Privacy Policy

Effective Date: June 26, 2018.

This Privacy Policy applies to information collected in relation to your use of southwest.placeplass.com by ETMA, Inc. d/b/a PlacePass (“PlacePass”) under an arrangement with Southwest® (collectively, the “Service”). This Privacy Policy describes how Southwest Airlines Co., P.O. Box 36647 TOP-1CR, Dallas, Texas 75235 (“Southwest,” “Company,” “we,” “our,” or “us”) collects, uses and shares information about you.

By using the Service, you agree and consent to our collection, use and disclosure practices, and other activities as described in this Privacy Policy.

Transfer of Information

The information collected from you through the Service may be transferred to, stored at, and processed in destinations outside of the country in which you are located, and may be accessible to the governments of such destinations under local law. This includes processing by us, our affiliates, our third party payment processing companies and other third parties who are described in the “Sharing of Information” section below. You agree to such transfer, storing and/or processing outside the country in which you are located. We will take steps reasonably necessary to help secure your information and to treat your information that we have collected in accordance with this Privacy Policy.

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Information Collection

Information You Provide to Us

We collect information you provide directly to us. For example, we collect information when you use the Service, book travel, register for the Service or set up an account, a Rapid Rewards® account, subscribe to our e-mails, participate in the Rapid Rewards® Program, , shop the Service, request customer support, or otherwise communicate with us through the Service.

The types of information we may collect include Personal Information. “Personal Information” is information that can be used to identify an individual (whether alone or in combination), such as your first and last name, e-mail address, zip code, billing address, shipping address, phone number, payment card information, social media account information, travel preferences, birth date, redress number, and demographic information. “Personal Information” also may include sensitive information, such as present and future health status, to allow us to better serve your needs (for example, to assist with meeting helicopter safety requirements).

You may choose to voluntarily submit certain other information to us through the Service, including Personal Information, but you are solely responsible for your own Personal Information in instances where we have not collected such information or requested that you submit such information to us.

Information We Collect Automatically

We and our service providers automatically collect certain information from and about you when you access or use the Service. This information may include, without limitation, demographic information; IP address; browser/device/hardware type; operating system characteristics; information about your use of the Service; and data regarding network connected hardware (e.g., computer or mobile device), such as unique device identifiers, type, model, version, MAC address, device or session ID, error related data status, capability, confirmation, functionality, performance data, and connection type. This information may also include clickstream data, which is information about the page-by-page paths you take as you browse through the Service.

This information is gathered by certain tools and methods such as:

  • Log Information: We collect information about your use of the Service, such as the type of browser you use, access times, pages viewed, your IP address and the referring link through which you accessed the Service.
  • Information Collected by Cookies and Other Tracking Technologies: We may use cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, in-app tracking methods, and other tracking technologies to collect information about you when you interact with the Service or e-mails, including information about your browsing and purchasing behavior. We may combine this information with other information we collect about you and use it for various purposes, such as improving the Service and your online experience, understanding which areas and features of the Service are popular, counting visits, understanding campaign effectiveness, tailoring our communications with you, determining whether an e-mail has been opened and/or links within the e-mail have been clicked, and for other internal business purposes.
  • Cookies: Cookies are data files that are placed on a computer when it is used to visit a website. These cookies may be used for many purposes, including, without limitation, tracking user preferences or web pages visited while using the Service. Most web browsers are set to accept cookies by default. If you prefer, you can usually set your browser to remove or reject cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Service. For example, cookies allow us and our third party service providers to store items in your cart between visits. In addition, please be aware that if you choose to block cookies, some advertising preferences that are dependent on cookies may not be able to be respected.
  • Web Beacons: We and our third party service providers may include small graphic images called web beacons, also known as “Internet tags” or “clear gifs,” in our web pages and e-mail messages. We may use web beacons or similar technologies for a number of purposes, including, without limitation, to count the number of visitors to the Service, to monitor how users navigate the Service, and to count how many e-mails that we sent were actually opened or how many particular articles or links were actually viewed.
  • Embedded Scripts: An embedded script is programming code that is designed to collect information about your interactions with the Service. It is temporarily downloaded onto your computer from our web server or a third party with whom we work, is active only while you are connected to the Service, and is deleted or deactivated thereafter.

Information we and our third party service providers automatically collect about you, such as how you interact with the Service, may be combined with your Personal Information. If we associate any such automatically-collected information with Personal Information about you, we will treat the combined information as Personal Information.

We and our business partners and other third parties may send you product promotions that are aligned with your purchase trends and/or interests identified through automatically-collected information.

Information We Collect From Our Partners and Other Sources

We may also obtain information about you (such as e-mail and address) from other sources and combine that with information we collect about you. If we receive Personal Information from a third party source and/or if we combine the information we receive from these third party sources with your Personal Information, we will treat that information as Personal Information. We are not responsible for the accuracy of the information provided by third parties or how such third parties collect, use and share such information.

We may obtain information from our partners and append it to our existing user information to better understand users’ interests and to provide more relevant content, including advertising.

We may append information about you that is publicly available or information that is aggregated and/or depersonalized by partners. This information may include, for example, your travel preferences and activity, household income range, or postal code. This information may be associated with personal information as described herein, such as email address, physical address, first and last name combined, or phone number. We may use a third party vendor with whom we share your information to assist with this.

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Use of Information

We, PlacePass, and third party service providers may use information about you for various purposes. Primary purposes for use of information include to:

  • Facilitate, personalize, and improve your travel experience and your online or app experience;
  • Process your registration with the Service, including verifying that your e-mail address(es) are active and valid and enrolling you in the Rapid Rewards® Program;
  • Manage your profile(s) and online account(s), including purchases, orders, payments, returns, exchanges, and blog comments;
  • Process and deliver frequent flyer points, sweepstakes, contest, promotion, and survey entries and rewards;
  • Respond to your comments, questions and requests and provide customer service;
  • Send you technical notices, updates, security alerts and support and administrative messages;
  • Contact you regarding your use of the Service and, in our discretion, changes to our policies; and
  • Prevent fraudulent transactions and monitor against threats.

In addition, there may be secondary purposes for use of information, such as to:

  • Create a usage profile of your preferences and provide advertisements, content or features that match your profile and interests;
  • Communicate with you about products, services, offers, promotions, rewards and events (including those offered by third parties) and provide news and information we think will be of interest to you (for information about how to manage these communications, please see the Your Choices section below);
  • Monitor and analyze trends, usage and activities;
  • Link or combine with information we get from others to help understand your needs and provide you with better service;
  • Improve the Service and other Southwest websites, applications, marketing efforts, products and services;
  • Conduct research and analysis, including focus groups and surveys, on the Service and other Southwest websites, applications, products and services;
  • Retarget across other sites (as described in the Advertising & Analytics Services and Online Tracking section below);
  • Carry out any other purpose disclosed elsewhere in this Privacy Policy or at the time you provide your Personal Information; and
  • Any other purpose, with your consent or as permitted or required by applicable law.

Whether a use is primary or secondary may change over time. Some of the information we collect for primary purposes may be used for secondary purposes.

PlacePass may use aggregated and anonymized transactional data for the purposes of accounting and investor documentation.

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Sharing of Information

Southwest’s and PlacePass’ agents, vendors, consultants, and other service providers have access to Personal Information to carry out work on our behalf.

We may also share information about you for various purposes. Primary purposes for sharing of information include:

  • With the Transportation and Security Administration (“TSA”) as legally permitted or required under the authority of 49 U.S.C. section 114, the Intelligence Reform and Terrorism Prevention Act of 2004 and 49 C.F.R parts 1540 and 1560;
  • To the maximum extent permitted by applicable law, in response to (i) subpoenas or other legal process or if in our good faith opinion such disclosure is required or permitted by law; and/or (ii) at the request of governmental authorities conducting an investigation;
  • To defend the terms of service or other policies applicable to the Service;
  • If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property, life, health, security and safety of us or any third party;
  • To the maximum extent permitted by applicable law, we may also use IP addresses, mobile device identifiers or any other information we collect to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies in our discretion. Such disclosures may be carried out without notice to you;
  • With our agents, vendors, consultants, and service providers for purposes of managing and fulfilling your travel reservations, product purchases, transportation services, tours, excursions, activities, concerts, events, and Rapid Rewards® Program points. For example, we may share your information with PlacePass, tour guides, and/or travel agencies, to help facilitate your transportation services, tours, excursions, activities, concerts, events, and the like.
  • With agents, vendors, consultants, and service providers to verify your address in order to ensure we maintain the accuracy of our database;
  • With our affiliates for internal business purposes (including but not limited to managing your travel and/or accounts);
  • In connection with, or during negotiations of, any proposed or actual merger, purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, amalgamation or any other type of acquisition of all or any portion of Southwest assets, financing, disposal, conveyance or transfer of all or a portion of our business to another company; and
  • With business partners, affiliates, and other third parties for facilitating, personalizing, and improving your travel experience.

In addition, there may be secondary purposes for sharing of information, such as:

  • With our business partners, affiliates and other third parties for purposes of sending their own marketing. For example, we may share your information with our financial institution Rewards® Partners for their direct marketing purposes, which may include, but is not limited to, marketing their co-branded credit cards to you;
  • With third parties who conduct analytics or data appending (such as the process described above) in order for us to offer you more relevant products and services;
  • For a purpose disclosed elsewhere in this Privacy Policy, or at the time you provide your Personal Information. For example, if you link your account to a corporate travel account, we may share Personal Information with your company’s travel administrators and other personnel; and
  • With your consent or at your direction or as required or permitted by applicable law.

Whether sharing is primary or secondary may change over time. Some of the information we share under primary purposes may be shared for secondary purposes. We may also share information we collect for other reasons we may describe to you.

In our sole discretion, we may also share aggregated or de-identified information.

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Advertising & Analytics Services and Online Tracking

We engage third parties to serve advertisements on our behalf across the Internet and to provide analytics about the use of the Service. In addition, we may participate in online advertising networks and exchanges that display relevant advertisements to the Service visitors based on their interests as reflected in their browsing of the Service and certain third party sites participating in the same networks and exchanges. These entities may use cookies, web beacons, pixels, embedded scripts, and other technologies to automatically collect information about your use of the Service, such as your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on the Service and other websites and better understand your online activity. Data collected from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such data was collected, or transferred to a non-affiliate for such purposes.

This means that some information about your browsing of the Service and certain third party sites may be shared with these companies for the purpose of delivering ads to you on the Service and certain third party sites, and Southwest may receive from some of these companies information about third party sites that you have visited. This information is used for marketing purposes and the practice is sometimes termed “retargeting” to indicate that information from one retailer is used to suggest to you relevant products offered by another retailer.

These and other third parties may also collect Personal Information about your online activities over time and across different websites when you use the Service.

We may also work with third parties to serve ads to you as part of a customized campaign on other websites or platforms.

This Privacy Policy does not cover any use of information that such third parties themselves may have collected from you (e.g., type of browser, operating system, domain name, day and time of visit, page(s) visited) or the methods used by the third-parties to collect that information (e.g., cookies, web beacons and clear gifs).

Note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, Southwest currently does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you may wish to visit http://www.allaboutdnt.com.

Certain advertising networks and exchanges may participate in the Digital Advertising Alliance (“DAA”) AdChoices Program and may display an Advertising Option Icon for interest-based ads. You can learn more about the DAA AdChoices Program at http://www.youradchoices.com. The DAA also offers a tool for opting out of the collection of cross-app data on a mobile device for interest-based advertising. To exercise choice for companies participating in this tool, download the AppChoice app at http://youradchoices.com/appchoices.

In addition, certain advertising networks and exchanges may participate in the Network Advertising Initiative (“NAI”). NAI has developed a tool that allows consumers to opt out of targeted advertising delivered by NAI members’ ad networks. To learn more about opting out of targeted advertising or to use the tool, visit http://www.networkadvertising.org/choices/. We are not responsible for effectiveness of, or compliance with, any third-parties’ opt out options or programs or the accuracy of their statements regarding their programs. Choices you make are both browser and device-specific.

The Service also has a specific marketing platform that uses persistent cookies. Click this link to opt out from our marketing platform’s persistent cookies (please note that if you delete your cookies or switch to a different browser you will have to repeat this procedure). Use of cookies by Southwest’s marketing platform is subject to its privacy policies. Please be aware that, even if you are able to opt out of certain kinds of targeted advertising, you will continue to receive generic ads.

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Third Party Websites

The Service contains hyperlinks to other websites or locations that we do not control and are operated and controlled by third parties (“Third Party Websites”). We make no representations regarding the policies or business practices of such Third Party Websites and encourage you to familiarize yourself with their privacy policies before providing them with your Personal Information. Our Privacy Policy does not apply to these Third Party Websites. You should read the privacy policy of each Third Party Website as these Third Party Websites may use their own cookies, web beacons and other technology to independently collect information about you. In addition, these Third Party Websites may solicit Personal Information from you.

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TSA Guidelines

The TSA requires us to request, and you to provide, your full name, date of birth, and gender for the purpose of watch list screening, under the authority of 49 U.S.C. section 114, the Intelligence Reform and Terrorism Prevention Act of 2004 and 49 C.F.R parts 1540 and 1560. You may also provide your redress number, if available. Failure to provide your full name, date of birth, and gender may result in denial of transport or denial of authority to enter the boarding area. TSA may share information you provide with law enforcement or intelligence agencies or others under its published system of records notice. For more on TSA privacy policies, or to review the system of records notice and the privacy impact assessment, please see the TSA web site at www.tsa.gov.

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Your Choices

Profile and Apps

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. The Service may allow you to access, review, correct, update, and remove or make inaccessible Personal Information you have provided through the Service’s registration or otherwise, and you may provide registration updates and changes. For modifications/changes, a Customer needs to contact us via the customer service email at swa-support@placepass.com or phone line at 617-665-5342. For cancellations, the customer can activate the process in three places: confirmation screen after booking, confirmation screen from voucher after booking, or reservation lookup tool on our site.

With respect to our mobile and other applications, you can prospectively stop all collection of information by the application by uninstalling the application. Also, you may at any time opt out from further allowing us to have access to your location data by adjusting the permissions in your mobile device.

We will make good faith efforts to make requested changes in our then-active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. Also, if you have made any public postings on the Service such as in forums or blogs, these communications cannot generally be removed, except California minors should see the Children section below.

Promotional Communications

You can opt out of receiving promotional e-mail communications from us at any time by following the instructions provided in those communications or e-mail us as detailed here

Please note that even if you opt out of receiving promotional communications, we, PlacePass, and our agents, vendors, consultants, and service may continue to send you non-promotional e-mails and other types of communications, as permitted by law, such as those about an ongoing business relations. For example, we, PlacePass, and our agents, vendors, consultants, and service may send e-mails that contain service-related announcements that affect your account, confirmations and updates regarding reservations you have made, requests for feedback on services and/or your specific travel experiences, or responses to your comments and feedback submitted to us, PlacePass, and our agents, vendors, consultants, and service.

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Children

The Service is not intended for and is not targeted to children under the age of thirteen (13). If you are a child under the age of thirteen (13), you are not permitted to use the Service and should not send any information about yourself to us through the Service.

We do not knowingly collect any personal information from children under the age of 13 and, if we learn that we have received information from a user under the age of 13, we will delete this information in accordance with the Children’s Online Privacy Protection Act (“COPPA”). If you are a parent or guardian and you believe that your child under the age of thirteen (13) has provided us with personal information without COPPA-required consent, please contact us by e-mail as detailed here.

Any California residents under the age of eighteen (18) who have registered to use the Service, and who have posted content or information on the Service, can request that such information be removed from the Service by contacting us by e-mail as detailed here or by sending a letter to Southwest Airlines Co., P.O. Box 36647 TOP-1CR, Dallas, Texas 75235 (Attention: Legal Counsel), stating that they personally posted such content or information and detailing where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished the post and archived copies of it may be stored by search engines and others that we do not control.

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Your California Privacy Rights

California law permits customers in California to request certain details about how their information is shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes.

We may from time to time elect to share certain information about you collected by us on the Service with third parties or affiliates for those third parties’ or affiliates’ own direct marketing purposes. For example, we may share your information with our financial institution Rewards® Partners for their direct marketing purposes, which may include, but is not limited to, marketing their co-branded credit cards to you.

If you are a California resident, you may request information about our compliance with this law by contacting us by e-mail as detailed here by sending a letter to Southwest Airlines Co., P.O. Box 36647 TOP-1CR, Dallas, Texas 75235 (Attention: Legal Counsel). Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this e-mail address or mail address.

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Data Security

Transmission via the Internet is not completely secure and Southwest cannot guarantee the security of your information collected through the Service.

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Changes to This Privacy Policy

This Privacy Policy is current as of the effective date set forth above. Southwest reserves the right to change this privacy policy from time to time consistent with applicable privacy laws and principles. If we make changes to this Privacy Policy we will notify you by revising the date at the top of this Privacy Policy, and in some cases, we may provide you with additional notice (such as adding a statement to the homepages of the Service or sending you an e-mail notification). If the changes are material, we may provide you additional notice.

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Contact Us

If you have any questions, complaints, or suggestions regarding this Privacy Policy, please feel free to contact us by phone, e-mail, or postal mail as detailed here.

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Governing Law and Forum Selection

This Privacy Policy and the relationship between you and Southwest shall be governed by the laws of the State of Texas without regard to any conflict of law provisions. You agree to the personal and exclusive jurisdiction of the courts located within Dallas, TX. You hereby consent to the exclusive jurisdiction and venue of the State and Federal courts in Dallas, Texas in all disputes. You agree and understand that you will not bring against SOUTHWEST OR ITS AFFILIATES NOR ANY OF THEIR RESPECTIVE OFFICERS, DIRECTORS, MANAGERS, EMPLOYEES OR AGENTS (COLLECTIVELY, THE “SOUTHWEST PARTIES”) any class action lawsuit related to your access to, dealings with, or use of the Service.