Privacy Policy

PLEASE READ THIS PRIVACY POLICY CAREFULLY.

Your privacy is important to us and we encourage you to familiarize yourself with our privacy practices set forth herein.

By accessing or otherwise using the website (the “Website”), you agree to be bound contractually by this Privacy Policy.  OTG Experience, LLC, a Delaware limited liability company (together with its affiliates, “OTG” and also referred to herein as “we”, “us”, “our” and similar terms), operates the Website. This Privacy Policy applies to information collected, used and maintained by OTG in conjunction with the Website.  The following information explains our information gathering, use, security safeguards and dissemination practices.

The Website is not directed to children under the age of 13.  If you are under the age of 13, please do not provide any personal information while using the Website.

Effective Date:  As of June 15, 2016

1.              PRIVACY POLICY; RIGHT TO MODIFY.

(a)            We Reserve the Right to Modify this Privacy Policy. We reserve the right to modify this Privacy Policy at any time by posting amended terms on the Website or otherwise notifying you of changes to this Privacy Policy. Your continued use after such amendment indicates your acceptance of the amended Privacy Policy. You should check this Privacy Policy periodically for modifications by referencing the Effective Date posted above. Unless stated otherwise, our current Privacy Policy applies to all Personally Identifiable Information that we receive about you from your use of the Website. Any changes that are made to this Privacy Policy will apply to both any Personally Identifiable Information that we hold prior to the Effective Date and any Personally Identifiable Information that we collect on or after such Effective Date.  However, we will not materially change our policies and practices to make them less protective of Personally Identifiable Information collected in the past without the consent of affected users.

(b)           Additional Consents. This Privacy Policy provides our general policies regarding the collection and use of Personally Identifiable Information as a result of your use of the Website.  If you wish to take part in certain products and services offered by us or our affiliates on the Website or at airports located throughout North America, at that time we may request specific permission to collect, use, and disclose Personally Identifiable Information about you in ways that are described in this Privacy Policy or such other privacy policy that may be applicable to such activities.  Typically, your permission is given by clicking a button or an icon to indicate your consent; you may opt out at any time.  If there is any inconsistency between the terms of this Privacy Policy and the consent that you give with respect to the collection, use, and disclosure of Personally Identifiable Information for a particular product or service, the terms of such consent will control.

2.              COLLECTION AND USE OF YOUR INFORMATION.

(a)            Types and Sources of Personally Identifiable Information in General.  Personally identifiable information is any information that can be used to identify or contact you (“Personally Identifiable Information”).  We may build and store user profile preferences based on your use of the Website, including any transactions completed via Website or if you elect to provide additional information about yourself.

(b)           What Personally Identifiable Information We Collect Directly from You.  We reserve the right to require you to register with OTG in order to receive certain benefits, offers or services and to provide certain registration data including your name, country, zip code or postal code (as appropriate) and email address or phone number (“Registration Data”).

(i)             By providing Registration Data, you agree to the collection and use of such data, including any Personally Identifiable Information contained therein, pursuant to the terms of this Privacy Policy.  Please keep in mind that we will not collect any Personally Identifiable Information from you unless you voluntarily submit such information to us.  Therefore, if you do not want us to obtain any Personally Identifiable Information about you, please do not voluntarily submit such information to us.  You do not have to provide us with any Personally Identifiable Information to use or access the Website.  However, if you choose to withhold requested information, you may not be able to make purchases on, use, visit or view certain sections of the Website or receive certain products, offers or services.

(ii)           If you submit Personally Identifiable Information, become a registered user and/or place orders for products and services through the Website, we may collect information about your use of the Website and such activities. You may also choose to communicate with us through email, text message, via the Website, via telephone, in writing, or through any other means.  We may collect all information in or about these communications.  To the extent that any such information gathered from or about these communications is Personally Identifiable Information, we will combine such information with information we receive from the Website and use all such information in accordance with this Privacy Policy.

(c)            Social Media.  We may offer you the opportunity to engage with us through third-party social networking websites, plug-ins and applications. Through these platforms, you may allow us to access information associated with your social media account. We may use this information to confirm your identity and to personalize your experience on the Website.

(d)           How We May Use Personally Identifiable Information We Collect. In general, we use the Personally Identifiable Information collected through the Website to help us, our business partners, and certain other third party businesses, concessionaires, vendors or suppliers (collectively, “Outside Contactors”), understand who uses the Website and how it is used, to personalize the user’s experience, to assist the user in using the Website and to improve the Website.  More specifically, we may use the Personally Identifiable Information collected through the Website for the following  purposes and for other similar purposes:

(i)             to establish and verify the identity of users;

(ii)           to respond to inquiries and fulfill your requests, including communicating with customers or Outside Contractors (e.g., via email or text message);

(iii)          to promote products and services on our behalf and on behalf of Outside Contractors and business partners, including by sending promotional text messages (if you have consented to receive text messages) and emails on our behalf or on behalf of our business partners and Outside Contractors, which promotions may be targeted based on your use of the Website;

(iv)          to open, maintain, administer and service users’ accounts or memberships; and

(v)           for our business purposes, such as data analysis, audits, developing new products, improving the Website, identifying usage trends, determining the effectiveness of promotional campaigns, and maintaining the security and integrity of our systems.

3.              WAYS THAT WE MAY SHARE PERSONALLY IDENTIFIABLE INFORMATION WITH THIRD PARTIES.

(a)            General Overview.  By providing Personally Identifiable Information, you agree to the collection, use and sharing of such data pursuant to the terms of this Privacy Policy.  Your Personally Identifiable Information may be shared with OTG’s third party business partners and Outside Contractors, as described in greater detail below.

(b)           Disclosure to Our Affiliates.  We may disclose your Personally Identifiable Information to our Affiliates.  For the purpose of this Privacy Policy, “Affiliates” means any person or entity which directly or indirectly controls, is controlled by or is under common control with us, whether by ownership or otherwise.  Any information relating to you that we provide to our Affiliates will be treated by those Affiliates in accordance with this Privacy Policy.

(c)            Disclosure to Our Outside Contractors.  We may contract with or employ Outside Contractors to provide specific services related to the Website and to offer or provide retail products and services on the Website. These Outside Contractors may sometimes have limited access to information collected on the Website, including your Personally Identifiable Information, in the course of providing products or services to you and/or us.  Access to your Personally Identifiable Information by these Outside Contractors is limited to the information reasonably necessary in order for the Outside Contractors to perform their limited function.  We also require that these Outside Contractors (i) protect the privacy of your Personally Identifiable Information in a manner consistent with this Privacy Policy, and (ii) not use or disclose your Personally Identifiable Information for any purpose other than providing you and/or us with the products or services for which they are contracted.

(d)           Sharing of Aggregate Non-Identifiable Information.  Some of your information may be shared on an aggregate basis in non-identifiable form and as a part of a larger set of statistics (e.g., statistics that indicate the percentage of our members that are female), but that information will not be sufficient to permit the recipient to identify you.  For instance, we may provide aggregated information to third parties regarding the number of unique users who use the Website, the demographic breakdown of the users of the Website, or the activities that users of the Website engage in while using the Website.  The third parties to which we may provide this information may include potential or actual advertisers, providers of advertising services (including website tracking services), airlines, Outside Contractors, sponsors, licensees, researchers and other similar parties.

(e)            Disclosure in Limited Circumstances.  Notwithstanding the foregoing, we may also use and disclose Personally Identifiable Information outside the normal use of the Website in the following limited circumstances: (i) if we are required to do so, (ii) if we have the good faith belief that such action is necessary (i.e., to comply with legal process served on us (e.g., to comply with a search warrant, subpoena or court order)), (iii) to respond to requests from public or government authorities, (iv) to protect the Website, such as in the event of an attempted breach of security, (v) to enforce our terms and conditions, or (vi) to protect you or the rights or property of another user of the Website.

(f)            Acquisition, Sale or Reorganization of Business.  As we continue to develop the Website and our businesses, we might acquire other business entities or assets or sell, license or transfer business entities or assets to third parties.  In such transactions, customer information generally is one of the assets acquired or transferred.  Also, in the event that all or substantially all of our assets are transferred, a merger, consolidation or reorganization, or a controlling interest in us is acquired, both Personally Identifiable Information and information that is not personally identifiable will be among the transferred assets.

(g)            Additional Privacy Policy Terms.  You acknowledge and agree that we operate restaurants, other food and beverage establishments, retail establishments and may have other commercial activities within airports and elsewhere throughout North America, and your use of or participation in such operations is subject to the terms and conditions related thereto including any privacy policy applicable thereto.  You acknowledge and agree that such privacy policies may be different than this Privacy Policy and such terms shall apply to such operations and/or activities to the extent that you elect to use or accept the same.

 

4.              AUTOMATIC COLLECTION OF NON-PERSONALLY IDENTIFIABLE INFORMATION ON THE WEBSITE. When you use or access the Website, or become a registered user of the Website, we may also collect information such as demographic information (e.g., age, profession or gender) that is collected and used on an aggregated, de-identified basis (“Non-Personally Identifiable Information”).  Non-Personally Identifiable Information may also include certain anonymous information about the date and time you used the Website, the pages you accessed while using the Website, and the Internet addresses of the websites (e.g. URL, IP address), if any, you visited that were linked to the Website.

(a)            We use Non-Personally Identifiable Information to help us understand the characteristics of people who use the Website, and to improve and market the Website in general.

(b)           We also use the Non-Personally Identifiable Information collected automatically by our servers primarily to help us administer and improve the Website.  In the event that we link any Non-Personally Identifiable Information with Personally Identifiable Information, we will treat such information as Personally Identifiable Information and only use such information in accordance with this Privacy Policy.

5.              OPT-IN OR OPT-OUT OPTIONS.  If you provide contact information in your Registration Data while using the Website, we may use that information to communicate with you (e.g., send you welcome email) in order to provide or offer services or confirm account data, user options and preferences.  We may send you electronic newsletters, information about services, news items that may be of interest to you, and provide you with targeted offers.  If you decide you no longer want to receive these communications from us, we will provide you with an option to “opt-out” and change your preferences.

6.              CONTACT US/REVIEW YOUR INFORMATION.  If you have submitted Personally Identifiable Information through the Website, or if someone else has submitted your Personally Identifiable Information, and you would like to review, request changes or have that information deleted from our databases, please contact us via e-mail or send a letter to our Privacy Compliance Coordinator at the address indicated below. We will then use reasonable efforts to change or remove your Personally Identifiable Information from our files, unless we are entitled or required to retain it.  You may also contact us through either of the above methods to request or review the Personally Identifiable Information that we have collected about you. We will use reasonable efforts to supply you with this information and correct any factual inaccuracies in this information. Our contact information is as follows:

OTG EXPERIENCE, LLC
c/o OTG MANAGEMENT
335 West Butler Avenue, Suite 120
Chalfont, PA 18914
Contact: Privacy Coordinator – [email protected]

7.              COOKIES AND OTHER TECHNOLOGIES OF WHICH YOU SHOULD BE AWARE WHILE USING THE WEBSITE.

(a)            Cookies. Cookies are pieces of information that a web site transfers to a device or a computer’s hard disk for record-keeping purposes. Cookies in and of themselves do not personally identify users, although they do identify a device or a user’s computer. Most internet browsers are initially set up to accept cookies.  We reserve the right to set up our devices and the Website to use or to allow the use of cookies.  Advertisers and other Outside Contractors that display ads on the Website may also use cookies, however, we do not have access to the information obtained from cookies issued from other sites.

(b)           IP Addresses.  IP addresses are used by a device or computer every time it is connected to the Internet.  The IP address is a number that is used by a device or computer on the network to identify that specific device or computer.  The IP addresses of each device we supply as part of the Website are automatically collected, primarily by third party internet site operators, as part of demographic and profile data known as “traffic data” so that data (such as the web pages you visit while using the Website) can be viewed by you.  We may use your IP address to attempt to identify you.

(c)            Referrers.  A Referrer is information passed along by our web browser that references the Web URL from which you linked when visit websites using the Website, and it is automatically collected by third party web servers as “traffic data.” Third party internet site operators, including our Outside Contractors, may use this information to identify broad demographic trends and/or to provide information tailored to your interests or in connection with agreements that we may have with such Outside Contractors.  You may be personally identified from this information.

(d)           System Information.  System information that we collect as part of “traffic data” includes time, the type of web browser being used, the operating system/platform, and CPU speed. This information is sent automatically by your web browser when you are connected to a website. We reserve the right to use this information for purposes of identifying broad demographic trends and may be used to provide information appropriate for your computer system. You will not be personally identified from this information.

8. OTHER WEBSITES, LINKS, ADVERTISERS AND INTERNET PROVIDERS. The Website contains links to other web sites. We reserve the right to permit Outside Contractors, including advertisers, and other third parties participating in the Website to provide links to their web sites, to link their web sites to the Website or to offer Internet access. The privacy practices of Outside Contractors, advertisers and such other third parties are not covered by this Privacy Policy, and we are not responsible for the privacy practices or the content of the web sites of such Outside Contractors, advertisers and other third parties.  For example, you may choose to use the Website to browse the Internet and such access may be provided by a third-party Internet provider.  If such Internet access is provided by a third-party Internet provider, we are not responsible for the collection, use, or disclosure of any information about you by such third-party Internet provider.  Additionally, if you make a purchase from a store or merchant listed on or linked to the Website, any information that you give, such as your payment card number and contact information, is provided to those merchants. These merchants and Outside Contractors have separate privacy and data collection practices, and we have no responsibility for these independent policies. You should be careful to review any privacy policies posted on any of these sites before signing up with and using them.

9.              INTERNET AND INFORMATION SECURITY ISSUES OF WHICH YOU SHOULD BE AWARE WHILE USING THE WEBSITE.

(a)            Information collected by the Website is stored in secure operating environments that are not available to the public. Our employees or Outside Contractors are required by us to maintain and uphold your privacy and security and are aware of our privacy and security policies and/or abide by their own privacy and security policies in order to safeguard your information. We will also use reasonable efforts to safeguard the confidentiality of your Personally Identifiable Information.  Unfortunately, data transmissions made by means of the Internet cannot be made absolutely secure.  Please keep in mind that if you give out Personally Identifiable Information online, such information may be collected and used by unauthorized third parties.

(b)           Although we strive to protect your privacy, we cannot guarantee the security of information you provide to us.  You disclose such information at your own risk.  As a result, while we strive to protect your personal information, WE CANNOT ENSURE OR WARRANT THE SECURITY OF ANY INFORMATION YOU TRANSMIT TO US, AND YOU DO SO AT YOUR OWN RISK.  Further, we will have no responsibility for disclosure of information due to errors in transmission or unauthorized acts of third parties.

10.           PROTECTION OF CHILDREN’S PRIVACY RIGHTS.  The Website is directed toward and designed for use by persons aged thirteen (13) years or older. IF YOU ARE UNDER THE AGE OF THIRTEEN (13), YOU CANNOT USE THE WEBSITE WITHOUT THE PERMISSION OF YOUR PARENT OR LEGAL GUARDIAN. Our policy is that we do not knowingly collect, use or disclose Personally Identifiable Information about visitors under 13 years of age.

11.           CONDITIONS OF USE.  If you choose to use the Website, your use and any dispute over privacy is subject to this Privacy Policy and our Terms and Conditions, including limitations on damages, resolution of disputes, and application of the law of the State of New York.

 
DMCA Notice

If you have a copyright infringement claim regarding any materials posted on the Website, you are directed to file a copyright infringement notice with us by sending a written communication that includes substantially the following information (please consult your attorney or review § 512(c)(3) of the United States Copyright Act to confirm the accuracy of these requirements):

(i) A physical or electronic signature of a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.

(ii) Identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted works at a single online website are covered by a single notification, a representative list of such works at that website.

(iii) Identification of the material that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit us to locate the material.

(iv) Information reasonably sufficient to permit us to contact the complaining party, such as an address, telephone number, and, if available, an electronic mail address at which the complaining party may be contacted.

(v) A statement that the complaining party has a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law.

(vi) A statement that the information in the notification is accurate, and under penalty of perjury, that the complaining party is authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.

Such written notice should be sent to our designated agent as follows:

 

DMCA Complaints

OTG EXPERIENCE, LLC
c/o OTG MANAGEMENT
335 West Butler Avenue, Suite 120
Chalfont, PA 18914
Contact: Privacy Coordinator – [email protected]

 

Please also note that under § 512(f) of the United States Copyright Act, any person who knowingly makes a material misrepresentation that activities or materials are infringing a copyright may be subject to liability.

Counter-Notification.

If you elect to send us a counter-notice, to be effective it must be a written communication provided to our designated agent that includes substantially the following (please consult your attorney or review § 512(g)(3) of the United States Copyright Act to confirm the accuracy of these requirements):

(A) A physical or electronic signature of the user.

(B) Identification of the material that has been removed or to which access has been disabled and the location at which the material appeared before it was removed or access to it was disabled.

(C) A statement under penalty of perjury that the user has a good faith belief that the material was removed or disabled as a result of mistake or misidentification of the material to be removed or disabled.

(D) The user’s name, address, and telephone number, and a statement that the user consents to the jurisdiction of Federal District Court for the judicial district in which the address is located, or if the user’s address is outside of the United States, for any judicial district in which we may be found, and that the user will accept service of process from the person who provided notification under subsection (c)(1)(C) or an agent of such person.

Such written notice should be sent to our designated agent as follows:

OTG EXPERIENCE, LLC
c/o OTG MANAGEMENT
335 West Butler Avenue, Suite 120
Chalfont, PA 18914
Contact: Privacy Coordinator – [email protected]

Please note that under Section 512(f) of the Copyright Act, any person who knowingly makes a material misrepresentation that material or activity was removed or disabled by mistake or misidentification may be subject to liability.

Please also be advised that it is our policy to terminate users’ access to and use of the Website in appropriate circumstances, where such users are repeat copyright infringers.

preFlight