Last Updated: May 10, 2019
2. General Terms
- Turbo Boutique Agency, LLC. may be referred to as “Turbo Boutique,” “we,” “our,” or “us.”
- We call a user of the Turbo Boutique Platform a “User,” or collectively, the “Users.”
- “You” and “your” refer to an individual User of the Turbo Boutique Platform.
- The community platform that we offer at our website (turboboutique.com/terms) is referred to as the “Site.”
- The platform and related services provided by Turbo Boutique, the Site and mobile applications (whether on iOS or Android), including without limitation information provided by Turbo Boutique to potential and actual Users in relation to the services, together are called the “Turbo Boutique Platform.”
3. Users Outside Of The U.S.
3(a) Important Information for Users Outside of the U.S. – Transfer of Data
3(b) EU-US Privacy Shield
Turbo Boutique’s commitment to comply with the Privacy Shield Principles
Turbo Boutique is committed to compliance with the EU-US Privacy Shield (as set forth by the U.S. Department of Commerce) regarding the collection, use, and retention of personal information from European Union member countries. Turbo Boutique has self-certified that it adheres to each of the Privacy Shield Principles:
- Accountability for Onward Transfer
- Data Integrity and Purpose Limitation
- Recourse, Enforcement, and Liability
Accountability for onward transfers
The Privacy Shield Principles describe Turbo Boutique’s responsibility for personal data that it receives from EU residents under the Privacy Shield and subsequently transfers to a third party processor. In particular, if third-party agents that process personal data on Turbo Boutique’s behalf do so in a manner inconsistent with the Privacy Shield Principles, Turbo Boutique will remain responsible and liable unless it can prove that it is not responsible for the event giving rise to the damage.
Right of access
You have a legal right to request a copy of the personal information that we have about you. You also have a right to correct, amend or delete such personal information where it is inaccurate or has been processed in violation of the Privacy Shield Principles.
Resolution of disputes and complaint mechanism
In compliance with the Privacy Shield Principles, Turbo Boutique commits to resolve complaints about your privacy and our collection or use of your personal information. If European Union citizens have any queries related to the processing of your personal information under the Privacy Shield framework, we encourage you to contact us directly in the first instance at: [email protected].
For any complaints that cannot be resolved with Turbo Boutique directly, we have agreed to cooperate with JAMS. If you are unsatisfied with the resolution of your complaint, you may contact JAMS at https://www.jamsadr.com/eu-us-privacy-shield for further information and assistance. These recourse mechanisms are available at no cost to you.
As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints regarding Turbo Boutique’s Privacy Shield certification not resolved by any other means.
Turbo Boutique is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
Disclosure of EU personal data to public authorities and law enforcement agencies
Turbo Boutique may be required to share your personal information in response to lawful requests by public authorities.
3(c) EU users and our lawful bases for using your data
Data protection law in Europe contains a number of “lawful bases,” which are legal justifications for allowing organisations like us to have your personal information in the first place. We have been careful to ensure we have a lawful basis for using all EU user data. Our lawful bases include:
- Performing the contract we have with you: In certain circumstances, we need your personal data to comply with our contractual obligation to deliver access to the Turbo Boutique Platform. For example, if you are a Client looking for a Flight Attendant closest to the departing FBO, we need your address so we can communicate the request to Flight Attendant in the approximate area and tell the Flight Attendant you choose where s/he needs to go.
- Legal compliance: Sometimes the law says we need to collect and use your data. For example, we might pass on details of people involved in fraud or other criminal activity to law enforcement.
- Legitimate interests: this is a technical term in data protection law which really means we have a good and fair reason to use your data and we do so in ways which do not materially impact your interests and rights. We sometimes require your data to pursue our legitimate interests in a manner that might reasonably be expected as part of running our business. For example, we will send you promotional communications about our service, subject to your legal rights to opt-out. We also analyse how Users interact with our Site and the Turbo Boutique Platform so we can understand better what elements of the design are working well and which are not working so well. This allows us to develop and improve the quality of the online experience we offer all our Users.
4. Information Received By Turbo Boutique
Personal Information Turbo Boutique collects certain information such as your name, address, approximate geographic location of your computer or mobile device, telephone number, email address and bank account and other Financial Information if you voluntarily choose to share such information with Turbo Boutique. We do require that you furnish this information when you register with us as a Flight Attendant or a Client, because we need the information in order to provide the Turbo Boutique Platform. When you register your account, and through communications transmitted through our Site and your use of the Turbo Boutique mobile application, we collect information including your name, address, phone number and email address. You also may choose to send Turbo Boutique personal information in an email message containing inquiries about the Turbo Boutique Platform. Certain offerings of the Turbo Boutique Platform, such as newsletters, surveys, contests, and the like are optional and so you are not required to enter them or to give us your data in connection with them. Where you do choose to enter them, we will use your data to operate and manage the survey, contest or similar in connection with our legitimate interest in promoting our business and the Turbo Boutique Platform.
Cookies and Other Technologies. When you visit websites on the Internet, your browser may automatically transmit information to the websites you visit throughout every visit, including ours. In a similar way, when you use our mobile applications, we will access and use mobile device IDs to recognise your device. Like many websites, we use “cookies” and equivalent techniques through our mobile applications to collect information. A cookie is a small data file that we transfer to your computer’s hard disk.
We utilize persistent cookies that only Turbo Boutique can read and use, and access mobile device IDs:
- to save your login information for future logins to the Turbo Boutique Platform;
- to assist in processing items during checkout;
- to hold session information; and
- to track user preferences.
We utilize session ID cookies and similar technologies:
- to enable certain features of the Turbo Boutique Platform;
- to better understand how you interact with the Site and the Turbo Boutique Platform;
- to monitor usage by our Users and web traffic routing on the Turbo Boutique Platform;
- to track the number of entries in Tubro Boutique promotions, sweepstakes and contests; and
- to identify visited areas of the Turbo Boutique Platform.
Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Turbo Boutique Platform and then close your browser.
Third party advertisers on the Site may also place or read cookies on your browser, and we may use Flash cookies (or local shared objects) to store your preferences or display content based upon what you view on the Site to personalize your visit.
You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you will not be able to use all portions or all functionalities of the Turbo Boutique Platform.
We and our service providers may also use “pixel tags,” “web beacons,” “clear GIFs,” or similar means in connection with the Turbo Boutique Platform and HTML-formatted email messages to, among other things, track the actions of Users and email recipients, to determine the success of marketing campaigns, and to compile statistics about Site usage and response rates. We also engage one or more third party service providers to serve online advertisements on our behalf. They may use a “pixel tag” which triggers a cookie to collect information about your visits to the Site and to other websites, and they may use that information and share and combine it with other information with their partners to show you advertisements for goods and services you might be interested in on the Site and on other websites and apps, including by observing the kinds of products and subject-matter you are interested in and certain demographic information about you.
The following table sets out the different categories of cookies that the Turbo Boutique Platform uses and why we use them. The lists of third party cookie providers are intended merely as illustrative not comprehensive:
Type of Cookie
Who Serves (for example)
These cookies (including local storage and similar technologies) tell us when you’re logged in, so we can customize your experience and connect your account information and settings.
● Turbo Boutique
These cookies help provide a localized experience by showing you your local metro area.
● Turbo Boutique
Site features and Services
● Turbo Boutique
Analytics and research
● Google Analytics
Things like cookies and pixels are used to deliver relevant ads, track ad campaign performance and efficiency, and to understand your interests from your online activity on the Site, mobile applications and other websites and apps. For example, we and our ad partners may rely on information gleaned through these cookies to serve you ads that may be interesting to you on other websites and in doing that your information (which will not contain your name, email address or other “real-world” identifiers) will be shared with other platforms in the digital advertising ecosystem all involved in assisting the delivery, purchase, reporting and analysis of digital advertising. Similarly, our advertisers may use a cookie, attribution service or another similar technology to determine whether we’ve served an ad and how it performed, or provide us with information about how you interact with them. For more information about interest-based ads, or to opt out of having your web-browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices if you are in the United States, or http://youronlinechoices.eu/ if you are outside the United States.
● Turbo Boutique
● Bing Ads
Social Media and Digital Advertising cookies and widgets
- DoubleClick: Google’s Doubleclick re-targeting cookie lets us serve personalized ads to you when you’re browsing other websites and social media platforms. You can control ad personalization on Google and partner websites here: https://policies.google.com/technologies/ads?hl=en-GB&gl=uk
- Facebook Impressions: We use Facebook Impressions to track the number of people that interact with our content on Facebook.
- Google Sign-in: We may allow you to sign up and log in using your Google account. If you sign up using Google, Google will ask your permission to share certain information from your Google account with us. This may include your first name, last name, email address, profile picture, and general location in order to create an account.
- LinkedIn Widgets: This tool enables visitors to engage with us via LinkedIn and show visitors relevant ads and personalized content on LinkedIn. To learn more about LinkedIn’s practices and to opt out, please visit https://www.linkedin.com/legal/privacy-policy and
- Bing Ads: We use Bings Ads to promote our company online and use the cookies provided by Bing to record completion of a transaction on our website. You can find out more about Bing cookies by visiting this site: https://advertise.bingads.microsoft.com/en-gb/resources/policies/microsoft-bing-ads-privacy-policy
Device Information. When you visit and interact with the Turbo Boutique Platform or the Site, Turbo Boutique may collect certain information automatically, including, but not limited to, the type of computer or mobile device you use, your mobile device’s unique device ID, the IP address of your computer or mobile device, your operating system, the type of Internet browser(s) you use, and information about the way you use the Turbo Boutique Platform (“Device Information”). We may use Device Information to monitor the regions from which Users navigate the Site or the Turbo Boutique Platform and for security and fraud prevention purposes. Tools with the goal of anonymizing certain Device Information (like the TOR network) are forbidden on the Turbo Boutique Platform. While we respect your right to hide this information, we believe that doing so is in conflict with the spirit of our platform and our desire to host an open and honest marketplace. Use of such tools hampers the functionalities of the Turbo Boutique Platform.
Identity Verification. We may collect personal information, such as your date of birth, taxpayer identification number, and address, to validate your identity or conduct background checks (“Identity Information”).
Financial Information. To help Flight Attendants set up a payment account and help Clients make payments to Flight Attendants and pay fees, we may collect financial information, including name, address, credit card number, bank routing numbers, tax information, and any other payment information (“Financial Information”).
Location Information. When you visit the Turbo Boutique Platform via a mobile application, we use GPS technology (or other similar technology) to determine your current location in order to determine the city you are located in and display a location map to improve service for our Users. We will not share your current location obtained in this manner with other Users. If you do not want us to use your location for the purposes set forth above, you should turn off the location services for the mobile application located in your account settings or in your mobile phone settings and/or within the mobile application.
Third Party Information. If you registered through a co-branded version of our Turbo Boutique Platform through one of our Partners (as defined below), they may provide us with basic information such as your name, address, and purchase history related to your flight needs. Additionally, we may receive additional information about you, such as demographic data, payment information, or fraud detection information, from third party Agents (as defined below) and combine it with other information that we have about you. Finally, Turbo Boutique works with third party Agents to perform identity checks and criminal background checks on Flight Attendants, and we receive information from them such as publicly available information about your criminal history.
Public Areas. Your profile on the Turbo Boutique Platform consists of information about you, and may include personal information, photographs, work history, skills, daily pay rates, feedback/rating information, and other information, including your username (“Profile”). The information in your Profile may be visible to all Users and the general public subject to the privacy choices you make within your Profile. If you choose to post a Listing via the Turbo Boutique Platform, the contents of such listing will be publicly viewable.
5. Turbo Boutique’s Use of Personal Information
Turbo Boutique uses Personal Information (including Identity Information and Financial Information) for the following purposes:
- To operate and make available the Turbo Boutique Platform. We use your data to connect you with other Users in order to enable the posting of, completion of, and payment for Bookings;
- For billing and fraud prevention, on the basis of our legitimate interests in ensuring a safe and secure environment in which Clients and Flight Attendants can meet and conduct business;
- To conduct identification, authentication, and background checks on Users, in order to advance our legitimate interests in ensuring the safety of our Users;
- To analyze Site usage as necessary for our legitimate interest in improving the Turbo Boutique Platform to grow our business;
- To contact you and deliver (via email, SMS, push notifications, or otherwise) administrative notices, marketing notifications, offers and communications relevant to your use of the Turbo Boutique Platform as necessary for our legitimate interests in proper communication and engagement with our Users and in promoting our business;
- To provide you with customer support in order to fulfill our contracts with Users;
- For internal market research, troubleshooting problems, and detecting and protecting against error, fraud or other criminal activity for our legitimate interests in ensuring a safe and secure environment in which Users can meet;
- To assist Users in the resolution of complaints and disputes between them, as necessary for our legitimate interests in facilitating good relations among Users;
- To enforce our Terms of Service in our legitimate interests in ensuring our rights are complied with; and,
Analytics and Market Research. Turbo Boutique may analyze your information and web navigational data based on your interests, and may use the analysis from this information in a way that doesn’t reveal a name, email address or other “real-world” identity (“Market Analysis”) in order to market the Turbo Boutique Platform, improve the likelihood of a sale to a group of potential Users, and increase the likelihood that a group’s experience with the Turbo Boutique Platform is relevant to its interests as a whole, as necessary for our legitimate interests in providing an engaging and relevant experience, promoting our services, and growing our business.
Turbo Boutique uses information to sell services to Users who express an interest in these services, through a poll for example, or to Users who can be presumed to have an interest based on results from our Market Analysis. We do this as necessary for our legitimate interests in providing an engaging and relevant experience, promoting our services, and growing our business.
Cell Phone Numbers. Turbo Boutique may use your cell phone number to call or send recurring text messages to you, using an autodialer or prerecorded voice, in order to provide you notifications about Bookings, for marketing purposes (with your consent where required by law), and to administer the Turbo Boutique Platform. If you would like more information about our policy, or to opt out, please review below or Section 8 of our Terms of Service, or contact [email protected]. You may be liable for standard SMS and per-minute charges by your mobile carrier. Turbo Boutique may also message you via “Push” messaging, which you can opt-out of on your mobile device. Data rates may apply.
Financial Information. We use Financial Information solely as authorized by you in order to operate the Turbo Boutique Platform and, in particular, to ensure that Flight Attendants are paid by Clients. We do this as necessary for our legitimate interests in providing our platform and services. To keep your financial data secure, we do not store full credit card information on our servers. We have contracted with a third party to process your payment card information.
6. With Whom Does Turbo Boutique Share Information?
Third Party Agents. To operate the Turbo Boutique Platform, including processing your transactions, we may share your information with our agents, representatives, contractors and service providers (“Agents”) so they can provide us with support services as follows:
- Email origination,
- Identity/background check requirements in relation to Flight Attendants (currently carried out by our providers BeenVerified and Checkmate);
- Fraud detection (currently carried out by our providers BeenVerified and Checkmate);
- Receipt or support services,
- Customer relationship management services,
- To otherwise help us provide the Turbo Boutique Platform, including all of the things described in the preceding section.
Other Users. Turbo Boutique facilitates contact between Clients and Flight Attendants and reserves the right to share a Flight Attendant’s contact information (e.g. phone number, or email and postal address) with a Client and vice versa, or with their legal or other representative, in order to facilitate the resolution of a dispute related to or arising from an interaction between two or more Users of the platform. This exchange of information is a mandatory part of the Turbo Boutique’s Platform.
Legal Obligations Turbo Boutique may disclose personal information or User Generated Content, including location data or communication data, to a third party if required to do so by law or pursuant to a court order, warrant or subpoena. Turbo Boutique reserves the right to disclose personal information from both private and public areas of the Site and the Turbo Boutique Platform in the absence of a court order warrant or subpoena if we are given reason to believe, in our sole discretion, that someone is causing injury to or interfering with the rights of Users, the general public, or Turbo Boutique or its partners, parents or affiliates.
It is our policy to provide notice to Users before producing their information in response to law enforcement requests unless (i) we are prohibited by law or court order from doing so, (ii) we have reason to believe the User’s account has been compromised such that the notice would go to the wrong person, or notice would otherwise be counterproductive or would create a risk to safety, or (iii) it is an emergency request and prior notice would be impractical (in which case we may provide notice after the fact).
You may opt-out of receiving communications from us and our partners, remove your information from our database, choose to not receive future communications related to the Turbo Boutique Platform, or cancel your account by logging on to the Site and clicking on the “Dashboard” tab, or by contacting us at [email protected].
During registration you choose whether to receive marketing correspondence from either Tubro Boutique or its partners and whether you want to participate in a variety of Turbo Boutique programs. This information remains on your Profile where you can, at any point, easily edit it to indicate that you have changed your mind. We may occasionally contact you with information about special events, sales, activities, promotions, contests, submission opportunities and programs. You always have the option to ask Turbo Boutique not to contact you with this information again.
You can opt out of receiving promotional communications from Turbo Boutique sent via text message at any time by following the instructions provided in those messages to text the word, “STOP”. Please note that your opt-out is limited to the phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt-out of receiving promotional communications, Turbo Boutique may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or Turbo Boutique’s ongoing business relations.
If you receive unsolicited email from a Turbo Boutique domain, please contact us at [email protected].
8. Turbo Boutique’s Information Retention Policy
We retain personal data for as long as you are a User in order to meet our contractual obligations to you, and for such longer period as may be in our legitimate interests and to comply with our legal obligations. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.
You have the right under certain circumstances:
- to be provided with a copy of your personal information held by us;
- to request the rectification or erasure of your personal information held by us;
- to request that we restrict the processing of your personal information (while we verify or investigate your concerns with this information, for example);
- to object to the further processing of your personal information, including the right to object to marketing as mentioned in the Choice/Opt-Out section above; and
- to request that your provided personal data be provided to you in a structured, commonly used and machine-readable format.
Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time. You can also change your marketing preferences at any time as described in the Choice/ Opt-Out section above.
You can exercise your rights by clicking on the “Dashboard” tab, then selecting “Notifications” to make your selections, or by contacting us at [email protected].
If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html ). The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.
9. User Generated Content
Flight Attendants who have provided Turbo Boutique with any videotape, film, record, photograph, voice, or all related instrumental, musical, or other sound effects, hereby consent to our use of these materials as User Generated Content in accordance with Section 9 of the Terms of Service.
10. Turbo Boutique’s Security of Collected Information
Your Turbo Boutique account is password-protected so that only you and authorized Turbo Boutique staff have access to your account information. In order to maintain this protection, do not give your password to anyone. Also, if you share a computer, you should sign out of your Turbo Boutique account and close the browser window before someone else logs on. This will help protect your information entered on public terminals from disclosure to third parties.
Turbo Boutique expressly disclaims any liability that may arise should any other individuals obtain the information you submit to the Turbo Boutique Platform.
11. How Can Users Update Their Information?
You can update your Personal Information at any time by logging in and clicking on the “Dashboard” tab. There you can view, update and correct your account information.
So that we can protect the integrity of sensitive data, there are certain pieces of information, such as your age, that you cannot alter yourself. For example, since children under 18 (UK) or 21 (US) are not allowed to register as Users, we need to take reasonable measures to preserve the accuracy of our Users’ ages.
Our databases automatically update any Personal Information you edit in your profile. Information transmitted through boards, chats, polls or through any other means remains in our databases and becomes the property of Turbo Boutique upon submission.
12. Notification of Changes
13. Children’s Privacy and Note to Parents and Guardians
We do not knowingly collect personal information from children under 13 years of age. The Turbo Boutique Platform is not directed to children under the age of 13 and children under 13 are not permitted to use the Turbo Boutique Platform. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will delete or disable such information. If you are a parent or guardian of a child under the age of 13, and you believe that your child has provided us with personal information, please let us know at [email protected].
14. Your California Privacy Rights
California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide California customers certain information upon request, or permit California customers to opt in to, or opt out of, this type of sharing.
Turbo Boutique may share personal information as defined by California’s “Shine the Light” law with third parties or affiliates for such third parties’ or affiliates’ own direct marketing purposes. California residents may obtain information about our compliance with this law by sending us a written request at [email protected]. Requests 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 Turbo Boutique is not required to respond to requests made by means other than through the provided email address or mail address.
15. Contacting Us?
Turbo Boutique’s staff will respond to all requests sent through mail or email from Users and parents of Users with questions about privacy or the types of personal information is stored on the Turbo Boutique’s database, or requests to nullify such personal information.