Privacy Policy

1. Introduction

FlyWith, Inc. ("FlyWith," "we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at flywith.com (the "Site") and use our software-as-a-service platform and mobile application (collectively, the "Services").

This policy applies to all users of our Services, including registered account holders, free trial users, and visitors to our Site. It does not apply to third-party websites, products, or services, even if linked to from our Services. Any terms we use in this Policy without defining them have the definitions given to them in our Terms of Service.

As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. Upon such changes, we will alert you by placing a notice on the FlyWith website, by sending you an email, and/or by other means. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

If you have any questions about this Privacy Policy, please contact us at privacy@flywith.com.

2. Information We Collect

We collect information in the following ways:

2.1 Information You Provide Directly

• Account Information: When you register, we collect your name, email address, password, and other such information as company name, job title, and billing information.
• Profile Information: Optional information you add to your profile such as a photo, phone number, or time zone.
• Payment Information: Credit card numbers, billing address, and other payment data. Payment card data is processed by our PCI-compliant third-party payment processor and is not stored on our servers.
• Communications: Any messages, support requests, feedback, or survey responses you send to us.
• Mobile Phone Number and SMS Consent: If you opt in to receive SMS notifications from FlyWith, we collect your mobile phone number and your consent status for the purpose of sending you transactional text messages related to your flight bookings.
• User-Generated Content: Data, files, and content you upload, input, or create while using our platform.
• Government Travel Identifiers (TSA Secure Flight): For flight bookings, we collect date of birth, gender, TSA Known Traveler Number (KTN), and DHS Redress Number from passengers as required for FAA/TSA Secure Flight compliance. This information is transmitted to the relevant Charter Operator and, where required, to the Transportation Security Administration. This data is treated as sensitive personal information and is subject to application-level encryption.

2.2 Information Collected Automatically

When you use our Services, we automatically collect certain technical and usage information, including:

• Log Data: IP address, browser type and version, operating system, referring URL, pages viewed, links clicked, and timestamps.
• Device Information: Device type, unique device identifiers, hardware model, and mobile network information.
• Usage Data: Features you use, actions you take, session duration, error reports, and performance data.
• Location Information: General geographic location derived from your IP address (country and city level). We do not collect precise GPS location unless you explicitly grant permission.
• Cookies and Tracking Technologies: See Section 6 for details.

2.3 Information from Third Parties

• Single Sign-On (SSO): If you log in via Google, Microsoft, or another SSO provider, we receive your name and email address from that provider.
• Integration Partners: If you connect third-party tools (e.g., CRM, calendar, or communication platforms), we may receive data you authorize from those services.
• Analytics Providers: We may use analytics providers to analyze how you interact and engage with the Services.
• Publicly Available Sources: We may collect publicly available professional information (e.g., LinkedIn) for sales outreach or account enrichment purposes.

3. How We Use Your Information

We use the information we collect to:

• Provide, operate, and maintain our Services, including processing transactions and managing your account.
• Personalize and improve your experience, including remembering your preferences and settings.
• Communicate with you, including sending transactional emails (receipts, security alerts, account notifications) and, with your consent, marketing messages.
• Respond to your support requests and troubleshoot issues.
• Monitor and analyze usage patterns, trends, and activities to improve our platform.
• Conduct fraud protection, security monitoring, and debugging.
• Comply with applicable legal obligations, including responding to lawful requests from public authorities.
• Market and sell the services offered on the Services.
• Carry out any other purpose described to you at the time the information was collected.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

4. How We Share Your Information

We do not sell your personal information for monetary consideration. We may share your information in the following circumstances:

4.1 Service Providers

We share data with vendors and service providers who perform services on our behalf, such as cloud hosting, payment processing, email delivery, customer support, analytics, and advertising. These providers are contractually required to use your data only as directed by us, are bound by confidentiality agreements, and are prohibited from using your data for other purposes.

4.3 Analytics Partners

We share data with analytics providers that track how users found, were referred to, or interact with our Services. These providers help us analyze platform usage and improve the Services.

4.4 Business Transfers

If FlyWith is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

4.5 Legal Requirements and Safety

We may disclose your information if we believe disclosure is reasonably necessary to:

• Comply with applicable law, regulation, or legal process (such as a court order or subpoena).
• Respond to requests from governmental or regulatory authorities.
• Enforce our Terms of Service or other agreements.
• Protect the rights, property, or safety of FlyWith, our customers, or the public.

4.6 With Your Consent

We may share information for other purposes with your explicit consent. You may withdraw consent at any time, though this will not affect the lawfulness of processing prior to withdrawal.

4.7 Aggregated or De-identified Data

We may create aggregated, de-identified, or anonymized data from the personal information we collect. We may use such data and share it with third parties for our lawful business purposes, including to analyze, build, and improve the Services and promote our business. We will not re-identify such data.

5. SMS/Text Messaging Privacy

If you opt in to FlyWith SMS Notifications, we collect and store your mobile phone number and SMS consent status. This information is used solely to send you transactional text messages related to your flight bookings, including 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.

We do not sell or share mobile or personal data with third parties, affiliates, or partners for marketing or promotional purposes. We only share data with third parties when it is strictly necessary to deliver our service and only under binding agreements that ensure confidentiality. Under no circumstances will mobile data be shared or sold for advertising or promotional use.

You may revoke your consent to receive SMS messages at any time by texting STOP to any FlyWith message. For help, text HELP or contact us at support@flywith.com. For full SMS program details including message frequency and supported carriers, see the SMS/Text Messaging Terms section of our Terms of Service.

6. Cookies and Tracking Technologies

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, "Cookies") to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base, and operate and improve our Services. Cookies are small pieces of data — usually text files — placed on your computer, tablet, phone, or similar device when you use that device to access our Services.

We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).

6.1 Types of Cookies We Use

6.2 Do Not Track

Please note that because of our use of Cookies, the Services do not support "Do Not Track" requests sent from a browser at this time.

6.3 Information About Interest-Based Advertisements

We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors, and research firms, to serve advertisements through the Services. These advertisements may be targeted based on your general profile, preferences, or behaviors ("Interest-Based Ads"). Information for Interest-Based Ads may be provided directly by you, or derived from your usage patterns on the Services and/or services of third parties.

To accomplish this, we or our service providers may deliver Cookies, including a file (known as a "web beacon") from an ad network. Web beacons allow ad networks to provide anonymized, aggregated auditing, research, and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites.

6.4 How to Control Cookies and Opt Out

You can decide whether or not to accept Cookies through your internet browser's settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies. You can also delete all Cookies that are already on your device. If you do this, however, some features and functionalities of the Services may not work.

You may also opt out of interest-based advertising using the following resources:

For individuals in the United States:

• Digital Advertising Alliance (DAA): www.aboutads.info/choices
• DAA's AppChoices program: www.aboutads.info/appchoices
• Network Advertising Initiative (NAI): www.optout.networkadvertising.org
• Google Analytics Opt-out: tools.google.com/dlpage/gaoptout

8. Data Security

We seek to protect your personal information from unauthorized access, use, and disclosure using appropriate physical, technical, organizational, and administrative security measures. Our security practices include:

• Encryption of data in transit using TLS 1.2 or higher.
• Encryption of data at rest using AES-256. Personal data is encrypted and stored in a private, isolated environment, accessible only by authorized roles and services with audited access to encryption keys.
• Role-based access controls and least-privilege access policies for our staff.
• Regular penetration testing and security audits.
• Passwordless authentication via secure sign-in methods.
• A formal incident response plan for data breaches.

Although we work to protect the security of your data, please be aware that no method of transmitting data over the internet or storing data is completely secure. We cannot guarantee absolute security, and any transmission of information is at your own risk. If you believe your account has been compromised, please contact us immediately at security@flywith.com.

9. Data Retention

We retain your personal information for as long as necessary to provide our Services or to perform our business or commercial purposes for collecting your personal information. When establishing a retention period, we consider who we collected the data from, our need for the data, why we collected it, and the sensitivity of the data.

For example:

• We retain your profile information and credentials for as long as you have an account with us.
• We retain your payment data for as long as we need to process your purchase or subscription, and as required by law (typically 7 years).
• We retain usage logs and analytics data for up to 24 months.
• We retain support communications for up to 3 years.
• We retain your device/IP data for as long as we need it to ensure our systems are working appropriately and efficiently.

In some cases we retain personal information for longer if doing so is necessary to comply with our legal obligations, resolve disputes, or collect fees owed. We may further retain information in an anonymous or aggregated form where that information would not identify you personally. When data is no longer needed, we will securely delete or anonymize it.

10. Consequences of Not Providing Your Data

You are not obligated to provide your personal information to us. However, there may be times where your information is required for us to provide you with our Services, deliver requested products, or provide you with the content, feedback, or other materials that you request from us. In certain situations, we will not be able to offer some or all of our products or Services to you without requesting or collecting your personal information.

11. Your Privacy Rights

11.1 General Rights for All Users

Regardless of your location, you may have the following rights with respect to your personal information. To exercise any of these rights, please contact us at privacy@flywith.com.

• Access: You may request disclosure of whether we collect personal information about you, and a copy of such data.
• Correction: You may request that we correct inaccurate or incomplete information.
• Deletion: You may request that we delete your personal information, subject to certain legal exceptions. Note: Self-service deletion is currently being implemented. In the interim, please submit deletion requests to privacy@flywith.com and we will fulfill them manually within the timeframes required by applicable law.
• Portability: You may request your data in a structured, commonly used, machine-readable format, transferable to another entity. Note: Automated data export is currently being implemented. In the interim, please submit portability requests to privacy@flywith.com and we will fulfill them manually within the timeframes required by applicable law.
• Withdrawal of Consent: If we are processing your data based on your consent, you may withdraw that consent at any time.
• Opt-Out of Marketing: You may unsubscribe from marketing communications at any time by clicking "Unsubscribe" in any marketing email or contacting us directly.

We will respond to your request within 45 days. In some cases, we may request additional information to verify your identity. We will not discriminate against you for exercising any of these rights.

11.2 California Residents — CCPA / CPRA Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

• Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected about you in the last 12 months, the categories of sources, the business or commercial purposes for collecting it, and the categories of third parties with whom we share it.
• Right to Delete: You may request deletion of personal information we have collected, subject to exceptions.
• Right to Correct: You may request that we correct inaccurate personal information we maintain about you.
• Right to Opt-Out of Sale or Sharing: We do not sell personal information for money. We may share certain identifiers with advertising partners for cross-context behavioral advertising, which may constitute "sharing" under CPRA. You may opt out by clicking "Do Not Sell or Share My Personal Information" on our Site.
• Right to Limit Use of Sensitive Personal Information: You may request that we limit our use of sensitive personal information to that which is necessary to perform the services.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of these rights.

California law (the "Shine the Light" law, Civil Code § 1798.83) also permits California residents to request, once per calendar year, information about the categories of personal information (if any) we disclosed to third parties for their direct marketing purposes in the preceding calendar year, and the names and addresses of those third parties. Please note that FlyWith does not sell personal information to third parties or disclose personal information to third parties for the third parties' direct marketing. To submit a Shine the Light inquiry, please contact us at privacy@flywith.com with the subject line "CCPA/Shine the Light Inquiry".

California residents may submit privacy requests by emailing privacy@flywith.com. We will respond within 45 days of receiving a verifiable request. You may designate an authorized agent to submit requests on your behalf.

11.3 Colorado Residents — CPA Rights

To the extent the Colorado Privacy Act ("CPA") applies to you as a Colorado resident, you may be entitled to the following rights. To exercise these rights, please submit a request to privacy@flywith.com.

• Right to Access & Data Portability: You may request that we disclose whether we are processing your personal information and provide access to it in a portable, readily usable format.
• Right to Correct Inaccurate Information: You may request that we correct inaccurate personal information using commercially reasonable efforts.
• Right to Delete: You may request deletion of certain personal information, subject to exceptions.
• Right to Opt Out of Sale, Targeted Advertising, or Profiling: You may opt out of the processing of your personal information for purposes of targeted advertising, sale, or profiling in furtherance of decisions that produce legal or similarly significant effects.
• Right to Appeal: If we deny your request, you may appeal by contacting us at privacy@flywith.com with the subject "Privacy Request Appeal." We will respond within 45 days. If you disagree with our appeal decision, you may contact the Colorado Office of the Attorney General.

11.4 Nevada Residents

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at privacy@flywith.com with the subject line "Nevada Do Not Sell Request" and providing us with your name and the email address associated with your account.

12. Do Not Sell or Share My Personal Information

As noted in Section 11.2, we may share certain data (such as device identifiers and browsing data) with advertising technology providers in a manner that may be deemed "sharing" under California law. You have the right to opt out of this sharing.

To opt out, please:

• Click the "Do Not Sell or Share My Personal Information" link in the footer of our Site.
• Submit a request via email to privacy@flywith.com with the subject line "Do Not Sell or Share."
• Adjust your cookie preferences via our Cookie Preference Center.

Once you opt out, we will honor your preference for at least 12 months unless you instruct us otherwise.

13. Children's Privacy

Our Services are not directed to, and we do not knowingly collect personal information from, children under the age of 13. Our platform is intended for business professionals and requires users to be at least 18 years of age. By signing up for an account or otherwise using our Services, you acknowledge you are over the age of 13 and are permitted to use our services in accordance with this Privacy Policy and our Terms of Service.

If we learn that we have inadvertently collected personal information from a child under 13 years of age, we will delete that information as quickly as feasible and without undue delay. If you believe that a child under 13 may have provided personal information to us, please contact us immediately at privacy@flywith.com.

14. Third-Party Links and Integrations

Our Services may contain links to third-party websites, and we offer integrations with third-party platforms. This Privacy Policy does not apply to those third-party services. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party sites or services. We are not responsible for the content or privacy practices on any websites or applications not operated by us, even though our Site might link to them.

We partner with third-party sponsors, affiliates, vendors, and other companies who might have links, content, or applications on the Services. These third parties might also use tracking tools to collect information about you. We do not control these third parties' tracking technologies or how they may be used. If you have questions about a specific integration, please contact that third party directly.

When you enable a third-party integration, you authorize that third party to share data with FlyWith as governed by your agreement with them. You can disconnect integrations at any time in your account settings.

15. International Data Transfers

FlyWith is based in the United States. Our Services are hosted and operated in the United States through FlyWith and its service providers. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your country.

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.

16. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, legal obligations, or regulatory requirements. We will notify you of material changes by:

• Sending an email to the address associated with your account.
• Posting a prominent notice on our Site or within the application with a revised "Effective Date."

We encourage you to review this policy regularly. Your continued use of our Services after the effective date of any changes constitutes your acceptance of the revised policy. If you do not agree to the changes, you must discontinue use of the Services.

Please note that if you've opted not to receive legal notice emails from us (or haven't provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them.

17. Governing Law and Jurisdiction

This Privacy Policy and any disputes arising out of or related to it or your use of our Services shall be governed by and construed in accordance with the laws of the State of Delaware, without regard to its conflict of law principles.

FlyWith, Inc. is incorporated under the laws of the State of Delaware. To the extent that any legal action or proceeding relating to this Privacy Policy must be brought in a court of law, you agree that such action shall be brought exclusively in the state or federal courts located in the State of Delaware, and you hereby submit to the personal jurisdiction and venue of those courts.

Please note that the state-specific rights described in Section 11 (California, Colorado, and Nevada) are based on the laws of those states and apply to residents of those states regardless of this choice-of-law provision. Those rights are not affected by this Governing Law clause.

18. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Company: FlyWith, Inc.

Customer Support: privacy@flywith.com

We will make every effort to respond to your requests within 45 days. For complex or numerous requests, we may extend this period by an additional 45 days with notice. If we are unable to verify your identity or for other permitted reasons, we may decline to respond to your request and will inform you that we have declined it, at which time you may submit an appeal.

© 2026 FlyWith, Inc. All rights reserved. This document is for informational purposes and does not constitute legal advice. Consult qualified legal counsel for your specific circumstances.