Privacy Policy

Privacy Policy
General
When you communicate with ROIPGM we collect information about you to help us provide and improve our services, websites, mobile application, features and content, and to administer our relationship with you (together, the “Service”). In this Privacy Policy, we describe the sources and types of information we collect, how we use it, when it may be shared with others, and how we reasonably attempt to safeguard its confidentiality and security. This Privacy Policy represents our policies and intended business practices; it is not a contract and does not create any legal rights or obligations.
We update this Privacy Policy from time to time. We encourage you to view the current version of the policy at any time on virginamerica.com.
What We Collect And How We Collect It
When you interact with ROIPGM directly or through our official company websites at roipgm.com (our “Sites”), our mobile application (“App”), social networking services, promotional activities, or otherwise communicate with us or certain third parties, we may receive information about you. We collect and maintain information about you and your travel companions when you book travel, make purchases, participate in sweepstakes or promotions, or participate in Elevate.
Personally Identifiable Information
Some of the information we collect on our Sites, IFE, App, through social networking services, and in promotional activities can be used to contact or identify you or is maintained in personally identifiable form (“Personal Information”). The Personal Information we may receive includes, but is not limited to:
• Name, physical addresses, e-mail addresses, and telephone numbers;
• Date of birth and gender;
• Passport number, Known Traveler number, or redress number;
• Credit card numbers, and associated billing information;
• Travel related information such as flight details, travel companions, emergency contacts, seating preferences, dietary requests, and medical needs;
• Transactional and online activity data related to points earned through Elevate partners;
• Corporate-contract, employer, or other affiliation (such as employer name, title, and contract information);
• Other personal information you may voluntarily provide to customer-service representatives or via your participation in surveys or focus groups.
We also receive information from you that is not itself Personal Information (e.g., zip code or individual preferences) (“Non-Identifying Information”). Certain Non-Identifying Information will be considered a part of your Personal Information if it is combined with other identifiers in a way that identifies you (e.g., combining your zip code with your street address). For the avoidance of doubt, the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other Non-Identifying Information.
Passive Data Collection
When you visit the Sites, whether as a registered user or an unregistered browser (either of these, a “ROIPGM User”), our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This log data includes, but is not limited to, information such as your computer’s Internet Protocol (IP) address, browser type or the website from which you are visiting, pages of our site that you visit, time spent on those pages, information you search for, access times and dates, and other statistics. We may use this information to monitor and analyze use of the Sites and the Service, increase the Sites’ functionality, security, and user-friendliness, and better tailor the Sites to our visitors’ needs. For example, some of this information is collected so that when you visit the Sites again, it will recognize you, and serve advertisements and other information appropriate to you and your interests. We also use this information to verify that visitors to the Site meet the criteria required to process their requests.
The App may collect certain information from you automatically in order to improve your experience and maximize functionality. This information may include but is not limited to your domain name, what App features you use, transaction history and details, amount of time you use the App, your device identification, data concerning your operating system and/or browser, and App links you click.
Cookies
Like many websites, we use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use persistent cookies to save your registration ID and login password for future logins to the Sites. We also utilize session ID cookies to enable certain features of the Sites, to better understand how you interact with the Sites, and to monitor aggregate usage by ROIPGM Users and web traffic routing on the Sites.
Third party advertisers on the Sites may also place or read cookies on your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from websites you visit. However, if you do not accept cookies, you may not be able to use all portions of the Sites or all functionality of the Service.
Changing Or Deleting Your Personal Information
All subscribers may review, update, correct, or delete the Personal Information in their registration profile by logging onto your account. If you completely delete all such information, your account may be deactivated. If you would like us to delete your record in our system, please contact ROIPGM and we will attempt to accommodate your request if we do not have any legal obligation to retain the record.
How Your Information Is Used
We use your Personal Information (in some cases, in conjunction with your Non-Identifying Information) to provide the Service, complete your transactions, administer your inquiries, and to contact you with ROIPGM e-mails, updates, promotional materials, and other information that may be of interest to you. To avoid having ROIPGM marketing and promotion e-mails classified as spam, please add jared@roipgm.com to your address book or safe sender list.
Who Your Information Is Shared With
We may employ third party companies and individuals to provide or assist in providing the services or products you request, perform Site-related services (e.g., maintenance services, Web analytics, and database management), or for other businesses purposes. These third parties have access to your Personal Information only to perform these tasks and are contractually obligated not to disclose or use it for any other purpose. We may also disclose Personal Information concerning your travel to third parties, such as employers, who have arranged for discounts or purchased travel or other services on your behalf.
We may share aggregated information such as demographic information, domain names, other site traffic information, etc., with third parties for industry analysis, demographic profiling, and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.
Social Networking
When you connect with ROIPGM through a forum, chat room, or other social networking service (including, without limitation, Twitter, Facebook, or Instagram), any Personal Information you share may be visible to other users and can be read, collected, or used by them or us. You are responsible for the information you choose to submit in these instances and are encouraged to read the privacy policies or statements of these social networking sites.
Compliance with Laws and Law Enforcement
ROIPGM cooperates with government and law enforcement officials and private parties to enforce and comply with the law. Personal Information may be collected, used, processed, and transferred to facilitate travel, including obtaining immigration and customs clearance, and to comply with, or assist in the development of, security or safety measures for passengers, baggage, or cargo.
We will disclose your Personal Information to government authorities or private parties pursuant to subpoenas or other legal process. We may also use or disclose your Personal Information as permitted by law to protect the property and rights of ROIPGM, our customers, our websites and its users, for fraud detection or prevention, for the prevention, detection, apprehension or prosecution of criminal acts, or when we, in our sole discretion, believe that disclosure is in the interest of aviation security or otherwise necessary or advisable.
Business Transfers
In the event ROIPGM is part of a business transaction with another company, such as a merger, corporate reorganization, acquisition, the sale of all or a portion of our assets, or in the event of bankruptcy, information that we have collected from or about you or your devices may be disclosed to such other entity as part of the due diligence or business integration process and may be included in any related transfer of assets.
How Your Information Is Protected
Security and International Transfer
ROIPGM is very concerned with safeguarding your information. We employ physical, procedural, and technological measures to protect your information from unauthorized access. While ROIPGM reasonably attempts to safeguard and prevent unauthorized access to your private information including, without limitation, your Personal Information, we cannot be responsible for the acts of those who gain unauthorized access, and we make no warranty, express, implied, or otherwise, that we will prevent unauthorized access to your private information. IN NO EVENT SHALL ROIPGM OR ITS AFFILIATES BE LIABLE FOR ANY DAMAGES (WHETHER CONSEQUENTIAL, DIRECT, INCIDENTAL, INDIRECT, PUNITIVE, SPECIAL OR OTHERWISE) ARISING OUT OF, OR IN ANY WAY CONNECTED WITH, A THIRD PARTY’S UNAUTHORIZED ACCESS TO YOUR INFORMATION, REGARDLESS OF WHETHER SUCH DAMAGES ARE BASED ON CONTRACT, STRICT LIABILITY, TORT OR OTHER THEORIES OF LIABILITY, AND ALSO REGARDLESS OF WHETHER ROIPGM WAS GIVEN ACTUAL OR CONSTRUCTIVE NOTICE THAT DAMAGES WERE POSSIBLE.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored Personal Information to you via e-mail or conspicuous posting on the Sites within a commercially reasonable time and without unreasonable delay, subject to (i) the legitimate needs of law enforcement; or (ii) any measures necessary to determine the scope of the breach and restore the integrity of the data system.
Your information may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, ROIPGM transfers Personal Information to the United States and processes it there. Your consent to this policy and your submission of Personal Information represents your agreement to that transfer.
Phishing
Identity theft and the practice currently known as “phishing” are of great concern to ROIPGM. Accordingly, safeguarding information to help protect you from identity theft is a priority. We do not and will not, at any time, request your credit card information, your account ID, login password, or national identification numbers in an unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.
Links to Other Sites
Our Sites and App contain links to other websites. If you visit an advertiser by clicking on an advertisement or third-party link, you will be directed to that third party’s website. Our provision of such third-party links or advertisements is not an endorsement, authorization, or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over these third-party websites. Other websites follow different rules regarding the use and disclosure of the personal information you submit to them, and we encourage you to read the privacy policies of the other websites you visit.
Our Policy Toward Children
Our Sites and App are not directed to children under 18. We will not knowingly collect personally identifiable information from children under the age of 13 without prior parental consent. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should ROIPGM and we will delete such information from our files. Notwithstanding the foregoing, Personal Information of minors will be retained and used to the extent necessary to provide the Service and to comply with applicable laws, including federal aviation or security regulations.
Contacting Us
If you have any questions about this Privacy Policy ROIPGM, please don’t hesitate to contact us at admin@roigpm.com

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