Business Class Guru Privacy Policy

Effective Date: August, 21, 2019

This website or mobile application, as applicable, is operated by Wholesale Flights, Inc. (“ Wholesale”, “ we”, or “ us”). Your privacy is important to Wholesale and we are committed to protecting the privacy of your information. This Privacy Policy describes how we collect, legal basis for processing, use, store, share and protect your information in connection this website or mobile application (the “ Site”), and the services (including, but not limited to, marketing and selling travel products and services) and tools (including, but not limited to, mobile applications and other software applications related to the Site (collectively, the “ Service”)).

Legal Basis for Processing of the Information: By accessing, visiting or using the Service, you expressly consent to our collection, use, disclosure and retention of your information as described in this Privacy Policy. Consent is required for us to process the data. You many withdraw consent at anytime by emailing us at info@wholesale-flights.com or sending a letter to us by postal mail at 851 Burlway Road # 502, Burlingame, CA 94010.

If you access or purchase the Service through a third-party service that provides a gateway to the Service, such as Google Play or iTunes (a “ Gateway Service”), you will have a separate, additional account relationship with that Gateway Service and the information you provide to that Gateway Service will be handled in accordance with the privacy practices of the applicable Gateway Service. Gateway Services are not partners or representatives of Wholesale and Wholesale is not responsible for the omissions or acts of a Gateway Service regarding the collection or use of your information.

We will notify you of changes to this Privacy Policy by posting the amended terms on the Service at least ten (10) days before the effective date of the changes. If you do not agree to the new terms, you may terminate your account within the applicable ten (10) day period by contacting us using the information in Section 16 below, and you will not be bound by the amended terms. Otherwise, the new terms will take effect after ten (10) days.

Information Collected from You by Wholesale.

We may collect information that you provide to us in connection with your use of the Service, send forms, e-mail messages, or other information to us through the Service.

In connection with your use of the Service, you may provide us with your personally identifiable information, which is information that, alone or in combination with other information, allows us to identify you, such as your name, address, phone number, e-mail address, contact preferences, credit card information, financial information or information relating to a technical support or Service issue. If you provide us with your personally identifiable information, you are giving us permission to use that information for the specific purpose for which it is provided and for any other purpose described in this Privacy Policy. Providing personally identifiable information is optional and you are not required to provide this information to use the Service.

Information Automatically Collected Through the Service.

When you use the Service, Wholesale may automatically collect information about you.

If you access the Service through a mobile device, we may collect information about your geo-location, including your geo-location relative to and within third party merchant locations. Further, we may collect information such as your mobile device ID, device type, and your use of functions, features, or notifications on the device, as well as signal strength relating to WIFI or Bluetooth battery level, functionality, temperature, and similar technical data. We may collect this information even if you are not logged in to the Service. If you use the Service through a mobile device and you do not want us to collect your geo-location information you may change your preferences through the “Settings” feature of the Wholesale mobile application.

If you access the Service through a computer, we may collect and store information such as your browser type, IP address, language, operating system, the state or country from which you accessed the website, the pages you view, the services you use, the date and time of your visit, the websites you visited immediately before and after visiting our websites, error logs, and other hardware and software information. Wholesale. maintains log files of the traffic that visits our Site. We do not link any information gathered in these log files to personal information. Log files are used to manage traffic loads and information technology requirements for providing reliable service. We may use third party analytics providers, such as Google Analytics, and various technologies, including cookies and similar tools, to assist in collecting this information. We may use this information to formulate statistical models about use of the Service, enhance the Service for our users, and provide you with tailored content and advertising. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser Add-on by clicking here.

Information Automatically Collected Through Cookies.

We may automatically collect information from you when you use the Service using “cookie” technology and similar online tools, such as web beacons and web pixels. “Cookies” are small files that a website stores on a user’s computer or device. We use cookies to identify customers when they visit our Site. Cookies are used to remember user preferences and maximize performance of the services we offer. Additionally, cookies help us to identify returning users so that we don't ask them to enter their email and password with every visit. Except as stated in this Privacy Policy, the information we collect with cookies is not sold, rented, or shared with any outside parties. We do not use cookies to obtain or retain any personal information about you apart from what you voluntarily provide us. Most web browsers automatically accept cookies, but you may set your browser to block cookies (consult the instructions for your browser on how to do this). Please note that if you decide to block cookies, this may interfere with your ability to perform certain transactions, use certain functionality, and access certain content on the website.

The Service may include links to other websites, third-party advertising, and other content from third-party businesses. These businesses, third-party websites, and advertising companies, or advertisers working on their behalf, may use web beacons and cookies to optimize or personalize advertising content, measure the effectiveness of their ads, and to track users who click on the links made available through the Service. These third-parties may use web beacons and cookies to track the actions of users online over time and across different platforms or web sites to deliver targeted electronic advertisements to an individual user. For information about how tracking works for online advertising purposes you can visit http://www.aboutads.info/choices. We do not have control over or access to cookies or web beacons that these third parties may use. We are not responsible for the privacy practices of these third parties and we encourage you to read their privacy policies.

Some third-party advertising companies may provide a mechanism to opt-out of their technology. For more information about the opt out process, you may visit the Network Advertising Initiative website, available at http://www.networkadvertising.org/managing/opt_out.asp.

Furthermore, if you access the Service through the internet, your browser may allow you to adjust your browser settings so that “do not track” requests are sent to the websites that you visit. Wholesale, however, will not disable tracking technology that may be active on the Service in response to any “do not track” requests that we receive from your browser.

Use of Information by Wholesale.

Wholesale may use information that we collect about you through the Service to:

  • personalize, measure, customize, and improve our services, advertising, and content and otherwise to enhance your experience of the Service;
  • prevent, detect, and investigate potentially illegal or prohibited activities, and enforce Wholesale’s Terms and Conditions;
  • provide access to the Service and to provide you with requested customer support and services and to process and respond to your inquiries;
  • troubleshoot problems and resolve disputes;
  • contact you with information, including marketing, promotional, and advertising information and recommendations that we believe may be of interest to you;
  • generate and review reports and data about our user base and service usage patterns;
  • analyze the usability, accuracy, effectiveness, or popularity of the Service;
  • provide you with information we deem relevant when you visit third party merchant locations;
  • compile aggregate data for internal and external business purposes;
  • provide you with other services requested by you as described when we collect the information; and
  • if you use the Site on a mobile device, with your consent, we may send push notifications to your mobile device to provide updates about the Service and other relevant messages. You can manage push notifications from the “Settings” page within your account. You may also be able to manage them from your mobile device’s settings page.


Disclosure of Information to Third Parties.

Wholesale may disclose your information to the following third parties:

  • Business Transfers; Bankruptcy. If Wholesale becomes involved in a merger, sale of assets, acquisition, securities offering, reorganization, bankruptcy, dissolution, or other transaction or if the ownership of all or substantially all of our business otherwise changes, Wholesale may share or transfer your information to a third party or parties in connection with the applicable transaction.
  • Our Service Providers: We may share your information with third party contractors or service providers who provide certain services to us or on our behalf, such as operating and supporting the Service or otherwise responding to your customer service requests. These service providers will only have access to the information needed to perform these limited functions on our behalf and are required to provide your information with at least the same level of protection and security as we use for the Service.
  • Aggregate Information. Wholesale may share information relating to users and visitors of the Service with affiliated or unaffiliated third parties on an aggregate basis. We note that, while this information will not identify you personally, in some instances these third parties may be able to combine this information with other data they have about you, or that they receive from third parties, in a manner that allows them to identify you personally.
  • Our Affiliates: We may share some or all of your information with our subsidiaries, parent company, and corporate affiliates, joint venturers, or other companies under common control with us for internal business purposes. We will require these entities to comply with the terms of this Privacy Policy regarding their use of your information.
  • Law Enforcement Authorities. To the extent permitted by law, we may share your information with governmental agencies, law enforcement, or authorized third parties, in response to a verified request relating to a criminal investigation, alleged illegal activity or any other activity that may expose us, you, or any other user of the Service to legal liability, or to protect our rights or property, or during emergencies when safety is at risk.
  • Third Party Business Partners. If you access the Service through a mobile device, we may, from time to time, share your geo-location information and device ID with a few carefully selected third party business partners that may use this information on behalf of themselves or their third party business partners to provide you with marketing information about products or services that may be of interest to you, for purposes related to analytics, advertising, attribution (e.g., measuring ad performance) and research. Further, we may sell or otherwise make available to third parties information that includes personally identifying information, specifically, names, phone numbers, e-mail addresses, and mailing addresses. We will not provide credit card numbers to third parties. If you do not want us to share any of your personal information with other organizations, you may opt-out by emailing us at info@wholesale-flights.com or sending a letter to us by postal mail at 851 Burlway Road # 502, Burlingame, CA 94010. We note that, if you have downloaded the Wholesale mobile application to your mobile device and you notify Wholesale of your election to opt-out, you will need to open the Wholesale mobile application and send us your opt-out request via the Send Feedback button located in the Settings tab in order for Wholesale to disable sharing of your information with certain third party business partners.


No Spam, Spoofing, or Spyware.

To report Wholesale-related spoof or spam emails to us, please forward the email to info@wholesale-flights.com. You may not use our communication tools to send spam or otherwise send content that would violate the Wholesale Terms and Conditions.

Security.

Wholesale takes reasonable measures to protect the information you provide to Wholesale or submit through the Service against theft, loss, and unauthorized use, disclosure, or modification. We cannot, however, warrant or guarantee the security of any information you transmit to Wholesale or submit through the Service and you do so at your own risk. No internet or email transmission is ever error-free or fully secure. Email sent through or to the Service may not be secure. You should use caution whenever submitting information online and take special care in deciding what information you send to us via email.

Wherever we collect sensitive information (such as credit card data), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for "https" at the beginning of the address of the web page.

While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment.

If you feel that this site is not following its stated information policy, you may contact us to notify us.

Use of Information Outside of Your Country of Residence.

If you are located outside of the United States and choose to use the Service or provide your information to us, your information will be transferred, processed and stored in the United States. U.S. privacy laws may not be as protective as those in your jurisdiction. Your agreement to the terms of this Privacy Policy followed by your submission of information in connection with the Service represents your agreement to this practice. If you do not want your information transferred to, processed or stored in the United States, you should not use the Service.

Accessing, Managing, and Changing Your Information.

You may change and update the information you provide through the Service, or change your preferences concerning how we use your information, as follows:

  • Changing, Updating or Deleting Your Information. You may make changes to the user information you have provided in connection with your Wholesale account by logging in to your account and changing the information, or by contacting us at info@wholesale-flights.com. If you choose to terminate your account, you may also request that we delete your information by contacting us at info@wholesale-flights.com. Following receipt of a request from you, we will take reasonable steps to update, correct or delete your information.

  • In addition, if you are a California resident under the age of 18 and are a registered user of the Service, you may request that we remove information or consent about you that you posted on the Service by (i) submitting a request in writing to info@wholesale-flights.com and (ii) clearly identifying the information or content you wish to have removed and providing sufficient information to allow us to locate the information or content to be removed. However, please note that we are not required to, and may not be able to, erase or otherwise eliminate content or information if (a) the information or content is anonymized so that you cannot be individually identified; (b) the information or content was posted, stored, or republished by another user; (c) other federal or state laws require us or a third party to maintain the information or content; (d) you do not follow the instructions posted in this Privacy Policy on how to request removal of your content or information; or (e) you have received compensation or other consideration for providing the content. Further, nothing in this provision shall be construed to limit the authority of a law enforcement agency to obtain the applicable content or information.

  • Email Communications. You can make changes regarding receiving email communications from us within your Wholesale account. You can also choose not to receive email communications from us by following the “unsubscribe” instructions in any email communication you receive from us.

  • Gateway Services. Wholesale does not control the information you provide to Gateway Services. If you want to change your preferences with regard to how an applicable Gateway Service collects or uses your information in connection with the Service, you should review the privacy practices of the applicable Gateway Service and adjust your privacy or other settings directly through the applicable Gateway Service.


No Use by Children.

Wholesale is not intended for use by children under the age of thirteen (13). We will never knowingly collect information directly from children under the age of thirteen (13) without verifiable parental consent. If you are under the age of thirteen (13), please do not provide us with information of any kind whatsoever. We encourage parents and guardians to spend time with their children online and to be familiar with the websites they visit. If you have reason to believe that we may have accidentally received information from a child under the age of thirteen (16), please contact us immediately at info@wholesale-flights.com.

Retention of Your Information.

We retain information for active Wholesale accounts if it is necessary and relevant for our operations. In addition, we may retain information from closed accounts to comply with the law, resolve disputes, prevent fraud, assist with any investigation, troubleshoot problems, enforce the Wholesale Terms and Conditions and take other actions permitted by law. The information we retain about you will be handled in accordance with this Privacy Policy. Wholesale will process personal information data and will store encrypted personal data indefinitely.

How to Contact Us.

If you have any questions about the Privacy Policy or our use of the information we collect from you in connection with the Service, you may contact us by email at info@wholesale-flights.com, or by postal mail at 851 Burlway Road # 502, Burlingame, CA 94010.

Your California Privacy Rights.

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you are a California resident and would like to request this information, please submit your request via email to the email provided above.

We are committed to providing you with meaningful choices about the information collected on our Services for third party purposes. You may visit the Network Advertising Initiative’s Consumer Opt-Out Link and/or the Digital Advertising Alliance’s Consumer Opt-Out Link to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit the Google Ads Settings page. However, we do not recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations and solutions.

Your rights as a data subject.

At any point while we are in possession of or processing your personal data, you, as a user, have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
  • Right of portability – you have the right to have the data we hold about you transferred to another organization.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.


All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data.

Dispute Resolution.

Any controversy or claim arising out of or relating to our privacy policy, or the breach of this privacy policy is subject to arbitration in accordance with the rules of the American Arbitration Association and is binding.