FlightBridge Privacy and Cookies Notice

Last Updated: July 6, 2021

1. Introduction

This Privacy and Cookies Notice /Notice at Collection (the "Notice") describes how FlightBridge, Inc. ("FlightBridge", "we", "our" or "us") handles personal information in connection with the operation of the FlightBridge website, available at www.flightbridge.com (the "Site"), and our online booking, logistics management and communications and operations management tool, which may be accessed through the Site or integrations (the "Services"). The Services also include our technical, maintenance and customer support services. The Site and the Services are made available for informational and research purposes and are intended for users acting in a professional capacity.

This Notice describes how FlightBridge uses the personal information obtained through the Site and the Services and with whom we may share it. If you are a European or Californian visitor or user, you may have additional rights with respect to your personal information we process. Please see the "Additional Information for European Visitors" and "Additional Information for California Residents" sections below for more information.

In addition, we de-identify and/or aggregate the personal information and other data we obtain through the Site and the Services (the "De-identified Data"). The requirements and limitations described in this Notice on our collection, use, sharing, disclosure, transfer and retention of personal information do not apply to such De- identified Data as well as other information that cannot be used to identify you.

This Notice does not describe the data handling practices of the FBOs, flight departments, aircraft operators, pilots and other customers (collectively, the "Customers") who use the Services nor those of the third-party partners or vendors with whom Customers connect to make bookings or other arrangements (such as hotels or car-rental companies)(collectively, the "Third-Party Vendors"). We encourage you to review the privacy notices and similar statements of the relevant Customers and Third-Party Vendors to learn about their privacy practices, including about the cookies and similar technologies they may use.

2. What Personal Information We Obtain

FlightBridge obtains personal information when you use the Site or the Services. This personal information may be provided by you directly, such as when you complete a form on the Site or it may be automatically collected from your browser or mobile device using technologies such as cookies. FlightBridge also obtains personal information in connection with our Customers’ use of the Services, including when they make bookings or other arrangements using the Services. In addition, FlightBridge obtains personal information about its Customers’ representatives as part of the contracting or registration process, for FlightBridge’s marketing purposes and during the ordinary course of business.

a. Personal information we obtain from you through the Site: We may ask you to provide your personal information when you use the Site. You may not be able to use certain features if you choose not to submit the requested personal information. The personal information we collect directly from you may include details such as:

• Contact information (e.g., name, email address, phone number, company name and address).
• Log in information (e.g., credentials for accessing the Services).

b. Personal information we obtain from Customers (and their authorized users) in connection with the Services: The personal information we obtain from our Customers and their authorized users may include details such as:

• Contact information (e.g., name, email address, company name and address).
• Log in information (e.g., credentials for accessing the Services).
• Other personal information provided through the Services.
• Personal information shared in connection with calls or requests to FlightBridge’s technical, maintenance and customer support services.

When Customers use the Services, we obtain personal information of individuals, including crew members and passengers, on whose behalf bookings or other arrangements are made by the relevant Customer (the "Passenger Data"). This may include:

• Contact information (e.g., name, email address, phone number and postal address) and demographic information (e.g., gender, date of birth).
• Government-issued identifiers, passport information and visa status for passengers and crew.
• Flight and aircraft information (e.g., origin and destination airports, estimated travel time).
• Payment card information.
• Other information they choose to provide through the Services (e.g., loyalty program numbers).

c. Personal information we obtain from other sources: We may combine personal information we obtain through the Site or in connection with the provision of the Services with other personal information we may have about you, including personal information obtained offline, from Third-Party Vendors (such as booking confirmation information) or from our affiliates. In connection with the Services, we may obtain information from publicly or commercially available sources, such as the Federal Aviation Authority or national equivalent. If you are a representative of a Customer or potential customer, we may obtain personal information about you from your organization, for example, through the contract negotiation process. We may obtain your personal information if you attend an industry conference or event. We may also obtain personal information from our affiliates.

d. Data automatically collected through cookies and similar technologies: We and our service providers may automatically obtain certain information (some of which may constitute personal information), when you access the Site and the Services from your web browser or mobile device, such as data about the number and frequency of visitors, technical data about browsers and devices used to access the Site and the Services, and data about crashes or other technical issues. In addition, we and third parties may automatically collect certain data through automated means about your activities over time across the browsers and devices you use to access the Site and the Services as well as across third-party sites, apps or other media. These technologies may assign or collect a unique identifier on your browser or device, and may reside, among other places, on your computer or device, within webpages or mobile apps. We may use these technologies to administer the Site and the Services, understand usage of the Site and the Services and improve the content and offerings of the Site and the Services.

Cookies and similar technologies on the Site or Services may be served directly by FlightBridge (referred to as ‘first-party cookies’) or by others such as data analytics companies (referred to as ‘third-party cookies’). Cookies and similar technologies are browser- and device-specific and may endure for different periods of time. Some are deleted automatically once you close your browser or exit the Site or Services. These are sometimes referred to as ‘session cookies’. Other cookies are ‘persistent cookies’, meaning that they remain on your device after your browser is closed.

You have the right to choose whether or not to accept certain cookies and similar technologies. However, if you choose to refuse or remove cookies and similar technologies, this could affect the availability and functionality of the Site or Services, as applicable.

The Site and Services uses analytics to measure usage and help improve both the user experience and functionality, including third-party analytics provided by Google Analytics. To opt-out of Google Analytics on your device or browser, please visit https://tools.google.com/dlpage/gaoptout and follow the instructions.

3. How We Use Personal Information We Obtain

We use personal information we obtain in connection with the operation of the Site and the provision of the Services for a number of purposes, including, but not limited to:

• Making the Site and the Services available, responding to requests or inquiries and providing customer support.
• Performing the Services contracted or requested by our Customers, including facilitating bookings and other arrangements and enabling integrations, APIs, data exchanges with systems used by our Customers, which may include our affiliates’ offerings and third-party offerings, such as Third-Party Vendors’ offerings.
• Improving the Site, the Services and other FlightBridge offerings and developing new products and services.
• Communicating with you about the Site, the Services and FlightBridge’s and our affiliates’ products and services.
• Analyzing and customizing the user experience.
• Generating statistics, performing data analytics, anonymizing and/or aggregating data to prepare internal, customer and industry insights.
• Detecting, preventing, and responding to violations of this Notice, violations of law, or other misuse of the Site or the Services.
• Complying with and enforcing applicable contractual obligations or industry and legal requirements (including legal process such as court orders, warrants or subpoenas).

With respect to Site visitors and representatives of Customers or potential customers, we may also use their contact information to send them communications, including email or other communications marketing and advertising FlightBridge’s or our affiliates’ products, services and other offerings.

4. With Whom We Share Personal Information

We may share personal information we obtain in connection with the operation of the Site and the Services:

• With Third-Party Vendors with whom you make bookings or other arrangements using the Services (e.g., hotels, car-rental companies).
• With our CAMP Systems affiliates and subsidiaries.
• With business partners (e.g., joint marketing partners).
• With other entities, as instructed or requested by the relevant Customer (e.g., a flight scheduling system as a result of APIs or integrations).
• With third parties that provide services or handle transactions on our behalf (e.g., email service provider).
• As we believe is necessary or appropriate to protect, enforce, or defend our legal rights, the privacy or safety of our employees, users of the Site and the Services or other individuals and entities, or to comply with or enforce applicable law or legal process, including responding to court orders, warrants, subpoenas and other requests from public and government authorities.

5. How We Protect Your Personal Information

We maintain reasonable administrative, technical and physical safeguards to protect the personal information we obtain through the Site and the Services. However, no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, while we make reasonable efforts to protect your personal information, we cannot guarantee its absolute security.

6. Third-Party Links And Features

The Site and the Services may contain links to third-party websites or features, including through integrations, APIs or other feeds. FlightBridge is not responsible for the collection or use of your personal information by such third parties. We encourage you to review the privacy policies or other similar statements applicable to third-party websites or features.

7. Do Not Track

FlightBridge does not currently take steps to respond to browsers’ "Do Not Track" signals as no uniform standard to respond to such signals has been developed at this time

8. International Data Transfers

FlightBridge operates the Site and the Services in different regions, including the United States. Information collected through the Site and the Services will be processed in and subject to the laws of the United States, which may not provide the same level of protection for your personal information as your home country. Where applicable, we take steps to comply with applicable legal requirements for the transfer of personal information.

9. Children’s Information

The Site is not directed to, nor does FlightBridge knowingly collect personal information from, children under the age of 13. If you become aware that your child or any child under your care has provided us with personal information without your consent, please contact us as indicated below.

10. Dispute Resolution/Terms Of Use

Any dispute concerning the Site or Services (including our use of your personal information) will be resolved per the dispute resolution provision and/or other applicable provisions in the Terms of Use, which govern your use of the Site and Services. Please take a few minutes to read the Terms of Use before using the Site or Services.

11. Changes To This Privacy Notice

We may update this Notice from time to time to reflect changes in our privacy practices or applicable laws. In accordance with applicable law, we may make such changes without prior notice. We will publish the updated version on the Site and indicate at the top of the Notice when it was most recently updated. Your use of the Site and the Services will be governed by the current version of this Notice.

12. Contact Us

If you have any questions about this Notice or, in accordance with applicable laws, you would like to review or request changes to the personal information collected in connection with your use of the Site and the Services, please contact us at privacy@flightbridge.com.

13. Additional Information For European Visitors

a. Who is Responsible for Your Personal Information?

Each FlightBridge Customer is the responsible data controller for the personal information they collect and maintain using the Services. Individuals with concerns about the personal information obtained through the Services should contact the relevant Customer with their concerns.

The data controller for personal information we obtain from representatives of Customers or potential customers for our own business purposes is FlightBridge, Inc. The below information applies to our data processing activities as a data controller only. You can contact FlightBridge, Inc. at privacy@flightbridge.com.

b. Legal Bases for Using Your Personal Information

We process personal information of Customers’ representatives or potential customers for different purposes on the following legal bases:

• To provide the Services in performance of a contract. We process personal information to perform our contractual obligations when we make the Services available to you at the request of a Customer. For example, this includes when we obtain your registration information and manage your user account. We may share your personal information on this legal basis with our affiliates and subsidiaries, our service providers and as instructed by the relevant Customer.
• To pursue our legitimate interests. We process your personal information to meet our legitimate interests when we use your personal information to provide you with the Site, to communicate with you about our offerings and for our advertising and marketing purposes. For example, our legitimate interests include making improvements to, customizing and understanding how you interact with the Site and the Services and sending you communications about products and services we think may be of interest to you. To accomplish our legitimate interests, we may share your information with our affiliates and subsidiaries and service providers (including for our advertising and marketing purposes), with business partners and in the context of a corporate transaction. We maintain safeguards to protect the information we process to pursue our legitimate interests.
• To comply with our legal obligations. We process and share your personal information as necessary to comply with our legal obligations when we use your information to protect our rights or the rights of others and when we share your information with other parties where required by law or as necessary to protect our rights.
• With your consent. We obtain your consent to process your personal information when we are required to do so by law. If consent is the legal basis on which we process your personal information, you can withdraw your consent at any time by contacting us using the information provided in the "Contact Us" section above.

c. Your Rights Over Your Personal Information

In certain circumstances, visitors and users of the Sites and Services and Customer’s representatives have a right to access or object to the use of personal information we hold about you as a data controller. You can also ask us to rectify, update, erase, restrict or to share such information in a usable format with another company. Such requests are subject to applicable law.

To exercise your rights in relation to Passenger Data we hold about you as a data processor on behalf of Customers who use the Services to make bookings or other arrangements on your behalf, you should contact the relevant Customer to exercise your rights.

We encourage visitors and users of the Sites and Services and Customer’s representatives to contact us to update or correct your personal information if it changes or if the personal information we hold about you is inaccurate. If you would like to discuss or exercise such rights, please contact us at privacy@flightbridge.com. We will contact you if we need additional information from you in order to honor your requests.

d. Storing Your Personal Information

We keep the personal information for which we are a data controller for as long as we have a relationship with you. After our relationship with you has ended, we retain your personal information as necessary and appropriate to enable us to:

• Maintain business records for analysis, understanding market trends and/or audit purposes and to improve the Site, the Services and other FlightBridge offerings.
• Comply with record retention requirements under applicable laws or other relevant legal, regulatory or industry requirements.
• Defend, establish, exercise or bring any existing or potential legal claims.
• Carry out fraud detection and prevention.
• Deal with any complaints regarding the Site, the Services or other FlightBridge’ and our affiliates’ offerings.

e. Contact, Questions and Complaints

European visitors can contact us at privacy@flightbridge.com. Individuals in the EEA, United Kingdom, and Switzerland whose Passenger Data is processed by FlightBridge as a data processor on behalf of a Customer should contact the relevant Customer with any requests or complaints.

We are committed to working with you to obtain a fair resolution in the event you have a complaint or concern about our data processing activities. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to a data protection authority.

14. Additional Information For California Residents

Under California law, specific disclosures are required, and California residents have additional rights regarding their personal information. Depending on the nature of your relationship with us, you may have certain rights. Please review this section to learn more.

a. Your California Consumer Privacy Act of 2018 ("CCPA") Rights

• You may have certain rights under CCPA with respect to the handling of your information by our Customers. If you would like to exercise your CCPA rights with respect to your Passenger Data submitted by a Customer to make a booking or other arrangement through our Services, please contact the Customer directly to exercise your CCPA rights. We are not responsible for and have no control over the privacy and data security practices of our Customers, which may differ from those explained in this Notice.
• If you directly visited or used our Site or Services in your individual capacity and are a resident of California, you may have the following rights:
  • Right to access your personal information. You may request to access the categories and specific pieces of personal information that we collected about you through the Site or Services.
  • Right to deletion. Subject to certain exceptions, you may ask us to delete the personal information we collected about you through the Site or Services.
  • Right to disclosure. You may request to receive additional details about the sources from which we collect information, the reasons we collect and share information, and the types of third parties with which we share the personal information we collected about you through the Site or Services.
  • Right to opt out of sales. Under CCPA, certain types of sharing of personal information may constitute a "sale" of your personal information. To opt out of the use of your information for interest-based advertising, please use the opt outs include in the Interest-Based Ads section above. If you reengage with us after opting out of the "sale" of your personal information, such as by signing up for a newsletter, your personal information will be collected and used in accordance with this Notice. When Passenger Data is shared with Third-Party Vendors in order to make a booking, that interaction does not constitute a "sale" of your personal information by FlightBridge under CCPA.
  • Right to be free from discrimination. You may exercise any of the above rights without fear of being denied goods or services.
  If you would like to exercise your CCPA rights with respect to the personal information we collected about you through our Site or Services, including the right to opt out of the sale of your personal information, please contact us with your request by email at privacy@flightbridge.com. For such requests, please put the statement "California CCPA Rights" in the body of your email, as well as your full name, email address, mailing address and specify the CCPA right you wish to exercise at this time.
• If you are a B2B representative of a Customer and we have obtained your personal information through the Site or the Services, you may have certain rights under CCPA. Please contact us with your request by email at privacy@flightbridge.com.

b. Minors

We do not knowingly collect or disclose personal information of minors under the age of 16, without affirmative authorization. If a Customer (or their authorized user) shares with us information about minors, they are responsible for obtaining any requisite affirmative authorization.