Southwest Airlines: Travel App

"With our business partners, affiliates and other third parties for purposes of sending their own marketing. For example, we may share your information with our financial institution Rewards® Partners for their direct marketing purposes, which may include, but is not limited to, marketing their co-branded credit cards to you."

Southwest shares personal information with business partners and affiliates so those third parties can conduct their own independent marketing campaigns targeting users.

"Data collected from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such data was collected, or transferred to a non-affiliate for such purposes. This means that some information about your browsing of the Service and certain third party sites may be shared with these companies for the purpose of delivering ads to you on the Services and certain third party sites."

Southwest engages in cross-device tracking, linking data collected from one browser or device to another linked device, and shares this browsing data with third-party advertising companies for retargeting purposes.

"We and our agents, vendors, and service providers may use GPS (global positioning systems) software and other location-based technologies to locate you so we may verify your location, and deliver relevant content to you based on your location. We may collect precise location information from your device."

Southwest collects precise geolocation data using GPS and other location-based technologies, going beyond what is necessary for core airline booking functionality.

"We and our agents, vendors, and service providers may use session replay and other technologies to collect page interaction information and other electronic communications and content from your use of the Services (such as content entry, mouse movements, screen captures, the date, time, and location of your visit, what areas of the Services you visit and for how long, what search terms or other data you enter, and what content you view and click on)."

Southwest uses session replay technology to capture granular user interactions including mouse movements, screen captures, and content entry — surveillance-level monitoring of how users interact with their services.

"Southwest reserves the right to change this Privacy Policy and its practices from time to time consistent with applicable privacy laws and principles. If we make changes to this Privacy Policy we will notify you by revising the date at the top of this Privacy Policy, and in some cases, we may choose to provide you with additional notice (such as adding a statement to the homepages of our Services or sending you an e-mail notification)."

Southwest can change its privacy policy at any time with notice limited to updating a date on the page. Additional notification like email is optional and at their discretion, even for material changes.

"We will retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you."

Southwest provides no specific retention timelines and reserves the right to retain data indefinitely based on broad justifications like potential litigation or regulatory requirements, with no clear deletion schedule.

"Please note that we may deny your request, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain Personal Information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests. ... Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons."

Southwest can deny deletion requests based on broad exceptions, and explicitly states that complete removal of data is not always possible, with residual data remaining on backup media indefinitely.