Privacy Policy

This privacy policy ("Policy") describes how Breeze Travel, Inc. ("BREEZE" or "us" or "we") collect, use, and share the information you provide to us or we gather from you while you access or use www.EnjoyTheBreeze.com (the "Site"), the BREEZE mobile application (the "App"), and related services that link to this Policy (together, the “BREEZE Services”).

We may also supplement this Policy with other privacy notices in the BREEZE Services. This Policy applies only to information collected by us through the BREEZE Services and does not apply to services that link to other privacy policies, including any third-party websites or services you connect to from our BREEZE Services, such as social-networking platforms or connected third-party applications. BREEZE is not responsible for the privacy practices or content of such third parties. We encourage you to read the privacy statements of those third parties.

We collect and process personal information about you with your consent and/or as necessary to provide the products you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests.

Personal Data Collected

As used in this Policy, “Personal Data” means information relating to you as an identified or identifiable individual. You provide Personal Data directly into the BREEZE Services. For example, as part of activating an account with BREEZE, we collect your name, email address and password, and home airport or country/region. If you create the account using one of the available social networking or third-party platform connection options (a “social sign-in” like Google, Facebook, or Apple), we will collect your associated email address and related profile information from the social sign-in provider. You may also identify your company or employer, as well as provide a photo of yourself. You may also provide us with additional email addresses for purposes of collecting itinerary information and to ensure that you retain access to your account even if you no longer have access to your primary email address.

To take full advantage of features and functionality of the BREEZE Services, you may also provide us with additional information for your profile, such as your travel preferences, like seat and meal preference. And you may input emergency contact details and government-issued identification numbers needed for travel, such as your passport or driver license number. This information helps you to keep your itinerary and travel information in one place. If you wish to receive alerts via text messages, you must provide your mobile phone number. If you purchase additional BREEZE Services, such as upgrading your account to BREEZE Pro, we will collect certain billing and payment information. We process any payments using third parties, and we would retain only the last four digits of your credit card number and expiration date.

We may also collect Personal Data from other sources and combine that with Personal Data we collect from you through the BREEZE Services, as described below.

If required by applicable law, we will collect your date of birth for the limited purpose of validating your identity if necessary to meet our compliance obligations.

Third-Party Connected Services

The BREEZE Services also enable you to connect your BREEZE Services account with third-party applications and service providers. These connected third-party applications may enable Personal Data about you to be transferred into the BREEZE Services. For example, if you add loyalty program using a connected third-party application, the corresponding loyalty program information may be transferred into the BREEZE Services. In other cases, Personal Data may be transferred to and from a third-party service so you can use the BREEZE Services with a third-party application you have chosen. For example, if you order eSIM with the BREEZE Services, Personal Data would be processed by these third-party services. Your use of any third-party applications or third-party services is subject to the terms and conditions you have agreed to with such third parties, including third-party privacy notices, and BREEZE is not responsible for the quality or accuracy of third-party data available to the BREEZE Services from third parties or how such third parties may use Personal Data.

Connecting Your Email and Calendar

You can choose to enable us to access one or more of your email accounts and calendar by connecting such account(s) with your BREEZE account. If you connect your email account or calendar, the BREEZE Services will automatically access and analyze the contents of emails in your email account(s) on an ongoing basis for the purpose of identifying travel and travel-reward related emails that may contain recent travel bookings, boarding passes, rental car reservations, restaurant reservations or hotel reservations. Once identified, travel itinerary and travel related information is then extracted from your emails into your BREEZE Services account so that you may access this information in the BREEZE Services. Notwithstanding anything else in this Policy, BREEZE only uses such information to provide or improve user-facing features and will not use or transfer such information (even if aggregated or anonymized) for serving ads, including retargeting, personalized, or interest-based advertising. BREEZE’s access to the email account is authorized through the email provider’s access mechanism. If you choose to have the BREEZE Services track your loyalty programs points, the BREEZE Services will store account details for each of your loyalty programs accounts, including your sign-in username and password for tracked accounts. This information will be used to enable the BREEZE Services, directly or indirectly through third-party service providers, to automatically access your applicable reward accounts and analyze and extract information from such accounts for use in the BREEZE Services. You may manage your connections to email and calendars accounts and disconnect at any time in the settings.

Third-Party Social Sign-Ins

You can sign in to our BREEZE Services using third-party social sign-ins (e.g., Google, Facebook, and Apple). These social sign-in providers will share certain Personal Data with us as described in their sign-in notices or in their privacy policies, which might include information such as your name, profile picture, age range, gender, and other public information. We encourage you to review prior to signing in through the applicable service

Cookies, Analytics, and Tracking

When you use the BREEZE Services through the Site, some information such as Internet protocol (IP) address, device or browser information, logs, or clickstream information is automatically collected about your usage and activity to address technical support issues and understand how you use the Site. BREEZE may use certain tracking technologies such as cookies, web beacons, or third-party analytics tools to obtain such information. Our App utilizes tracking technologies from third-party service providers we have engaged to provide services on our behalf. In some cases, these are analytics providers that provide services such as application analytics and crash reporting. In other cases, these are advertising or campaign measurement providers. These providers may also automatically collect some of the information described above, including, for example, usage information, IP address, access times, browser type and language, device type, device identifiers, and Wi-Fi information. These providers may also automatically collect the above information about you through the App and on other sites and services, including personally identifiable information about your online activities over time and across different websites, devices, online services, and applications when you use our App. Some third parties help us and others associate your activities across the browsers and devices you use, or that your household uses, for retargeting, cross-device advertising, analytics, and measurement purposes. The third-party analytics and advertising providers we use include: Adobe Analytics, Crashlytics, and Apsalar. Some third-party providers allow you choices about their collection or use of your information. Some of these providers may also be members of the Network Advertising Initiative (NAI) or Digital Advertising Alliance (DAA), which each provide a simple way to opt out of ad targeting from participating companies.

You may find out more about the various tracking tools used on the Site and adjust your preferences for the Site in the TrustArc Cookie Consent Manager, which you can access at any time by clicking on the Cookie Preferences link in the footer of the Site.

Contacts

From the Site, you can access and import contacts from your other online address books, like Google, Apple, and Outlook. If you would like us to invite another individual to join the BREEZE Services, you may provide us their email address so that we may send them an invitation on your behalf to visit the BREEZE Services. When using the App, the App may also access your device contacts if you enable those permissions.

Location Data

Certain features of the BREEZE Services may collect precise geolocation data, including through GPS (global positioning systems), IP address, and other location-based technologies.

How Personal Data Is Used

BREEZE will use Personal Data as described in this Policy and as disclosed to you in the BREEZE Services, which include for the following purposes:

Creating and maintaining your travel itineraries and your profile and otherwise providing, operating, hosting, maintaining, connecting, and improving the BREEZE Services.
Responding to your comments and questions and providing customer service.
Training and operating automated systems that recognize and extract travel related information from emails and calendars.
Updating you on new features and functionality of the BREEZE Services, as well as other news and information about products and services offered by BREEZE, other affiliated companies, and our selected partners.
Providing you information via email or another form of electronic notification related to your use, requests, and purchases, such as transaction confirmations, invoices, technical notices, and other notices about security, privacy, and administrative issues relating to your use of the BREEZE Services.
Personalizing your BREEZE Services experience, content, marketing, and recommendations, including to target content and services to more closely match your interests or location.
Creating anonymized or de-identified and aggregated data sets, statistics or other metrics from Personal Data to improve our products and services or provide information about travel generally.
Enforcing our terms and conditions or protecting our business, partners, or users.
Protecting against, investigating, and deterring fraudulent, unauthorized, infringing, or illegal activity.
Comply with statutory obligations, including checks required by applicable export laws.

Choices You Have Regarding Personal Data

Profile and Transaction Information

Through the profile and settings pages within the Site and the App, you can update profile information associated with your account at any time, such as contact and payment information, travel preferences, privacy and sharing settings, and alerts and connected applications. If you have granted access to your account to team members to manage your itineraries, they may also be permitted to edit the information you have provided to us and to designate others to access and edit such information. You may change who has access to your information by changing your publishing options in your account settings. You may choose to display certain information you give us in your public profile. Our Site may offer publicly accessible blogs or community forums. You should be aware that any information you choose to share in these areas may be read, collected, and used by others.

If you otherwise wish to ask for access, correction, or deletion of any of your information held by us, or a change in the way we use your information, please contact us at privacy-request. We reserve the right to charge you a fee, as permitted by applicable law, and may decline requests that are unreasonable, prohibited by law, or are not required to be honored by applicable law.

Location Data

The BREEZE Services provide features that require your precise location and the use of location services on your mobile device through the App. Some of these features may be available only to users of the premium “Pro” version of the BREEZE Services. You may enable or disable these BREEZE Services within the App and the privacy settings in your mobile device. Features such as Foods, weather, time) require that location services on your mobile device be set to always provide location information. The BREEZE Services may also provide you with navigation services within certain airports or between destinations based on your itinerary or destinations that you have specified. These services require that location services on your mobile device be enabled only when you are using the App.

Connections with Other Services

Other third-party services you have chosen to connect with the BREEZE Services may be enabled or disabled through selections in the Site or the App. You usually can also enable or disable connections through the third-party services themselves. Certain third-party services we may feature through our BREEZE Services give you social-media options to interact with buttons or widgets that let you “like” information or post information about your activities publicly from the BREEZE Services to third-party sites and platforms or privately within your network. By connecting your BREEZE Services account with third-party services, you enable third-party services to access the BREEZE Services API and gain access to your itinerary information, as well as your profile information. Their use of this information is governed by their user terms with you and their privacy policies.

Email and Marketing Choices

Please note that even if you unsubscribe from promotional email messages, we may still need to contact you with important transactional information related to your account and your use of the Service. For example, even if you have unsubscribed from our email messages, we will still send you emails relating to security, billing, or account services such as password reset.

Push and Text Message Alerts

You may manage the push message alerts regarding flight delays, gate changes, and other alert information specific to your itinerary sent by the BREEZE Services to your mobile device through the settings page in your mobile device.

Connections, Groups, and Sharing Your Travel Information

The BREEZE Services enable you to keep in touch with your contacts and other members of the BREEZE Services when you travel, such as by importing your contacts as described above. You may search for and join groups of BREEZE Services users so that you can more easily coordinate travel and share travel information. In your settings menu, you may configure certain privacy controls that enable the sharing of profile information, traveler information, and itinerary information and statistics with other users or with the general public (including external search engines). You can share specific itineraries with both BREEZE Services users and non-users. If we send an email itinerary on your behalf to a non-user, you represent that you have permission to direct us to email such person.

Cookies

You also have choices regarding some of the technologies used to track your use of the BREEZE Services. You may find out more about the various tracking tools used on the Site and adjust your preferences for the Site in the TrustArc Cookie Consent Manager, which you can access at any time by clicking on the Cookie Preferences link in the footer of the Site. Note that the settings are limited to the particular browser installed on a particular device. So if you use BREEZE Services with different browsers or different devices, including a mobile device, you may have to disable the tracking cookies in the browsers of all relevant devices. It may not always be possible to disable cookies in the App, and disabling cookies on the Site will not disable tracking technologies on the App. We may not recognize or respond to every type of "do not track" signal or other mechanisms that provide consumers the ability to exercise choice regarding the collection of Personal Data about an individual consumer’s online activities over time and across third-party websites or online services, but we give you certain choices about how we collect Personal Data as described in this Policy. For more information on how we collect Personal Data for these purposes, see the “Cookies, Analytics and Tracking” section.

How BREEZE Shares Personal Data

The BREEZE Services may share your Personal Data as described in this Policy and as follows:

With your consent.
With third parties to the extent that you have enabled a connection between your BREEZE Services account and a third-party service.
With other BREEZE users or the public through your public profile in accordance with your privacy settings, if you share itineraries, and if you grant another BREEZE user access to manage or view your travel plans.
When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of BREEZE, our users, or others; and in connection with the enforcement of our terms and contracts.
In connection with a corporate transaction, such as a divestiture, merger, acquisition, consolidation, or asset sale, or in the unlikely event of bankruptcy. We may assign or transfer your information as part of the transaction.
With third-party vendors, consultants, and other service providers that are working on our behalf and need access to your information to provide specific services to us as part of the BREEZE Services, such as credit card processing companies, or hosting, email messaging, or SMS providers.
In an aggregated form that does not directly identify you.
As required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served to us.

How Personal Data May Be Transferred to the United States

The BREEZE Services operate from data centers in multiple locations globally, including in the United States. Using the BREEZE Services may result in the transfer, use, processing, or storage of Personal Data in the United States or any other country/region where BREEZE operates or maintains facilities or service centers, including jurisdictions that may not have data privacy laws that provide protections equivalent to those provided in your home country/region. BREEZE takes steps designed to ensure that the Personal Data is processed according to applicable law wherever the data is located and the provisions of our agreements, including any intercompany data-processing agreements among corporate affiliates.

By providing your information to us through your use of the BREEZE Services, you agree to that transfer, storage, and processing of your Personal Data in the United States.

Rights for Certain Users

Users Residing in the European Economic Area (EEA)

Breeze Travel, Inc., is the controller of your Personal Data for the BREEZE Services.

You can request from BREEZE access at any time to information about which Personal Data BREEZE processes about you and the correction or deletion of such Personal Data. Please note, however, that BREEZE can or will delete your Personal Data only if there is no statutory obligation or prevailing right of BREEZE to retain it. Kindly note further that if you request that BREEZE deletes your Personal Data, you will not be able to continue to use any BREEZE Services that require BREEZE’s use of your Personal Data.

If BREEZE uses your Personal Data based on your consent or to perform a contract with you, you can further request from BREEZE a copy of the Personal Data that you have provided to BREEZE. In this case, please contact privacy-request and specify the information or processing activities to which your request relates, the format in which you would like to receive this information, and whether the Personal Data should be sent to you or another recipient. BREEZE will carefully consider your request and discuss with you how it can best fulfill it.

Furthermore, you can request from BREEZE that BREEZE restricts your Personal Data from any further processing in any of the following events: (i) you state that the Personal Data BREEZE has about you is incorrect, subject to the time BREEZE requires to check the accuracy of the relevant Personal Data, (ii) there is no legal basis for BREEZE processing your Personal Data and you demand that BREEZE restricts your Personal Data from further processing, (iii) BREEZE no longer requires your Personal Data but you state that you require BREEZE to retain such data in order to claim or exercise legal rights or to defend against third party claims, or (iv) in case you object to the processing of your Personal Data by BREEZE based on BREEZE’s legitimate interest, subject to the time required for BREEZE to determine whether it has a prevailing interest or legal obligation in processing your Personal Data.

BREEZE may decline to process requests that are manifestly unfounded, excessive, or fraudulent, or are not otherwise required by local law.

If you take the view that BREEZE is not processing your Personal Data in accordance with the requirements in this Privacy Policy or under applicable EEA data protection laws, you can at any time lodge a complaint with the data protection authority of the EEA country/region where you live or with the data protection authority of the country/region or state where BREEZE has its registered seat.

If applicable under French law, you can also send us specific instructions regarding the use of your personal information after your death by contacting us at privacy-request.

Users Residing in California

For individuals within the State of California, you instead have the right to request from BREEZE access to your Personal Data that BREEZE collects, uses, or discloses about you; to request that BREEZE delete Personal Data about you; to opt out of the sale of Personal Data, if applicable; to non-discriminatory treatment for exercise of any of your data protection rights; in case of request from BREEZE for access to your Personal Data, for such information to be portable, if possible, in a readily usable format that allows you to transmit this information to another recipient without hindrance.

Please note, however, that BREEZE can or will delete your Personal Data only if there is no statutory obligation or prevailing right of BREEZE to retain it. Kindly note further that if you request that BREEZE deletes your Personal Data, you will not be able to continue to use any BREEZE Service that requires BREEZE’s use of your Personal Data.

Please direct any requests to exercise your rights to privacy-request. You can also designate another person to submit requests to exercise your data protection rights to BREEZE. You can give authorization to such person by granting them a limited power of attorney to exercise your data protection rights on your behalf. BREEZE may decline to process requests that are manifestly unfounded, excessive, or fraudulent, or are not otherwise required by local law.

BREEZE will take steps to ensure that it verifies your identity to a reasonable degree of certainty before it will process the data protection right you want to exercise. When feasible, BREEZE will match Personal Data provided by you in submitting a request to exercise your rights with information already maintained by BREEZE. This could include matching two or more data points you provide when you submit a request with two or more data points that are already maintained by us.

In accordance with the verification process set forth in the California Consumer Privacy Act (“CCPA”), BREEZE will require a more stringent verification process for deletion requests, or for Personal Data that is considered sensitive or valuable, to minimize the harm that might be posed to you by unauthorized access or deletion of your Personal Data. If BREEZE must request additional information from you outside of information that is already maintained by BREEZE, BREEZE will only use it for the purposes of verifying your identity so you can exercise your data protection rights, or for security and fraud-prevention purposes.

We do not sell personal information to third parties. We do share personal information with third parties for the business purposes described in this Privacy Policy.

Other

The services hereunder are not intended for use by the citizens of the Russian Federation who reside in Russia. If you are a Russian citizen residing in Russia, you are hereby notified that any Personal Data that you input into the services will be solely at your own risk and responsibility. You explicitly agree that we may accumulate your Personal Data and will process this data in the United States and in other countries/regions, and that you will not hold BREEZE accountable for any potential nonobservance of the Russian Federation legislation.

The BREEZE Services are not directed to users below the age of 16 years, or equivalent minimum age in the relevant jurisdiction. If you are younger than 16, you cannot register with and use the BREEZE Services. BREEZE does not knowingly collect the Personal Data of children under the age of 13. If you are a parent or guardian and believe BREEZE collected information about a child, please contact BREEZE as described in this Privacy Policy. BREEZE will take steps to delete the information as soon as possible. Given that the BREEZE Services are not directed to users under 16 years of age, and in accordance with the disclosure requirements of the CCPA, SAP does not sell the Personal Data of any minors under 16 years of age.

BREEZE and its products, technologies, and services are subject to the export laws of various countries/regions including, without limitation, those of the European Union and its member states, and of the United States of America. You acknowledge that, pursuant to the applicable export laws, trade sanctions, and embargoes issued by these countries/regions, BREEZE is required to take measures to prevent entities, organizations, and parties listed on government-issued sanctioned-party lists from accessing certain products, technologies, and services through BREEZE’s websites or other delivery channels controlled by BREEZE. This may include (i) automated checks of any user registration data as set out herein and other information a user provides about his or her identity against applicable sanctioned-party lists; (ii) regular repetition of such checks whenever a sanctioned-party list is updated or when a user updates his or her information; (iii) blocking of access to BREEZE’s services and systems in case of a potential match; and (iv) contacting a user to confirm his or her identity in case of a potential match.

Security and Retention of Personal Data

We maintain data handling and storage practices and procedures that are designed to promote the integrity and confidentiality of the personally identifiable information. No method of transmission over the Internet or method of electronic storage is completely secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

We retain your Personal Data for as long as necessary to provide the BREEZE Services and for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly. The criteria used to determine retention include (1) the length of time Personal Data is needed to provide the applicable services (such as maintaining and improving the performance of the BREEZE Services, enabling system security measures, and maintaining appropriate business and financial records); (2) if users have provided, created, or maintained Personal Data with the expectation that we will retain it until they affirmatively remove it (in which case we may maintain the data until actively deleted by the user); (3) whether the Personal Data is of a sensitive type (a shortened retention time may be appropriate); and (4) whether we are subject to a legal, contractual, or similar obligation to retain the data (such as mandatory data retention laws in the applicable jurisdiction, government orders to preserve data, or data that must be retained for the purposes of litigation).

Updates and Questions

We may update this Policy from time to time without notice to you other than posting the revised policy on the BREEZE Services or by providing such notice about or obtaining consent to changes as may be required by applicable law. If we change our Policy, we will post those changes to this Policy and change the effective date above. We encourage you to periodically review this page for the latest information on our privacy practices.

If you have any questions about this Policy, or to file any complaint regarding this policy, please contact us at the following address:

Breeze Travel, Inc.
5 Hamlins Xing
Dover, MA 02030
USA
Telephone: +1 508 292 8684
breeze@enjoythebreeze.com

Breeze Travel Inc. will investigate and attempt to resolve complaints and disputes regarding the collection, use, and disclosure of personal information by referencing the privacy principles stated in this Policy.

Translations of this Policy

This Policy is written in the English language. If any translated versions of this Policy conflict with the English language version, the English language version of this Policy shall control.