The Privacy Policy (PP) specifies that types of “personal information” collected from users, handling of such information and dissemination of such information to third parties.  Similar to the Terms of Use, we have attempted to keep the technical and legal language to a minimum in light of our perception that your audience is likely to be consumers from the general public and for recreational and family-oriented activities.  You will note that the PP (and TOU) cover come functionalities that are not yet enabled on the Holy City Helicopters website (e.g., username and password protection).  Nonetheless, we have included references to such functionality to maintain the robustness of the PP and TOU in case such functionality is subsequently added to the website.  Below are highlights of the Draft:

Definitions and Use of the Holy City Helicopters website is Consent to Terms of PP and TOU:

The PP indicates that any user that accesses the Services agrees to be bound by the terms and conditions set forth in the TOU and PP.  The user is informed that the TOU and/or PP may be amended from time to time and that the user’s continued use constitutes agreement with such amendments.

Applications of PP

The PP applies to the Holy City Helicopters Site and Services and does not extend to anything that is inherent in the operation of any third party website, the Internet, or any other network via which the Services are used or accessed.   The PP sets forth that other networks may be covered by other terms of use or privacy policies that are beyond Holy City Helicopters’ control and may be inconsistent with the terms and conditions of Holy City Helicopters website’s PP or TOU.  Thus, the PP explains that Holy City Helicopters is not responsible for the privacy practices or the content of any third party websites or services.


The PP establishes terms and definitions for types of information collected from Visitors and Subscribers of the Site.  For example, contact information that is used to set up or update an Account is referred to as “Contact Information”, credentials used for security purposes are referred to as “Access Credentials”, and information included in a Subscriber’s profile or associated with a subscription is referred to as “Context Information”.  A profile, Holy City Helicopters Content, or portions thereof (e.g., Contact Information, Access Credentials, Context Information, etc.) are collectively referred to as Personal Information.  In sum, the Personal Information constitutes information that the user provides to Holy City Helicopters as well as information that Holy City Helicopters may collect over time from the user.

Collected Personal Information:

The PP identifies several types of information that Holy City Helicopters may collect. For instance, the PP explains that Holy City Helicopters may collect device information, user history information, location information, cookies/beacons, and other data associated with a Visitor or Subscriber and/or a device associated with a Visitor or Subscriber.

License Grant to Holy City Helicopters to use Personal Information:

The PP grants a broad irrevocable fully paid-up and royalty-free license to Holy City Helicopters to use, display, modify, make derivative works of, obfuscate, de-identify, encode, translate, copy, transmit, or sublicense Personal Information throughout the universe for Holy City Helicopters’ own commercial, research, and quality improvement purposes.

Use of Personal Information:

The PP sets forth the various uses of Personal Information by Holy City Helicopters.  For example, the PP explains that Holy City Helicopters may use Personal Information for internal use, creating de-identified personal information, Holy City Helicopters communications to Visitors and Subscribers, or to third parties  to comply with the law, and for security purposes.  The PP explains that Holy City Helicopters does not share Personal Information with any third parties, Visitors, or Subscribers except as described in that PP and that Holy City Helicopters will attempt to notify Visitors and Subscribers who have provided Personal Information in the case of a change in ownership or control.

Thus, Personal Information may not be provided to a third party unless expressly permitted by the Subscriber or Visitor or to comply with the law.  Holy City Helicopters reserves the right, however, to share de-identified Personal Information with a third party.

Choices and Obligations:

The PP sets forth Visitor and Subscriber rights, including the right to change, access, and delete personal information, the right to delete an account, and other obligations and warranties.

Policy Toward Child:

An eligibility term is included in the TOU that indicates that users must be at least 13 years old and have authority to access the website.  This establishes the age requirement and avoids triggering onerous Child Online Privacy Protection Act (COPPA) provisions.  Furthermore, the PP sets forth that Holy City Helicopters is not intended for children under the age of 13 within the meaning of COPPA.  The PP instructs parents/guardians of children under the age of 13 who have provided Holy City Helicopters any personal information, to contact Holy City Helicopters.