Privacy Policy

Top Flight Assistance understands that your privacy is important to you. We are committed to protecting the privacy of your personally-identifiable information as you use this website. This Privacy Policy tells you how we protect and use information that we gather from you. By using this website, you consent to the terms described in the most recent version of this Privacy Policy. You should also read our Terms of Use to understand the general rules about your use of this website, and any additional terms that may apply when you access particular services or materials on certain areas of this website. “We,” “our” means Top Flight Assistance and its affiliates. “You,” “your,” visitor,” or “user” means the individual accessing this site.

Purpose and Applicability

This Privacy Policy/Notice (“Notice”) sets out the privacy practices of TWR Legacy, Inc, doing business as Top Flight Assistance and its affiliates (“TFA”) for their websites (“Sites”), mobile applications (“Apps”) and Internet-based activities (“Web Services”), including, without limitation, the Sites at https://topflightassistance.com/ (including all of its subdomains). The Web Services include, without limitation, for example, the TFA’s e-mail, push notifications and SMS/MMS communications. The Sites, together with the Apps, Web Services, are the “Platform.”

The TFA-affiliated entity that operates a Site or App is identified within that Site or App. The words “user,” “you” and “your” mean users of any part of the Platform, and the words “we,” “our”, and “us” mean the TFA-affiliated entity that operates the applicable portion of the Platform.

This Notice explains the information that we gather about you while you use the Platform, the ways in which we use, secure, and share that information, and your rights regarding your personal information. Also, this Notice sets forth your rights specific to the State of California or other states, for example, as set forth in the California Consumer Privacy Act (“CCPA”) and other applicable California privacy laws. This Notice does not apply to any information you may provide us, or that we may collect by other means not covered in this Notice.

What We Collect and How

We collect information through the Platform, including personal information about you. Some information you may enter of provide to us yourself, while other information, like cookie, location, and device data, we gather or derive through various means. We will retain that information for so long as you have an account or we have a legal or business purpose for it, unless otherwise stated herein. Your personal information may be collected, processed, and stored on servers in the United States and in other countries. The following explains what we collect and how we collect it.

Information You Enter or Provide
to Us Directly

You may provide us with information in order to use, or participate in, certain features of the platform, such as, without limitation, any of the following: registering for an account; for signing up for e-mail newsletters; direct messaging us via Instagram or Twitter; starting a conversation with the us on; posting to TFA-affiliated social media sites or signing up for SMS Alert. If you register for an account at one of the Sites, Apps, you will need to provide certain information, such as your first and last name, password, and e-mail address. You may also have the option to provide additional information for a user profile, such as your photo, demographic information, and birthdate. You may log into your account to access and edit certain information associated with your account, such as your contact information.

Online Purchases. If you make a purchase of Services on the Platform, you will need to provide the following information:

  • Financial Information. To pay for your TFA purchase we collect your credit card number and associated information, which we process in order to fulfill your purchase. In order to provide information for your receipts, past orders and to facilitate future orders you may make, we may store your credit card if you so choose.

Other Places You Provide Information. You may have the opportunity to provide information at other areas of the Platform. These include, for example and without limitation:

  • Communications with us. If you provide feedback through a form or contact us via e-mail, we will collect your name and e-mail address, as well as any other content or information you provide.

  • Surveys, promotions, etc. We collect information you provide by participating in surveys, sweepstakes, contests, promotions, or other solicitations.

  • Public postings. We may also collect information you post at other areas of the Platform, such as public areas of the Platform including message boards, blogs, social media sites, and reviews.

  • Human Verification Online. On many of our web forms on the Sites and Apps, we utilize the Google reCAPTCHA service to fight spam and abuse on our Platform and verify that you are a human and not a “bot” based on a score returned to us from Google’s servers after you interact with that third-party service. The use of reCAPTCHA is noted by the presence of a badge image that appears in the bottom right corner of a user’s screen. For clarity, web forms on the Sites and Apps that incorporate the third-party reCAPTCHA service are also subject to Google’s Privacy Policy and Google’s Terms of Use.

  • Augmented Reality (“AR”). You may provide us with information in order to use, or participate in, certain features of the Platform, such as taking a selfie photograph, interacting with an augmented reality (“AR”) application that creates an image of some or all parts of your face, or texting yourself a web link to your mobile phone number. Any selfie photograph(s) you take and/or AR images that you create (does not include photograph(s) that are over-written with re-takes) are publicly stored and hosted on a cloud image server indefinitely. We also store privately and securely any mobile phone numbers shared with us in order to maintain a required contact history and opt-in / opt-out status.

Information We May Gather from You;
Cookies, Device, Location, and Other Site Visit Information

Information collected on Sites. When you access any of the Sites through a web browser, including on mobile devices, we collect technical information that identifies your computer, software, browser settings and Internet Service Provider (ISP), such as your Internet Protocol (IP) address (a unique number that is automatically assigned to your computer when you access the web); network MAC address (a unique number that is assigned to your network card by the manufacturer); your AdID (the unique identifier assigned to you for advertising purposes); network operator; browser type and version; operating system and version; domain name; device’s preferred language; country information configured in your browser; a randomly assigned, unique user identification number (UID) set by us; and/or other characteristics relating to your device, its software and the mode of communication with us; as well as information regarding your visit to the Site, such the date, time and duration of a visit, the specific webpages you visit, the links you click throughout the Site, and/or the external websites from which you arrived at the Site or to which you linked from the Site (see our cookie policy for more information). When you use the Sites, we also collect location data that is provided by your ISP or a third-party data provider, such as your ZIP code, city, and state. You may choose not to accept cookies using your browser. See our cookie policy for more information. Information collected on Mobile Apps. When you access any of the Apps using your mobile device, we collect the unique device ID number of the mobile device; the unique identifier assigned to your mobile device for advertising purposes, such as your Identifier for Advertising (IDFA) on iOS devices or your Google Advertising ID (AAID) on Android devices; your Bluetooth MAC address (a unique number that is assigned to your Bluetooth radio by the manufacturer); as well as information about your mobile device model, operating system and version, and/or mobile communications carrier. When you access the App using your mobile device, we collect the location data (such as your current latitude/longitude coordinates) that is provided by your mobile device (if you enable that feature on your device and choose to share your location with us).

How We Use Information

Platform Operation. We use the information we collect to operate, maintain and improve the Platform and our products and services, such as to respond to comments and questions and provide customer service; send information including confirmations, invoices, technical notices, updates, security alerts and support and administrative messages; communicate about promotions, upcoming events, and other products and services offered by us and/or by third parties, including through the use of contextual and interest-based advertising; link or combine the information we collect with other information we get from third parties, to help understand your interests and provide you with better service; or content, to improve our Platform, or to communicate with you regarding promotions, upcoming events, and other products and services offered by us and/or by third parties, including through the use of contextual and interest-based advertising; protect, investigate and deter against fraudulent, unauthorized or illegal activity; provide and deliver the products and services you request; identify you as a user in our system, such as when we feel it is necessary to enforce compliance with our Terms of use or to protect the Platform, customers, or other individuals; facilitate the creation of and secure any accounts you created on our Platform; develop and improve marketing and advertising for the Platform; and/or for other purposes in operating the Platform.

We may create de-identified information records and “aggregate data” reports about how users use the Platform, such as the number and frequency of visitors to the Sites or the Apps, which may be derived from technical and/or personal information. This information cannot be readily tied back to you, your account, your web browser, your image, or your mobile device. We may use this de-identified information for business purposes, such as to enhance the content of and improve the Platform, for example by allowing us and third parties authorized by us to ascertain how often individuals use areas of the Platform so that we may focus on and improve those areas.

We may use technical data we gather to enable us or a third-party to provide you with information about products and services while you are using the Platform.

We may use your mobile phone number for the purposes stated herein, including for mobile SMS/MMS messaging or content.

Advertising. We use analytics services, advertising companies, advertising networks, and advertising exchanges to help analyze how users use and navigate the Platform and to engage in advertising on our behalf and on behalf of mall retailers, including contextual advertising, mobile geo-fence-based advertising, re-targeting based advertising and interest-based advertising. These companies may use data about your visits to the Platform and other websites or mobile applications in order to provide advertisements about goods and services that may be of interest to you which are offered by us or by our retailers. Those companies are instructed to follow industry guidelines with regard to interest-based advertising, such as the Digital Advertising Alliance’s principles for online behavioral advertising. Among other things, the ads that are displayed to you should have the AdChoices icon or a similar mechanism which you may click to direct you to a website where you may opt-out of interest-based advertising. If you would like more information about this practice and how to opt-out of receiving communications from these third-party advertising companies, please visit https://youradchoices.com/.

Various data collected for advertising purposes may be restricted through cookies. See our Cookie Policy for more information.

How We Share Information

We share your information with others as follows.
 
Other Users. If you create an account, information such as your username, photo, birthday, and other information you enter may be displayed to other users of the Platform to facilitate user interaction within the Platform. We will not reveal your contact information to other users without your permission.
 
Some of your activity on and through the Platform is public by default. This may include, but is not limited to, content you post publicly through message boards, blogs, social media, or reviews on the Platform. If you choose to provide information using certain public features of the Platform, that information may be governed by the privacy settings of those particular features and may be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information.
 
Promotions. If we sponsor surveys, sweepstakes, contests, promotions, or other solicitations for third parties, we may share the information you provide with those third parties. We may also share such information with third parties that provide marketing and advertising on our behalf, as well as with our retailers.
 
We use various third parties that may do one or more of the following activities in regard to credit card transactions: (a) validate, screen for fraud, facilitate, and process credit card transactions, (b) charge and settle credit card transactions, and/or (c) tokenize, vault and store credit card data. We require those third parties to use your information only to process the credit card transactions for us. Without limiting the generality of the foregoing, you authorize us to collect, share, store, and otherwise use your information in conjunction with: Amazon Web Services and other systems that we use to deliver our service.
 
Social Media. We may share certain data, such as your mobile telephone or e-mail contact information, with social media outlets, like Facebook and Instagram, in connection with our agreement to share such information with them, in order to provide more targeted advertisements about goods and services from us or mall retailers that may be of interest to you.
 
Location Data. We may share location data collected from your ISP, Sites, and/or the Apps via your mobile device with third parties that provide marketing, advertising, and analytics services on our behalf, as well as for our retailers.
 
Our Affiliates. We may share any and all of your information you have provided or we have collected, purchased, derived or produced with our trusted subsidiaries and entities in which we have an ownership or is under common control with us, for purposes of providing you with better service or content, or to communicate with you regarding promotions, upcoming events, and other products and services offered by us and/or those affiliates, including through the use of contextual and interest-based advertising.
 
Third Party Service Providers. We may share your information with third-party service providers that assist us in operating the Platform, for and on our behalf, such as a hosting company or e-mail provider. They are instructed to use the information only to assist us in operating the Platform. We may also share your information with third-party service providers other than for their assistance, such as sharing your feedback with our vendors to improve the Platform. We may also share your information with third parties that provide marketing and advertising on our behalf, as well as with our retailers.
 
We may share de-identified data concerning retail consumer behavior with third parties, including entities with whom we have entered into an agreement to provide such de-identified data for analytics or marketing purposes.
 
We may also share with our retailers de-identified segment information, which is information that does not identify you personally, but allows the retailers to know more generally the products being purchased through, and the consumers who are using, the Platform.
 
Required by Law or To Protect Interests. We may disclose your information to (i) comply with laws, rules, regulations, legal processes and governmental requests; (ii) enforce this Notice and our terms of use, including investigation of potential violations of this Notice or the Terms of Use; (iii) detect, prevent or otherwise address fraud, security or technical issues (such as for fraud protection, credit risk reduction and spam/malware prevention); (iv) respond to user support requests; (v) avoid liability, or to protect our rights or property or the rights or property of anyone else (such as when user is believed to be in violation of our terms of use; and/or (vi) protect the rights, property and safety of our companies, partners, contractors, customers, users and the public (such as to report suspected illegal activity to law enforcement).
 
Corporate Activity. If we sell assets (or the assets of a division or subsidiary) to another entity or if we are acquired by or merged with another entity, we may share with such entity information about users of the Platform that is related to that part of our business that is sold to or acquired by or merged with the other entity.

Do Not Sell My Personal Information;
Opt-out;Children; State Rights

In General

Children. The Platform is not directed to children under the age of 18. We do not knowingly collect personal information from children under the age of 18, nor do we knowingly distribute such information to third parties. If we become aware that we received personal information from someone under the age of 18, we will take steps to delete such information from our records. If you believe we have personal information from someone under 18, please contact us at [email protected]
 
We use and disclose the information collected as explained in this Notice. How we use and disclose that information may be supplemented in the area where you provide the information.
 
Terminating Your Account. You may terminate an account you set-up on any of the Sites, the Apps, etc. by e-mailing us at [email protected] . If you terminate your account, any association between your account and information we store will no longer be accessible through your account. We may retain the information collected prior to termination for archival and/or legal purposes, except as otherwise set forth in this Notice. Any information you shared in public areas of the Platform will remain in those areas until it is deleted in accordance with our data retention policy.
 
You may adjust the settings on most devices to allow the Sites or App to gather, or to disable it from gathering, location positioning data. Certain features, such as a mall locator, may not work as effectively if you disable location positioning data.
 
Do Not Track. Do not track is a voluntary program among Internet advertisers that is intended to give users the ability to opt-out of interest-based advertising. There are a few ways in which your computer may transmit a “do not track” signal to certain websites and online services you visit, and currently no standard has been established. We do not respond to do not track signals, and the settings in your browser will have no effect on the Sites.
 
Interest-based Advertising Opt-out. Among other things, the ads that are displayed to you may have the AdChoices icon or a similar mechanism which you may click to direct you to a website where you may opt-out of interest-based advertising. If you would like more information about this practice and how to opt-out of receiving communications from these third-party advertising companies, please visit this link.

Security

We have endeavored to put into place reasonable security measures in an effort to protect information against unauthorized access, destruction, or alteration while it is under our control. However, no method of transmission over the Internet, and no method of storing information, can be 100% secure. So, we cannot guarantee the absolute security of your transmissions to us and of your information that we store.

State Specific Rights

California Privacy Rights
 
The following are rights specific to consumers and shoppers who are residents of the State of California only (we may require proof of California residency in advance or in response to a request invoking CCPA rights):
 
California Privacy Protection Act (CCPA). Consumers (as defined in the CCPA) that use the Platform and who are residents of the state of California (CA) have the right to, no more than twice in any 12-month period, for activities on the Platform in the 12 months prior to such consumer’s request:
 
  1. Know what personal information is being collected by TFA about them, for what business purpose, and from what types of sources;
  2. Access the personal information that has been collected by TFA about them;
     
  3. Know if this personal information that is being collected by TFA about them is being disclosed to a third-party or sold to a third-party, and if being sold, whom it is being sold to*;
  4. Opt-out of the sales of any personal information that is being collected by TFA about them *; and
  5. Request any personal information about you that has been collected by TFA already be deleted.

* NOTE: TFA does not sell any personal information that it collects. For full details on how we may share information on you, please see our how [inert link we share your information section of this Notice.

To request one or more of these CCPA rights regarding the Platform, please do one of the following:

  1. Send a formal written request to [email protected] with your name, email address, and if applicable, your mobile phone number (if you receive text messages from TFA) and which CCPA right(s) you wish to invoke.

  2. Mail us a request including a photo or scanned copy of your state ID or driver’s license, your name, email address, and if applicable, your mobile phone number (if you receive text messages from TFA) and which CCPA right(s) you wish to invoke to the following address: Dillon Miller Ahuja Boss LLP, 5872 Owens Avenue, Suite 200, Carlsbad CA 92008

Shine the Light. California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits our shoppers who are California residents to request and obtain from TFA once a year, free of charge, information about the personally identifiable information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to: Dillon Miller Ahuja & Boss LLP, 5872 Owens Avenue, Suite 200, Carlsbad CA 92008

Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response. Also note that under California law, businesses are only required to respond to a shopper’s request once during any calendar year.

Eraser Law Notice to Minor Users. Registered users of an online service directed towards minors who are under 18 years of age and live in California (“Minor Users”), under California SB 568 (“Eraser Law”), have the right to request removal of content that such Minor Users post on a website (“Minor Posted Content”). As stated above, the Platform is not directed to children under the age of 18, so the Eraser Law may not be applicable to the Platform. Although, the Platform is not directed towards minors, upon receipt of a fully completed removal request TFA will use commercially reasonable efforts to remove Minor Posted Content from the portion of the Platform referenced in the request form, as long as your eligibility has been reasonably established. Any such request to remove Minor Posted Content does not ensure complete or comprehensive removal of the Minor Posted Content. Minor Users must complete the removal request accurately and in its entirety in order for the request to be processed.

 

Other State Privacy Rights

Nevada Residents. If you are a resident in the state of Nevada, please note that we do not sell your information to third parties for any monetary compensation. Thus, any request from a resident of Nevada directing us not to sell the information we collect from you is inapplicable, and we will not respond to such requests. If you have any questions about our third-party disclosure practices, please contact us at [email protected]

 

Non-U.S. Residents

Residents of other countries outside the U.S., such as the European Union, may have other rights. As stated in our terms of use, while you may be able to setup an account as a user outside the U.S., we make no assurances or representations of any kind that the Platform is suitable for use in the country in which you reside.

By accessing the Platform, establishing an account, or making a purchase, you consent to the processing of your personal information as provided in this Notice. You may withdraw that consent by contacting us at [email protected] You are required to provide certain personal information in order to open and maintain an account. Your failure to provide such information may preclude you from establishing an account or may subject your account to termination. An account may be required to make certain types of online purchases, as a guest style checkout option is not always available across all of our Sites and Apps.

If at any point you believe the personal information we process about you is incorrect, you may access your account and modify it there, or otherwise request to see the information and to have it corrected or deleted by contacting us at [email protected] If you wish to object to or raise a complaint on how we have handled your personal information, you may contact our Data Protection Officer who will investigate the matter. You may also be able to have your personal information transferred by contacting us at [email protected]

If you are not satisfied with our response or believe we are processing your personal information not in accordance with law, you may complain to the data protection authority in your jurisdiction.

 

General Data Protection Regulation (GDPR)

If you are a resident of the European Union (EU), believe your information has been stored on the Platform, and wish to exercise one or more of your GDPR rights regarding your personal data on the Platform (which may include Personal Data Access, Rectification, or Erasure), please mail us a request including a photo or scanned copy of your valid photo ID, your name, email address, and if applicable, your mobile phone number (if you receive text messages from TFA) and which GDPR right(s) you wish to invoke to the following address: Dillon Miller Ahuja Boss LLP, 5872 Owens Avenue, Suite 200, Carlsbad CA 92008.

Our Data Protection Officer (DPO) may contact him at [email protected]

Changes to this Privacy Notice

We may amend this Notice from time to time. All versions of the Notice are dated with the effective date of that version of the Notice (i.e., the date on which the applicable version of the Notice was posted to the Platform). Our use of information we learn about you will be governed by the most recent Notice in effect. Your use of the Platform signifies your acceptance of the most recent Notice in effect.

The following supplements the terms of use and privacy policy and explains the use of cookies and related technologies on the websites (“Sites”) operated by TFA, Inc. and its affiliates (“TFA”), including the Sites at https://topflightassistance.com/ (including all of its subdomains). The TFA entity that operates a Site is identified at that Site. The words “user,” “you” and “your” mean users of the Site, and the words “we,” “our” and “us” mean the TFA entity that operates the Site.

Cookies Used

The Sites employ browser-based, HTTP and/or HTTPS cookies, which are small text files placed on your computer’s hard drive or mobile device’s onboard storage and subsequently read by the domain owner that placed them as you visit a website, as well as web beacons (also known as pixel tags), which are electronic images embedded into a webpage, and HTML5 storage which allows data to be stored locally within the browser, in lieu of cookies. Cookies are used for a number of purposes, such as authentication, providing security, maintaining your preferences, advertising, website improvement and analytics. We may also engage third party vendors to use these technologies on our behalf.

We and/or our third-party vendors utilize session cookies, which expire typically at the end of your visit to our Sites, and persistent cookies, which are cookies that remain within your computer or mobile device over a period of time. In addition to our creating and placing a cookie on your computer or mobile device, we have arrangements with third party vendors which may also create and place cookies on your computer or mobile device as you visit the Sites. These third parties collect and store information to provide services to us, will change from time to time, and may include Google, Salesforce, DoubleClick, Quantcast, Pingdom, Nasdaq, Hot Jar, Twitter, Pinterest, Facebook, AppNexus, Strikingly, The Trade Desk, Yahoo Ad Exchange, Marin Software, iGoDigital and MaxMind.

The first time you visit the Sites, we assign you a unique ID, which is stored in the cookie file on your computer or mobile device. This ID is used to identify you as you navigate the Sites, and when you return to the Sites after having visited elsewhere through the Internet. We collect and retain information regarding your visits to and navigation through the Sites, such as the webpages visited and the dates, times, and duration of your visits.

Disabling Cookies

You may choose not to accept cookies through a setting on most browsers (which can also be set to notify you each time a cookie is set). If you choose to refuse cookies, or if you delete cookies, you may not be able to use all of the features of the Sites.

Collection and Use of Information from Cookies

 
Sites Improvement and Analytics 
 To help us improve and enhance the Sites, we use cookies and web beacons for record keeping, to track your movements when you visit the Sites and to help us and our authorized third-party analytics vendors to understand how the Sites are utilized. We may use this information in aggregate form or, alternatively, we may keep the information in an individual profile. 

 
Preferences
We use cookies to maintain your preferences on the Sites, such as to keep you logged into your account or to save various states and decisions you make while browsing the Sites.
 
 
Compliance with Terms of Use
We use IP addresses, MAC addresses and other computer or device identifying technologies to identify a user when we feel it is necessary to enforce compliance with our terms of use or to protect the Sites, our customers, or other individuals.
 
 
Marketing and Advertising
We use cookies and other technologies to identify that your web browser or mobile device has accessed areas of the Sites and may associate that information with your account if you have one. We and/or our affiliates and/or the third-party vendors we engage may use the information you provide and that is generated from cookies and other technologies in order to serve advertisements to you on our or our affiliates behalf and for our retailers, such as more relevant, interest-based advertising.
 
 
Sharing Information from Cookies
We may share information collected from cookies and other technologies with third parties that provide services on our behalf. We may share such information with social media outlets to which you subscribe. We may share such information with third parties that provide marketing and advertising for us and with our retailers. We may also share such information with our affiliates, as outlined in our privacy policy.

Contact

We welcome your questions and comments about privacy, and what we do. Please feel free to contact us at [email protected]

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