HackingTechnologyInformationStolen CredentialsData ExfiltratedCustomer Data InvolvedIdentity (basic)Government IDMediumContained

Wheels Up Partners LLC

bd_418363a44db49d87 · schema v1 · pii pii-v1

Severity

Medium

Discovered

Oct 23, 2025

Filed

Dec 9, 2025

To disclose

7 weeks

Affected

36state residents only

Linked

7 filings

Confidence

66%

Full breach record for Wheels Up Partners LLC →

Wheels Up Partners LLC notified the New Hampshire Attorney General on December 9, 2025, of a data event affecting 36 state residents. Unauthorized access occurred on October 20, 2025, and was detected on October 23, 2025. The incident involved the copying of files containing names and Social Security numbers. Wheels Up engaged third-party specialists, notified federal law enforcement, and provided one year of credit monitoring through Epiq to affected individuals.

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Incident timeline

undetected · 3 days

discovery → filing · 7 weeks / 47 days

Oct 20, 2025

Begins

Oct 23, 2025

Discovered

Dec 9, 2025

Filed

vs. sector median

12 wks faster

This filing is one of 7 about the same incident.View merged incident

Linked disclosures

Why this link?

Regulatory filings (6) · sorted by filing gap

Vermont State AGbd_272437d64a14b7bc2025-12-09Verified
Maine State AGbd_9cf28bc955fcf6612025-12-09Candidate
Indiana State AGbd_dd0902282a24ecba2025-12-09Verified
Nebraska State AGbd_f6fb2f75b9ea288b2025-12-09Verified

Show 2 more filings ↓up to 1d gap

Texas State AGbd_879f14f45eeb5af52025-12-10 · +1dVerified
Massachusetts State AGbd_9a642cd350a6740e2025-12-10 · +1dVerified

Name: Mullen Coughlin LLC
norm: mullen coughlin

Name: Wheels Up Partners LLC
norm: wheels up
Domain: wheelsup.com
Industry: Technologyllm

Discovered: Oct 23, 2025
Breach occurred: Oct 20, 2025
Undetected for: 3 daysoccurrence → discovery
Materiality determined: —
Notification sent: Dec 9, 2025
Affected individuals: 36state-resident count only
Data types: Identity (basic)Government ID
Attack vector: Unauthorized Access
MITRE ATT&CK: T1078 Valid AccountsT1119 Automated Collection
Threat actor: External
Regulator citations: Notified federal law enforcementProvided notice to New Hampshire Attorney General
Initial access: valid_credentials

During the incident: Launched an investigation with the assistance of third-party specialists
Completed a comprehensive review of the impacted files
Notified federal law enforcement
Provided access to credit monitoring services for one (1) year through Epiq
Providing written notice of this incident to relevant state regulators
Providing written notice... to the three (3) major credit reporting agencies
Changes made: Implemented additional security measures related to data privacy and cyber security to strengthen our networked environment
Working to implement additional safeguards and training to its employees
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 7 weeks(47 days from discovery to filing)
Compliance flags: — (clock not assessable for this source)

Status: No extraction artifact recorded for this disclosure.

Filing propagation · 7 filings · 7 states

View merged incident ↗

Vermont State AGDec 9 · first

Maine State AGDec 9 · first

Indiana State AGDec 9 · first

Nebraska State AGDec 9 · first

New Hampshire State AGDec 9 · first · this page

Texas State AG+1d

Massachusetts State AG+1d

Evidence ladder

Leak-site claim

Attacker assertion only. Establishes: claim date, group, alleged victim.

Press / market report

Unlocks: incident narrative, operational impact. Still no compliance clock.

State AG / regulator filingThis record

Unlocks: discovery date, data types, affected count, compliance clock.

SEC 8-K / victim statement

Unlocks: materiality, stated response, full audit trail. Ceiling removed.

Source URL: https://mm.nh.gov/files/uploads/doj/remote-docs/wheels-up-partners-20251209.pdf
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: Dec 9, 2025
Raw hash: e46bdb8de80d938a260599b1259b1e412165e78c4098f24d97766e610097b154

Linked disclosures

Regulatory filings (6) · sorted by filing gap

Reporting entityMullen Coughlin LLC

Victim entityWheels Up Partners LLC

Incidentdiscovered Oct 23, 2025

Stated responseLaunched an investigation with the assistance of third-party specialists

Complianceclock not assessable

Extraction provenanceno artifact recorded

Source provenancemm.nh.gov