Privacy Policy

Effective Date: April 27th, 2014

Thank you for visiting WishFly™.com, a site (“Site”) owned and operated by Karma Ventures United LLC (“COMPANY”).  Company is committed to treating the personal and corporate information of our users with respect and sensitivity.  Our privacy commitment is described in this Privacy Policy. As our services evolve and we perceive the need or desirability of using information collected in other ways, we may from time to time amend this Privacy Policy and we will post the revised Privacy Policy on our Site with a notice indicating that our Privacy Policy has been updated.  The revised Privacy Policy will supersede and replace any previous policy policies effective as of the date on which the revised Privacy Policy is posted.  Your continued use of our Site, services or products after any change represents and confirms your consent and agreement to any such changes.

This Policy is part of our Terms and Conditions of Use. Please click here to see that Agreement.  Capitalized terms not otherwise defined herein shall have the meanings set forth in our Terms and Conditions of Use.

Application of this Privacy Policy

This Privacy Policy applies to your use of the Site (regardless of means of access) or any of the current set of services and products from and its Travel Suppliers.  Travel Supplier’s terms and conditions and privacy policy shall also apply to all Travel Services. Their Privacy Policy can be found here (

We are not responsible for the privacy practices of any Travel Suppliers although we do encourage you to read the applicable privacy policies and terms and conditions of such Travel Suppliers.

General Information

We believe that you have the right to understand how your information is stored and used. We require that sites linked to our Site contain a notice identifying their privacy policies. We are not responsible for the privacy practices of any third parties or the content of linked sites although we do encourage you to read the applicable privacy policies and terms and conditions of such parties or web sites.

Information You Provide Us

In general, you can visit WishFly™.com without telling us who you are or revealing any information about yourself.   If you want to register as Member for a Company account  (”Company Account”) we may collect your name, company name, email address, telephone number, street address, social security, taxpayer and immigration information, payroll, insurance and banking information. On rare cases, we may ask you to provide your identity documentation, ("Personally Identifiable Information" or "PII").    You may be asked to choose log-in information, such as your email address and a password which will be used to access your account.  

By providing your PII to us, you explicitly agree and consent to our collection and use of such information as described in this Privacy Policy.

Information Automatically Collected - Email, Facebook information, and name.

We (or our Travel Suppliers or other service providers acting on our behalf) may collect information about the COMPANY services and products that you use and how you use them.  This information includes information that may identify you as well as statistical information (“Analytics”) that does not identify you.  Some Analytics may be correlated with your PII.  Usage Information may include:

a)  Device Information:  We may collect device-specific Information (such as your hardware model, operating system version, unique Device identifiers and mobile network Information including phone number).  We may associate your Device identifiers or phone number with your COMPANY Account.

b)  Log Information:  When you use COMPANY Products, we may automatically record or log information from your device, its software, and your activity using the COMPANY services or products.  This may include:

  • The device’s Internet Protocol (“IP”) address;
  • Identification numbers associated with your devices;
  • Device event Information such as crashes, system activity and hardware settings;
  • Locale preferences;
  • Application activity such as app upload, app download, app installation, app uninstallation, app start, app play duration, app stop, app crashes, app network activity and app resource consumption;
  • Date and time stamps associated with transactions;
  • System configuration information;
  • Metadata;
  • Information provided by you in any blog, video or otherwise communicated to us directly on the Site, by phone, email or otherwise and
  • Other interactions with COMPANY services or products.

The collection and use of your PII or other personal information may be necessary for us to provide you with a service or product, communicate with you, or maintain our relationship with you.  Please be advised that if you choose not to provide us with PII or other personal information, we may not be able to provide these things to you, in whole or in part.

Protecting Children's Privacy

This Site is not designed nor intended to be attractive to use by minors.  If you are a minor in your country of residence, you may use this Site and or its services and products only with the involvement f your parent or guardian.   We do not knowingly collect PII from children under the age of 13.  If we learn that we have inadvertently collected PII from a child under the age of 13, we will delete the information.

Company does not knowingly use, disclose, compile, or allow third parties to use, disclose, or compile the PII of California residents who are under the age of 18 for the purposes of marketing or advertising services or products to such children in violation of California law.  Any California residents under the age of 18 who has registered to use the Site and who post content or information on this Site can request that such content or information be removed from the Site by contacting us as indicated below.


We use cookies to personalize our Site for you and to collect aggregate information about site usage by all of our users. A cookie is a text file that our Site transfers to your computer's hard drive for record-keeping purposes and to enhance the quality of your visit to our Site. The cookie assigns a random, unique number to your computer.  Cookies are small text files that our Site places on your browser to enable our system to recognize your computer and allow us to see how you use our site. Further general information about cookies and how they work is available at

The cookies we use on our Site include:

Session cookies: These temporary cookies expire and are automatically erased whenever you close your browser window. We use session cookies to grant our users access to content and to enable actions they must be logged in to do.

Persistent cookies: These usually have an expiration date in the distant future and remain in your browser until they expire or you manually delete them. We use persistent cookies to better understand usage patterns so we can improve the site for our customers. For example, we may use a persistent cookie to associate you with your user account or to remember your choices on the Site, but this only works when cookies on our site are enabled.

Third party cookies: We permit limited third parties to place cookies through the Site to provide us with better insights into the use of the Site or user demographics or to provide relevant advertising to you.  For example, we utilize Google Analytics to analyze usage patterns of the Site.  Google Analytics generates a cookie to capture information about your use of the Site which Google uses to compile reports on website activity for us and to provide other related services.  Google may use a portion of your IP address to identify their cookie, but this will not be associated with any other data held by Google.  

We may also permit third party service providers to place cookies through our Site, as indicated above, to perform analytic or marketing functions where you are notified of them and you have consented to the usage.   We do not control the use of such third party cookies or the resulting information and we are not responsible for any actions or policies of such third parties.

Your use of our Site will be deemed to be your consent to the placement of cookies on your computer or other device.  If you prefer not to receive cookies through our Site, you can set your browser to either reject all cookies, to allow only “trusted” websites to set them, or to accept only those cookies from those sites you are currently on.  Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our Site and use it.

If you refuse cookies, this will limit system performance and may even cause certain features of the Site to malfunction or not to work at all.


This Site is capable of recognizing when your Web browser is set to a “Do Not Track” setting, or other mechanisms that allow you to exercise a choice regarding our collection of  information about your online activities over time or across third party websites.  We engage third party vendors who may collect such information in order to provide advertisements that are more relevant to your interests.

Use of Information

The use of your information is subject to the Privacy Policy and Terms of Use in effect at the time of use. The provisions contained herein supersede all previous notices or statements regarding our privacy practices with respect to this Site.

We may use aggregated data (independent of any personal identifiers) for research and commercial purposes. This information includes what areas our users visit most frequently and what services they access most often. This information helps us develop a better site that is more useful and accessible to you.

We may use your PII internally for our general commercial purposes including, among other things, to offer our own, our affiliates’ or third-party products and services that we think you may find of interest, but only COMPANY, its subsidiaries and third party contractors involved in distributing the offers or providing the products or services will have access to your PII.  Our subsidiaries and contractors will be required to use any PII we provide them only for that intended purpose.

We may reveal PII about you to unaffiliated third parties: (1) if you request or authorize it; (2) if the information is provided to help complete a transaction for you; (3) if the information is provided to comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas, to enforce our Terms of Use or other agreements, or to protect our rights, property or safety or the rights, property or safety of our users or others (e.g., to a consumer reporting agency for fraud protection etc.); (4) if the disclosure is done as part of a purchase, transfer or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, customer information may be one of the transferred assets); (5) if the information is provided to our agents, outside vendors or service providers to perform functions on our behalf (e.g., analyzing data, providing marketing assistance, providing customer service, processing orders, etc.); (6) to allow them to market to you, or (7) as otherwise described in this Privacy Policy.

We may need to disclose your PII to comply with applicable laws, legal processes, and governmental or quasi-governmental requests or to exercise our legal rights or defend against legal claims.  We may disclose PII and other information available to us when we believe, in our sole discretion, disclosure is necessary or appropriate in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the rights, property, or physical safety of any person, violations of Company’s Terms and Conditions of Use or other agreements, or as otherwise required or permitted by law.

We may use your email address to contact you to respond to your inquiries or to provide information on products or services to you. You can elect not to receive emails from us either by "unsubscribing" to an email you receive or by contacting us as indicated below.

We may provide your email and phone number to our Travel Partners to organize your travel plans.

Opt-Out Rights

If you do not wish to receive offers or other notices from us in the future, you can "opt out" by contacting us at the address indicated at the end of this policy or by following the “unsubscribe” instructions in any communication you receive from us.  Please be aware that you are not able to opt out of receiving communications about your account or any transactions with us.

Accessing Your Information

You are required to provide us with accurate and up to date information.  WishFly™ gives you the ability to amend your data at any time by accessing your account on our site (by clicking on the "account details" tab link on the home page), modifying the information on your account page,  [etc.]. Any changes will affect only future uses of your PII.

Subject to any legislation that might, from time to time, oblige us to store the information for a certain period of time, we will respect your wishes to correct inaccurate information.  Otherwise, we will hold your information for as long as we believe it will help us to achieve our aims as detailed in this policy.

You can ask us whether we are keeping personal information about you and you can ask to receive a copy of that personal information. Before sending you any personal data, we will ask you to provide proof of your identity. If you are not able to provide proof of your identity, we reserve the right to refuse to send you any personal data. We will respond as quickly as we can to your requests for details of personal information we hold about you.


We have security measures in place in our physical facilities and in our computer systems, databases, and communications networks that are designed reasonably to protect information contained within our systems from loss, misuse or alteration. Data we collect is securely stored on our servers. We use latest encryption technology to protect your personal details.

We are not responsible for maintaining the confidentiality of any non-public information that you provide us. If there is information that you wish to protect from disclosure to others, do not provide it to us.

No method of electronic transmission or storage is 100% secure.  Therefore, we cannot guarantee absolute security of your PII.   You also play a role in protecting your information.  Please safeguard your user name and password and do not share them with others.  If we receive instructions using your log-in information we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your account or any other breach of security.  We reserve the right to refuse service, terminate accounts, or remove or edit content in our sole discretion.

Your California Privacy Rights

For California Residents Only. We may disclose your personal information to our affiliates or other third parties including Cheapoair, WePay, and Paypal  who may use that information to market to you directly. Pursuant to California’s “Shine the Light Act”, California residents are permitted to request information about the manner in which we share certain categories of information with third parties for their marketing use. Please email us at to request a copy of our disclosure pursuant to California law.

Links to Third-Party Sites

When you use the Site or our service, you may be directed to other websites that are beyond our control.  These may include merchant sites or payment sites.  We may also allow thirds-party sites or applications to link to the Site. We are not responsible for the privacy practices of any third parties or the content of linked sites but we do encourage you to read the applicable privacy policies and terms and conditions of such parties or web sites. This Privacy Policy only applies to this Site.

International Transfers

The PII we receive may be held on our computers and systems of our offices and datacenters in the United States or across the world and may be accessed by or given to our staff or other authorized third parties working outside the country you are located.   Accordingly, your information may be processed by us in the United States or such other jurisdiction where laws regarding data protection may be less stringent than the laws in your country.  By using this Site and by providing any personal information to the Site, all users, including without limitation users in Canada and the European Union, fully understand and unambiguously consent to the collection and processing of such information in the United States or some other worldwide location.

Links to Social Media Websites and Platforms

We may link to third party websites or social media platforms such as Facebook, Twitter, You Tube [others], which are outside of our control and are not covered by this Privacy Policy.  We are not responsible for the privacy policies or the content of third party websites or social media platforms.  If you have any questions about how these other websites use your information, you should review their policies or contact them directly.  By allowing a link to such third party websites we are not in any way endorsing, promoting or representing the quality of that website.

Changes to our Privacy Policy

As our services evolve and we perceive the need or desirability of using information collected in other ways, we may from time to time amend this Privacy Policy. We encourage you to check our Site frequently to see the current Privacy Policy and Terms of Use in effect and any changes that may have been made to them. If we make material changes to this Policy we will post the revised Policy and the revised effective date on this Site. Please check back here periodically or contact us at the address listed at the end of this Policy.

Contacting Us

This site is owned and operated by Company.   If you have any questions or suggestions with respect to this policy, or if you wish to ask us to delete, correct, or show you your information as provided above, you can simply click on Contact Us to send us an email on

You may mail us on:
302 Fifth Avenue
Floor 8
New York
NY 10001

Effective Date: April 27th, 2014

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