Frontier Airlines

"Geolocation Data: Geolocation data includes physical location information, such as GPS data. To provide a better experience on our Network and provide passengers with an expedited booking process."

Frontier collects precise GPS location data, justified broadly as improving the user experience and expediting bookings, which goes beyond what is strictly necessary for an airline service.

"Frontier Airlines reserves the right, at any time, to add to, change, update, or modify this Privacy Notice, simply by publicly posting such change, update, or modification on this Website. Any such change, update, or modification will be effective immediately upon public posting on this Website. By continuing to access, browse, use this Website, or otherwise provide the information described above to Frontier Airlines, you acknowledge that you have read, understand, and agree to the terms and conditions of this Privacy Notice, as amended."

Frontier can unilaterally change its privacy policy at any time with no direct notice to users, and continued use of the website constitutes acceptance of the new terms.

"We may share your Transaction Information with our affiliates, as well as with unaffiliated third parties who perform services for Frontier Airlines or who otherwise are involved in the fulfillment of your Transaction. In addition to Frontier Airlines using cookies and web beacons on our Sites, we allow certain third-parties to include their own cookies and/or web beacons within our webpages. These companies' use of cookies and/or web beacons is subject to their own privacy policies, not the Frontier Airlines Privacy Notice."

Frontier shares user data with affiliates, unaffiliated third parties, and allows third-party cookies and web beacons on its sites that are governed by those third parties' own policies, not Frontier's.

"Targeting cookies are used by marketing companies to target and retarget you with advertisements that may interest you based on your browsing habits. These cookies are used to deliver advertisements relevant to your interests. Targeting cookies can store which Websites the user visited, the web pages visited, any products purchased, or other advertisements that were clicked on."

Frontier uses targeting cookies that track users across websites, storing browsing history, pages visited, and products purchased to build advertising profiles and retarget users.

"Frontier Airlines engages with a third-party provider, Cognigy, for chat functionality which monitors, records and maintains chat transcripts for a period of time, less than 31 days. Further, your Personal Information, including any correspondence with us, may be used in connection with customer relations correspondence and may be retained for use in evaluating and improving our customer relations and assistance programs."

While chat transcripts have a 31-day retention limit, the policy provides no clear deletion timeline for the vast majority of personal information collected, stating it may be retained indefinitely for customer relations purposes.

"If you are a FRONTIERMiles member and request deletion of part or all your personal information, that could affect your FRONTIERMiles and DISCOUNT DEN memberships. If we cannot retain your personal information, you will no longer be a FRONTIERMiles member or have a DISCOUNT DEN subscription, and so would forfeit any accrued miles and future DISCOUNT DEN benefits would be removed."

Requesting data deletion results in forfeiture of all accrued loyalty miles and paid subscription benefits, creating a punitive disincentive against exercising privacy rights.

"Internet and network activity information includes browsing history, search history or information on a consumer's interaction with a Website, application or advertisement, and Internet protocol addresses (a.k.a. IP Address). To provide a better experience on our Network and improve services for our passengers."

Frontier collects detailed browsing history, search history, and application interaction data, which extends beyond what is strictly necessary for booking and managing airline travel.

"While Frontier Airlines will try to process requests for customers living outside the state of California, and other states with consumer data privacy laws that are applicable to Frontier, we reserve the right not to honor any requests made by consumers residing outside of those states. If you are a FRONTIERMiles member and request deletion of part or all your personal information, that could affect your FRONTIERMiles and DISCOUNT DEN memberships."

Frontier reserves the right to deny deletion requests from users outside certain states, and exercising deletion rights results in loss of loyalty program membership and accrued benefits, discouraging users from requesting deletion.