FREQUENTFLIER.COM PRIVACY POLICY

We understand that making purchases online involves a great deal of trust on your part. We take this trust very seriously, and make it our highest priority to ensure the security and confidentiality of the personal information you provide to us. Please read the following policy to learn about our privacy practices. By visiting our U.S. website, www.frequentflier.com, you are accepting the practices described herein.

• What information we collect from you

• How we use your information

• With whom we share your information

• How you can access your information

• Your choices with respect to the collection and use of your information

• How we protect your information

• Children's privacy

• External links

• Changes to this Privacy Policy

• How you can contact us

What information we collect from you

In General. We receive and store any information you enter on our Web site or give us in any other way. This includes information that can identify you ("personal information"), including your email address. We also may request information about your traveler preferences and ticketing options. You can choose not to provide information to us, but in general some information about you is required in order for you to register as a member; participate in a survey, contest, or sweepstakes; ask us a question; or initiate other transactions on our site.

Information from Other Sources. We also may periodically obtain both personal and non-personal information about you from affiliated entities, business partners and other independent third-party sources and add it to our account information. Examples of information we may receive include: updated delivery and address information, purchase history, and demographic information.

Automatic Information. We automatically collect some information about your computer when you visit FrequentFlier.com. For example, we will collect your IP address, Web browser software (such as Netscape Navigator or Internet Explorer), and referring Web site. We also may collect information about your online activity, such as stories viewed. One of our goals in collecting this automatic information is to help customize your user experience.

Cookies and Other Web Technologies. When you visit FrequentFlier.com, we may assign your computer a "cookie" (a small, unique identifier text file). You can always choose not to receive a cookie file by enabling your Web browser to refuse cookies or to prompt you before accepting a cookie. Please note that if you refuse to accept cookies from FrequentFlier.com, you may not be able to access many of the travel tools offered on our site. We also may use Web beacons (also known as clear gifs, pixel tags or Web bugs) to deliver or communicate with cookies, to count users who have visited certain Web pages on our site, and to understand whether you have come to our site from an online advertisement displayed on a third-party website.

Information Collected by Third Parties. Third parties, such as vendors, advertising entities, and business partners, may use cookies and other technologies (such as Web beacons or single-pixel GIFS) to collect information about your online activities. The purposes for collecting this information includes: to measure usage of our site; to analyze, modify, and personalize advertising content on FrequentFlier.com and other sites; and to provide ads about goods and services we hope will be of interest to you. We do not have access to or control over cookies or other features these third parties may use, and the information practices of these third parties are not covered by this Privacy Policy. Some of these third parties may be third-party network advertisers that offer you the option of not having this information collected. To learn more, please click here.

How we use your information

We use information about you for the following general purposes: to provide you with the products and services you request; to communicate with you in general; to respond to your questions and comments; to measure interest in and improve our products, services, and Web site; to notify you about special offers and products or services that may be of interest to you; to otherwise customize your experience with FrequentFlier.com; to reward you as part of any reward and recognition program you choose to join; to solicit information from you, including through surveys; to resolve disputes, or troubleshoot problems; to prevent potentially prohibited or illegal activities; to enforce our Terms of Use; and as otherwise described to you at the point of collection.

Please review "Your choices with respect to the collection and use of your information" below.

With whom we share your information

FrequentFlier.com may share your information with the following entities:

• Third-party vendors who provide services or functions on our behalf, including operation of web sites, business analytics, customer service, marketing, distribution of newsletters, surveys or sweepstakes programs, and fraud prevention. These companies have access to personal information needed to perform their functions but are not permitted to share or use the information for any other purpose.

• Business partners with whom we may jointly offer products or services. You can tell when a third party is involved in a product or service you have requested because their name will appear with ours. If you choose to access these optional services, we may share information about you, including your personal information, with those partners. Please note that we do not control the privacy practices of these third-party business partners and recommend that you evaluate their practices before deciding to provide your personal information.

• Companies within our corporate family. We may share your personal information with our corporate affiliates. To the extent that our corporate affiliates have access to your information, they will follow practices that are at least as restrictive as the practices described in this Privacy Policy. They also will comply with applicable laws governing the transmission of promotional communications and, at a minimum, give you an opportunity in any commercial email they send to choose not to receive such e-mail messages in the future.

We also may share your information:

• In response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us.

• When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of FrequentFlier.com, our customers, or others; and in connection with our Terms of Service and other agreements.

• In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy. Other than as set out above, you will be notified when personal information about you will be shared with third parties, and you will have an opportunity to choose not to have us share such information.

We also may share aggregate or anonymous information with third parties, including advertisers and investors. For example, we may tell our advertisers the number of visitors our Web site receives or the most popular sections of our site. This information does not contain any personal information and is used to develop content and services we hope you will find of interest.

Your choices with respect to collection and use of your information

• As discussed above, you can choose not to provide us with any information, although in order to receive communications, you must provide your email address.

• If you wish to stop receiving e-mails from us, you will have the opportunity to opt-out of future communications in every email that we send you.

• The Help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Please note that if you refuse to accept cookies from FrequentFlier.com, you will not be able to access portions of our site.

How we protect your information

We want you to feel confident about using FrequentFlier.com. While no Web site can guarantee security, we have implemented appropriate administrative, technical, and physical security procedures to help protect the personal information you provide to us. For example, only authorized employees are permitted to access personal information, and they only may do so for permitted business functions. In addition, we use encryption when transmitting your sensitive personal information between your system and ours, and we employ firewalls and intrusion detection systems to help prevent unauthorized persons from gaining access to your information.

Children's privacy

FrequentFlier.com is a general audience site and does not offer services directed to children. Should a child whom we know to be under 13 send personal information to us, we will use that information only to respond directly to that child to inform him or her that we must have parental consent before receiving his or her personal information.

External Links

If any part of the FrequentFlier.com Web site links you to other Web sites, those Web sites do not operate under this Privacy Policy. We recommend you examine the privacy statements posted on those other Web sites to understand their procedures for collecting, using, and disclosing personal information.

Visiting our websites from outside the United States

This Privacy Policy is intended to capture information collected through our Web site from residents of the United States. If you are visiting our website from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, but please be assured that we take steps to ensure that your privacy is protected. By using our services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Policy.

Changes to our Privacy Policy

FrequentFlier.com may update this Privacy Policy in the future. We will notify you about material changes to this Privacy Policy by sending a notice to the email address you provided to us or by placing a prominent notice on our Web site.

If you provided your email address to us before January 10, 2008, and you have not re-registered on our site or otherwise provided your email address to us after that date, we will continue to use your email address only for the purpose of sending you the newsletter to which you originally subscribed.

How you can contact us

If you have questions about either Privacy Policy (or your travel planning or purchases), please email us using this link.

This Privacy Policy is effective as of January 10, 2008.