Privacy Policy - USA

Sky Pay Group, Inc. trading as Pay Later Travel (“Pay Later,” “we,” “us”) offers travelers a “lay-by” system to book air travel at the current fare and pay in full before the travel date in interest-free instalments (“Services”). You can learn about our Services at our website: https://www.paylatertravel.com/ (“Website”).

This Privacy Notice describes how we collect, use, and manage personal data from and about individuals (“you” or “your”) when:

• You visit our Website
• You use our Services or communicate with us in other ways
• We receive your information from our business partners, company affiliated websites, or other third parties.
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Please review this Privacy Notice carefully. By using our Services or visiting our Website, you are giving your consent to the collection, use, disclosure, and retention of your personal data as described in this Privacy Notice. Please contact us if you have difficulties accessing our Privacy Notice. If you do not agree with the terms in this Privacy Notice, please do not use our Services or Website and do not provide your personal data to us.

We may update this Privacy Notice from time to time to take into account changesin our practices for the handling of personal data. We do so by posting an amended Privacy Notice on our Website and you should regularly review the most recent version. Your continued use of our Services or Website or other communications with us following the posting of any changes constitutes your acceptance of our Privacy Notice as revised.

If you are a Texas resident, please see “Texas Residents: Your Texas Privacy Rights.

”If you are a California resident, please see “California Residents: Your California Privacy Rights.”
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1. Personal Data. We use the term “personal data” in this Privacy Notice to refer to information that identifies, describes, or is reasonably capable of being associated or linked, directly or indirectly, to an identifiable individual. Personal information also includes any information that can be used on its own or combined with other information to identify, contact, or profile an individual.
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2. Data Collection. We collect information from you, including personal data, when you:
   • Visit our Website
   • Set up an account on our Website
   • Use the chat or other features on our Website
   • Use our Services
   • Communicate with us in other ways including by telephone, e-mail ortext/SMS messages (with prior consent where required).
     
     We may also receive your personal data from our business partners including digital advertising networks, social media networks, or other third parties.
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3. Personal Data You Provide. The types of personal data we collect depends on how you use our Services and may include the following:
   
   • Name
   • Telephone number
   • Email address
   • Street address
   • Username and password for your account
   • Air travel destination, travel dates, and other booking information
   • Passport information and other travel documents (if applicable)
   • History of your transactions and communications with Pay Later and other websites we operate
   • Transportation Safety Administration (TSA) number
   • Airline loyalty program membership number
   • Responses to customer surveys
   • Testimonials about our Services
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4. Payment Information. When you book a flight using our Website and select a payment plan, you will be directed to the website of an authorized payment processor such as Stripe or PayPal to provide your payment information. The payment processor will collect your card information to process your transaction and installment payments on our behalf. We do not process card transactions or store full payment card numbers. The payment processor’s separate privacy policy will control how your personal data is handled by the payment processor. Payment processors are required to use secure encryption in processing the transaction and are not permitted to use our customer’s personal information for their own commercial purposes. The payment processor may provide some transaction and limited card information to us, but not your card or account details.
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5. Information from Third-Party Sources. We may receive certain personal data from third-party sources such as:
   
   • Transaction information from our payment processors
   • Website usage and internet tracking data from data analytics providers and advertising networks
   • Transaction and website usage data from other websites operated by our company or affiliated companies
   • Social media information if you associate a social media account with your PayLater account
   • Demographic information (such as age, gender, income, employment) from commercial marketing sources and publicly available databases.
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6. Sensitive Personal Information. Due to the nature of our business, we may collect travel documents, including passports, that contain sensitive personal information. This sensitive personal information is only shared with third parties when required by law or necessary to process your transaction. We do not sell, rent, loan, trade, lease, or otherwise transfer sensitive information for profit to any third party.
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7. Online Data Collection. We use first-party and third-party cookies, pixels, beacons, and other internet tracking technologies (collectively referred to as“cookies”) to enable some Website functions to operate, to collect data about how visitors use our Website, and to track user interactions with our ads and posts on other websites and social media platforms. For more information about the data we collect using cookies, see the section titled “How We Use Cookies and How You Can Restrict Cookies and Targeted Advertising.” The data collected by us or third parties through the cookies on our Website may include the following:
   
   • Browsing time, duration, pages viewed, buttons clicked, the date, time, and contents of searches performed, and functions used during your visits to the Website and your account
   • IP address or mobile device identifier, which provide general location information
   • Randomly generated ID number
   • Device type, browser type, and operating system
   • Browsing and search history, internet location from which you navigated to our Website, and the location you went to when leaving our Website
   • Shopping cart activity including when you begin, complete, or abandon a Service transaction
   • Transaction activity including making a payment on the Website and the payment method used
   • Interactions with our advertisements placed on other websites and social media platforms
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8. Information Not Covered by this Privacy Notice. This Privacy Notice does not cover information that is:
   
   • Publicly available
   • Anonymized, aggregated, or de-identified so that cannot be used for identification purposes
   • Collected by third parties on platforms, features, or websites you reach by navigating from links on our Website
   • Information about our current and former employees, job applicants, or collected only for business-to-business purposes.
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Subject to the terms of this Privacy Notice, Pay Later may collect and use personaldata for the following purposes.

• Establish and maintain your Pay Later account and our customer relationship with you
• Identify you when you log into your Pay Later account
• Administer your account and process your bookings including sending you booking confirmations, changes in bookings, availability of Services, and force majeure circumstances
• Respond to your requests, questions, feedback, and complaints, whether directly or through our outsourced customer service agents
• Process payments for Services including payment card verification/screening; and payment information for accounting, billing and audit purposes and detector prevent any fraudulent activities
• Maintain a history of your transactions with us
• Inform you about additional Services that may be of interest to you, including information about our business partners’ products and services related to your travel plans, unless you have opted out of receiving marketing emails or not subscribed to receive text messages from us
• Display online advertising and marketing on social media and other websites, including targeted advertising as described in “How We Use Cookies and How You Can Restrict Cookies and Targeted Advertising”
• Perform statistical analysis and user profiling for marketing and Website improvement purposes based on characteristics, interests and preferences of users of our Website and Services and other websites and services we operate. However, we do not conduct automated decision-making based on user profiles and will obtain your express consent before using your personal data for any decision-making that has a legal or other significant effect
• Obtain and publish your customer testimonials, comments, and/or reviews (either without identifying you or identifying you with your consent) including through a posting feature available on the Website and/or third-party platforms such as Trustpilot
• Track and measure usage of our Website to maintain and improve performance
• Track and measure user interactions with our text and e-mail messages
• Detect and address technical issues with our Services and Website
• Detect and prevent potential fraud or misuse of our Services and Website
• Comply with legal requirements including U.S. Federal Aviation Administration (FAA) regulations.
• For other purposes that are consistent with and reasonably expected based on the purposes listed above
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1. We do not sell personal data: We do not sell, lease, or transfer personal data for monetary consideration.
2. Data shared for Website analytics. We and third-party website analytics partners may use cookies, pixels, web beacons, tags and other tracking technologies (together referred to as “cookies”) to compile data about visits to our Website and other websites we operate and analyze how visitors and customers use these sites. Our analytics partners may include Google, Amplitude, Microsoft, and other analytics services.
3. Data shared for targeted advertising. We may authorize advertising partners, including Google, Tik Tok, Bing, Meta (Facebook) and others, to use cookies on our Website to collect data about how users interact with our Website and other websites and to measure the effectiveness of online advertising. For more information, see “How We Use Cookies and How You Can Restrict Cookies and Targeted Advertising.” The data shared for targeted advertising data helps us to:
   
   • Develop demographic information about our users
   • Deliver targeted advertising based on a profile of our users’ internet activity
   • Assess the effectiveness of our marketing programs.
   • Send shopping cart reminder messages.
4. Disclosure of personal data for operating purposes. The operation of our Services and Website involves sharing or allowing third parties to collect or have access to certain personal data consistent with the purposes for which the information was collected as described in this Privacy Notice or with your express consent. Depending on your interactions with us, these third parties may include:
   
   • Airlines to process your bookings and change requests
   • Payment processors to facilitate your payments for our Services and provide anti-fraud screening and payment transaction security
   • Third parties to operate certain functions and features on our Website such as airline booking services and Intercom, which provides our messaging and chat feature
   • Service providers that assist with business functions such as handling customer service calls and Website services and providing IT support services such as hosted applications, data storage, e-mail marketing, text message marketing, debt collection, and professional services such as accounting and legal services
   • Internet data analytics providers that use cookies and other technologies to provide statistical reports and help us analyze usage of our Website and user demographics
   • Government and law enforcement authorities to comply with applicable laws, regulations, legal process, and governmental requests
   • Investigators and others when reasonably necessary to protect the security or integrity of our Services, Website, or customers
   • Transaction parties, in connection with a corporate transaction, such as anacquisition, merger, or reorganization
   • For any other purpose with your consent
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1. Cookies. We use data automatically collected on the Website through cookies and similar technologies to: (i) personalize our Services, such as remembering your information so that you will not have to re-enter it during a visit or on subsequent visits; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of our Services and marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and other activities. You can obtain more information about cookies by visiting https://allaboutcookies.org/.
2. Targeted advertising cookies. Pay Later or our authorized advertising partners (such as Meta, Google, and Microsoft) may place cookies on your device or browser and use the data they collect to build a profile of your preferences and interests based on your internet activities they track over time and across many different websites and platforms you visit. The data collected by advertising networks also may be linked across the different devices you use. They use this information to direct advertisements to you and other users with a similar profile of online interests and characteristics and to help us assess whether our online advertising campaigns are successful. This type of personalized, profile-based advertising is commonly referred to as “targeted advertising.” Although targeted advertising cookies do not store directly identifying personal information, such as your name, e-mail address or phone number, they store data to identify your unique browser or device.
3. Restricting cookies. You can limit some of the ways cookies are used on our Website. Please note that restricting the cookies stored on your browser ordevice does not mean you will no longer see online advertisements. It means the ads that you do see will not be based on a profile of your interests. Most browsers have an option for limiting or restricting cookies, which will prevent your browser from either accepting new cookies or allow you to decide whether to accept certain cookies. You can also delete cookies that are already on your browser or device. If you do this, however, it may impact the overall functionality of some features of our Website and Services.
4. Restricting cookies through browser settings. Information for cookie controls provided by some commonly used browsers is available at the links below. PayLater is not responsible for the effectiveness of any third parties’ cookie blocking or opt-out programs or the accuracy of their statements regarding their programs.
   
   • Safari:
     On desktop at: https://support.apple.com/guide/safari/manage-cookiessfri11471/mac and Safari Mobile (iPhone and iPads) at https://support.apple.com/en-us/HT201265: Note that, by default, Safari is engineered to protect you from being tracked from site to site unless youdisable Intelligent Tracking Prevention (ITP).
   • Firefox:
     By default, Firefox protects you from cross-site tracking so long as you have not disabled Enhanced Tracking Protection (ETP).
     See https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox?redirectlocale=en-US&redirectslug=delete-cookies-remove-info-websites-stored.
   • Chrome:
     https://support.google.com/chrome/answer/95647?hl=en#zippy=%2Cdelete-cookies-from-a-site
   • Microsoft Edge:
     https://support.microsoft.com/en-us/windows/microsoft-edge-browsing-dataand-privacy-bb8174ba-9d73-dcf2-9b4a-c582b4e640dd.
     Edge is intended to protect you from being tracked between websites.
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1. Text messages and marketing. When you create an account or make a purchase using our Services, we will ask for your express consent at check out to send you text notifications about your order, cart reminder messages, payment reminders, and marketing offers. You can unsubscribe from further text messages by replying “STOP” to any text message you receive from us. Message and data rates may apply.
2. Transmission of text messages. We will only use information you provide through the Website to transmit the text messages and respond to you, if necessary. In transmitting text messages, some of your information will be accessible to platform providers, phone companies, and other vendors who assist us in the delivery of text messages.
3. E-mail messages and marketing. By entering your email address to create an account or at checkout, you agree that we may send you email notifications and marketing messages. You can opt-out of receiving e-mail marketing communications from us by following the “unsubscribe” instructions included in each of our e-mail marketing messages. You can also opt-out by emailing us at the address provided under “Contact Us” below. and providing the names/email address that you want us to remove from our marketing database and add to our ‘Do Not Contact’ list. It may take up to ten days to process your request to unsubscribe from e-mail marketing messages. If you opt-out of marketing messages, we may still send e-mails to you that involve your account or responses to your questions.
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1. Security measures. We maintain commercially reasonable security procedures and practices appropriate to the nature of the categories and specific types of personal data we collect. However, neither people nor systems can operate in a fully secure manner and no method of transmission over the Internet or method of electronic data storage is fully secure. While we use reasonable efforts to protect your personal data and select third-party service and feature providers we believe also use reasonable precautions, we cannot guarantee the security of the personal data you provide to us.
2. Your password. When you open a Pay Later account, you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else who has obtained your password directly or indirectly through you, even if that person was not authorized by you. You should notify us of any unauthorized use of your password or account, and, if any unauthorized use is suspected, you should immediately reset yourpassword.
3. When to notify us. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account with us has been compromised), please immediately notify us of the problem.
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1. Retention Period. We will retain your personal data as long as your account is active and to comply with our legal obligations, implement our document retention program, resolve disputes, enforce our agreements, and for marketing purposes. When we no longer have a business or legal reason to keep your personal information, we will delete, destroy, or de-identify (anonymize) the information.
2. Determining Retention Period. In determining retention periods, we take into consideration any contractual obligations, applicable laws, and business considerations we reasonably believe are compatible with your expectations and the purposes for which we collected your personal data.
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1. Third-Party Sites. Our Website may contain links to features, social media, or websites that are owned and operated by third parties. We provide these links for your convenience. Data collection and interactions on any third-party website or service are subject to the third party’s privacy practices and policies, not ours. We have no control over and assume no responsibility for the content, accuracy, or privacy practices of any third-party websites or services. For information about how these third-party services collect and manage personal data, please refer to their privacy policies.
2. Third-party Features. Our Website may use other companies’ applications to power some features. These third-party features may be branded with the PayLater logo, even though they are not operated or controlled by us. For example, the message feature on our Website is operated by Intercom. Their privacy terms are linked in the feature and can be found here: https://www.intercom.com/legal/privacy. We also use a third-party payment processor when you make a payment online using your Pay Later account. These third parties can access your personal data when you use the features they provide on our Website
3. Social Media. You may choose to interact with our Website through your social media account (LinkedIn, X, Facebook, YouTube) by clicking on the social media icon on the Website, following us on a social media network, or posting a comment to one of our pages. The social media network may send us the data you make available to third parties through the settings on your social media account. This data may include your profile, gender, username, user ID associated with your social media account, age range, language, and other data you permit the social network to share with third parties. We use this data to enable you to use interactive functionalities between our Website and the social media network and allow us to send messages to your social media account about Pay Later.
4. Links to Third-Party Websites. Our Website may include links to websites operated by third parties that have content we think may be of interest to you. If you click on a third-party link, you will be directed away from our Website to that third-party website and any personal data you provide to that third party website will be available to the third-party operator. The third-party website operator may also collect your IP address or device identifier and other internet browsing data and may set a cookie to enable their features to function and track your usage of their website.
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It is important that the personal data we have about you is accurate and current. You are responsible for informing Pay Later of changes to such data. You can update or correct your contact and billing information using your Pay Later online account or by contacting us as explained in “Contact Us.” We will take steps to modify your information promptly in our records.

1. Must be 18 to Use Services. Our Services are available only to persons who can form legally binding contracts under applicable law. Without limiting the foregoing, the Services are not available to individuals under the age of eighteen (18). By using the Services, you represent that you are over the age of 18.
2. Under Age 13. The Website is not directed toward children under the age of thirteen (13) years. We do not knowingly collect personal data about children under the age of 13 without verifiable consent from a parent or legal guardian. If you have reason to believe that a child under the age of 13 has provided personal data to us through the Website or Services, please contact us. See “Contact Us” below.
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1. Changes to this Privacy Notice. We reserve the right to modify this Privacy Notice at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Notice, we will notify you by updating the date of this Privacy Notice and posting it on our Website and in app stores where the mobile application for Services covered by this Privacy Notice are available for download. We may (and, where required by law, will) also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email (if you have an account where we have your contact information) or another manner through our Website or third-party mobile application Services.
2. Effectiveness of Changes. Any modifications to this Privacy Notice will be effective when we post the revised terms on the Website and/or upon implementation of the new changes (or as otherwise indicated at the time of posting). In all cases, your continued use of the Website and Services after the posting of any modified Privacy Notice indicates your acceptance of the terms of the modified Privacy Notice.
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1. This section of our Privacy Notice provides additional information for residents of Texas about their rights under the Texas Data Privacy and Security Act of 2024 (“TDPSA”), as amended from time to time. This section applies only to personal information collected by Pay Later and explains how Texas residents can submit requests to exercise their rights (“Consumer Requests”).
2. Opt-Out of Targeted Advertising. Texas residents may opt out of having their information used to provide targeted advertising. For more information about targeted advertising, read the section titled “How We Use Cookies and How You Can Restrict Cookies and Targeted Advertising,” and “Third-Party Features, Social Media, and Links.”
3. Opt-Out of Profiling. Texas residents have the right to opt out of the processing of the personal data for the purpose of profiling in furtherance of a decision that produces a legal or similarly significant effect. The term“profiling” refers to automated decision-making that is based on using your personal information to analyze or predict your economic situation, health, personal preferences, and other behaviors. Sky Pay Group does not currently use profiling to make decisions. If a situation arises in which Sky Pay Group expects to use profiling in a way that would have a legal or other significant effect, we will provide an opportunity for you to opt-out in advance.
4. Request to access information. Texas residents may request Sky Pay Group to confirm if Sky Pay Group is collecting their information. Texas residents also have a right to access the collected information.
5. Request to correct inaccuracies. Texas residents may also request a correction of inaccuracies in the personal information we collect.
6. Request to delete information. Texas residents may request that information collected by or for Sky Pay Group be deleted.
7. Consent to use or disclosure of sensitive personal information: We will only use your Sensitive Information for the purpose disclosed to you at the time we asked you to provide it.
8. Request for Portable Data. Texas residents have the right to request, if technically feasible, to have their data transferred to a portable, readily usable format so that you may transmit the data to someone else.
9. Designate an Authorized Agent. Texas residents can use a global setting approved by the Texas Attorney General (such as the Global Privacy Control), an Internet browser setting, or other authorized agent or process to exercise a right to opt-out or submit a personal information request. Sky Pay Group may require the agent to provide verification of their authority.
10. Exercising your TDPSA Rights. You can submit a request to exercise your rights under TDPSA by using any of the following methods:
    
    • Online privacy request form: Click Here
    • US mail:
      Sky Pay Group, inc. trading as Pay Later Travel
      Attention: E-mail: support@paylatertravel.com
      Toll-free phone: +1 (888) 974 0329
11. How We Respond to Texas Consumer Requests. We are legally required to verify your identity before we can fulfill your or your authorized agent’s request. We reserve the right to decline to consider repeated requests from a consumer in accordance with TDPSA.
    We will confirm receipt of your Consumer Request within ten (10) business days and may request additional information necessary to verify your identity and that you are authorized to make the request. We will respond to any verifiable Consumer Request within forty-five (45) calendar days of receiving it, subject to delays and exclusions as permitted by law. If we require more time to respond, we will let you know the reason and the extension period in writing. If you have an account with us, we may respond via that account. Otherwise, we will use the email address or U.S. Postal address you provided to us when making the request.
    If we cannot comply with all or part of your request, we will explain the reasons why. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information readily from one entity to another entity.
    We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We will not discriminate against you if you make a request to exercise your TDPSA rights
12. Right to Appeal. If we deny your request, you may appeal the decision by contacting us as described in the section “Exercising your TDPSA Rights.” We will review your request and will respond to your request within 60 days from the day we receive the request for appeal, explaining the reason for the decision on appeal. If your request is denied on appeal, you have the right to contact the Texas Attorney General’s Office as explained at its website: www.texasattorneygeneral.gov.
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1. Under the California “Shine the Light Law,” California residents may request a list of the types of customer information, if any, provided to third parties for their direct marketing purposes and the names and addresses of all third parties with which we have shared such information during the past calendar year. We will provide the information to you free of charge within thirty (30)days of your request.
2. To make a “Shine the Light” request, California residents may send a written request to support@paylatertravel.com. We will respond within thirty (30) days of receiving your request to the address you designated in your request, which may be an email address or street address.
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1. If you have questions about your privacy or wish to discuss this Privacy Notice, please contact us at:
   E-mail: support@paylatertravel.com
   Phone: +1 (888) 974 0329
2. We will endeavour to respond to all privacy queries, corrections and complaints promptly. Sometimes this may mean we will need to assess and investigate your request and confirm the identity of the person making the request.