Privacy Policy

Effective September 15, 2026 · Version 2026.09.15

This Privacy Policy ("Policy") explains how FlyWith, Inc. ("FlyWith," "we," "us" or "our") collects, stores, uses, and discloses personal data about you, the rights and choices you have with respect to your personal data, how we communicate with you and how you can make requests or submit inquiries to us about your personal data.

Contents:

  • About Us
  • What Does This Policy Cover
  • How Is This Policy Updated
  • Information We Collect
  • How We Use Your Personal Data
  • Disclosure of Personal Data
  • How We Protect Your Personal Data
  • Cookies, Mobile Identifiers, and Other Information Collection Tools
  • Social Media and Other Third-Party Providers and Services
  • Retention of Personal Data
  • Your Privacy Rights and Choices
  • Text Messaging
  • Children's Privacy
  • International Data Transfers
  • Contact Us

About Us

FlyWith, Inc. operates a membership-based technology platform, accessible through our mobile app and website, that helps Members discover, coordinate, and book private travel services provided by independent, licensed third-party operators. FlyWith is a technology platform; we do not own, operate, or control aircraft, and we do not provide air transportation. This Privacy Policy applies to your use of our app, website, and related services.

What Does This Policy Cover

This Policy applies to personal data we collect both online and offline, including personal data we collect through (i) the website at flywith.com or any successor (the "Site"); (ii) our web and mobile application (the "App"); (iii) other products and services we may offer that link to these Terms (collectively, the "Services"); and (iv) any other interactions you may have with us.

In this Policy, "personal data" means any information that identifies, relates to, describes, is reasonably capable of being associated with or reasonably can be used to identify an individual or household and other data that is linked to personal data or is otherwise defined as "personal data," "personal information," or "personally identifiable information" by applicable laws.

This Policy does not apply to any products, services, websites, or content that are offered by third parties or have their own privacy policy, including the Charter Operators who operate flights booked through the Services.

How Is This Policy Updated

We may modify this Policy from time to time. If we make changes, we will revise the "Last Updated" date at the top of the Policy on our Services and use reasonable efforts to provide you additional notification, such as by sending you an email notification. We encourage you to review this Policy each time you visit our Site or use our Services to stay informed of our privacy practices and the choices available to you.

Information We Collect

The personal data we collect about you depends on how you interact with us or use our Services. We describe below the categories of personal data we collect and the sources of this information.

Information You Provide to Us

We collect personal data from you when you apply for or accept Membership, complete identity verification, book or arrange a flight, add family members, delegates, guests, or companions, send us an email, fill out a form, respond to a survey, or otherwise communicate with us. Types of personal data we may collect include:

  • Contact and account information such as your first and last name, email address, telephone number, mailing address, and account username and password.
  • Membership and eligibility information such as information you provide in your membership application and onboarding.
  • Government Travel Identifiers (TSA Secure Flight) such as date of birth, gender, TSA Known Traveler Number (KTN), International / Advance Passenger Information System (APIS) travel data, and Department of Homeland Security (DHS) Redress Number, which we collect from you and each traveler in your booking as required for Federal Aviation Administration (FAA) / Transportation Security Administration (TSA) Secure Flight compliance, and which we transmit to the relevant Charter Operator and, where required, to the TSA and other governmental authorities. We treat this information as sensitive personal information.
  • Identity verification information such as a "liveness" selfie image you submit through our designated identity-verification provider to verify your identity.
  • Travel Preferences: Your travel preferences, accommodation needs, meal preferences and other similar information.
  • Payment information such as payment card or bank account information, which we and/or our third-party payment processors collect to process amounts payable in connection with your membership and bookings, as described in the applicable Charter Services Agreement.
  • Communications with us including correspondence, customer-support and member-services interactions (including in written and audio format), and survey responses.
  • Information About Other Users such as family members, delegates, guests, referrals, and companions, including their name, email address, phone number, travel preferences, accommodation needs, meal preferences, and any other information you provide to us. Additionally, if you choose to sync your address book with our Services, we collect contact information to help you identify and connect with other FlyWith members in your network.
  • Any additional information that you choose to provide.

Information Collected Automatically When You Interact With Us

We and our service providers may automatically log personal data about you, your computer or mobile device, and your interaction over time with the Services, such as:

  • Device information. We may collect information about your device(s) such as Internet Protocol ("IP") addresses, browser type and version, device type, hardware model, mobile network information, unique device identifiers, operating system, log information, error messages, and other technical information.
  • Transaction information. We may collect information when you conduct transactions through the Services, such as membership purchases and renewals and flight bookings.
  • Pseudonymous identifiers. We may collect pseudonymous identifiers such as unique cookie and device identifiers (as described further below), mobile device identifiers, and other identifiers derived from your device information.
  • Usage information. We may collect information about your use of the Services, such as the pages or screens you viewed, the features you used or interacted with, referring website addresses, and details about any links or communications with which you interacted.
  • Information collected by cookies and other tracking technologies. Please see the section "Cookies, Mobile Identifiers, and Other Information Collection Tools" below for more details.
  • Geolocation information. We may automatically collect approximate location data (such as city, region, or ZIP code) from your device or IP address. See "Opt-Out of Location Collection on Mobile" below.
  • Log and diagnostic information. We may collect technical logs and diagnostic data, such as error reports, crash data, performance data, and information about how the Services are functioning.
  • Security data. We may collect information such as authentication data, audit logs of account and delegate activity, and information used to detect and prevent fraud.

Information We Collect From Other Sources

We may also collect personal data about you from other sources and combine it with information we collect through the Services. For example, if you log in using a single sign-on ("SSO") provider such as Google or Microsoft, we receive your name and email address from that provider. We may also receive information from identity-verification and fraud-prevention providers, payment processors, and our service providers.

In addition, as part of our identity verification process, we may receive limited information collected by our third-party provider (currently Stripe) through their ID verification flow, including captured images of your ID document, selfies, extracted data from your ID document, keyed-in information, and verification result. We use this information to verify your identity and confirm that you are who you say you are.

Information We Infer or Derive

We may derive information or draw inferences about you based on the personal data we collect or have otherwise received about you.

How We Use Your Personal Data

Depending on how you interact with us and the Services you use, we use your personal data:

  • To provide and improve our Services. To provide, operate, maintain, develop, support, troubleshoot, and improve our Services and your account, including to process membership applications and bookings and to arrange air charter transportation on your behalf.
  • To verify identity and eligibility. To verify your identity and the identity of family members, delegates, and adult companions, confirm eligibility, and maintain the security and integrity of the membership network.
  • To comply with aviation and government requirements. To collect and transmit Government Travel Identifiers and related information to Charter Operators and governmental authorities as required by federal aviation-security regulations.
  • To respond to you. To provide member services and support and respond to your requests, inquiries, comments, and concerns.
  • For service communications. To send you booking confirmations, flight-status updates, itinerary changes, payment receipts, and other transactional or relationship messages, and to notify you about changes, updates, security alerts, and announcements related to our Services.
  • To personalize your experience. To customize our offerings and personalize your experience while using our Services.
  • For safety and security. To detect and protect against fraud, illegal activity, security incidents, and harm to the rights, property, or safety of FlyWith, our members, Charter Operators, or others.
  • For advertising and marketing. To provide you with marketing communications and information about our Services.
  • For corporate transactions. To process personal data in connection with a merger, reorganization, financing, sale of assets, acquisition, or other corporate transaction.
  • To comply with legal and financial obligations. To comply with our legal, regulatory, tax, and financial obligations (including responding to court orders, subpoenas, and other legal process), resolve disputes, enforce our agreements, and exercise our legal rights.
  • With your consent. To process your personal data in accordance with your consent or at your direction.
  • For other notified purposes. To carry out any other purpose conveyed to you at the time the information was collected.

Disclosure of Personal Data

We may disclose your personal data as follows or as otherwise described in this Policy:

  • Charter Operators and travel providers. We disclose your personal data, including Government Travel Identifiers, to the Charter Operators that operate your flights and, where applicable, to other providers necessary to fulfill your booking.
  • Governmental and aviation authorities. We disclose Government Travel Identifiers and related information to the Transportation Security Administration and other governmental authorities as required by federal aviation-security regulations and applicable law.
  • Affiliates and subsidiaries. We disclose your personal data to our affiliates and other organizations under common control for the purposes described in this Policy.
  • Vendors and service providers. We disclose your personal data to our vendors and service providers to perform functions for which we engage them, such as cloud hosting, identity verification, fraud prevention, payment processing, email and SMS delivery, customer and member support, and analytics.
  • Third parties you intentionally interact with. We disclose your personal data to third parties when you use our Services to intentionally interact with those third parties or direct us to do so, including when you connect a third-party integration.
  • Analytics providers. We disclose personal data to our analytics partners (see the Cookies, Mobile Identifiers, and Other Information Collection Tools section below).
  • Professional advisors. We disclose your personal data to our professional advisors, such as our lawyers, accountants, and insurers, in connection with the management of our business.
  • Corporate transactions. We disclose your personal data as part of, in connection with, or during negotiations of any merger, sale of assets, financing, acquisition, or other corporate transaction.
  • Aggregated, anonymized, or de-identified information. We disclose aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you, and we will not attempt to re-identify it.
  • Law enforcement and legal proceedings. We disclose your personal data when we believe doing so is reasonably necessary to comply with applicable law or legal process, to enforce our agreements, to protect our rights, property, or safety or those of others, to support auditing and compliance functions, and to prevent, detect, and remedy fraud or illegal activity.
  • With your consent or direction. We disclose personal data with your consent or at your direction.

How We Protect Your Personal Data

We implement commercially reasonable physical, technical, and procedural measures to help protect personal data from unauthorized access or use. However, the transmission of information via the internet is not completely secure. If you have questions about the security of personal data we collect, please contact us using the information provided below.

Cookies, Mobile Identifiers, and Other Information Collection Tools

What Are Tracking Technologies?

We and our service providers use cookies, mobile identifiers, software development kits ("SDKs"), and similar tracking technologies to collect information about you and your use of our Services. A cookie is a small file containing a string of characters that is sent to your device when you visit a website or use an online service, and allows that service to recognize your browser or device. Cookies may store unique identifiers, user preferences, and other information.

Types of Tracking Technologies We Use

  • Necessary Cookies. These cookies are strictly necessary to make our Services function properly and ensure basic functionality and security.
  • Functional Cookies. These cookies help perform certain functions, such as remembering preferences.
  • Performance/Analytics Cookies. These cookies help us understand how visitors use our Services, such as page views, time on site, and feature usage.
  • Duration. We may use session-based and persistent tracking technologies. Session-based technologies expire when you close your browser or App session. Persistent technologies remain on your device for a period determined by their configuration or until you delete them.

Your Controls and Opt-Out Choices for Tracking Technologies

  • Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings.
  • Google Analytics. To the extent we use Google Analytics, you can opt out by installing the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
  • PostHog. You can learn more about how PostHog processes your personal data by visiting https://posthog.com/privacy.

Note that opt-out mechanisms are device- and browser-specific. You will need to opt out separately on each device and browser you use, and these tools apply to participating companies only.

Do Not Track

Some Internet browsers can be configured to send "Do Not Track" signals. We currently do not respond to "Do Not Track" or similar signals.

Third-Party Technologies

We may permit third-party service providers, analytics partners, and advertising partners to collect information through tracking technologies on our Services. These third parties may use this information for their own purposes in accordance with their own privacy policies. We do not control these third parties' tracking practices.

Opt-Out of Location Collection on Mobile

We may collect approximate location information (such as city, region, or ZIP code) based on your device's IP address or, if permitted, your device's location services. You can opt out of location collection at any time through your device settings. Because operating-system interfaces change periodically, consult your device manufacturer's support resources for current instructions.

Push Notifications

If you are a registered user of the App, we may send push notifications to your device delivering information, alerts, updates, and other notices relating to the Services. You may manage or opt out of push notifications at any time through the App's settings or your device's operating-system settings. Opting out of push notifications does not affect your consent to receive other electronic communications from FlyWith, including by email.

Consent for Optional Tracking Technologies

Where required by applicable law, we obtain your consent prior to placing or using optional cookies that are not (i) strictly necessary to provide the Site or Services or (ii) for the purpose of facilitating a communication.

Social Media and Other Third-Party Providers and Services

Third-Party Partners

From time to time, we may offer third-party products or services on our Services or links to other websites, and we may work with third-party providers who independently collect and process your personal data, such as identity-verification, payment-processing, and analytics providers. The privacy practices of these third parties are governed by their own privacy notices. We are not responsible for the security or privacy of any information collected by these third parties, and we encourage you to review their privacy notices.

Social Media

Some aspects of the Services may allow you to interface with social-media services. By using these interfaces, you may allow us to access information about you from those services. For a description of how such services handle your information, please refer to their respective privacy policies and terms of use.

AI Services

Our Services use artificial intelligence (AI), including large language models, provided by third-party vendors. We use these AI services both to assist you directly (for example, general inquiries and navigation through our chat features) and to support back-end processing of information you submit to us (for example, helping structure and complete booking requests). When you interact with our chat features, you may be communicating with an automated AI system rather than a human representative.

When you use our Services, you acknowledge that (i) information you submit, including personal data, may be processed by third-party AI providers; (ii) we will process any personal data you share according to this Policy; and (iii) the third-party AI provider will process your personal data in accordance with its own privacy policy, and we are not liable for its handling of your personal data.

Retention of Personal Data

We will retain your personal data for as long as is necessary to fulfill the purposes for which it was collected and for the business purposes explained in this Policy. Even after we stop providing Services to you, and even if you close your account, we may retain your personal data to the extent permitted by applicable law:

  • to comply with our legal and regulatory obligations;
  • to protect against fraudulent or abusive activity on our Services; and
  • to exercise, establish, or defend legal claims.

To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data; the potential risk of harm from unauthorized use or disclosure; whether the information is needed to provide Services; whether there is a contractual or legal need to retain the data; and applicable legal requirements.

Your Privacy Rights and Choices

Consistent with applicable law, you may exercise the rights described in this section. To exercise your rights, please contact us as set forth below.

While it is our policy to respect the rights of individuals, your exercise of these rights is subject to certain exemptions and exceptions, and some rights may be limited where we are required or permitted by law to continue processing your personal data to deliver Services, defend our rights, or meet our legal and regulatory obligations.

If you contact us to exercise any of these rights, we may need to verify your identity before implementing your request, and we will try to comply as soon as reasonably practicable and within the timelines required under applicable law.

Opt Out of Direct Marketing

You may opt out of receiving direct marketing communications from us by following the unsubscribe instructions in those communications or by contacting us as set forth below. Please note there are certain communications we are required to send you that relate to the Services (e.g., transactional booking and flight messages, support, and important legal notices) that you may not be able to opt out of.

Text Messaging

If you opt in to receive SMS notifications from FlyWith, Inc., we collect your mobile phone number and your SMS consent status in order to send you transactional text messages related to your flight bookings, such as booking confirmations, flight-status updates, itinerary changes, and payment receipts.

Your consent to receive SMS messages is not required as a condition of purchasing any goods or services from FlyWith, Inc. Message and data rates may apply, and message frequency will vary. You may revoke your consent to receive SMS messages at any time by replying STOP to any message from FlyWith, Inc. For help, reply HELP or contact us at support@flywith.com.

We do not sell or share your mobile phone number or SMS consent data with third parties for marketing or promotional purposes. We share this information only with the service providers that help us deliver our messaging services, under agreements that require confidentiality.

Children's Privacy

Our Services are intended for adults and are not directed to children. Membership and account creation requires individuals to be at least twenty-one (21) years of age. We do not knowingly collect personal data from children under the age defined under applicable law. If you believe a child has provided us with personal data, please contact us using the information below so we can take appropriate action.

International Data Transfers

We process and store your personal data in the United States. Our Services are directed to users in the United States. By using our Services, you acknowledge that any personal information about you, regardless of whether provided by you or obtained from a third party, is being provided to FlyWith in the U.S. and will be hosted on U.S. servers, and you authorize FlyWith to transfer, store, and process your information to and in the United States.

Contact Us

You may contact us using the information below.

FlyWith, Inc.
Attn: Privacy
4630 S. Kirkman Rd. STE 354-17604
Orlando, FL 32811

E-mail: privacy@flywith.com