Privacy Policy

This Privacy Policy is effective from February 18th, 2022. 

As part of our commitment to protecting your privacy when you interact with us, The Sole Broker LLC ("The Sole Broker," "we," "us" or "our") provides this Privacy Policy to inform you about our collection, use and disclosure of information when individuals (“you”) visit or any other website that links to this Privacy Policy (the "Sites"). This Privacy Policy may be updated from time to time. If we make any changes, we will post the new Privacy Policy here. You are advised to consult this Privacy Policy regularly for any changes.

1. Information Collected By The Sole Broker

The Sole Broker gathers the following types of information:

We collect information that identifies or can be used to contact you as an individual (collectively, "Personal Information") that you voluntarily provide when you visit the Sites, including your name, postal address, telephone number, email address, payment information, and any other information you provide when you communicate with us.

You may provide this Personal Information, for example, when you join by creating an account or when you make a purchase. If you create an account on the Sites, we will also ask you to create a password. We may combine the Personal Information that you provide with other information that we collect about you such as purchase history or customer service history.

We may also combine the information we receive from you with information (including Personal Information) we obtain from other sources.

We (or third parties that work with us) may automatically collect certain technical information from you when you use the Sites. We may collect this technical information using "cookies" or similar technologies such as "web beacons," pixels, or tags. Cookies are small amounts of data that are stored within your computer's Internet browser and that are accessed and recorded by the websites that you visit, as well as by the companies that place advertising on websites, so that they can recognize the same browser navigating online at a later time. Web beacons are web page elements that can recognize certain types of information on your computer such as cookies and the time and date of a page viewed.

Information collected by cookies and similar technologies may include, without limitation:

  • the pages you visit within the Sites;

  • the date and time of your visit to the Sites;

  • the websites you visit before or after visiting the Sites;

  • the Internet Protocol (IP) address used to connect your computer to the Internet;

  • your computer and connection information such as your browser type and version, operating system and platform;

  • whether you open and whether you click on any link contained in an email message that we send you; and/or

  • your purchase history.

    See the “Digital Advertising and Analytics” section of this Privacy Policy to learn more about the use of this information and the choices available to you.

2. Use of Information

We use the information described above for the following purposes:

  • to process and fulfill any orders you place through the Sites, including to send you emails to confirm your order status and shipment;

  • to communicate with you and to send you information by email or other means about our products, services, contests and promotions (unless you have opted out of our promotional communications);

  • to help us develop and improve the Sites and our services;

  • to tailor the Sites and our services to your interests;

  • for internal business purposes, including analytics and marketing purposes;

  • to comply with the law and to maintain the security of the Sites and our business; or

  • for other purposes as disclosed to you at the point of information collection.

3. Sharing of Information with Third Parties

We may share your information, including Personal Information, with third parties as follows:

  • Affiliates: We may share information with our affiliates, including The Sole Broker Brooklyn, which will handle the information under their own respective privacy policies. Where required by law, we will give you a choice about this sharing.

  • Service Providers: We may employ other companies or individuals to provide certain services to or on behalf of us such as operating and supporting the Sites, fulfilling orders you place through the Sites, shipping your orders, processing your payment, analyzing ad performance or other data, or performing marketing or consulting services.

  • Third-Party Referral Partners: To help provide you with better offers, we may work with third-party referral partners. If you visit the Sites by linking directly from a third-party website, we may provide the third party with select information about your individual transaction that you made after being referred. In order to track and credit your transaction the third-party website may give you a unique code, cookie or graphic which will uniquely identify you. The presence of a third-party navigation bar at the top of any page on any Site is an indication that the third-party website may have access to information about your activity on such Site.

  • Law Enforcement and Government Authorities: We may disclose Personal Information to government authorities or third parties when we believe disclosure is required or permitted pursuant to a legal request, subpoena or other legal process. We may also use or disclose your information as required or permitted by law to perform charge verifications, report or collect debts owed, fight fraud or protect our rights or property as well as those of our affiliates or customers. You should be aware that, following disclosure to any third party, your Personal Information may be accessible by others to the extent permitted or required by applicable law.

  • Business Transfer: In the event that The Sole Broker is sold, has its assets acquired or transferred, whether voluntarily or involuntarily, or merges or becomes affiliated with any other division, individual or entity, any information owned or under the control of The Sole Broker may be one of the transferred assets. We may also disclose information to potential buyers as part of a potential transfer of control.

  • With Consent or Notice: We may share your information with your consent or as otherwise disclosed at the time of data collection or sharing.

  • Aggregate and Deidentified Information: We may share aggregated or deidentified information without limitation, including the technical information that we collect automatically as described above.

4. Digital Advertising and Analytics

We may partner with ad networks and other ad serving providers (“Advertising Providers”) that serve ads on behalf of us and others on non-affiliated platforms. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information Advertising Providers collect about your use of the Sites and other sites or apps over time, including information about relationships among different browsers and devices. This type of advertising is known as interest-based advertising. You can visit or to learn more about interest-based advertising and how to opt out of this advertising on your browser by companies participating in industry self-regulatory programs.

Note that choosing to opt out will not stop advertising from appearing in your browser. It may make the ads you see less relevant to your interests. Advertising Providers may continue to collect data for other purposes, including analytics and other operational purposes.

If you delete your cookies or use a different browser, you will need to renew your opt-out choice. You may also be able to limit data collection for advertising purposes using tools available on your device. Additionally, your browser may offer tools to limit the use of cookies or to delete cookies; however, if you use these tools, the Sites may not function as intended.

We may also work with third parties that collect data about your use of the Sites and other sites or apps over time for non-advertising purposes. Flight Club uses Google Analytics and other third-party services to improve the performance of the Sites and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data when you use the Sites, visit, and to opt out of Google Analytics, visit

5. Children

The Sites are for a general audience and are not directed to children under the age of 16. We do not knowingly collect Personal Information from children under the age of 16. If a parent or guardian becomes aware that his or her child has provided us with Personal Information, he or she should contact us at If we become aware that a user is under the age of 16 and has provided us with Personal Information, we will delete such Personal Information from our files.

6. Security

We use appropriate security measures to protect against the loss, misuse or alteration of your Personal Information. To make sure your Internet browser is using the latest security features, you may want to download the most recent version of it, which should have full SSL (Secure Socket Layer) support.

7. EU-U.S. and Swiss-U.S. Privacy Shield

We comply with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework, as applicable (collectively, the “Privacy Shield Framework”) as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information transferred from European Economic Area (“EEA”) member countries and/or Switzerland, as applicable, to the United States. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement and liability. If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles will govern. To learn more about the Privacy Shield program and to view our certification page, please visit The Federal Trade Commission has jurisdiction over our compliance with the Privacy Shield Framework.

We are accountable for information that we receive under the Privacy Shield Framework and subsequently transfer to a third party. We may transfer information provided by our Users to third parties described above in this Privacy Policy. We are responsible under the Privacy Shield Principles if third parties to whom we transfer information to process this information on our behalf do so in a manner inconsistent with the Privacy Shield Principles. In cases of onward transfer to third parties of personal data of EEA or Swiss individuals received pursuant to the EU-U.S. Privacy Shield or the Swiss-U.S. Privacy Shield, respectively, we are potentially responsible. We may also be required to disclose information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

EEA and Swiss individuals have the right to access the personal data (as that term is defined in the Privacy Shield Framework) that we maintain about you, and you may be able to correct or amend that information if it is inaccurate or has been processed in violation of the Privacy Shield Principles, to the extent allowed by law. To exercise this right, please email

In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your personal information. EEA and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at: For any complaints that cannot be resolved with us directly, we commit to cooperate with EEA data protection authorities and the Swiss Federal Data Protection and Information Commissioner, as applicable and comply with the advice given by EEA data protection authorities and/or the Swiss Federal Data Protection and Information Commissioner with regard to data transferred from the EEA and Switzerland, as applicable. A binding arbitration option may also be made available to you in order to address Privacy Shield complaints not resolved by any other means.

Retention of personal information of EEA individuals will be handled in accordance with our data retention policy. Where we process personal data of EEA individuals as a data controller, such individuals: (i) may have the right to request access to and rectification or erasure of personal information by emailing (ii) may restrict the processing of personal information, object to processing, and/or exercise the right of data portability; and (iii) may have certain rights to withdraw consent without affecting the lawfulness of processing and the right to lodge a complaint with a supervisory authority. For any requests or information regarding the rights set out above, please contact us by emailing us at

8. Links to Other Sites

The Sites may contain links to other websites. If you click on another third party link, you will be directed to that third party's website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.

The Sites may also include integrated social media tools or “plug-ins,” such as social networking tools offered by third parties. If you use these tools to share personal information or you otherwise interact with these features on the Sites, those companies may collect information about you and may use and share such information in accordance with your account settings, including by sharing such information with us and the general public. Your interactions with third-party companies and your use of their features are governed by the privacy policies of the companies that provide those features. We encourage you to carefully read the privacy policies of any accounts you create and use.

9. Corrections/Information Removal/Opt-Out

If your name, email, postal address, or telephone number changes, you may update, correct or delete the relevant information by contacting us at In addition, if you no longer wish to receive promotional communications from us you may opt out by emailing us at, sending a letter to: 2110 Richmond Road, Suite J, Staten Island, NY, 10306 Attn.: Customer Service, or by clicking on the unsubscribe link within any marketing email you receive from us.

10. Nevada Privacy Rights

Under Nevada law, Nevada residents may submit a request directing us not to make certain sales of personal information we maintain about them, if we engage in such sales in the future. To exercise this right, please contact us by email at

11. California Privacy Rights

This section contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to “personal information” that is subject to the CCPA including personal information that The Sole Broker collects when you visit our physical locations. Consumers with disabilities may access this notice by contacting for an alternative format of this notice.

Personal Information We Collect and Disclose for a Business Purpose. We collect the categories of personal information about California consumers identified in the chart below. As further set forth in the chart below, in the past 12 months, we have disclosed California consumers’ personal information to third parties for business or commercial purposes.

Categories of Personal Information: Collected in the last 12 months: Categories of sources from which information is collected: Business or commercial purposes for collection, use, and sharing: Disclosed for business purposes to the following categories of third parties:
Personal and online identifiers (such as first and last name, email address, or unique online identifiers) Yes All categories listed below. All purposes listed below. All categories listed below.
Categories of information described in Section 1798.80(e) of the California Civil Code (such as phone number, bank account number, credit card number, or debit card number) Yes All categories listed below. All purposes listed below. All categories listed below.
Commercial or transactions information (such as records of personal property or products or services purchased, obtained or considered) Yes Consumers. All purposes listed below. All categories listed below.
Internet or other electronic network activity information (such as browsing history, search history, interactions with a website, email, application, or advertisement) Yes All categories listed below. All purposes listed below. All categories listed below.
Biometric information (such as call recordings) Yes Consumers. To receive your calls to exercise your rights regarding personal information as described below. None.
Geolocation information Yes All categories listed below. All purposes listed below. All categories listed below.
Inferences drawn from the above information about your predicted characteristics and preferences Yes All categories listed below. All purposes listed below. All categories listed below.

Categories of Sources. We collect this personal information from the following categories of sources: Consumers, including through activity on our website and mobile application; Service providers; and _ Affiliates not under the Flight Club brand.

Why We Collect, Use, and Share California Information. We use and disclose the personal information we collect for one or more of our commercial and business purposes, as further described in this Privacy Policy. These commercial and business purposes include, without limitation: Our commercial purposes, which include: Facilitating transactions with The Sole Broker; Fulfilling transactions with The Sole Broker; and Marketing and advertising for The Sole Broker. Our business purposes as identified in the CCPA, which include: Auditing related to our interactions with you; Legal compliance; Detecting and protecting against security incidents, fraud, and illegal activity; Debugging to identify and repair errors that impair existing intended functionality; For the performance of services on our behalf, such as the provision of customer service, the processing or fulfillment of orders and transactions, the verification of customer information, the processing of payments, the provision of advertising, marketing or analytic services, and the provision of other similar services on our behalf; Internal research for technological improvement; Activities to maintain and improve our services; Short-term, transient uses; and Other operational purposes.

We may also use and disclose the personal information we collect to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

Recipients of California Personal Information. We do not sell the personal information we collect to third parties.

We disclose the categories of personal information designated above to the categories of third parties listed below for business purposes: Service providers; Affiliates not under the Sole Broker brand; and _ Government entities.

Your Rights Regarding Personal Information. California residents have certain rights with respect to the personal information collected by businesses. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations: The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about you, the categories of sources from which we collected your personal information, our purposes for collecting or selling your personal information, the categories of your personal information that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared personal information. The right to request that we delete the personal information we have collected from you or maintain about you. _ The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

To exercise any of the above rights, please contact us using the following information with an explanation of the rights you wish to exercise and submit the required verifying information, as further described below: _ By phone at (646) 346-6760 * By email at

In certain circumstances permitted by the CCPA or because of a conflict with applicable law, we may deny all or part of a request to exercise the above rights, in which case we will notify you of such denial and the reasons for such denial.

Verification Process and Required Information. At a minimum, we will ask you for your name, email address, and telephone number. Note that we may need to request additional information from you to verify your identity or process your request, although you will not be required to create an account with us to submit a request or have it fulfilled. We will use the personal information you provide us in connection with your exercise of the above rights only to review and comply with your request.

Authorized Agent. You may designate an authorized agent to make a CCPA request on your behalf by designating such agent in writing or through a power of attorney. Before we accept a CCPA request from an agent, we will require the agent to provide us with proof that you have authorized the agent to make the CCPA request on your behalf, and we may need you to verify your identity directly with us.

Minors’ Right to Opt In. We do not sell the personal information of minors under 16 years of age.

12. Contact Information

If you have any questions or concerns about this Privacy Policy, please contact us at or 2110 Richmond Road, Suite J, Staten Island, NY, 10306.