1. INFORMATION WE COLLECT

We collect information from and about you in order to operate our business, provide and improve our products and services, communicate with you, respond to your inquiries, fulfill your requests, and conduct marketing and promotional activities. The information we collect may include “Personal Information” or “Personal Data,” as those terms are defined under applicable laws.

For purposes of this Privacy Policy, Personal Information generally includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Where required by applicable law, we also treat certain technical identifiers, such as Internet Protocol (IP) addresses, device identifiers, and cookie identifiers, as Personal Information.

The categories of Personal Information we collect may vary depending on how you interact with the Channels, the Pan Am entity involved, and the nature of the products or services requested.

Information You Provide to Us

We may collect Personal Information that you voluntarily provide to us through the Channels or through offline interactions, including when you:

• Sign up to receive newsletters, marketing communications, or other updates through any Pan Am Channel
• Submit inquiries, request information, or otherwise communicate with us through online forms, email, telephone, or in person
• Participate in surveys, promotions, special events, or similar offerings
• Submit content or materials to us, including through community or feedback channels (e.g., submissions to community@panam.com)
• Engage with concierge services, consultations, or advisory services offered by certain Pan Am entities
• Provide information in connection with travel planning or experience-related services, where applicable

Depending on the interaction, the Personal Information you provide may include, without limitation:

• Identifiers and Contact Information, such as name, postal address, email address, telephone number, and other contact details
• Demographic Information, such as date of birth, age range, gender, or similar characteristics, where voluntarily provided
• Communications and Correspondence, including the content of emails, inquiries, feedback, or other communications you submit to us
• User-Generated Content, such as photographs, videos, testimonials, reviews, or other materials you voluntarily submit or authorize us to use

Any such collection will be addressed in applicable supplemental privacy notices or addenda, which may be accessed through the Table of Contents by selecting the relevant link or by using the link provided below.

Information That Is Collected Automatically

When you visit or interact with our Channels, we may automatically collect certain information about your device and usage of the Channels (“Device and Interaction Information”), subject to your cookie and tracking preferences.

This information may include, without limitation:

• Internet Protocol (IP) address
• Browser type and version
• Device identifiers and operating system
• Referring URLs and pages viewed
• Date and time of access
• General or approximate location information derived from IP address
• Interaction data, such as pages visited, links clicked, and navigation patterns

We use this information to operate and secure the Channels, analyze performance, understand usage trends, and improve our services.

Automatic collection may occur through cookies, pixels, scripts, analytics tools, or similar technologies, as further described in the “Service Providers That May Use Cookies or Process Personal Information,” section below.

Cookies and Similar Technologies

We use ConsentPro (https://consentpro.com/) to manage cookie consent preferences and ensure compliance with applicable data protection laws.

ConsentPro provides the following functionality:

• Automatic detection and blocking of scripts and tracking technologies prior to user consent
• Categorization of tracking technologies by provider and purpose
• Region-specific consent experiences based on geolocation
• Automated storage of consent records and proof of consent
• Technical enforcement of user consent choices

Scripts, cookies, and tracking technologies that are not classified as strictly necessary are automatically blocked until consent is provided.

Users may access or update their cookie preferences at any time by clicking the cookie symbol located in the lower-left corner of the screen or by selecting the “Cookie Preferences” link available in the footer of the applicable Channel.

Consent preferences are stored and maintained in accordance with applicable legal requirements.To learn more about what information of yours we collect and why, please see our “Cookies, Analytics, and Tracking Technologies” section below.

Information Collected Offline

We may collect Personal Information through offline interactions, including but not limited to:

• Trade shows, conferences, and events (e.g., business cards, badge scans, sign-up sheets)
• In-person meetings, consultations, or concierge services
• Telephone calls and email communications
• Paper forms, surveys, or written correspondence
• Physical mailings and responses thereto

Information collected offline may be combined with information collected through the Channels, to the extent permitted by applicable law.

Information Collected from Third Parties

The Company may receive Personal Information from third parties in connection with business, marketing, or operational activities, including:

• Business partners and collaborators, where information is shared in connection with joint offerings, inquiries, or referrals
• Service providers, acting on our behalf and subject to contractual restrictions
• Third-party platforms, such as social media or professional networking platforms, where you interact with us or our content
• Data providers or business intelligence services, used in connection with permitted marketing, outreach, or business development activities
  
  

Information received from third parties is processed in accordance with this Privacy Policy and applicable law.

Pixel Tags 

We use 'pixel tags' (small graphic images also called web beacons or clear gifs) or similar technologies to track information in the aggregate about your use of the Sites like the web pages you view, the links you click, and the time you spend on a page. We use this information to monitor the effectiveness of our advertising and marketing campaigns so we can learn how to best deliver your customer experience. We also use pixels to track our email campaigns to determine whether recipients opened the email and what links they clicked on from the email.

Embedded Scripts

An embedded script is programming code that is designed to collect information about your interactions with the Sites, such as the links you click on. The code is temporarily downloaded onto your device from our server or a third-party service provider, is active only while you are connected to a Site and is deactivated or deleted thereafter.

Relationship to Cookie Preferences

Certain third-party tools described above rely on cookies or similar technologies. You may manage your preferences for such technologies through our Cookie Preference Center at any time by clicking the cookie symbol located in the lower-left corner of the screen or by selecting the “Cookie Preferences” link available in the footer of the applicable Channel.

Sensitive Personal Information

Certain Pan Am entities may collect Sensitive Personal Information where necessary to provide services requested by you or to comply with legal or regulatory obligations. This may include, where applicable, information such as passport details, known traveler numbers, dates of birth, dietary needs, accessibility requirements, or similar information required to facilitate services.

Sensitive Personal Information is processed solely for permissible business purposes, is subject to heightened safeguards, and is not used for purposes beyond those authorized by applicable law.

Where applicable, such additional collection and related tools or technologies will be described in that entity’s Supplemental Privacy Notice, which is identified in the “{Entity-Specific} Supplemental Privacy Notice” page on the specific entity’s site and by clicking the link available in the site’s footer.

Payment Information

Where applicable, payments may be processed through third-party payment processors. The Company does not store full payment card numbers and does not retain payment information beyond tokenized confirmations or records necessary to document a transaction.

Additional information regarding entity specific payment processing may be provided in applicable supplemental notice(s).

Combination of Information

We may combine information we collect from you directly, information collected automatically, and information received from third parties, to the extent permitted by applicable law, for the purposes described in this Privacy Policy.

2. HOW WE USE YOUR INFORMATION

We may use Personal Information we collect from and about you for a variety of business and commercial purposes, consistent with this Privacy Policy and as permitted by applicable law. The purposes for which we use Personal Information depend on how you interact with the Channels, the Pan Am entity involved, and the nature of the products or services requested.

Without limitation, we may use Personal Information for the following purposes:

Provision of Services and Business Operations

• To operate, maintain, and administer the Channels and related services
  
• To respond to inquiries, requests for information, or communications submitted by you
  
• To provide concierge, advisory, consulting, or experience-related services, where applicable
  
• To facilitate travel-related or experience-related services, where permitted and subject to any applicable supplemental privacy notices
  
• To manage business relationships, including communications with customers, partners, vendors, and prospective partners
  

Communications

• To communicate with you regarding your inquiries, requests, or interactions with the Company
  
• To send administrative, transactional, or service-related communications, including confirmations, notices, and updates
  
• To provide customer service and respond to feedback, comments, or requests for support
  

Marketing and Promotional Activities

• To send marketing, promotional, or informational communications, subject to your preferences and applicable law
  
• To personalize marketing content, where permitted, including based on your interactions with the Channels
  
• To conduct outreach related to Pan Am products, services, experiences, or offerings, including those of affiliated entities, where permitted
  
• To administer promotions, surveys, events, or similar initiatives
  

You may opt out of marketing communications at any time as described in the “Your Privacy Choices and Controls” section below.

Analytics, Research, and Improvement

• To analyze usage of the Channels and understand how users interact with our websites, applications, and services
  
• To evaluate and improve the performance, functionality, and security of the Channels
  
• To conduct internal research, reporting, and business analysis
  
• To develop, test, and improve products, services, and user experiences
  

Security, Fraud Prevention, and Integrity

• To protect the security and integrity of the Channels, systems, and business operations
  
• To detect, investigate, and prevent fraud, unauthorized access, misuse, or other unlawful or prohibited activities
  
• To enforce our Terms of Use, agreements, and policies
  
• To protect the rights, property, or safety of the Company, our users, employees, partners, or others
  

Legal and Regulatory Compliance

• To comply with applicable laws, regulations, and legal obligations
  
• To respond to lawful requests from courts, regulators, law enforcement, or other authorities
  
• To establish, exercise, or defend legal claims
  
• To maintain records required for legal, regulatory, or compliance purposes
  

Business Transfers and Corporate Transactions

• To evaluate or carry out a merger, acquisition, reorganization, restructuring, sale of assets, financing, or other corporate transaction involving the Company or its affiliated entities
  
• To facilitate due diligence and related business activities in connection with such transactions, subject to appropriate safeguards
  

Combination and De-Identification of Information

• To combine information collected from different sources, including information provided directly by you, information collected automatically, and information received from third parties, to the extent permitted by applicable law
  
• To create aggregated, anonymized, or de-identified data that does not reasonably identify you, which may be used for analytics, research, or business purposes
  

Purposes Disclosed at the Time of Collection or With Consent

• For any other purpose disclosed to you at the time your Personal Information is collected
  
• For purposes to which you otherwise consent, where required by applicable law

3. HOW WE SHARE YOUR INFORMATION

We may disclose or otherwise make available Personal Information we collect from and about you to third parties as described below, and as permitted by applicable law. The categories of recipients and the purposes for which Personal Information may be shared depend on the nature of your interaction with the Channels, the Pan Am entity involved, and the services requested.

We do not sell Personal Information for monetary consideration in the traditional sense. However, certain disclosures may be considered a “sale” or “sharing” under applicable privacy laws, such as U.S. state privacy statutes, including where information is disclosed for cross-context behavioral advertising or similar purposes. Where required by law, you may opt out of such disclosures as described in the “Your Privacy Choices and Controls” section below.

Sharing with Affiliated Pan Am Entities

We may share Personal Information with our affiliated entities within the Pan Am brand family for legitimate business purposes, including operational, administrative, analytical, customer service, and marketing purposes.

Such sharing may include, without limitation:

• Coordinating responses to inquiries or requests
  
• Facilitating services across Pan Am entities
  
• Managing customer and partner relationships
  
• Conducting internal reporting and analytics
  
• Sending marketing communications, where permitted by law and subject to your preferences
  

Personal Information that is service-specific or sensitive in nature (such as information provided in connection with travel planning, accessibility needs, or other specialized services) may be subject to additional restrictions and may be accessed only by the Pan Am entity or personnel with a legitimate need to know. Certain information may remain exclusive to a specific Pan Am entity, as further described in applicable supplemental privacy notices or addenda, available as a link in the footer of that entity’s site.

You may opt out of the sharing of your Personal Information with affiliated entities for their own direct marketing purposes, where required by applicable law, as described in the “Your Privacy Choices and Controls” section below.

Service Providers and Vendors

We may share Personal Information with third-party service providers, contractors, and vendors who perform services on our behalf or support our business operations. These may include, without limitation, providers of:

• Customer relationship management and communications platform
  
• Website hosting, publishing, and analytics services
  
• Document storage and delivery services
  
• Customer support and administrative services
  
• Security, fraud prevention, and infrastructure services
  

Service providers are authorized to access or process Personal Information only as necessary to perform services on our behalf and are contractually required to protect the information and to use it solely for the purposes for which it is disclosed.

Third-Party Marketing and Advertising Partners

Where permitted by applicable law and subject to your preferences, we may share certain information with third-party marketing, analytics, or advertising partners to support marketing campaigns, measure effectiveness, or deliver relevant content.

Additionally, we will disclose your information to a third party (or parties) when you direct us to do so or you consent to the sharing, and your information will then be subject to the privacy policy and practices of that third party. For example, you may be presented with an opportunity to receive information or marketing offers from one or more third parties or to use an interactive feature or third-party application.

At present, Pan Am does not actively engage in targeted advertising through third-party advertising platforms. However, we reserve the right to do so in the future, subject to applicable law and your consent or opt-out preferences. Any such activities will be governed by this Privacy Policy and, where required, by additional disclosures made available in the “Additional Tools and Future Technologies” section below.

You may opt out of the sharing or processing of Personal Information for purposes of targeted advertising or similar activities as described in the “Cookies, Analytics, and Tracking Technologies” and “Your Privacy Choices and Controls” sections below.

Data Providers and Business Development Activities

We may share Personal Information with, or receive Personal Information from, third-party data providers or platforms used for business development, verification, or outreach purposes, including contact and company information obtained in a business-to-business context. Such sharing is conducted in accordance with applicable law and subject to appropriate contractual safeguards.

Unaffiliated Third Parties for Direct Marketing.

We may share personal data with unaffiliated third parties for their own direct marketing and other purposes. You may opt out of our sharing personal data we have collected about you with unaffiliated third parties for their direct marketing purposes as described in the "Updating Your Personal Data" section below.

Other Third Parties

As further described in the “How We Use Your Information” section above, we may share your information to protect your safety or the safety of others when we have reason to believe that disclosing the information is necessary to identify, contact or bring legal action against someone who may be causing injury to you, our employees or otherwise injuring or interfering with our rights, property or operations, other customers, or anyone else who could be harmed by such activities; to comply with legal obligations, such as when required by law, or in response to any demand by law enforcement authorities in connection with a criminal investigation, or civil or administrative authorities in connection with a pending civil case or administrative investigation; and to maintain the security of the Channels and services and to resolve or troubleshoot technical issues.

Legal Obligations and Protection of Rights

We may disclose Personal Information to third parties, including law enforcement, regulators, courts, or other authorities, when we believe such disclosure is necessary to:

• Comply with applicable law, regulation, legal process, or governmental request
  
• Enforce our Terms of Use, agreements, or policies
  
• Protect the rights, property, or safety of the Company, our users, employees, partners, or others
  
• Detect, investigate, or prevent fraud, security incidents, or unlawful activities
  

Business Transfers and Corporate Transactions

We reserve the right to disclose or transfer Personal Information in connection with any merger, acquisition, reorganization, restructuring, sale of assets, financing, bankruptcy, or similar corporate transaction involving the Company or its affiliated entities. In such circumstances, Personal Information may be transferred as part of the transaction, subject to appropriate confidentiality and data protection safeguards.

Disclosures at Your Direction or With Your Consent

We may share Personal Information with third parties when you direct us to do so or when you otherwise consent to the disclosure. In such cases, the third party’s use of your information will be governed by its own privacy policy and practices, and we encourage you to review those policies before providing consent.

4. COOKIES, ANALYTICS, AND TRACKING TECHNOLOGIES

Cookies and Similar Technologies

We use cookies and similar technologies (including pixels, tags, and scripts) to support essential website functionality, analyze performance, and, where permitted by your preferences, support marketing and analytics activities.

Cookies are small data files stored on your device that allow a website to recognize your browser or device and store certain information. These technologies may be used to:

• Enable essential website functionality
  
• Maintain security and session integrity
  
• Remember user preferences
  
• Analyze website performance and usage
  
• Support marketing and communications activities, where permitted
  

Non-essential cookies and tracking technologies are disabled by default and will not be activated unless and until you provide affirmative consent through our Cookie Preference Center or banner, where required by applicable law.

We use ConsentPro (https://consentpro.com/) to manage cookie consent preferences and ensure compliance with applicable data protection laws.

We may work with third-party service providers, analytics providers, and technology partners to operate the Channels, understand how users interact with our services, and support marketing and communications activities, subject to applicable law and your preferences.

Users may access or update their cookie preferences at any time by clicking the cookie symbol located in the lower-left corner of the screen or by selecting the “Cookie Preferences” link available here or in the footer of the applicable Channel.

Consent preferences are stored and maintained in accordance with applicable legal requirements.

Analytics and Performance Service Providers

The Channels currently utilize analytics and performance tools provided by our website hosting and publishing platform, including Webflow Analyze (https://webflow.com/feature/analyze), to collect aggregate and diagnostic information about how users interact with our websites.

These tools may collect information such as:

• Page views and navigation patterns
• Approximate geographic location based on IP address
• Device and browser information
• General usage and performance metrics

This information is used to operate, monitor, and improve the performance, reliability, and functionality of the Channels.

Certain information collected through the Channels is collected or processed on our behalf by third-party service providers that support our business operations, website hosting, analytics, communications, document delivery, and related services. These service providers may collect or receive Personal Information in order to perform services for us and are contractually restricted from using such information for purposes other than providing services on our behalf, except as otherwise permitted by applicable law.

Service Providers That May Use Cookies or Process Personal Information

Certain Personal Information collected through the Channels is processed by third-party service providers that support our technical infrastructure, communications, analytics, document management, and business operations. These service providers act on our behalf pursuant to contractual agreements that restrict their use of Personal Information to the provision of services for Pan Am and prohibit unauthorized use or disclosure, except as permitted by applicable law.

The categories of service providers we currently engage include, without limitation:

Website Hosting, Publishing, and Analytics

Webflow, Inc.
Privacy Policy: https://webflow.com/legal/privacy

Webflow provides website hosting, content management, site security infrastructure, and analytics functionality (including Webflow Analyze). Webflow may process technical data such as IP addresses, device identifiers, browser information, and usage metrics to support site functionality, performance monitoring, and reliability.

Consent Management

ConsentPro
Privacy Policy: https://consentpro.com/privacy-policy

ConsentPro is used to manage user consent preferences for cookies and tracking technologies. It provides automated script detection and blocking, categorization of tracking technologies, region-specific consent configurations, and storage of consent records in accordance with applicable data protection laws.

ConsentPro enforces user consent choices by preventing non-essential tracking technologies from loading unless and until consent is provided.

Customer Relationship Management and Communications

HubSpot, Inc.
Privacy Policy: https://legal.hubspot.com/privacy-policy

HubSpot is used for customer relationship management (CRM), email communications, marketing automation, form collection, and internal tracking of business inquiries. HubSpot may process contact information, communication history, engagement data, and related business records in connection with providing these services.

Document Storage and Collaboration

Google LLC (Google Drive)
Privacy Policy: https://policies.google.com/privacy

Google Drive is used for internal document storage, file collaboration, and secure document management.

Dropbox, Inc.
Privacy Policy: https://www.dropbox.com/privacy

Dropbox may be used for secure file sharing and document delivery to clients or partners.

We may engage additional service providers from time to time to support our operations. Where such providers process Personal Information, they will be subject to appropriate contractual and regulatory safeguards consistent with applicable law.

We may implement additional analytics tools in the future, such as Google Analytics or similar services, subject to applicable law and your consent preferences. If and when such tools are implemented, additional disclosures may be provided in this Privacy Policy or through supplemental notices available on the respective entities site.

Targeted Advertising and Marketing Technologies

Pan Am does not currently deploy third-party targeted advertising technologies such as advertising pixels, retargeting scripts, or cross-context behavioral advertising tools across its Channels.

However, we may elect to implement such technologies in the future, subject to applicable law and user consent requirements.

If implemented, such technologies may involve the use of cookies, pixels, tags, or similar tools provided by advertising partners to:

• Deliver content tailored to user interests;
  
• Measure campaign performance and conversion activity;
  
• Understand user interactions across websites or digital services;
  
• Improve marketing effectiveness and audience engagement.
  

Any future deployment of targeted advertising technologies will:

• Be subject to user consent where required by law;
  
• Be integrated into our Cookie Preference Center;
  
• Be disclosed in this Privacy Policy and/or applicable Supplemental Privacy Notices;
  
• Include identification of the relevant technology providers and links to their respective privacy policies.
  

If such technologies are implemented, this section of the Privacy Policy will be updated accordingly, and we will provide notice of material changes in accordance with the “Changes to This Privacy Policy” section.

Additional Tools and Future Technologies

From time to time, the Company may implement additional tools or technologies, including analytics platforms, advertising platforms, optimization tools, communication tools, or customer engagement technologies. Where such tools involve the collection or processing of Personal Information, we will update this Privacy Policy or provide supplemental disclosures, as required by applicable law.
‍
If such tools or technologies relate specifically to the site of particular Pan Am entity, the applicable details will be set forth in that entity’s Supplemental Privacy Notice, which will be further described in the "Supplemental {Entity}-Specific Information” section of this Policy and may be accessed through the Table of Contents by selecting the corresponding link.

Do Not Track and Global Privacy Control

Some web browsers offer settings or signals intended to communicate user privacy preferences regarding online tracking, including Do Not Track (“DNT”) and Global Privacy Control (“GPC”).

Do Not Track:

("DNT") signals offered by some web browsers are settings that request that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and/or other web services you encounter while browsing to stop tracking your activity. 

Global Privacy Control:

GPC is a browser-based signal that communicates a user’s preference to opt out of certain types of online tracking. You can find out more about and set up GPC here. The Channels are configured to recognize GPC signals and, where technically feasible, to honor such signals in accordance with applicable law.

Notwithstanding the foregoing, the Company’s Channels are configured such that non-essential cookies and tracking technologies are disabled by default and are only activated if and when a user affirmatively provides consent through the Cookie Preference Center or cookie banner presented on the applicable Channel.

Users may effectively exercise tracking-related preferences at any time by declining cookies when first prompted or by adjusting settings through the Cookie Preference Center, which provides a functional mechanism to limit or prevent the use of non-essential cookies and similar technologies.

NAI/DAA Opt-Out:

Some of the companies we use may be members of the Network Advertising Initiative ("NAI") or Digital Advertising Alliance ("DAA"). The NAI provides information regarding targeted advertising and the opt-out procedures of NAI members , including opt-out mechanisms for web browsers, mobile and other connected devices, and a tool to opt out from participating NAI members using your hashed email address for interest-based advertising. You may also want to visit the DAA's website (https://digitaladvertisingalliance.org/), which provides information regarding targeted advertising and offers an opt-out for DAA-participating companies.

Please note that opting out through these mechanisms does not opt you out of being served advertising, and that you will continue to receive generic ads while online. Your opt-out choices are typically browser and device specific; if you disable your cookies, upgrade your browser after opting out or if you use multiple different devices, please opt-out on each device and each browser separately. 

Your Privacy Choices Related to Advertising and Analytics

Depending on your jurisdiction, you may have the right to opt out of the sharing or processing of your Personal Information for purposes of targeted advertising or similar activities. You may exercise such rights through:

• The Cookie Preference Center
• Browser or device-level privacy settings
• Submitting a request as described in the “Your Privacy Choices and Controls” section below

Please note that opting out of targeted advertising does not mean you will no longer receive advertisements, but that the advertisements you receive may be less relevant to your interests.

5. YOUR PRIVACY CHOICES AND CONTROLS

You may have certain choices regarding how we collect, use, and share your Personal Information. The availability of these choices may depend on how you interact with the Channels, the Pan Am entity involved, and where you are a resident, please see the Jurisdiction-Specific Rights section below.

Marketing and Communications Preferences

You may opt-out of (a) commercial email or direct-mail marketing messages from our brands, (b) having your personal data made available to affiliated companies for their direct marketing purposes, and/or (c) sharing of your personal data with unaffiliated third parties for their direct marketing purpose as set forth below.

1. Email. You may unsubscribe from marketing emails we send you through the opt-out mechanism included in each such email. Note, however, that we reserve the right to send you certain communications relating to your use of the Channels, notices of changes to this Privacy Policy or other terms, or similar administrative and transactional messages. 
2. Marketing and Promotional Texts. You may also sign up to receive marketing or promotional text messages from us, including special online or other offers. You do not have to opt-in to text messages to make purchases from us. If you opt-in, we may send you text messages and alerts using an autodialer, automated SMS or autodialed technologies and standard messaging and data rates may apply. Message frequency may vary. You can always opt-out of text messages by replying STOP. You will then receive a confirmation text that you have been opted out. For more information regarding text messages, please contact us using the methods provided on our Contact Us page. Any such text messaging activities are subject to our Terms of Use.
3. Tracking Update Texts. You may also sign up to receive order updates, flight status or booking confirmations via text message, and you will receive text messages when a flight status or booking changes, or when each of your package(s) is shipped, out for delivery, delivered, or encounters an exception or delay. If you sign up, we may send you text messages and alerts using an autodialer, automated SMS or autodialed technologies and message and data rates may apply. Text Message frequency will be based on the number of account orders you place. You can always opt-out of these tracking order update text messages by replying NO or STOP to an order update text. For more information regarding our text messaging, please contact us using the methods provided on our Contact Us page. Any such text messaging activities are subject to our Terms of Use.
4. Push Notifications. We may send promotional and non-promotional push notifications or alerts to your mobile device. You can elect to stop receiving those messages at any time by changing the notification settings on your mobile device.

Accessing, Updating, or Correcting Your Information

The Channels may contain webpages or applications through which you can correct or update some of the personal data you have provided (such as via an online account) or through which you may be able to unsubscribe or modify the email newsletters or similar communications we send to you. If you have an online account, you are responsible for maintaining and updating, as applicable, your account registration data with current, accurate, and complete information. If you would like to request that we correct personal data that we have on file about you and that you believe is inaccurate, please email us at privacy@panam.com.

Cookie and Tracking Preferences

We use cookies and similar technologies (including pixels, tags, and scripts) to support essential website functionality, analyze performance, and, where permitted by your preferences, support marketing and analytics activities.

Cookies are small data files stored on your device that allow a website to recognize your browser or device and store certain information. These technologies may be used to:

• Enable essential website functionality
  
• Maintain security and session integrity
  
• Remember user preferences
  
• Analyze website performance and usage
  
• Support marketing and communications activities, where permitted
  

Non-essential cookies and tracking technologies are disabled by default and will not be activated unless and until you provide affirmative consent through our Cookie Preference Center or banner, where required by applicable law.

Additional information regarding cookies, analytics, and tracking technologies is provided in the “Service Providers That May Use Cookies or Process Personal Information” section above.

If you disable or reject certain cookies, some features of the Channels may not function as intended.

Opt-Out of Sharing or Processing for Certain Purposes

We may work with network advertisers, ad agencies, analytics service providers, and other vendors to serve our advertisements on our Channels and third-party websites, apps, and elsewhere online and to provide us with data regarding use of and traffic on the Channels (including without limitation the pages viewed and the actions users take when visiting the Channels) and the effectiveness of our advertisements. For example, if you click on an advertisement for Company, our service provider(s) may be able to tell us the advertisement you clicked on and where you were viewing the advertisement. The advertisements you see may be served by us or one or more third parties, who may use data about your activities on the Channels, and other websites and services you visit across the various devices you use, to provide you targeted content and advertising. Our service providers may collect certain data about your visits to and activity on the Channels and other websites and services and may use this data to target advertising to you.

These third parties may set and access their own tracking technologies on your device (including without limitation cookies and web beacons) and may otherwise collect or have access to information about you (such as Device ID/Interaction Information). Some of these parties may collect personal data over time when you visit the Channels or other online websites and services. Cookies and web beacons, including without limitation those set by third-party network advertisers, may be used to (among other things): target advertisements, prevent you from seeing the same advertisements too many times, and conduct research regarding the usefulness of certain advertisements to you. We may share certain data such as device identifiers, Device ID/Interaction Information, hashed information, records of transactions you conduct on our Channels or offline, and other types of de-identified or pseudonymized data with third-party advertising companies, analytics providers, and other vendors for advertising and analytics purposes. In addition, we and our third-party service providers may use this data to perform matching with third-party cookies to provide targeted online marketing. If you would like to opt-out of third-party advertising and analytics, there are a variety of tools available to you:

1. Cookie Opt-Out Tools. To disable sharing through cookies set on our site by third parties for advertising and analytics purposes, please adjust your settings by using our Cookie Preference Center. Residents of some states have additional rights to opt-out of the sharing or processing of their personal information for purposes of targeted advertising, as described in the Jurisdiction-Specific Rights section below for more information.
2. Do Not Track / Global Privacy Control. Do Not Track ("DNT") signals offered by some web browsers are settings that request that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and/or other web services you encounter while browsing to stop tracking your activity. Global Privacy Control ("GPC") is a technical specification in your browser settings that you can use to automatically inform websites of your privacy preferences with regard to third party online tracking. You can find out more about and set up GPC here. Our channels are configured to recognize and respond to the GPC signal.
3. NAI/DAA Opt-Out. Some of the companies we use may be members of the Network Advertising Initiative ("NAI") or Digital Advertising Alliance ("DAA"). The NAI provides information regarding targeted advertising and the opt-out procedures of NAI members, including opt-out mechanisms for web browsers, mobile and other connected devices, and a tool to opt out from participating NAI members using your hashed email address for interest-based advertising. You may also want to visit the DAA's website, which provides information regarding targeted advertising and offers an opt-out for DAA-participating companies

Jurisdiction-Specific Rights

Residents of certain U.S. states, including but not limited to California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Texas, Utah, and Virginia, may have the following rights, subject to applicable law and certain exceptions:

Notice at Collection

The Personal Information we collect about you will depend upon how you use our Sites or otherwise interact with us. This section describes the categories of Personal Information, as defined under California law, that we may collect about you when you visit our Sites or interact with us, the Business Purpose for which the data is collected, and how the information may be shared or sold.  This section also describes the manner in which Personal Information was collected and used in the past 12 months. 

Category of Personal Information Collected: 

Identifiers. This category includes real name; alias; contact information (such as postal address, phone number, and email address); unique personal identifier; online identifier; device identifier; Internet Protocol address; account name; birth day, month and year; or other similar identifiers.  

Categories of Sources from which the Information was Collected:  We may collect this type of information directly from you, from Cookies and tracking technologies, Third-party social media companies, Affiliated Brands and other third-party business partner and/or from Third Party data resellers. 

Business or Commercial Purpose(s) for which Information is Collect to allow you participate in the Channels, or features or activities we offer; to process a transaction (through our Channels or in our stores) or your account registration, verify your identity or eligibility, and send you confirmations and receipts; to send you information and special offers from us, our advertisers, or third-party business partners; to contact you regarding any problems with your merchandise order or account; to respond to your inquiries and provide customer service related to your use of the Channels; to administer and manage our affiliate program, through which third parties make money by referring customers to our Channels; to protect against misuse of the Channels, fraud, or any criminal activity; to help us serve you better, including personalizing your shopping experience and tailoring content, recommendations, and offers we display to you, including advertisements; to improve the Channels or our products and services; for legal, regulatory and internal business purposes; to detect and troubleshoot problems, resolve disputes, and enforce applicable agreements and policies for the Channels; and for other purposes disclosed to you at the time of collection or undertaken with your consent. 

Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose: Affiliated Brands; Service providers, such as those described in the "SHARING OF INFORMATION" section of our Privacy Policy, above; Third parties we partner with for contests, sweepstakes, or promotions; Third party advertising and analytics companies; Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition; Third parties or affiliated companies when you agree to or request that we share your information with them; and Other third parties (including government agencies) to comply with law, regulation, or legal request (such as pursuant to subpoenas or court orders) or to protect or defend our or any third party’s legal rights. 

Categories of Third Parties to Whom this Type of Personal Information is Sold or Shared (for Cross Contextual Behavioral Advertising) Third parties and Affiliated Brands for their own marketing purposes and third-party advertising, analytics, and similar marketing business partners may have access to this data and this may be considered a "sale" or "share" under the CCPA and CPRA under certain circumstances.

Category of Personal Information Collected: 

Any Categories of Personal Information as Defined in Subdivision (e) of Cal. Civ. Code Section 1798.140.  This category includes name; physical characteristics or description; address; telephone number; driver's license,  state identification card number; or passport information, education; occupation or field; and gift card information. Categories of Sources from which the Information was Collected:  We may collect this type of information directly from you, from Third-party social media companies, Affiliated Brands and other third-party business partner and/or from Third Party data resellers. Business or Commercial Purpose(s) for which Information is Collected: We may collect this information to allow you participate in the Channels, or features or activities we offer; to process a transaction (through our Channels or in our stores) or your account registration, verify your identity or eligibility, and send you confirmations and receipts; to send you information and special offers from us, our advertisers, or third-party business partners; to contact you regarding any problems with your merchandise order or account; to process your employment application; to respond to your inquiries and provide customer service related to your use of the Channels; to administer and manage our affiliate program, through which third parties make money by referring customers to our Channels; to protect against misuse of the Channels, fraud, or any criminal activity; to help us serve you better, including personalizing your shopping experience and tailoring content, recommendations, and offers we display to you, including advertisements; to improve the Channels or our products and services; for legal, regulatory and internal business purposes; to detect and troubleshoot problems, resolve disputes, and enforce applicable agreements and policies for the Channels; and for other purposes disclosed to you at the time of collection or undertaken with your consent. 

Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose: Affiliated Brands; Service providers, such as those described in the "SHARING OF INFORMATION" section of our Privacy Policy, above; Third parties we partner with for contests, sweepstakes, or promotions; Third party advertising and analytics companies; Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition; Third parties or affiliated companies when you agree to or request that we share your information with them; and Other third parties (including government agencies) to comply with law, regulation, or legal request (such as pursuant to subpoenas or court orders) or to protect or defend our or any third party’s legal rights. Categories of Third Parties to Whom this Type of Personal Information is Sold or Shared (for Cross Contextual Behavioral Advertising): Affiliated Brands and third-party business partner for their own marketing purposes.

Category of Personal Information Collected: Characteristics of Protected Classifications under California or Federal Law. This category includes age; marital status; and sex (including gender). 

Categories of Sources from which the Information was Collected:  We may collect this type of information directly from you, from Third-party social media companies, Affiliated Brands and other third-party business partner and/or from Third Party data resellers. 

Business or Commercial Purpose(s) for which Information is Collected: to help us serve you better, including personalizing your shopping experience and tailoring content, recommendations, and offers we display to you, including advertisements; and to improve the Channels or our products and services.  

Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose: Affiliated Brands; Service providers, such as those described in the "SHARING OF INFORMATION" section of our Privacy Policy, above; Third parties we partner with for contests, sweepstakes, or promotions; Third party advertising and analytics companies; Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition; Third parties or affiliated companies when you agree to or request that we share your information with them; and Other third parties (including government agencies) to comply with law, regulation, or legal request (such as pursuant to subpoenas or court orders) or to protect or defend our or any third party’s legal rights.  

Categories of Third Parties to Whom this Type of Personal Information is Sold or Shared (for Cross Contextual Behavioral Advertising): Affiliated Brands and third-party business partner for their own marketing purposes.

Category of Personal Information Collected: 

Commercial Information.  This category includes information about your transactions at our stores and online, including records of items considered, purchased, and returned; information about reviews you have written; information about your customer service contact history (such as when you interact with our customer service team over the phone or through chat or if you respond to our text messages, including transcriptions of conversations and IVR recordings); information about your participation in our loyalty program or other member programs (such as how many points you have and promotion codes we send to you); and information about your participation in any contests, sweepstakes, or promotions. 

Categories of Sources from which the Information was Collected:  We may collect this type of information directly from you, from Third-party social media companies, Affiliated Brands and other third-party business partner and/or from Third Party data resellers. 

Business or Commercial Purpose(s) for which Information is Collected: to allow you participate in the Channels, or features or activities we offer; to process a transaction (through our Channels or in our stores) and send you confirmations and receipts; to respond to your inquiries and provide customer service related to your use of the Channels; to administer and manage our affiliate program, through which third parties make money by referring customers to our Channels; to protect against misuse of the Channels, fraud, or any criminal activity; to help us serve you better, including personalizing your shopping experience and tailoring content, recommendations, and offers we display to you, including advertisements; to improve the Channels or our products and services; for legal, regulatory and internal business purposes; and to detect and troubleshoot problems, resolve disputes, and enforce applicable agreements and policies for the Channels. 

Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose: Affiliated Brands; Service providers, such as those described in the "SHARING OF INFORMATION" section of our Privacy Policy, above; Third parties we partner with for contests, sweepstakes, or promotions; Third party advertising and analytics companies; Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition; Third parties or affiliated companies when you agree to or request that we share your information with them; and Other third parties (including government agencies) to comply with law, regulation, or legal request (such as pursuant to subpoenas or court orders) or to protect or defend our or any third party’s legal rights. Categories of Third Parties to Whom this Type of Personal Information is Sold or Shared (for Cross Contextual Behavioral Advertising): Third parties and Affiliated Brands for their own marketing purposes and third-party advertising, analytics, and similar marketing business partners may have access to this data and this may be considered a "sale" or "share" under the CCPA and CPRA under certain circumstances.

Category of Personal Information Collected: 

Internet or Other Electronic Network Activity. This category includes: the hardware model, browser, and operating system you are using; the URL or advertisement that referred you to the Channel you are visiting; all of the areas within the Channels that you visit; devices you have used to access the Channels; login information (such as your last login); your time zone; location information based off your IP address; mobile network (if applicable); and session recordings. 

Categories of Sources from which the Information was Collected:  We may collect this type of information from cookies and tracking technology. 

Business or Commercial Purpose(s) for which Information is Collected:  to administer and manage our affiliate program, through which third parties make money by referring customers to our Channels; to protect against misuse of the Channels, fraud, or any criminal activity; to help us serve you better, including personalizing your shopping experience and tailoring content, recommendations, and offers we display to you, including advertisements; to improve the Channels or our products and services; for legal, regulatory and internal business purposes; and to detect and troubleshoot problems, resolve disputes, and enforce applicable agreements and policies for the Channels. 

Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose: Affiliated Brands; Service providers, such as those described in the "SHARING OF INFORMATION" section of our Privacy Policy, above; Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition; Third parties when you agree to or request that we share your information with them; and other third parties (including government agencies) to comply with law, regulation, or legal request (such as pursuant to subpoenas or court orders), or to protect or defend our or any third party’s legal rights. 

Categories of Third Parties to Whom this Type of Personal Information is Sold or Shared (for Cross Contextual Behavioral Advertising): Third parties and Affiliated Brands for their own marketing purposes and third-party advertising, analytics, and similar marketing business partners may have access to this data and this may be considered a "sale" or "share" under the CCPA and CPRA under certain circumstances.

Category of Personal Information Collected: Audio, electronic, visual, thermal, olfactory, or similar information
We may collect images or recordings from you when you use certain features of the Channels, such as writing product reviews. We may also contact you directly regarding re-use of a photo or video you have created. Depending on what they capture, these images and recordings could be considered Personal Information under CCPA. 

Categories of Sources from which the Information was Collected:  We may collect this type of information directly from you, from Third-party social media companies, Affiliated Brands and other third-party business partner and/or from Third Party data resellers. 

Business or Commercial Purpose(s) for which Information is Collected: to allow you participate in the Channels, or features or activities we offer; and for product development, marketing, and similar business purposes. 

Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose: Affiliated Brands; Service providers, such as those described in the "SHARING OF INFORMATION" section of our Privacy Policy, above; Third parties we partner with for contests, sweepstakes, or promotions;  Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition; Third parties when you agree to or request that we share your information with them; and Other third parties (including government agencies) to comply with law, regulation, or legal request (such as pursuant to subpoenas or court orders) or to protect or defend our or any third party’s legal rights. Categories of Third Parties to Whom this Type of Personal Information is Sold or Shared (for Cross Contextual Behavioral Advertising): We do not sell or share this category of information.

Category of Personal Information Collected: Inferences Drawn from Any of the Information Identified Above to Create a Profile about a Consumer. We may draw inferences from any of the information we have collected or may receive inferences drawn by a third party. These inferences may relate to your perceived interests, preferences, characteristics, or behavior. 

Categories of Sources from which the Information was Collected We may draw these inferences ourselves or acquire them from third-party data resellers. 

Business or Commercial Purpose(s) for which Information is Collected: to help us serve you better, including personalizing your shopping experience and tailoring content, recommendations, and offers we display to you, including advertisements; and to improve the Channels or our products and services. 

Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose: Affiliated Brands; Service providers, such as those described in the "SHARING OF INFORMATION" section of our Privacy Policy, above; Third parties we partner with for contests, sweepstakes, or promotions;  Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition; Third parties when you agree to or request that we share your information with them; and Other third parties (including government agencies) to comply with law, regulation, or legal request (such as pursuant to subpoenas or court orders) or to protect or defend our or any third party’s legal rights. 

Categories of Third Parties to Whom this Type of Personal Information is Sold or Shared (for Cross Contextual Behavioral Advertising): Affiliated Brands and third-party business partners for their own marketing purposes. In addition, third-party advertising, analytics, and similar marketing business partners may have access to this data, including to better serve you more relevant and sometimes location-based advertisements, and this may be considered a "sale" or "share" under the CCPA and CPRA under certain circumstances.

Category of Personal Information Collected: Sensitive Personal Information. When you place an order, we will collect your payment information when applicable. 

Categories of Sources from which the Information was Collected: We may collect this type of information directly from you. 

Business or Commercial Purpose(s) for which Information is Collected: to process your order. 

Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose: service providers, such as payment processors. 

Categories of Third Parties to Whom this Type of Personal Information is Sold or Shared (for Cross Contextual Behavioral Advertising): We do not use or disclose Sensitive Personal Information for any reasons other than the permissible business purposes set out in Cal. Civ. Code Sec. 1798.140(e) (2), (4), (5), (8), and as authorized by regulations adopted by the California Privacy Protection Agency.

We will retain the above Personal Information at least as long as necessary to accomplish the business purpose for which it was collected, comply with any laws or regulations, resolve disputes, and enforce our agreements.

User-Generated Content and Submissions

If you submit content to us through community, feedback, or similar channels (including submissions to community@panam.com), you acknowledge that such content may be reviewed, moderated, stored, and used by the Company for business, marketing, promotional, or other lawful purposes, subject to this Privacy Policy and applicable law.

If you wish to request removal or modification of user-generated content you have submitted, you may contact us at privacy@panam.com. We will review such requests in accordance with applicable law and our legitimate business interests.

Limitations

Please note that certain choices may be limited where:

• The information is necessary to provide a requested service
• The processing is required to comply with legal or regulatory obligations
• The processing is necessary to protect the security or integrity of the Channels or our operations

6. DATA RETENTION

We retain Personal Information for as long as is reasonably necessary to fulfill the purposes for which it was collected, including to provide our services, operate our business, comply with legal and regulatory obligations, resolve disputes, enforce our agreements, and protect our legal interests, unless a longer retention period is required or permitted by applicable law.

Retention periods may vary depending on the nature of the information, the Pan Am entity involved, the context in which the information was collected, and applicable legal or operational requirements.

Retention Criteria

In determining appropriate retention periods, we consider factors including, but not limited to:

• The purpose for which the Personal Information was collected and used
  
• Whether the information is necessary to provide requested services or maintain an ongoing relationship
  
• The sensitivity of the information
  
• Applicable legal, regulatory, accounting, or reporting requirements
  
• The need to establish, exercise, or defend legal claims
  
• Security and risk management considerations
  

General Retention Timeframes

Subject to the criteria above and applicable law, we generally apply the following retention practices:

• Customer relationship management and marketing records: Personal Information maintained in our CRM systems is generally retained for up to 365 days following the most recent interaction or activity, unless a longer retention period is required for business or legal purposes.
  
  
• Communications and correspondence: Emails and other customer or business communications are generally retained for up to 24 months, after which they may be deleted or anonymized, unless retention is required for legal, regulatory, or dispute-resolution purposes.
  
  
• Analytics and technical data: Analytics and usage data is generally retained for up to 365 days, subject to aggregation, anonymization, or deletion thereafter.
  
  

These timeframes are guidelines and may be adjusted where necessary to comply with applicable law or to support legitimate business needs.

Exceptions and Extended Retention

We may retain certain Personal Information for longer periods where required or permitted by law, including where necessary to:

• Comply with legal or regulatory obligations
  
• Maintain records for tax, accounting, or audit purposes
  
• Respond to or defend against legal claims or regulatory inquiries
  
• Prevent fraud or misuse of our services
  
• Enforce our agreements, policies, or terms
  

In such cases, access to retained Personal Information is restricted to authorized personnel and subject to appropriate safeguards.

Deletion and De-Identification

When Personal Information is no longer required for the purposes described above, we will take reasonable steps to delete, anonymize, or de-identify such information in accordance with applicable law and our internal policies. De-identified or aggregated information may be retained and used for analytical, research, or business purposes, provided it cannot reasonably be used to identify an individual.

Requests Affecting Retention

Requests to delete Personal Information are subject to the retention requirements described in this section and any applicable legal exceptions. Additional information regarding data subject requests is provided in the “Your Consumer Data Rights and How to Exercise Them” or “Jurisdiction-Specific Rights” sections below.

7. DATA SECURITY

We implement and maintain reasonable administrative, technical, and physical safeguards designed to protect Personal Information against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use, taking into account the nature of the information, the purposes for which it is processed, and the risks associated with such processing.

While no method of transmission over the Internet or method of electronic storage is completely secure, we seek to use commercially reasonable measures appropriate to the sensitivity of the information and our business operations.

Security Measures

Our security practices may include, without limitation:

• Access controls designed to limit access to Personal Information to authorized personnel with a legitimate business need
  
• Use of secure systems and infrastructure to host and process Personal Information
  
• Monitoring and review of systems to detect and address potential security risks
  
• Contractual obligations requiring service providers to implement appropriate security measures when processing Personal Information on our behalf
  

Specific security controls and procedures may vary depending on the Pan Am entity involved, the systems used, and the nature of the information processed.

Third-Party Service Providers

We require third-party service providers that process Personal Information on our behalf to implement reasonable security measures appropriate to the nature of the services provided and the information processed. However, we are not responsible for the security practices of third parties outside of our control.

Data Breach Notification

In the event of a security incident or data breach involving Personal Information, we will take reasonable steps to investigate the incident and, where required by applicable law, notify affected individuals and relevant authorities within the timeframes prescribed by law.

Such notifications may include information about the nature of the incident, the categories of information involved, and steps individuals may take to protect themselves, as required or appropriate under the circumstances.

User Responsibility

You are responsible for maintaining the confidentiality of any information you submit to us and for taking appropriate steps to protect your own devices, accounts, and communications from unauthorized access.

Limitations

Despite our efforts, no security safeguards can guarantee absolute protection. Accordingly, to the fullest extent permitted by applicable law, we disclaim any liability for unauthorized access, disclosure, loss, or misuse of Personal Information resulting from circumstances beyond our reasonable control.

8. INTERNATIONAL DATA TRANSFERS

The Company is headquartered in the United States, and the Channels are operated from the United States. As a result, Personal Information collected through the Channels or through offline interactions may be transferred to, processed, and stored in the United States or in other jurisdictions where the Company, its affiliated entities, or its service providers operate.

Data protection and privacy laws in such jurisdictions may differ from, and in some cases may be less comprehensive than, the laws of the jurisdiction in which you reside.

Cross-Border Processing

By accessing the Channels, interacting with the Company, or providing Personal Information to us, you acknowledge and consent, to the extent permitted by applicable law, to the transfer, processing, and storage of your Personal Information in the United States and other jurisdictions for the purposes described in this Privacy Policy.

Personal Information may be accessed by Company personnel and service providers located in different countries solely for purposes consistent with this Privacy Policy and subject to appropriate safeguards.

Safeguards for International Transfers

Where required by applicable law, the Company will implement appropriate safeguards designed to protect Personal Information transferred across borders, which may include contractual, technical, or organizational measures recognized under applicable data protection laws. 

Such safeguards may evolve over time as laws, regulations, and the Company’s operations change. The Company may provide additional information regarding international data transfers or applicable safeguards through updates to this Privacy Policy or through supplemental notices, where required.

Future International Operations

As the Pan Am brand and its affiliated entities expand globally, including potential future targeting of individuals in jurisdictions outside the United States, the Company may adopt additional measures, disclosures, or representative arrangements as required by applicable law. Any such measures will be reflected in updates to this Privacy Policy or through applicable supplemental notices.

Government Access and Legal Requests

Personal Information transferred to or stored in the United States or other jurisdictions may be subject to lawful access requests by courts, regulators, or government authorities in accordance with the laws of those jurisdictions. The Company will respond to such requests as required by law and will take reasonable steps to ensure that any disclosures are lawful and limited in scope.

9. YOUR CONSUMER DATA RIGHTS AND HOW TO EXERCISE THEM

Depending on your jurisdiction of residence, you may have certain rights with respect to your Personal Information under applicable data protection and privacy laws. These rights may include the right to access, correct, delete, or obtain information about the processing of your Personal Information, as well as the right to opt out of certain uses or disclosures of your Personal Information.

This section describes those rights and how you may exercise them. Additional rights or disclosures may apply based on your location and will be provided where required by applicable law.

U.S. State Privacy Rights

Residents of California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Texas, Utah, and Virginia have certain rights under state law. Please see the information below for a summary of your rights, how to exercise your rights and the information we require in order to respond to your requests. Please note that we may ask for certain information to verify the request in accordance with applicable law.

Right to Opt-Out of Sale or Sharing / Right to Opt-Out of Processing for Certain Purposes:

‍You have the right to opt-out or ask us not to sell or share your personal information, or to process your personal information for the purpose of targeted advertising. To exercise this right, please email your request to privacy@panam.com (include your first and last name and email address associated with your account), or contact Customer Service (Contact Us), or by clicking on the “Your Privacy Choices” button located in the site’s footer. Please note, certain information may be collected automatically via cookies on our website and shared with third parties for marketing purposes, and this may be considered a “sale” or “sharing” under applicable law.  To opt out of this automated sharing, please manage your cookie setting by clicking here.

Right to Know:

You have the right to request access to the personal information specific to you individually, that we collected, used, disclosed, and/or sold about you in the last 12 months. You also have the right to request that we provide to you a copy of the individual pieces of personal information we have collected about you in the last 12 months.  To exercise your right to access, please email your request to privacy@panam.com (include your first and last name and email address associated with your account), or contact Customer Service (Contact Us). You will be required to provide certain information which we will use to verify your identity and your request.

Right to Appeal. If you submit a consumer data rights request under this section, and we deny the request, or fail to act on the request within a reasonable period of time, you have a right to appeal the denial or failure to act. To exercise your right to appeal, please email your request to privacy@panam.com ((include your first and last name and email address associated with your account), or contact Customer Service (Contact Us). You will be required to provide certain information which we will use to verify your identity and your request.    

Right to Correct:

You have the right to request that we correct inaccuracies in any of your personal information that we collected from you and retained, taking into account the nature of the personal data and the purposes of processing your data.  To exercise your right to correct, please  email your request to privacy@panam.com (include your first and last name and email address associated with your account), or contact Customer Service (Contact Us). You will be required to provide certain information which we will use to verify your identity and your request. You may also view, update and correct your personal information as described in the “Updating Your Personal Data” section above.

Right to Delete:

You have the right to request that we delete personal information that we have collected about you which we have collected from you. Please note that certain exceptions apply to this right, such as when we must retain your information to comply with law or to protect our legal interest. We will retain a record of any transactions completed with us, and your deletion request. In addition, if you have any merchandise credits with us, we will retain your information until your balance is zero. If your information is to be retained for any other reason, we will notify you of any such exceptions as applicable to your request. To exercise this right, please email your request to privacy@panam.com (include your first and last name and email address associated with your account), or contact Customer Service (Contact Us). You will be required to provide certain information which we will use to verify your identity and your request.

Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of any of your rights. However, we may offer certain financial incentives, charge reasonable fees related to your requests, or deny your right to know, right to request deletion, or right to opt-out of sale or sharing in accordance with applicable law.

International Users

Pan Am Global Holdings, LLC and its affiliated entities are organized and operated in the United States. As a result, Personal Information collected through the Channels may be transferred to, stored, and processed in the United States and in other jurisdictions where we or our service providers operate.

If you are located outside the United States, including in the European Economic Area (“EEA”), the United Kingdom (“UK”), or other jurisdictions with data protection laws that differ from those of the United States, please be aware that your Personal Information may be transferred to countries that may not provide the same level of data protection as your country of residence.

Where required by applicable law, including the General Data Protection Regulation (“GDPR”) and the UK GDPR, we implement appropriate safeguards designed to protect Personal Information transferred internationally. These safeguards may include:

• Standard Contractual Clauses approved by the European Commission or UK authorities;
• Contractual data protection obligations imposed on service providers;
• Data processing agreements incorporating GDPR-compliant provisions;
• Technical and organizational security measures designed to protect Personal Information against unauthorized access, loss, or misuse.

In certain circumstances, Personal Information may also be subject to lawful requests by public authorities, including courts or law enforcement agencies, in the United States or other jurisdictions, in accordance with applicable laws.

If you access or use the Channels from a jurisdiction outside the United States, you acknowledge that your information will be processed in accordance with this Privacy Policy, applicable supplemental policies and applicable law. If you do not agree with the transfer, processing, or storage of your Personal Information as described herein, you should refrain from using the Channels or engaging with our services.

Pan Am is committed to maintaining compliance with applicable international data protection laws and continually evaluates and enhances its data protection practices. If you believe that our data handling practices do not align with applicable data protection requirements in your jurisdiction, or if you have concerns regarding international transfers of your Personal Information, we encourage you to contact us at privacy@panam.com

We welcome feedback and inquiries to help ensure that our practices remain transparent, lawful, and aligned with evolving regulatory standards.

Notice of Financial Incentives

Under California regulation, certain aspects of our loyalty and similar programs, which provide benefits to consumers, may be considered a financial incentive program. We collect personal information from you in connection with our loyalty program, e.g. contact information (name, email address, residential address) and commercial information (like purchase history) for a number of reasons, including to administer the program, contact you with regard to your account (if any), to provide the benefits to you, to better serve you, and to fulfill your requests associated with the program.

To opt into our loyalty or similar programs, as set forth herein you will need to provide certain information, register for an account and agree to the applicable program terms, or otherwise follow the instructions associated with the loyalty or other similar programs. Participation in our loyalty or other similar programs is voluntary and you can withdraw at any time.

To the extent that we provide programs that may be considered a financial incentive because the program is directly or reasonably related to the collection, deletion or retention of consumer personal information, the value is reasonably related to the overall value we receive from the personal information participants provide specific to the program minus the costs and expenses we incur in providing the program.

Notice to Nevada Residents

If you are a Nevada resident, you have the right to request that we not to sell your personal information. To exercise this right, please email your request to privacy@panam.com (include your first and last name and email address associated with your account), or contact Customer Service (Contact Us). Please note that we may ask for additional information to verify the request in accordance with applicable law.

The categories of Personal Information we collect, the sources of such information, the purposes for which it is used, and the categories of third parties to whom it may be disclosed are described throughout this Privacy Policy, including in the sections titled “Information We Collect,” “How We Use Your Information,” and “How We Share Your Information.”

Where required by applicable law, additional jurisdiction-specific disclosures or addenda may be provided in connection with a particular Pan Am entity, service, or offering.

10. Submitting Requests, Appeals, and Authorized Agents

Submitting Requests

To exercise any of the rights described above, you may submit a request by contacting us at:

Email: privacy@panam.com

Please include your full name, email address, and a description of your request. We may request additional information as necessary to verify your identity and process your request, in accordance with applicable law.

At present, the Channels do not require users to create accounts. Requests will therefore be verified using the information provided in the request and other information reasonably available to us.

Authorized Agents

If you are an authorized representative submitting a request on a user’s behalf, please complete the applicable request per the instructions above. Alternatively, you may submit a copy of a valid power of attorney. In either case, please also indicate in your email the nature of your request. The consumer’s identity, in addition to your own, will need to be independently verified for us to fulfill your request. We may also ask the consumer to directly confirm with us that they provided you permission to submit a request. Please keep in mind that if we do not receive adequate proof that you are authorized to act on the consumer’s behalf, we may deny the request.

Verification of Requests

We will take reasonable steps to verify your identity based upon the information you provide and the type of request you are making.

When you exercise your Right to Know, Right to Delete, and/or Right to Correct, we may ask that you provide us with information, beyond your full name, to verify your identity and fulfill your request. If we are unable to verify that the individual submitting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on their behalf), we will not be able to process the request.

If we are unable to verify your identity, we may be unable to fulfill your request.

Response Timing

We aim to respond to verified consumer data rights requests within five (5) to seven (7) business days, subject to applicable law. Where permitted, response times may be extended as allowed by law, and we will notify you if an extension is required.

Right to Appeal

If we deny your request or fail to act on it within a reasonable period of time, you may have the right to appeal our decision, depending on your jurisdiction.

To submit an appeal, please contact us at privacy@panam.com and clearly indicate that you are submitting an appeal. Appeals will be reviewed by appropriate personnel and responded to in accordance with applicable law.

Limitations

The rights described in this section are subject to certain limitations and exceptions under applicable law. We may deny or limit requests where permitted by law, including where fulfilling the request would interfere with legal obligations, ongoing investigations, or the rights of others.

11. CHILDREN’S PRIVACY

The Channels are not directed to children under the age of eighteen (18), and the Company does not knowingly collect Personal Information directly from individuals under 18.

In limited circumstances, the Company may process information relating to a minor where such information is provided by a parent, legal guardian, or other authorized adult in connection with a requested service (for example, where information is necessary to facilitate travel, accommodations, or related services). In such cases, the information is processed solely for the purpose for which it was provided and in accordance with applicable law.

If the Company becomes aware that it has collected Personal Information directly from an individual under the age of 18 without appropriate authorization, it will take reasonable steps to delete such information as soon as practicable, subject to applicable legal requirements.

Parents or legal guardians who believe that a child has provided Personal Information to the Company without appropriate authorization may contact us using the information provided in the “Contact Us” section below.

12. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or the Company’s privacy practices, or if you wish to exercise any of your rights described herein, you may contact us using the information below.

Data Controller

For purposes of applicable data protection and privacy laws, the data controller is:

Pan Am Global Holdings, LLC
4100 MacArthur Blvd
Suite 100
Newport Beach, CA 92660
United States

Privacy Contact

Email: privacy@panam.com

Requests submitted via email should include your full name, contact information, and a description of your inquiry or request. We may request additional information as necessary to verify your identity and process your request in accordance with applicable law.

Global Privacy Officer

The Company’s Global Privacy Officer is:

Terri McManus
In-House CounselEmail: terri.mcmanus@panam.com

Response Timing

We endeavor to respond to privacy-related inquiries and verified consumer data rights requests within five (5) to seven (7) business days, subject to applicable law. Where permitted or required, response times may be extended, and we will notify you if an extension is necessary.

Additional Information

This Privacy Policy applies to all Channels operated by the Company unless otherwise stated. Supplemental notices or entity-specific addenda, where required, will be made available through the applicable Channel.

13. CHANGES TO THIS PRIVACY POLICY

The Company reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, technologies, legal requirements, or business operations.

When we make changes to this Privacy Policy, we will revise the “Effective Date” date at the top of the policy. Material changes may be communicated through the applicable Channels or by other means as required by law.

Your continued access to or use of the Channels after any changes to this Privacy Policy constitutes your acknowledgment of an agreement to the updated policy, to the extent permitted by applicable law.

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