Privacy Policy

Last updated 12.12.2024

Cullen Aviation, LLC ("Company" or "We" or “Us”) respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect or that you may provide when you visit the website www.cullenaviation.com (the “Website”), or  purchase, download  install, register with, access, or use Cullen Aviation (the "App" and together with the Website the “Services”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies only to information we collect through the Services, and in email, text, and other electronic communications sent through or in connection with the Services.

This policy does not apply to information that we collect offline or on any other Company apps or websites, including websites you may access through the Services or you provide to or is collected by any third party.

PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, DO NOT ACCESS OR USE THE WEBSITE, OR DOWNLOAD, REGISTER WITH, OR USE THE APP. BY ACCESSING OR USING THE WEBSITE, OR DOWNLOADING, REGISTERING WITH, OR USING THE APP, YOU AGREE TO THIS PRIVACY POLICY. THIS POLICY MAY CHANGE FROM TIME TO TIME. YOUR CONTINUED USE OF THE SERVICES AFTER WE REVISE THIS POLICY MEANS YOU ACCEPT THOSE CHANGES, SO PLEASE CHECK THE POLICY PERIODICALLY FOR UPDATES.

1. Children Under the Age of 16

The Services are not intended for children under 16 years of age, and we do not knowingly collect personal information from children under 16. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please email us at charter@cullenaviation.com.

2. Information We Collect and How We Collect It

We collect information from and about users of our Services:

  • Directly from you when you provide it to us.
  • Automatically when you use the Services.

Information You Provide to Us

When you download, register with, or use the Services, we may ask you provide information:

  • By which you may be personally identified, such as name, postal address, email address, telephone number, or date of birth ("personal information").
  • That is about you but individually does not identify you.

This information includes:

  • Information that you provide by filling in forms through the Services. This includes information provided at the time of registering to use the Services, subscribing to our service, and requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with the Services.
  • Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Details of transactions you carry out through the Services and of the fulfillment of your orders. You may be required to provide financial information before placing an order through the Services.
  • Your search queries on the Services.

Information We Collect Through Automatic Data Collection Technologies

When you download, access, and use the Services, it may use technology to automatically collect:

  • Usage Details. When you access and use the Services, we may automatically collect certain details of your access to and use of the Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the Services.
  • Device Information. We may collect information about your mobile device and internet connection, including the device's unique device identifier, IP address, operating system, browser type, mobile network information, and the device's telephone number.
  • Stored Information and Files. The Services also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
  • Location Information. The Services collect real-time information about the location of your device.

If you do not want us to collect this information you may opt out at any time by contacting us at charter@cullenaviation.com. Note, however, that opting out of the Service’s collection of location information will disable its location-based features.

We also may use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services (behavioral tracking). Please email us at charter@cullenaviation.com for information on how you can opt out of behavioral tracking on or through the Services and how we respond to browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

Information Collection and Tracking Technologies

The usage information we collect helps us to improve our Services and to deliver a better and more personalized experience by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Services according to your individual interests.
  • Speed up your searches.
  • Recognize you when you use the Services.

The technologies we use for automatic information collection may include:

  • Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our Services.
  • Web Beacons. Pages of the Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related statistics (for example, recording the popularity of certain App content and verifying system and server integrity).

Third-Party Information Collection

When you use the Services or their content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

  • Third-Party Electronic ID Verification Service Vendors, including those that process biometric information
  • Vendors for tax reporting
  • Derivatives service providers
  • Marketing and promotions providers (to promote our Services)
  • Telecommunications technology providers (to send you messages, including SMS messages)
  • CTF/AML service providers (for the purposes of transaction monitoring)
  • Data hosting service providers and payment vendors (for off-site data hosting)
  • Security service providers (for investigating fraud and security incidents)
  • Analytics providers (to understand how you use our Services)
  • Payment processing companies (to process transactions on our behalf)
  • Document repository services providers
  • Customer support vendors
  • Chatbots
  • Basic Customer Information, Supplemental Identification Information, EIDV Information, Institutional Information, Usage Information,

These third parties may use tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

3. How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information, to:

  • Provide you with the Services and their contents, and any other information, products, or services that you request from us.
  • Fulfill any other purpose for which you provide it.
  • Give you notices about your account, including expiration and renewal notices.
  • Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • Notify you when App updates are available, and of changes to any products or services we offer or provide though it.
  • To allow you to participate in interactive features on the Services.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

Financial institutions. We use Plaid Inc. (“Plaid”) to gather your data from financial institutions. By using the Services, you grant Cullen Aviation, LLC and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid end user privacy policy.  We also use financial institutions to process your ACH funds transfers from your funding source bank account to us for use of the Services.

We use location information we collect to provide customer support and enable device-based settings.

4. Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

In addition, we may disclose personal information that we collect or you provide:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Cullen Aviation's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Cullen Aviation, LLC about users of the Services is among the assets transferred.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce our rights arising from any contracts entered into between you and us, including the EULA, terms of service, and for billing and collection.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Cullen Aviation, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

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5. Choices About Our Collection, Use, and Disclosure of Your Information

We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.

  • Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. You can choose whether or not to allow the Services to collect information through other tracking technologies by emailing us at Charter@cullenaviation.com. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Services may then be inaccessible or not function properly.
  • Location Information. You can choose whether or not to allow the Services to collect and use real-time information about your device's location through the device's privacy settings. If you block the use of location information, some parts of the Services may become inaccessible or not function properly.
  • Promotion by the Company. If you do not want us to use your email address to promote our own products or services, you can opt-out by emailing us at Charter@cullenaviation.com. You can also always opt-out by logging into the Services and adjusting your user preferences in your account profile.

We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

6. Accessing and Correcting Your Personal Information

We strive so you can review and change your personal information by logging into the Services and visiting your account profile page.

You may also send us an email at Charter@cullenaviation.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

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7. Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

7. Changes to Our Privacy Policy

We may update our privacy policy from time to time. If we make material changes to how we treat our users' personal information, we will notify you by email to the primary email address specified in your account. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting this privacy policy to check for any changes.

8. Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: Charter@cullenaviation.com.

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