We will not share personal information with nonaffiliates either for them to market to you or for joint marketing-without your authorization.
For California Customers. We will not share personal information with nonaffiliates either for them to market to you or for joint marketing-without your authorization. We will also limit our sharing of personal information about you with our affiliates to comply with all California privacy laws that apply to us.
For Massachusetts, Mississippi and New Jersey Customers. We will not share personal information from deposit or share relationships with nonaffiliates either for them to market to you or for joint marketing-without your authorization.
For Vermont Customers. We will not disclose information about your creditworthiness to our affiliates and will not disclose your personal information, financial information, credit report, or health information to nonaffiliated third parties to market to you, other than as permitted by Vermont law, unless you authorize us to make those disclosures. Additional information concerning our privacy policies can be found at www.crossriverbank.com or call 1-877-55CRB55.