Last updated September 1, 2022
Previous versions of the Intelsat.com policies and GogoAir.com policies
Intelsat Privacy Policy Summary
The Intelsat Privacy Policy (including our Cookie Policy) applies to Personal Information (as defined below) collected by or on behalf of Intelsat US LLC and its subsidiaries, service providers and affiliates (collectively, “Intelsat”, “us”, or “our”). In the event of a conflict between this summary and the full Policy, the full Policy will control.
This policy is for users of our services, including for instance our website, subdomains, blog, Careers site, the MyIntelsat customer portal, and our other customer service systems (together, the “Service”). By using the Service you agree to this Privacy Policy and our Terms of Use.
Information Collected
- We collect Personal Information that you provide, which may include registration details, your name and email address, personal identifiers and your service preferences.
- We collect usage information about how the Services are accessed and used about how you use our technology platforms, such as browser type, operating system, the page served, the time, the type of content being transmitted (e.g., video content) or application being used, how many users visited the Sites, origin and destination information, flight information, subscriber status and preceding page views.
- We, and the advertising and other data companies we use, utilize cookies and web beacons to manage the Platforms, tailor our communications with you and personalize your experience on the Platforms.
- We may supplement the information we collect with information from external parties, for example if you link to us from a social media platform.
Uses and Sharing
- We use the information collected to operate and develop our services and to improve personalized content based on your preferences including advertisements, features and service performance.
- We may share your information with roaming partners, airline partners and external parties who store and process your information on our behalf. These include group companies who provide services to us in several countries and who are obligated to follow this Privacy Policy.
Your Choices and Access Rights
- You have certain rights to access, rectify, erase, obtain or transfer, and restrict the processing of your Personal Information if you are a data subject of the European Economic Area (EEA), United Kingdom (UK) or Switzerland.
- You have certain rights to know, delete, and opt out of the “Sale” (as defined by the CCPA) of your Personal Information if you live in California.
- You have the right to opt out of targeted advertising.
INTELSAT PRIVACY POLICY
Last updated September 1, 2022
General
Intelsat US LLC and its subsidiaries, service providers and affiliates, (collectively, “Intelsat,” “us” or “we”) respect your concerns about privacy and value our relationship with you. This Privacy Policy is intended to inform you of the types of information we collect, as well as our policies and practices regarding the collection, use and disclosure of that information through the web pages, tracking technologies, interactive features, mobile applications, our Careers site, blogs and their respective contents at Intelsat’s on-ground and in-flight URLs, including among others www.intelsat.com (collectively, “Intelsat Domains”), in addition to our Twitter, Facebook and other social networking sites, and their respective contents (collectively, the “Sites”), and the Intelsat services (collectively with the Sites, the “Services”), whether accessed via computer, mobile device or other technology.
QUICK GUIDE TO CONTENTS
Click on one of the links below to jump to the listed section:
- Information We Collect and How We Use and Process Your Information
- How We Share Your Information
- Consent to Processing, Transfer and Storage of Information; Disputes
- Your Rights under the General Data Protection Regulation (GDPR)
- Your Rights under California Law
- Your Rights Under Canadian, Brazil, Japan and Mexico Laws; Additional Information
- Other Choices About Your Personal Information
- Data Retention
- Links to Other Sites
- Security of Your Information
- Children
- Updates to Our Privacy Policy
- How to Contact Us
Personal Information You Provide to Us
When using the Services, you will, in most cases, be required to provide information that could reasonably be used to contact you, or to identify you personally, or that otherwise relates to your person (collectively, “Personal Information”) such as your:
- Name
- Mailing and/or billing address
- Financial information such as bank or credit card details
- Telephone number
- Email address and email preferences
- Employer information (e.g., for Careers site)
- Password for your Account and password hint question
When you provide us information for “refer a friend” messages, we use the information only to send the message you request and the information will not be used for other marketing purposes unless your friend consents. You may be identified to the friend in connection with such message. Please check that friends you refer are happy for us to contact them.
Information Collected by Automated Means
We may collect certain types of online activity data automatically when you use the Services.
We use this information to manage our network and provides us with information about the use of the Services, to help you with Service-related questions, to provide partner-sponsored sessions, to deliver content and advertising to you, and to present content in a form that can be viewed most easily from your device. We also use your IP or Mac address or T Mobile ID to determine the general geographic region from which you are accessing the Sites. This allows us to present appropriate content and inform you of special rules or rights that may apply to people in your jurisdiction and allows us to execute service transfers and landings.
We may receive information about your activities (such as clicking on an ad or viewing certain content) on our Sites or on other sites, which we or others collect when you browse the web. This may include information obtained through tracking technologies, such as cookies and we beacons.
As further described in our Cookie Policy, we use cookies and similar to collect data to recognize you on, off, and across different services and devices where you have engaged with our Services. You can opt out of our use of data from cookies and similar technologies that track your behavior for ad targeting and other ad-related purposes. For more information, please visit our Cookie Policy or adjust your Cookie Settings.
We use information collected about your activities on our sites to understand the way visitors use our Sites, to improve our Sites and other services we offer, and to personalize the content you see to show you information and offers that may interest you. We use information about your activities on other sites to gain additional information about your interests and preferences, and to determine where we should place marketing messages that may interest you and select messages from our partners that may interest you, if you consent to this. Tracking technologies also help us determine how to arrange the pages on our Sites in the most user-friendly ways.
Information From Third Parties
Intelsat may receive information about you from external parties. For example, if you are on another website and you opt-in to receive information from Intelsat, that website will forward to us your email address and other information about you so that we may contact you as requested. You may also choose to participate in an external party application or feature (such as one of our Facebook or Twitter applications or a similar application or feature on an external party website) through which you allow us to collect and share (or the external party to collect and share) information about you, including Personal Information. In addition, we may receive information about you if other users of an external party web site give us access to their profiles and you are one of their “connections” or information about you is otherwise accessible through your “connections” web page, profile page or similar page on a social networking or other external party website or interactive service.
We may also supplement the information we collect about you through the Services with other information from external parties. We may match the information we receive about you from external parties with the information we collect from you ourselves. For example, using multiple data sources, we derive your airline, tail number, origin, destination, and flight number of the flight when you access the Services. We use this information to enhance our ability to serve you, to tailor our content to you and to offer you opportunities to purchase products or services that we believe may be of interest to you.
General Purposes for Which We Use and Process Your Information
In general, we use and store information we and our service providers collect about and from you to:
- Enter into and perform the contract between you and Intelsat (to provide the Services and process payment information)
- Pursue our legitimate business interests (to provide the Services to you, respond to requests that you make, manage our network and business, provide training, troubleshooting and support, improve the Services, and better tailor content, advertisements, offers and the features, performance, and support of the Services, and to support Intelsat’s educational, networking, marketing, social, recruiting, and other business purposes)
- Fulfill any orders or requests that you make to us in the course of our business with you
- Verify and respond to your requests, questions and comments, including as part of the “Contact Us” feature on our website or your exercise of any relevant data subject rights
- Manage our network and protect our website and our customers (for security purposes)
- Tailor content, advertisements, offers and the features of the Services
- Enable you to create an account, store log-in credentials, and customize certain services, such as the MyIntelsat customer portal
- Consider you for current or future job opportunities if you create an account on our Careers site
- Conduct market research and tracking of sales data, including contacting you directly or via a third party to participate in customer satisfaction surveys or questionnaires via telephone, email or otherwise, and soliciting your opinions or feedback on Intelsat’s business activities
- Comply with legal and/or regulatory obligations and exercise our legal rights
- Identify you as the sender of, and to process, your emails
- Improve, enhance, and tailor the Websites for you (for example by providing content or features that match your interests), and to improve and enhance the overall experience for all users of the Websites
- Send you marketing and advertising materials, electronic newsletters, or promotional emails about our products and services Introduce you to additional value-added services offered by our partners that we feel may be of interest to you, if you have consented to this
- Fulfil purposes disclosed at the time you provide your Personal Data or otherwise with your consent
- Act in accordance with your consent and/or opt-out mechanisms with respect to the use of cookies and other similar technologies, as required by EU Directive 2002/58/EC and any successor legislation
- Comply with applicable law governing CPNI, to the extent that certain information that we collect in providing Intelsat’s inflight connectivity services constitutes customer proprietary network information (“CPNI”).
We do not use automated systems to make decisions about you.
Except as otherwise stated in this Privacy Policy (including our Cookie Policy), we do not sell, trade, rent, or share your Personal Information with external parties, unless you ask or authorize us to do so. We may share non-Personal Information, such as aggregate user statistics, demographic information, and usage information with external parties. We may also share your information as disclosed at the time you provide your information, as set forth in this Privacy Policy and in the following circumstances:
Roaming Partners. Intelsat has agreements in place with various companies (typically hotspot aggregators or telecommunications companies) (“Roaming Partners”) that provide the Services to their customers (“Roaming Partner Users”). If you are a Roaming Partner User, we may send to the applicable Roaming Partner: (a) the userID and password you submit to us when you sign in to use the Services in order to authenticate you and for security purposes; and (b) information regarding the times that you started and stopped use of the Services and bandwidth used.
Airline Partners. In order to provide the Services efficiently and carry out your requests, we may also disclose Personal Information, such as your email address, device identifier, and usage information to the airline partner on whose plane you have accessed the Services. To the extent you visit the websites of our airline partners, the privacy policies of those websites will govern.
External Parties Providing Services on Our Behalf. In order to provide the Services, carry out your requests, make various features, services and materials available to you through the Services and respond to your inquiries, we may share your Personal Information or usage information with external parties that perform functions on our behalf, such as (a) companies or individuals that: host or operate our Sites; analyze data; provide customer service; or manage payments; (b) advertisers; and (c) sponsors or other external parties that participate in or administer our promotions or provide marketing or promotional assistance. These service providers may have access to your information for the limited purpose of providing the service we have contracted with them to provide. These service providers do not have any independent right to share this information and may use it only as we direct.
Your Agreement to Have Your Personal Information Shared. While using the Services, you may have the opportunity to opt-in to receive information and/or marketing offers from someone else or to otherwise consent to the sharing of your information with an external party, including companies who advertise their services via the Service. If you agree to have your Personal Information shared, your Personal Information will be disclosed to the external party and the Personal Information you disclose will be subject to the privacy policy and business practices of that external party.
Affiliates. To facilitate our marketing and communications efforts, we may share some or all of your Personal Information with our Affiliates (“Affiliates” are parent companies, subsidiaries, joint ventures, or other companies under a common control), in which case we will require our Affiliates to honor this Privacy Policy.
Other External Parties. To the extent you visit external party websites, the privacy policies of those websites will govern.
In Connection with a Sale of Change of Control. If Intelsat becomes involved in a merger, divestiture, restructuring, reorganization, dissolution, or transaction involving the sale of all or substantially all of its assets, Intelsat may disclose and/or transfer your information during any such process. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use information you have provided through the Sites in a manner that is consistent with this Privacy Policy. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to external parties.
Law Enforcement Compliance. We may be required by law, regulation, or executive or administrative order, or by law enforcement officers and other governmental agencies acting under the color of law, to record some or all of your communications on or through the Services. We may, and you hereby authorize us to, disclose your Personal Information (including your Account Information, if applicable) and other information including your communications through the Services, if required by applicable law or by law enforcement officers acting under the color of applicable law, or if we believe in good faith that such disclosure is necessary to: (a) comply with relevant laws orders or regulations or to respond to subpoenas or warrants served on us; or (b) protect or defend the rights, property, or safety of Intelsat, you, other users, or external parties (especially in emergency situations); (c) to address fraud, security, or technical issues; or (d) to protect Intelsat’s rights or property.
Governmental Authorities. Some governmental authorities may require that we share your Personal Information with them (e.g., for sales on Gol, we may be required to share your Personal Information and transaction/purchase details with the applicable Brazilian tax authority). We may, and you hereby authorize us to, disclose your Personal Information to applicable governmental authorities to the extent required by applicable law.
By accepting this Privacy Policy, whether by establishing an Account (as defined below), signing-in to your Account, accessing the Services as a guest, or otherwise using the Services, you agree to the terms of this Privacy Policy and you expressly consent to the processing, transferring and storing of your Personal Information according to this Privacy Policy.
If you wish to withdraw or modify your consent to our collection, use or disclosure of the Personal Information provided to us, we reserve the right to terminate your Account or your continued use the Services if the withdrawal or modification of your consent would or could adversely affect our operations or the Services.
There may be cases where restrictions on the amount of data that can be disclosed to data subjects under applicable law (for example, if that would necessarily involve disclosing data about another person). Intelsat is permitted to withhold some types of Personal Data in certain circumstances, subject to applicable local law requirements.
If you are a User who resides outside the United States, please be aware that information we collect will be transferred to and processed in the United States. The laws of the United States may not protect the privacy of your information at the same level as provided by the laws of your country. In an effort to safeguard individual privacy, we will only transfer (within the meaning provided under the relevant data protection laws) personal information from the European Economic Area (EEA),United Kingdom (UK) or Switzerland to the United States if one of the following applies: we have entered into an agreement using standard contract clauses (approved by the European Commission or a European data protection authority, or by the UK data protection authority for transfer from the UK) with our service provider, business partner, or Affiliate regarding the transfer or you give your express consent to the transfer. By using the Services, or providing us with any information, you consent to the collection, processing, maintenance and transfer of such information in and to the United States and other applicable countries in which the privacy laws may not be as comprehensive as, or equivalent to, those in the country where you reside and/or are a citizen.
For disputes related to processing, transferring or storing of information, please contact us.
In addition, in the EEA, UK and Switzerland, data subjects have the right to lodge a complaint with a supervisory authority.
If you are in the European Economic Area (“EEA”), you have certain rights and protections under the law regarding the processing of your personal data. In addition to the notice provided above, the following notice applies to EU data subjects. In the event there is a conflict between the two as it applies to EU data subjects, this section shall take precedence. For purposes of this section, the term “Personal Data” shall have the meaning given by Regulation (EU) 2016/679.
You have the following rights with respect to the personal data which we collect about you:
Right to Access Personal Data. You have the right to view and request copies of your personal data.
Right to Rectification. You have the right to request inaccurate or outdated personal information be updated or corrected.
Right to Erasure. You have the right to request that your personal data be deleted (but note that this is not an absolute right and may be subject to exemptions based on certain laws).
Right to Restrict Data Processing. You have the right to request the restriction or suppression of your personal data.
Right to be Notified. You have the right to be informed about the collection and use of your personal data.
Right to Data Portability. You have the right to ask for your data to be provided to you or transferred to another data controller.
Right to Object. You have the right to object to the processing of your personal data.
Right to Withdraw Consent. You have the right to withdraw previously given consent to process your personal data.
To exercise your rights under the GDPR, you may follow the link to our webform, or contact us.
We do not use your Personal Data for any automated decision making covered by Articles 22(1) and (4) of Regulation (EU) 2016/679.
Data Protection Office
If you have any questions about this Privacy Policy, please feel free to contact us.
Complaints
You may file a complaint with a data protection authority for your country or region if you believe an infringement of applicable data protection law has occurred. A list of data protection authorities is available here.
If you are a California resident, you have specific privacy rights under the California Consumer Privacy Act (“CCPA”).
Right to Know. You have the right to ask us to disclose the personal information we have collected, shared, or sold about you in the past 12 months. If we are able to verify your identity, we will provide the categories of Personal Information we have collected about you, the categories of sources from which we collect it, our business or commercial purpose for collecting the personal information, and the specific pieces of personal information we collected.
If we have disclosed your personal information to any third party for any reason, we will also tell you the categories of personal information we disclosed, the categories of third parties with whom we shared it, and the purpose for which we shared it.
Right to Opt Out of Sale of Your Personal Information. California law defines “sell” very broadly. Sharing information such as your IP or Mac address or online identifier or allowing another party to have access to your travel preferences may be considered a “sale” of personal information. You have the right to tell us “Do Not Sell My Personal Information” to third parties.
Note that if you clear cookies on your browser, or use a different browser of device, you may have to opt-out again to make your “Do Not Sell” choice effective.
Right to Deletion. You have the right to request that we delete any personal information we have collected about you. We will only do this if we can confirm your identity, and in some cases, we are required or permitted by law to retain all or some of your information for specific purposes.
Authorized Agent. You have the right to appoint an authorized agent to exercise these rights for you.
You have the right not to be discriminated against, for example by receiving a different quality of services, if you exercise any of these rights.
To exercise your rights under the CCPA click here, or contact us. In order to respond to your request, we may validate your email address if you have an account with us. If you use an authorized agent to exercise rights for you, we will confirm that the agent is authorized by you.
When you make a request to access or delete your information or opt out of sale, we will generally confirm receipt of your request within 10 days, and respond within 45 days, though in some cases we have the right to take additional time if needed.
Financial Incentives. Our loyalty program requires you to provide personal information to join the program so that we can associate the program benefits with your account and to associate your account with partner airlines.
“Shine the Light” Law. If you are a California resident, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please contact us, and indicate in your communication that you are a California resident making a “Shine the Light” inquiry.
Brazilian and Mexican citizens with inquiries or complaints regarding this Privacy Policy should contact us and identify that you are making an inquiry or complaint under Brazilian or Mexican law.
If you are a Mexican or a Brazilian resident and wish to limit the use or transfer of any of the Personal Information provided to us, you may contact us and indicate that you are making such a request under the relevant country’s law. Please note that unless you state otherwise, we may send any corrected or updated Personal Information to every organization to which your Personal Information has been disclosed in accordance with this Privacy Policy. In accordance with our routine record keeping, we may delete certain records that contain Personal Information you have submitted through the Services. Please note that we may be required (by applicable law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). You should be aware that it is not always possible to completely remove or delete all of your information from our databases without some residual data remaining in our archives because of backups and other reasons. If you are a Mexican resident, your request to verify, correct, update, delete or limit the use or transfer of any of the Personal Information provided to us, will be processed within 20 days of the date on which we receive it.
You may withdraw your consent at any time; however, Intelsat will not be able to provide or continue to provide Services or marketing communications to you.
Notice to Canadian, Brazilian and Mexican Residents – Access to Personal Information / Contact Information
We are accountable for all Personal Information in our custody and control and have designated a Privacy Office that is ultimately accountable for the handling of all Personal Information in our custody and/or control, and for ensuring that we are complying with the principles described in this Privacy Policy.
If you have any questions about the accuracy of information that we have collected about you, you can have access to that information in order to verify and update it, unless we are permitted or required under applicable laws to refuse your access to such information.
For Canadian and Brazilian residents, your opt-out request from promotion communications will be processed within 10 days of the date on which we receive it. For Mexican residents, your opt-out request from promotional communications will be processed within 20 days of the date on which we receive it.
Promotional Communications. We offer you choices regarding the collection, use, and sharing of your Personal Information. When you receive promotional communications from us, you may indicate a preference to stop receiving further promotional communications from us and you will have the opportunity to opt-out by following the unsubscribe instructions provided in the promotional email you receive or by contacting us directly using the information provided at the end of this policy.
Intelsat does not charge for this opt-out service, and your opt-out request will be processed within 30 days of the date on which we receive it.
Targeted Advertising. Intelsat licenses technology to serve advertisements on its own Sites and within its content as that content is served across the Internet. In addition, Intelsat may use external party analytics vendors to evaluate and provide us with information about the use of the Services and viewing of our content. We do not share Personal Information with these external parties, but ad network providers, the advertisers, the sponsors, and/or analytics service providers may set and access their own Cookies, pixel tags and similar technologies on your Device and they may otherwise collect or have access to information about you, including usage information. We and our network advertisers may target advertisements for products and services in which you might be interested based on your use of the Services, visits to the Sites and other websites. We may use a variety of companies to serve advertisements.
If you prefer to not receive targeted advertising, you may opt-out of some network advertising programs that use your information. To do so please visit the Digital Advertising Alliance (DAA) Opt-Out Page. European users can also visit a similar service run by the European Interactive Digital Advertising Alliance (edaa). Please note that even if you choose to remove your information (opt-out), you will still see advertisements while you’re browsing online. Additionally, many network advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. The DAA Opt-Out Page provides a tool that identifies its member companies that have Cookies on your browser and provides links to those companies.
Regardless of your indicated email preferences, we may send you administrative emails regarding the Services, including, for example, purchase confirmation, account creation confirmation, and notices of updates to our Terms of Use Agreement or Privacy and Cookie Policy.
We may engage in programs with our airline or other partners and their advertising partners for certain promotional programs, such as free session passes. Any such program will be clearly marked and will require your consent to share any personal information before you may engage with the promotion.
Some mobile device operating systems also provide the ability to control the use of your mobile advertising IDs for ad personalization. Please visit the manufacturer’s website for information about whether your device provides this functionality and how to utilize it.
We will retain your Personal Data for as long as needed or permitted for the purpose(s) for which it was provided to us or obtained by us and as outlined in this Privacy Policy. The criteria used to determine the applicable retention period for your information includes the length of time we have an ongoing relationship with you and provide services to you, and whether there is a legal obligation to which we are subject that requires us to retain your information.
Our provision of links to other websites or locations is for your convenience and does not signify our endorsement of such other websites or location or its contents. We have no control over, do not review and cannot be responsible for these outside websites or their content. These other websites may send their own Cookies to your Device, may independently collect data or solicit Personal Information and may or may not have their own privacy policies. Please be aware that the terms of our Privacy Policy do not apply to these outside websites. You should independently assess the authenticity of any website which appears to be or claims that it is one of our Sites (including those linked to through an email or social networking page).
The connection through which you access the Services is an SSL-encrypted link. However, following such initial access, due to multiple users of our inflight Wi-Fi access point, Intelsat does not provide an encrypted communication channel, such as Wired Equivalent Privacy (WEP), or Wi-Fi Protected Access (WPA2), between our in-flight Wi-Fi access point and your Device. Intelsat’s inflight internet connectivity service generally supports secure Virtual Private Network (VPN) and Secure Shell (SSH) access. If you have VPN, Intelsat recommends that you use secure VPN protocols for greater security. Subject to the network management and limitations provisions discussed in our terms of use for the inflight internet connectivity service (accessible inflight at link and on the ground at link), SSL-encrypted websites or pages, typically indicated by “https” in the address field and a “lock” icon, can also generally be accessed through the inflight internet connectivity service. You should be aware, however, that data packets from un-encrypted Wi-Fi connections can be captured by technically advanced means when they are transmitted between a user’s Device and the Wi-Fi access point. You should therefore take precautions to lower your security risks. Intelsat recommends that you follow good security practices, such as ensuring that file-sharing is not enabled while accessing the Internet from an un-encrypted public network and that laptops have a personal firewall and other protections against malware. Intelsat recommends that sensitive or private information should not be accessed via or transmitted over an un-encrypted connection.
Intelsat takes reasonable steps to protect the information provided to us from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet transmission is ever fully secure or error free, so we cannot ensure or warrant that the security of any information you transmit us will be secure from theft, loss, or unauthorized access or use, and we make no representation as to the efficacy, or appropriateness of the technical, administrative and procedural measures we use to safeguard such data.
Our Services are not directed to, and we do not intentionally gather Personal Information about, users who are under the age of 16. If we become aware that we have unknowingly collected Personal Information from a child under the age of 16, we will make reasonable efforts to delete such information from our records. If you believe that we might have any information from or about a child under 16, please contact us.
From time to time, we may revise this Privacy Policy to reflect changes in the law or technology, or changes in our privacy practices. Any changes will be effective immediately upon the posting of the revised Privacy Policy on the Sites. If we make any material changes that affect your rights and your personal information, we will provide you with a prominent notification prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
If you have any questions or comments regarding our privacy practices, please contact us or call (844) 875-2020. You may also contact Intelsat at:
Attn: Privacy Program Office, Legal Department
7900 Tysons One Place
McLean, VA 22102-5972
USA
This document was developed in English. Any translations are strictly for convenience and the English-language version shall control in all circumstances where the translation introduces ambiguity, inconsistency, or different or specialized meanings.
