Privacy Notice for Viasat Mobility Services
Scope of this Privacy Notice
This Privacy Notice applies to the personal data that Viasat and its affiliates collect, use, and share when you access or use our global mobility services including our inflight (aviation), maritime, rail, bus (or other transportation service) satellite broadband internet connectivity, communications, content and advertising-supported services (collectively, the “Mobility Services”). Viasat’s use of personal data for other Viasat services, websites, or practices (separate from the Mobility Services) are covered under different privacy notices available when you interact with us, including on Viasat’s Privacy Center at www.viasat.com/privacy.
The term “Viasat” (or “us,” “we”, or “our”) in this Privacy Notice means Viasat, Inc., Inmarsat Global Limited and our affiliated group companies around the world. Information on the group company that is the owner (or data “controller” or similarly defined term under applicable laws) of the Mobility Service you are using is available in the “Viasat Controller Entities Addendum” included with this Privacy Notice.
Please read this entire Privacy Notice to be fully informed about how we treat your personal data and your rights. This includes information in the “Additional Information Based on Your Location” section of this Privacy Notice that include details on our personal data processing that apply depending on your location, e.g., region, country, or state.
We collect personal data about you from the following sources in relation to the Mobility Services:
- Directly from you. We collect personal data like your name and contact information when you voluntarily choose to provide us with this information.
- Indirectly. We collect personal data about you indirectly, including through automated means. We capture this Information through your use of the Mobility Services, which may involve using cookies and other tracking technologies, as explained in the “Cookies and Similar Tracking Technology” section of this Privacy Notice.
- Third parties. We also collect information about you from third-party sources such as our partners and business customers (like airlines), as well as service providers that provide marketing, analytics, and data, including advertising networks data. Some of this collection may occur even before your initial interaction directly with us.
The following table describes the personal data we collect from and about you depending on the Mobility Service, some of which we combine in our systems.
Personal Data Description |
Information Source |
|---|---|
Identifiers such as your name or alias, Mobility Service account credentials like username and password, online identifiers (e.g., cookies and similar tracking technology), airline frequent flyer account number or pilot and crew identifiers (for our inflight internet services), and other similar identifiers |
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Contact details such as address, phone number and email address used for contact or service support purposes |
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Financial and related information like your credit card number for payments and payment transaction related details |
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National identification numbers such as your tax identification number that we associate with your access to Mobility Services in certain countries |
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Customer transaction information such as records of the Mobility Services you purchase from us, including payment amount, type(s) of Mobility Services, and records of our interactions with you, including when and how you contact us and the content of those interactions |
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Service usage information on your interactions with our Mobility Services, such as the date and time you access the Mobility Services |
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Online usage information including Internet and other network activity data that we capture as an internet service provider (ISP), including the website domains you visit, the date and time of visits, and related network metadata, details of mobile apps on your device that make use of the Mobility Services, malicious traffic your device may encounter when visiting websites, and crash reports |
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Device information including IP address, device type, unique device ID numbers like your device MAC Address, modem and router information, operating platform and system, and browser-type, browser plug-in types and versions |
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Geolocation information using IP address, WiFi access points and GPS that gives your general geographic location, e.g., location of the aircraft or ship on which you’re traveling, and other technical information that associates your location to your use of the Mobility Services |
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Sensory information such as audio recordings of customer service calls in relation to the Mobility Services |
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Characteristics such as date of birth, job title, and gender that we collect in relation to your account (such as through our maritime Fleet Hotspot Service) |
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Inferences derived from personal data such as purchase preferences and interests to form a view on what we think you may want or what may be of interest, for our or our customer’s (e.g., airline) marketing and commercial purposes |
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Interests and membership information including loyalty or frequent flyer membership status and interests that we may collect in connection with our inflight WiFi and related content and ad-supported services |
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Travel data such as details on the origin, destination, current location, departure and arrival time, and other details about your flight or travel route (maritime, rail, buses, etc.) that features our Mobility Services |
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Marketing and communications preferences including your interest in receiving marketing from us and our third parties and your communication preferences |
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Social media content such as comments that you post on public pages or our Mobility Services or Third-Party Services that are publicly available and may be processed by Viasat |
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We use the personal data that we collect from and about you for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your information.
Laws in some locations where we operate require that we disclose our legal basis to process your personal data, which includes the following bases depending on the Mobility Service:
- Contract – we require certain personal data to provide and support the Mobility Services you purchase or request from us.
- Consent – in some cases, we may ask for your consent before we collect, use, or disclose your personal data; you can voluntarily choose to give or deny your consent without negative consequences to you.
- Legitimate Interests – we may use or disclose your personal data for the legitimate business interests of either Viasat or a third party (such as our airline customers), but only when we’re confident that your privacy rights will remain appropriately protected.
- Legal Obligation – there may be instances where we must process and retain your information to comply with laws or to fulfill certain legal obligations.
If we rely on our (or a third party’s) legitimate interests to collect and use your personal data, these interests normally will be to operate and provide our Mobility Services, communicate with you and respond to your questions, improve our Mobility Services or use the insights to improve or develop new services, market or promote either our Mobility Services or the services of a third-party that are closely partnered with our Mobility Services, or to detect or prevent illegal activities.
If we need to collect personal data by law, or under the terms of a contract between you and us and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to execute with you (to provide you with Mobility Services). In this case, we may have to cancel your Mobility Service with us, and we will notify you if this is the case.
The following table provides more details on our purposes for processing your personal data and the related legal bases.
Purpose |
Personal Data |
Legal basis |
|---|---|---|
Register you as a customer, administer our contract with you and provide the requested Mobility Services to you, including to develop or deliver other products or services in collaboration with your travel or transportation provider (such as your airline) |
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Contract |
Communicate with you about the Mobility Services, product and service updates and availability, updates to our terms of service |
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Contract |
Respond to inquiries and requests from current and prospective customers, including for customer support quality assurance and training purposes, and related recordkeeping |
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Legitimate Interests of Viasat |
Secure the personal data of Mobility Service users and customers, prevent fraud, and address threats to your safety or the safety of others. For example, we may use malware and spyware monitoring tools to detect suspicious activity or unauthorised access to our Mobility Services |
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Legitimate interests of Viasat |
Manage compliance with our service terms, or to bring and defend legal claims, including recovery of debts |
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Legitimate interests of Viasat
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Maintain, support, and improve our IT systems, including to repair and debug our systems |
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Legitimate interests of Viasat |
Learn about our current and prospective customers and Mobility Services users to improve our Mobility Services, and to develop new products and services and improve our marketing, customer relationships and experiences. This includes identifying usage trends and patterns and evaluating this information on an aggregated, specific group(s), and individual basis |
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Legitimate interests of Viasat |
Contact current and prospective customers about products, services, and events we think may be of interest to you, including with promotional mailers and electronic communications (where authorized to do so by law and by our travel partners and customers) |
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Consent (where required); otherwise, legitimate interests of Viasat |
Personalize and customize your experience with our Mobility Services, including to provide local or otherwise targeted content and information, e.g., using browser or WiFi terminal/device-related location data to customize Viasat information presented when using our Mobility Services |
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Consent (where required); otherwise, legitimate interests of Viasat |
Administer surveys to collect customer perceptions and measure satisfaction (where permitted by our travel partners and customers) |
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Legitimate interests of Viasat |
Manage our use of cookies and tracking technologies used with our Mobility Services, and enable you to manage your cookie preferences |
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Consent (where required); otherwise, legitimate interests of Viasat |
Comply with the legal obligations to which we are subject and to support our general business operations |
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Legal obligation |
Fulfill arrangements with our business partners, which may include sharing personal data with our partners and customers, such as the airline or other transport mode on which you are traveling, to contact you for their promotional and informational purposes |
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Consent (where required); otherwise, legitimate interests of Viasat and third parties |
We may disclose your personal data to the following categories of recipients:
- Viasat (including Inmarsat) group companies. We share information across the Viasat group of companies to help us operate our business and Mobility Services or for their own purposes, such as to provide their services to you. These entities are in various countries around the world. A list of countries in which Viasat entities are located can be found here and here. If a group company uses your information for its own purposes, those entities are ‘controllers’ (or a similar-meaning term) of your personal data. Depending on the purpose, we may share information with group companies either in an identifiable format or an aggregated and anonymized manner such that you cannot be identified through this information. Generally, the personal data that we process will be accessible to Viasat, Inc. in the U.S., where permitted by law.
- Third-party service providers. We use third-party companies to perform services on our behalf. These service providers provide business, professional, payment processing, passenger care and support, marketing and advertising, analytics and measurement, regulatory compliance, and technical and hosting support to us, help us operate and administer activities in support of our business and the Mobility Services. These vendors include consulting services by groups and individuals, technology platform and cloud hosting providers like Amazon Web Services, Salesforce, and other third-party technology application providers. These parties are not permitted by us to use or share your personal data for their own or another third party’s commercial purposes. As our Mobility Services are global, these third parties are in countries around the world.
- Roaming partners. Viasat has agreements in place with companies (typically telecommunications or satellite communications companies) (“Roaming Partners”) that provide the Mobility Services to their customers (“Roaming Partner Users”). If you are a Roaming Partner User, we may send to the Roaming Partner your phone number, device ID, and information relating to your use of the Mobility Services (for example, information about the flight you are on when using the Mobility Services). We share this data to authenticate you, give you access to the Mobility Services, prevent fraud, and for our Roaming Partners’ business process analysis.
- Business partners (including airlines and other travel partners). To provide the Mobility Services efficiently, fulfil your requests, and provide you with offers and promotions tailored to your interests, we may also disclose personal data like your name, email address, and other identifiers to our partner or customer with whom you are interacting or traveling (the airline on which you’re flying, for example). When we offer services or promotions in collaboration with a third-party partner who will receive your information for its own use, we will inform you of that at the time of collection and you may choose whether to participate in the offering. We may also disclose your information to the travel provider in connection with their operational or commercial purposes, and otherwise may disclose your information based on your consent.
- Credit agencies or bureaus. We in some scenarios (e.g., certain maritime services) engage with credit agencies or bureaus to carry out credit checks so that we can make credit and solvency decisions for certain Mobility Services (excluding commercial air inflight connectivity services). These credit agencies/bureaus are in various countries around the world.
- Entities involved in corporate transactions. We may sell or purchase assets during the normal course of our business. In connection with these transactions, we may disclose your personal data or transfer this information to another entity as part of a potential or actual acquisition or merger of Viasat or any portion of our assets. If we bring or are defending a reorganization, bankruptcy, or similar event, your personal data may be considered our asset and sold or transferred to third parties. These third parties are in various countries around the world.
- Law enforcement, governmental, judicial, investigative, and related entities. We may share your information to protect and secure our Mobility Services, network, and IT systems and applications, and business, and in connection with an investigation of fraud, intellectual property infringement, interference with our rights, property or users, or other activity that is illegal or may expose you or us to legal liability, including as required or requested by outside auditors or advisors, law enforcement or other government officials.
We also may share your information with third parties when we have reason to believe that a disclosure is necessary to address potential or actual injury or interference with our rights, property, operations, users, or others who may be harmed or may suffer loss or damage. We may share your information when we believe that it is necessary to protect our rights, investigate, or enforce our policies, terms or other legal document or contract, or to comply with a judicial proceeding, court order, or legal process served on Viasat. We may share your data with public authorities such as tax authorities, to comply with our legal obligations.
We also may share your information when we have reason to believe it is necessary to investigate or enforce our policies, terms, or other legal document or contract related to the Mobility Services or rights of a third party.
- Other parties with your consent to the disclosure.
- Third parties who receive aggregate or anonymous information. We may share aggregate or anonymous information derived from your personal data with third parties, including our business partners, for their business, marketing, or analytics uses. When we do, we take steps so that this information cannot be used to identify you.
Cookies are small data files placed on your computer or mobile device when you visit a website or online platform. We use cookies and similar tracking technology like pixels and web beacons (collectively, “Cookies”) including those of third-party service providers to operate and enhance our Mobility Services and understand how you navigate our Mobility Services, to maintain user preferences or settings, combat fraud, help to ensure compliance with our policies and terms of use, and in some cases support our online advertising for the Mobility Services. We ask you to provide your consent to use Cookies when required by law.
For information about the types of Cookies we use, why, and how you can control Cookies, please see the Cookie Notice presented on the Mobility Service you are using (where applicable based on local laws).
The Mobility Services may include hyperlinks to or include on or in connection with the Mobility Services (e.g., apps and plug-ins), websites, locations, platforms, or services operated by third parties, including airlines or other transportation partners (“Third-Party Services”), and you can use the Mobility Services to navigate to access and use Third-Party Services. These Third-Party Services may use their own Cookies to independently collect information about you and may solicit personal data from you.
When you access these Third-Party Services, the applicable third party’s policies and terms and conditions govern those services. We are not responsible for and makes no representations or warranties regarding the policies or business practices of any third parties, including, without limitation, any informational content, products, services, software, or other materials available on a third-party website. We encourage you to familiarize yourself with the third party’s privacy policies and terms of use.
We take our responsibility to protect your information seriously and use appropriate technical, physical, and organizational measures to safeguard the information that we process through our Mobility Services. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal data. No security system is 100% secure, however, and we cannot guarantee our security measures will not be compromised.
Your personal data may be transferred to, and processed in, countries other than the country in which you reside. These countries may have data protection laws that are different than the laws of your country (and, in some cases, may not be as protective).
The servers that process personal data related to our Mobility Services are primarily located in the United States, UK, Ireland, and the Netherlands though personal data also may be transferred to India, Australia and the countries in which our business is established, or our Mobility Services are available, and potentially other countries. This means that when we collect your personal data, we or our service providers will process it in different countries. Please see the Privacy Notice section "When We Share Your Personal Data" for further information on third parties with whom we may share your personal data.
We take appropriate safeguards to help ensure that your personal data remains protected in accordance with this Privacy Notice. These include, for example, implementing the UK and European Commission’s Standard Contractual Clauses for transfers of personal data between our group companies, which require group companies that are parties to these agreements to protect personal data they process from the European Economic Area, Switzerland, and the UK in accordance with data protection laws in those areas. Where appropriate, we also put in place additional safeguards to protect your personal data when it is transferred to countries considered to be less protective.
Information on the Standard Contractual Clauses we have in place between our Viasat group companies can be provided on request. We have implemented similar appropriate safeguards with our third-party service providers and partners.
EU-US, UK Extension and Swiss-US Data Privacy Framework
Viasat, Inc. participates in the EU-US Data Privacy Framework, the UK Extension to the EU-US Data Privacy Framework, and the Swiss-US Data Privacy Framework. Please review the Data Privacy Framework Addendum included in this Privacy Notice to learn more.*
*Viasat, Inc. will not rely on the Swiss-US Data Privacy Framework or the UK Extension to the EU-US Data Privacy Framework until they enter into force, but Viasat, Inc. will adhere to their required commitments in anticipation of their effective date.
Where Viasat, Inc. relies on the EU EU-US Data Privacy Framework, the UK Extension to the EU-US Data Privacy Framework, and the Swiss-US Data Privacy Framework, these will apply to transfers of personal data to Viasat, Inc. instead of the Standard Contractual Clauses in place between the Viasat group companies.
If you are in one of the locations listed below, please review the “Location-specific Addendum” portion of this Privacy Notice for location specific information about our collection and use of your personal data and your related rights.
- United States (including state-specific information, e.g., CA, CO, VA)
- UK, Switzerland, and European Union
- Brazil
- Mexico
We retain the personal data we collect from you where we have an ongoing legitimate purpose to do so as described in the “How We Use Your Personal Data and Our Legal Bases” section above. For example, where we process your information based on a contract with you, we generally will retain the information for the length of the contract to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements.
When we no longer have an ongoing legitimate business need to process your personal data, we will either delete or anonymize it or, if this is not possible (for example, because your personal data has been stored in backup archives), we will securely store your personal data and isolate it from any further processing until deletion is possible.
We do not use your personal data to engage in automated decision-making that will have a significant effect on you (legally or otherwise).
Depending on your location, the privacy laws that apply to our Mobility Services give you certain rights over the personal data we process about you. These rights are in addition to your right to know or be informed about how we process your data, which we honor through this Privacy Notice. Your data protection rights may include:
- You can access, correct, update or request deletion of your personal data. You also can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data. You can exercise these rights at any time by submitting a request through our online Privacy Rights Request Form or by contacting us at privacy@viasat.com. You also have the right to avoid discrimination by us in response to exercising your rights.
- You have the right to opt-out of marketing communications we may send you. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails you receive from us.
- If we collect and process your personal data with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of our processing activity prior to your withdrawal, nor will it affect our processing of your personal data conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority.
Requests to exercise your data protection rights |
Please submit a request using our Privacy Rights Request Form to exercise your data protection rights. You also can contact us at privacy@viasat.com at any time. While your location determines what rights are available to you, we respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. |
Requests to stop sending directed marketing |
You can unsubscribe from marketing emails by clicking the unsubscribe link at the bottom of the email. You also can use our Privacy Rights Request Form to instruct us to remove you from our marketing campaigns. |
The Mobility Services are not directed to children under 13 years old (or older, if applicable law provides for different protections), and we do not intentionally collect personal data from children. If you become aware that we have inadvertently collected personal data from a child, please notify us using the contact details under the “How to Contact Us” section below.
We may update this Privacy Notice from time to time in response to changing business, technical or legal developments. When we update this Privacy Notice, we take the necessary measures to inform you and provide you with appropriate choice, consistent with the significance of the changes we make, and in compliance with applicable data protection laws.
The “Last Updated” date displayed at the top of this Privacy Notice indicates when this Privacy Notice was last updated.
If you have any questions or concerns about our use of your personal data, please contact us using the following details:
Viasat, Inc.
Attn: Viasat Privacy Office
901 K Street, NW, Suite 400
Washington, DC 20001
Email: privacy@viasat.com
Last updated: January 24, 2024