Effective Date: May 23, 2025
This Privacy Policy describes how 39a Concepts, LLC ("we," "us," or "our"), a corporation registered in New York, collects, uses, and shares personal information of users of the website http://FlyN96.com (the "Site") and the services offered through the Site. We are committed to protecting your privacy and ensuring the security of your personal information.
1. Information We Collect
We may collect the following types of personal information when you use our Site and services:
- Information You Provide Directly:
- Account Information: When you create an account, we collect your name, email address, password,3 and potentially other contact information.
- Course Enrollment and Progress Information: We collect information related to your enrollment in our flight training courses, including lesson plans, progress reports, performance and grading data, and any documents you upload to our student portal.
- Communications: If you contact us directly, we may receive additional information about you, such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide.
- Payment Information: While we strive to use third-party payment processors for financial transactions, if we collect payment information directly, it will include details such as credit card numbers or bank account information. (Please note: Specify if you use a third-party payment processor and link to their privacy policy).
- Information We Collect Automatically:
- Log Data: Like most websites, we automatically collect certain information when you visit our Site. This may include your Internet Protocol (IP) address, browser type, operating system, referring URLs, access times, pages viewed, and links clicked.
- Cookies and Similar Technologies: We use cookies and similar tracking technologies to track activity on our Site and hold certain information. Cookies are small data files stored on your device. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.
2.6 How We Use Your Information
We use the information we collect for various purposes, including to:
- Provide, operate, and maintain our Site and services.
- Process your registration and manage your account.
- Deliver and track your progress in our flight training courses.
- Process payments for our services.
- Communicate with you, including responding to your inquiries, providing customer support, and sending you updates and administrative messages.
- Send you marketing and promotional communications, where permitted by law and with your consent where required.
- Improve our Site and services, including analyzing usage trends and user feedback.
- Personalize your experience on our Site.
- Maintain the security and integrity of our Site and services, including preventing fraud and abuse.
- Comply with legal obligations, including the New York SHIELD Act and other applicable laws and regulations.
3. How We Share Your Information
We may share your personal information in the following circumstances:
- Service Providers: We may share your information with third-party vendors, service providers, contractors, or agents who perform services on our behalf, such as website hosting, data analysis, payment processing, email delivery, and customer service. These service providers are obligated to protect your information and are restricted from using it for any other purpose.
- Flight Instructors: Your course-related information, including performance and uploaded documents, will be accessible to authorized flight instructors involved in your training.
- Legal Requirements: We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to:
- Comply with a legal obligation or governmental request.
- Protect and defend the rights or property of 39a Concepts, LLC.
- Prevent or investigate possible wrongdoing in connection with the Site or services.
- Protect the personal safety of users of the Site or the public.
- Business Transfers: If 39a Concepts, LLC is involved in a merger, acquisition, or asset sale, your personal information may be transferred. We will provide notice before your personal information is transferred and becomes subject to a different privacy policy.
- With Your Consent: We may share your information for other purposes with your explicit consent.
We do not sell your personal information to third parties.
4. Data Security
We implement and maintain reasonable administrative, technical, and physical safeguards to protect the security, confidentiality, and integrity of your personal information, as required by the New York SHIELD Act and other applicable laws. These measures are designed to protect your information from unauthorized access, use, alteration, and disclosure. However, please be aware that no method of transmission over the internet or method of electronic storage is 100% secure, and we cannot guarantee its absolute security.
5. Data Retention
We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as for tax, accounting, or other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it.
6. Your Rights and Choices
Depending on your location and applicable law, you may have certain rights regarding your personal information, including:
- Access: You may have the right to request access to the personal information we hold about you.
- Correction: You may have the right to request that we correct any inaccurate or incomplete personal information.
- Deletion: You may have the right to request that we delete your personal information, subject to certain exceptions.
- Opt-Out of Marketing Communications: You can opt-out of receiving promotional emails from us by following the unsubscribe instructions provided in those emails. Please note that even if you opt-out of marketing communications, we may still send you non-promotional messages, such as those related to your account or our ongoing business relations.
- Cookie Choices: You can manage your cookie preferences through your browser settings.
To exercise any of these rights, please contact us using the contact information provided below. We will respond to your request in accordance with applicable law.
7. Children's Privacy
Our Site and services are not directed to individuals under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has provided us with personal information, we will take steps to delete such information. If you are a parent or guardian and believe that your child has provided us with personal information without your consent, please contact us.
For users between the ages of 13 and 18, we recommend they seek parental consent before providing any personal information.
8. Third-Party Websites
Our Site may contain links to other websites not operated or controlled by us ("Third-Party Sites"). The information that you share with Third-Party Sites will be governed by the specific privacy policies and terms of service of the Third-Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third-Party Sites directly for information on their privacy practices and policies.
9. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
10. Contact Us
If you have any questions about this Privacy Policy or our privacy practices, please contact us:
39a Concepts, LLC
admin@39aconcepts.com
Important Considerations and Disclaimers:
- This is a template and NOT legal advice. It is crucial to consult with a legal professional to ensure this privacy policy is complete, accurate, and compliant with all applicable laws and regulations, including any specific nuances of New York law and federal regulations relevant to your business activities (e.g., FAA regulations if applicable to pilot training records).
- Review and customize: Carefully review and customize all sections, especially those related to specific data collection practices (e.g., payment processors, specific types of documents uploaded), third-party services you use, and your actual data handling procedures.
- NY Privacy Act (NYPA): As noted in the search results, the NYPA is still under consideration. If it passes, this policy will need to be updated to reflect its specific requirements (e.g., explicit consent for data processing, data fiduciary responsibilities, rights regarding automated decision-making). Stay informed about changes in New York privacy law.
- Internal Policies: Remember that a public-facing privacy policy should be supported by internal data security and privacy policies and employee training, as highlighted by New York's SHIELD Act requirements.
- Cookie Consent Banner: Ensure your website's cookie consent mechanism is clear, truthful, and not misleading, in line with the NY Attorney General's guidance. Users should have genuine control over non-essential cookies.
- Data Breach Notification Plan: Have a plan in place for data breach notifications as required by the SHIELD Act.