Panasonic Avionics Corporation (“PAC,” “we,” “us,” or “our”) values your privacy. In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose information that we obtain about users of the inflight internet services (the “Services”) on behalf of the airline you are traveling with (“your airline”). To ease your review of this Policy, please you the interactive table of content below to reach the relevant section:
By using the Services, you acknowledge that your personal information will be handled as described in this Policy and, if payment is made via PAC WISP, you consent to the Terms of Sale, which are incorporated by reference into this Policy. If we are not processing payment on behalf of your airline, the Terms of Sale will not be linked here.
The Services are made available to you directly through your airline, not directly by PAC. We act as a data processor on behalf of your airline, who is the controller, and your airline’s privacy policy will also apply to how your personal information is collected, used and disclosed. If you have any questions or comments about your privacy rights please contact your airline.
Protecting the privacy of persons under the age of 16 is especially important. For that reason, we do not knowingly collect or maintain information from persons we actually know are under 16 without parental consent, and no part of the Services are structured to attract anyone under 16. If a person under 16 has provided personal information to us, we ask that a parent or guardian of the person contact us at privacy@panasonic.aero if they would like us to stop processing such information and have it removed from our database and we will use all reasonable efforts to do so.
Type of Personal Information We Collect About You
We collect information about you directly from you and from your airline, as well as automatically through your use of the Services. When used in this Policy, personal information means “any information about an identifiable individual”. Information that is anonymized or de-identified is not personal information.
Information Collected Directly From You: The information collected from you depends on how you use the Services. To use the Services without creating an account, we collect your email address and payment information. If you create an account for your use of the Services, we also collect identifiers such as your email address, name, country of residence, and payment information. In order to use your airline frequent flyer or rewards program miles or points to pay for the Services, we collect your rewards program membership number. You may also provide us with additional information, such as your seat number on your flight, if applicable. When you contact our customer service center, we will collect your name, contact information, such as your email address and phone number, and your reasons for contacting us.
Information We Collect from your Airline: We collect information about you from your airline. When you use the Services, we may receive information from your airline such as passenger seat assignments and information about your frequent flyer status and account balance (such as when you use your miles or points to pay for the Services).
Information We May Collect Automatically: We automatically collect the following information about your use of the Services, including through the use of network management tools. When you navigate the login page to the Services, we collect: your browser type and operating system; Service pages you view; links you click; your IP address; the length of time you visit the Services; the airline that you are traveling with to access the Services and your flight’s route. When you initiate an internet session on the Services, we collect information about the amount of bandwidth you use. We also aggregate data about passengers’ use of the Services, such as the number of sessions, the number of sessions purchased and the most popular domains from a given flight.
How We May Use Your Information
We may use your information to provide the Services and to customize your experience during your flight.
We may use your personal information in accordance with your Airline’s instructions, namely:
PAC may share personal information to your airline, service providers and other third parties for the purposes detailed in this Policy.
More specifically, we may share your personal information as follows:
Airlines: The Services are only available through your airline. We may share information with your airline about how its passengers use the Service. This may include both personal information, such as Service users’ names and email addresses, and aggregate information, such as the number of passengers that used the Service or the most popular domains visited during a flight;
Affiliates: We may share the information we collect about you to our affiliates or subsidiaries for the purposes described in this Policy; however, if we do so, their use and sharing of your personal information will be subject to this Policy;
Service Providers: We may share the information we collect from you to third party vendors, service providers, contractors, processors or agents who provide services on our behalf;
Business Transfers: If we are or may be acquired by or merged with another company, if any of our assets are transferred to another company or as part of a bankruptcy proceeding, we may transfer the information we have collected about you to the other company;
In Response to Legal Processes: We may also share the information we collect from you in order to comply with the law, a judicial proceeding, a court order, or another legal process, such as in response to a subpoena;
To Protect Us and Others: We may also share the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Sale or this Policy, or as evidence in litigation involving PAC or your airline.
The following table summarizes our personal information collection, use, and sharing practices in the preceding 12 months since we last updated this Policy.
As reflected in this table, we may share your personal information as follows.
| Category of Personal Information Collected on Behalf of Airline | Examples | Categories of Sources | Business/Commercial Purpose | Categories of Third Parties with Whom PAC Shares PI |
| Identifiers | Full name, email address, country of residence, phone number, purchase details, and flight information | You, your airline | Processing payments, protecting against malicious, deceptive, fraudulent or illegal activity and enabling or effecting, directly or indirectly, a commercial transaction | Service providers, payment processors, law enforcement authorities, and those involved in legal proceedings, with consent |
| Unique identifiers or personal identifiers | IP address, device IDs | You | Processing or fulfilling orders and transactions, debugging to identify and repair errors that impair existing intended functionality and enabling or effecting, directly or indirectly, a commercial transaction providing customer services | Service providers, payment processors, law enforcement authorities, and those involved in legal proceedings, with consent |
| Financial information | Credit card or other payment information | You | Processing or fulfilling orders and transactions | Service provider payment processors |
| Internet and other network activity | Browsing activity | You, Your mobile devices and computers used to access our Site | Customer inquiry and trouble shooting purposes | Your airline |
We have not sold your personal information in the preceding 12 months and do not intend to sell in the future without your prior written consent. We do not and will not sell the personal information of minors under 16 years of age without affirmative authorization.
We use cookies only to keep a record of your review and consent to our privacy practices as well as as part of session management, and is needed in order to provide the service.
Cookies are small text files that are saved on your device’s hard drive through your web browser for record-keeping purposes.
You may delete or disable certain of these technologies at any time via your browser.
The Services may contain links to third-party websites, such as to your airline and advertising sponsors. 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.
We will store your personal information for only as long as necessary to fulfill the purposes for which it was collected.
We will store your personal information for only as long as necessary to fulfill the purposes for which it was collected, except where otherwise required or permitted by law. Once no longer required, your personal information will be securely destroyed or anonymized (so the information no longer identifies you).
Please note that if your personal information is collected by a third party, it will be retained in accordance with the privacy policies and records retention requirements of that third party.
We have implemented technical and organizational measures to protect your information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.
The measures we have implemented to protection your personal information include physical, administrative and electronic (technological) security measures that are reasonable given the sensitivity of the information collected, the amount, distribution and format of the personal information, and the methods of storage. However, there is always a certain level of risk involved when personal information is collected, processed and stored and we are unable to guarantee the security of your personal information.
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.
You may modify personal information that you have submitted by logging into your account and updating your information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Services for a period of time.
If you are a resident of the European Union, please see the Information for EU Data Subjects section below for additional information on accessing your information and other legal rights available to you under European Union law.
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, if you are a California resident, you have the right to know what personal information is collected and disclosed about you under the California Consumer Privacy Act of 2018. Additionally, you have the right to access and delete your personal information
How to Exercise Your Rights: Since we process personal information on behalf of your airline in connection with the Services, requests to access, correct, amend, or delete personal information should be submitted directly to your airline. We will provide assistance to your airline, as necessary. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your or your minor child’s personal information.
Your request must provide sufficient information that allows your host airline to reasonably verify you are the person or authorized representative about whom we, or the host airline, collected personal information. Before handling your request, your airline may ask you for additional information to confirm your flight information, identity or for security purposes.
For further information, please visit American Airline’s website and privacy policy.
Right to Access Your Personal Information: You have the right to request access to the specific pieces and categories of personal information collected about you over the past 12 months and: (a) the categories of sources for the personal information; (b) the business or commercial purposes for collecting that personal information, legal basis and methods of processing; and (c) the third parties or categories of third parties to whom your personal information may be transferred.
Right to Delete Your Personal Information: You also have the right to request deletion of your personal information. If the processing of your personal information is necessary for compliance with a legal obligation, the establishment, exercise, or deference of legal claims or when required for our essential business purposes, such as providing services to you, your business may not be required to comply with your request.
Right to Non-Discrimination: You have the right to be free from discrimination in product quality, goods or services if you choose to exercise your privacy rights under the California Consumer Privacy Act.
Do Not Track Signals: We do not respond to Do Not Track signals to the extent received from a web browser. Because there currently is not a universally accepted technological or legal standard for recognizing or honoring DNT signals as reflections of user choice, we do not respond to them at this time. Once such technology is created and has received applicable regulatory approval, we will consider (a) whether it is possible; and (b) if so how it can be incorporated within our environment in the future.
In its capacity of data processor providing services to your airline, PAC complies with the General Data Protection Regulation (“GDPR”) and assists your airline in complying with its data controller’s obligations.
The Legal Basis for Processing Your Personal Information Under GDPR: We are a data processor and process your personal information on behalf of your airline, which is the controller of your personal information.
We may process your personal information on the following legal basis:
Right to Restrict the Processing of Your Personal Information: You have the right to restrict the processing of your personal information in the following circumstances: (i) you contest the accuracy of the personal information; (ii) the processing is unlawful but you wish to restrict rather than prohibit the processing of your personal information; (iii) the purposes for processing your personal information no longer exist, but you require the personal information for the establishment, exercise, or defense of legal claims; or (iv) you have legitimately objected to the processing of your personal information and the processing is therefore restricted pending the verification of whether the legitimate grounds of your airline override your objection.
We can continue to process your personal information following a request for restriction:
Right to Data Portability: To the extent that we process your personal information (i) based on your consent or under a contract and (ii) through automated means, you have the right to receive such personal information in a structured, commonly used, machine-readable format, from your data controller.
Right to Object to the Processing of Your Personal Information: You can object to any processing of your personal information based on the legitimate interests of your airline or PAC if you believe your fundamental rights and freedoms outweigh such legitimate interests. If you raise an objection, we have an opportunity to demonstrate that your airline or PAC has compelling legitimate interests that override your rights and freedoms.
How to Exercise Your Rights: If you would like to exercise any of the rights described above, please contact American Airlines.
We ask that you please attempt to resolve any issues with your airline or PAC first if you have concerns about the processing of your personal information, although you have a right to contact your supervisory authority at any time.
Before handling your request, your airline may ask you for additional information to confirm your flight information, identity or for security purposes.
We may not always be able to fully address your request, such as if doing so would impact the duty of confidentiality we owe to others or if we are legally entitled to deal with the request in a different way.
PAC is currently in the process of applying for re-certification to the Swiss-US and EU-US Privacy Shields due to an inadvertent lapse. Where the personal information that we collect through or in connection with the Services is transferred to and processed in the United States or anywhere else outside the European Economic Area (EEA) for the purposes described above, we will take steps to ensure that the information receives an adequate level of protection, including by entering into data transfer agreements and using the EU Commission approved Standard Contractual Clauses.
If you have questions about this Processor Privacy Policy, you may contact us at privacy@panasonic.aero. If you have a disability and need access to this privacy policy, please, call us at 1-800-716-1805.
Please note, however, that PAC processes your personal information on behalf of your airline. If you wish to exercise rights and choices with regard to your personal information, please contact your airline directly. We will support your airline as needed in responding to your request.
This Policy is current as of the Effective Date set forth below. 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 accordingly.