A large airline by its nature will provide services to individuals around the world. It is a clear candidate for the GDPR to apply to it in respect of those act

A large airline by its nature will provide services to individuals around the world. It is a clear candidate for the GDPR to apply to it in respect of those activities as a result. The scope of GDPR extends to entities providing services to individuals in the European Union so is not limited solely to citizens. Additionally, if an EU citizen is in the US and uses a US service provider's services, then that US service provider is not within the scope of the GDPR. The legal disclaimer on the Verizon Up specifically states that the offer is only available to US residents. On that basis I would say that Verizon, in relation to this specific programme, does not appear subject to the GDPR. I don't know about the full extent of their services however so may be subject to GDPR if they satisfy the Art 3 GDPR requirements (https://gdpr-info.eu/art-3-gdpr/ https://gdpr-info.eu/art-3-gdpr/).