Unifi Privacy Policy

Last Updated: December 2022

 Unifi Aviation, LLC and our affiliates and subsidiaries (“Unifi”, “we”, “us” or “our”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website unifiservice.com or access any other media form, media channel, mobile website, or mobile application related or connected thereto (collectively, the “Site”). Please read this Privacy Policy carefully. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE SITE.  YOUR PERSONAL INFORMATION MAY BE PROCESSED IN THE COUNTRY WHERE IT WAS COLLECTED AS WELL AS OTHER COUNTRIES (INCLUDING THE UNITED STATES) WHERE LAWS REGARDING PROCESSING OF PERSONAL INFORMATION MAY BE LESS STRINGENT THAN THE LAWS IN YOUR COUNTRY.  BY UPLOADING PERSONAL INFORMATION TO THE SERVICES YOU WARRANT THAT YOU HAVE THE RIGHT TO TRANSFER SUCH INFORMATION OUTSIDE YOUR COUNTRY AND INTO THE UNITED STATES.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Effective” date of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site, and you waive the right to receive specific notice of each such change or modification. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Site after the date such revised Privacy Policy is posted.

COLLECTION OF YOUR INFORMATION

We may collect information about you in a variety of ways. The information we may collect on the Site includes:

Contact Information. If you use the Contact Us feature of the Site or contact us in another way, you may provide us with your full name, phone number, email address, city, state, zip code and information about the nature of your request, question or comment.

Account Information. The Site allows some users register to create an account with us.  To create an account, you will provide us with your name, email, phone number and account password.

 Business Data. We collect information related to other employees, owners, directors, officers, or contractors of a third-party organization (e.g., business, company, partnership, sole proprietorship, nonprofit, or government agency) with whom we may conduct, or possibly conduct, business activities.

 Job Applicant Information. If you fill out an application for a job available on the Site, you will be asked to provide us with personal information about yourself so we can evaluate your application (“Job Applicant Information”), such as Contact Information; information in your curriculum vitae (“CV”), resume, cover letter, or similar documentation; educational background including degrees, certificates, transcripts; credit history and/or criminal background screenings (where relevant to your application and permitted under applicable law); and, other unique information in your application that you choose to share with us, such as personal preferences, hobbies, social preferences, etc. If you have a disability and would like for us to consider an accommodation, you may provide that information during the recruitment process. Unifi may also ask for information such as race, ethnicity, or gender for the purposes of monitoring our equal opportunity program and compliance. However, for the purposes of your application this information is voluntary. If you provide us with this information, it will not be considered in the hiring or selection process.

Unifi will use and otherwise process Job Applicant Information for recruiting and job placement purposes including notification of future job opportunities with Unifi and its affiliates and subsidiaries and for job opportunities with Unifi’s related companies under the control of the same ownership group as Unifi. Unifi will also use Job Applicant Information for on-boarding purposes and background screening, including enrolment in payroll and applicable employee benefit schemes, preparation of employment contract, and other administrative purposes necessary for you to commence employment with Unifi, if applicable. Unifi’s legal bases to use and process Job Applicant Information include that the processing is necessary for: Unifi’s legitimate interests, including those described above, as processing Job Applicant Information is necessary to carry out the hiring process and to make it possible for you to apply for and/or be appointed to a position at Unifi, its affiliates and subsidiaries and other companies under the control of the same ownership group as Unifi; compliance with Unifi’s legal obligations, such as accounting and tax requirements;  the performance of the employment contract between you and Unifi, if any; for the purposes of carrying out the obligations and exercising rights under employment law; and where applicable, you, may subsequently withdraw at any time by contacting us via the information in the “CONTACT US” section, without affecting the lawfulness of processing before its withdrawal.  As necessary, and in connection with these purposes, authorized processors, including, but not limited to, members of the Human Resources department, the Finance department, the IT department, Legal department, and senior executive managers of Unifi, its affiliates and subsidiaries and Unifi’s related companies under the control of the same ownership group as Unifi may access and otherwise process Job Applicant Information in connection with their job responsibilities.

Transaction and Payment Information. If you use the link provided on the Site to make a payment, you will be transferred to the Unifi portal (“Unifi Portal”), which is powered by US Bank.  Any payment information you submit on the Unifi Portal is subject to the Unifi Privacy Policy.  Unifi does not have access to the information you used to make a payment and does not store this information on our servers.  We also collect and retain information pertaining to your orders for our products and services.

Marketing Data. We collect and retain data on your marketing preferences and your subscriptions to our publications.

Your Feedback. You may provide us, and we retain, feedback from you about our Site as well as our products and services generally, which may include data gathered from any surveys in which you participate.

Usage and Technical Data. Like most website operators, Unifi collects certain technical data when you use our Site, such as a user’s Internet Protocol (IP) address, browser type, language preference, referring site, and the date and time when users visit the Site. We may also collect information about the device you’re using to access the Site, including the type of device, the operating system, device settings, and device identifiers.

 When you do not provide personal information that we request, we may not be able to provide you the requested service or complete a transaction, and you agree that Unifi will not be liable or otherwise responsible for any actions resulting therefrom.

INFORMATION SOURCES

Most often, we collect personal information directly from you, such as when you directly engage with us. We may also collect personal information about, or related to you, from third parties, such as our recruitment vendors, background and credit check providers, public agencies responsible for assisting in the employment eligibility and verification prFocess, publicly available sources, and your identified references.  We may also obtain information about you from public sources or third parties. For example, you may also choose to provide us with access to certain personal information stored by third parties such as job-related social media sites (e.g., LinkedIn). We do not request, and please do not provide us with, any details that can be used to access or control any of your social media accounts.

 USE OF YOUR INFORMATION

Unifi may use personal information for several business and administrative purposes, or to further our legal or other business interests. Generally, we use personal information for the following reasons:

Services and transactions. We may use your personal information to deliver services to you or carry out transactions you have requested, including, but not limited to, providing information on our products or services you have purchased or otherwise use, processing product orders, handling warranty claims, answering customer service requests, and facilitating the use of our Site and payment card transactions.

Improving our Business. We may use your personal information to perform business analyses or for other purposes that help us to develop and improve the quality of our business, products and services. We may use your personal information to conduct research, analyze your purchasing preferences, identify the products and services that best meet your requirements, and measure the effectiveness of the advertising we serve you. Where permitted by law, we may combine the information that we collect via our Site with other information we hold about you (such as information about your use of our products and services) in order to offer you an improved and consistent customer experience when interacting with us or for other purposes set forth in this Privacy Policy.

Improving our Site. We use the information we collect to provide full access and functionality of the Site, such as to enable users to enjoy and easily navigate the Site; to protect against users seeking to hack into the Site; and to assess the level of general interest in the Site.

Marketing. In accordance with applicable laws and regulations, we may use your personal information to inform you of our products or services which may be of interest to you, and to otherwise communicate with you about offerings, events, news, surveys, special offers, and related topics. You are able to opt-out from marketing communications sent via e-mail at any time, free of charge by using the “unsubscribe” link in any e-mail marketing materials you receive from us.

Enforcement and Business Interests. We may use the personal information we collect in order to detect, prevent and respond to fraud, intellectual property infringement, violations of our terms and conditions, violations of law or other misuse of our Site, products, or facilities. We may use personal information to administer and protect our business and our Site, including system maintenance, support, reporting and hosting of data. We may, in our sole discretion, use personal information to promote, defend or protect our legal, regulatory, or business interests

Job Applicant Information. We use Job Applicant Information to identify and evaluate job applicants, including assessing skills, qualifications, and interests; communicate with applicants about the recruitment process and your application; comply with our legal, judicial, regulatory, administrative, or other corporate requirements; analyze and improve our application and recruitment process, including by executing satisfaction surveys; accommodate individuals who may have specialized needs during the employment process.

DISCLOSURE OF YOUR INFORMATION

 We may disclose non-personally identifiable aggregated information about our users without restriction.  We may also share personally identifiable information we have collected about you in certain situations. Your information may be disclosed as follows:

Corporate Group Sharing . We share personal information among our affiliates and subsidiaries and these recipients may use your personal information in accordance with the terms and conditions of this privacy policy (e.g., marketing, surveys) or their own data privacy representations. In addition to the foregoing, Unifi may provide, or leverage for our own use, computer networks and systems of affiliates and subsidiaries and the personal information may be transmitted or retained thereon.

By Law or to Protect Rights. If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.

 Third-Party Service Providers. We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. The foregoing explicitly excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Other Third Parties. We may share your information with advertisers and investors for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes, as permitted by law. The foregoing explicitly excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Sale or Bankruptcy. If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party.

Social Media Platforms

We may engage with you on various social media platforms (e.g., Facebook, Twitter, Pinterest, Instagram). If you contact us on a social media platform for customer support or for other reasons, we may contact you via the social media’s direct message tools. Those communications to and from us are governed by this Privacy Policy. However, you use of a social media platform is also subject to the policies and terms of the relevant social media platform. Certain social media platforms may also automatically provide us with your personal information, the information we receive will depend on the terms that govern your use of the social media platform(s) and any privacy settings you may have set. The Site includes social media features and widgets (e.g., the “Facebook Like” button, the “Share This” button) or interactive mini-programs that run on the Site. These features may collect your IP address and which Site page you are accessing and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Site. Your interactions with these features are governed by the privacy statement of the relevant social media platform that provides them.

TRACKING TECHNOLOGIES

Cookies and Web Beacons

We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Site to help customize the Site and improve your experience. For more information on how we use cookies, please refer to our Cookie Policy posted on the Site, which is incorporated into this Privacy Policy. By using the Site, you agree to be bound by our Cookie Policy.

Website Analytics

We may also partner with selected third-party vendors to allow tracking technologies and remarketing services on the Site through the use of first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Site, determine the popularity of certain content and better understand online activity. By accessing the Site, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions.

Site Monitoring

Please be aware that we use cookies and other tracking technologies within the Site to monitor and record any and all activities and communications to, from, and on, the Site in order to safeguard, improve, and analyze usage of, the Site, and for the other purposes listed herein. For the avoidance of doubt, you hereby acknowledge, agree, and consent to, such monitoring and recording.

THIRD-PARTY WEBSITES

The Site may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Site, any information you provide to these third parties is not covered by this Privacy Policy and will be subject to the privacy policy and terms of service of the third-party providing the site or service.  Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Site.  If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.

SECURITY OF YOUR INFORMATION

We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a username and password to access our Site, you are responsible for maintaining the security and confidentiality of those credentials and not revealing them to others. You must contact us immediately if you have reason to believe that your username or password to our Site has been compromised. You acknowledge and agree that we may contact you via email or other electronic communications in the event we are legally required to notify you of a data security incident or event related to your personal information

Our Data Retention Criteria

The period during which we store your personal information varies depending on the purpose for the processing. For example, we store personal information needed to provide you with products and services, or to facilitate transactions you have requested, for so long as you are a customer of Unifi. We store your personal information for marketing purposes until you have opted-out of receiving further direct marketing communications in accordance with applicable law. In all other cases, we store your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy, following which time it is either anonymized (where permitted by applicable law), deleted or destroyed.

DATA LOCATION

Unifi is based in the United States and the personal information that we collect and process is retained and stored in the United States. Please be aware that (i) the United States may not provide the same level of protection of personal information as in your country, state, or jurisdiction of residence or nationality, (ii) the European Union and other foreign authorities have determined that, in some circumstances, the United States does not provide an adequate level of protection for personal information, and (iii) when transferred to the United States, your personal information may be accessible by, or otherwise made available to, United States authorities and officials pursuant to judicial and/or administrative orders, decrees, and demands, and/or other domestic laws, statutes, and regulations, applicable in the United States. By continuing to provide us such information you hereby consent to your personal information being transferred to, and stored in, the United States.

We Do Not Sell Your Personal Information

Unifi does not, to the best of our knowledge, sell or rent, personal information that we have collected or retain about you to any other third-party for any purpose. Accordingly, we do not offer individuals the ability to “opt-out” of the selling or renting of personal information because we do not engage in those practices.

POLICY FOR CHILDREN

We do not knowingly solicit information from or market to children under the age of 13 and children under 13 years of age are not permitted to visit the Site for any reason. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below and we will delete the information.

YOUR RIGHTS AND RESPONSIBILITIES

You are permitted, and hereby agree, to only provide personal information to Unifi if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable data protection law, statute, or regulation.

You may have certain rights under applicable data protection law with respect to personal information about you that is collected through the Sites or when you contact or otherwise engage with us. To exercise any of these data privacy rights, please contact us, or have your authorized agent contact us, in accordance with the “Contact Us” section listed below. In the event you submit, or your authorized agent submits on your behalf, a data request, you (and your authorized agent) hereby acknowledge and agree, under penalty of perjury, that you are (or the authorized agent of) the consumer whose personal information is the subject of the request. We will respond to any data requests within the timeframes required by law, and we may charge a fee to facilitate your request where permitted by law.

Marketing. You have the right to opt-out of receiving electronic direct marketing communications from us.  All electronic direct marketing communications that you may receive from us, such as e-mail messages,

California Privacy Rights. Pursuant to the California Consumer Privacy Act of 2018, as amended (“CCPA”), California residents have additional data privacy rights, including the following:

  • Right to Know: The right to know about what personal information Unifi collects about you, and our intended use of, and purposes for collecting, your personal information. The personal information that we collect from you, the purposes for which it is used, the source of such personal information, and the parties to whom we share your personal information, among other issues, are set forth in this Privacy Policy (see above).
  • Access: The right to access general categories and/or the specific pieces of personal information we have collected, used, disclosed, or sold about you over the past twelve (12) months, including the sources from which the personal information was collected; the business or commercial purpose for which your personal information was collected, used, disclosed, or sold; and, the third parties with whom we have shared your personal information.
  • Deletion/Erasure: The right to request that we delete/erase your personal information under certain circumstances.
  • Data Portability: The right to request that Unifi transfers, to the extent technically feasible, personal information in certain forms and formats.
  • Nondiscrimination: The right not to be subject to discrimination for asserting your rights under the CCPA.

To exercise any of the CCPA’s data privacy rights set forth herein, please contact us in accordance with the “Contact Us” section listed below. If you would prefer, you may designate an authorized agent to submit a CCPA privacy request on your behalf.  An authorized agent must be registered with the California Secretary of State to conduct business in California.

Privacy Request Verification Process. If you (or your authorized agent) makes any request related to your personal information under the CCPA, Unifi will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. Unifi will, to the extent required or permitted by law, require you (or your authorized agent) to verify your request via email or other means and match at least two pieces of personal information we have previously collected from you before granting you access to, or erasing, specific pieces or categories of personal information, or otherwise responding to your request. We may require written documentation that demonstrates a third party is authorized to serve as your agent for the purposes of submitting the requests set forth herein, unless you have provided the authorized agent with power of attorney pursuant to California Probate Code §§ 4121 to 4130. None of the CCPA’s rights are absolute and are subject to legal and regulatory exceptions and exemptions. For more information about the CCPA, please see: https://oag.ca.gov/privacy/ccpa.

Opt-Out Rights / Do Not Sell My Personal Information. California residents have the right to opt-out of the sale of their personal information. However, Unifi does not sell your personal information to third parties for profit, or monetary or other valuable consideration.

European Union (EU), Switzerland, and United Kingdom (UK)

 

Data Protection Rights. If you are located in the EU, Switzerland, or the UK, you have the following data protection rights:

 

  • Right to Know: The right to know about what personal information Unifi collects and processes about you, including the types and categories of personal information we collect and process, the sources of such personal information, our retention criteria, with whom we share your personal information, cross-border data transfers, and how to file complaints and inquiries.

 

  • Automated Decision Making. Unifi does not engage in any activity that subjects our customers, Site users, survey participants, or others to a decision based solely on automated processing, including profiling, which produces legal effects, or similarly significantly results, impacting them.

 

  • Access Rights. You may ask us whether we process any of your personal information and, if so, receive access to such personal information. When complying with an access request, we will also provide you with additional information, such as the purposes of the processing, the categories of personal information concerned as well as any other information necessary for you to exercise the essence of this right.

 

  • You have the right to have your personal information corrected/rectified in case of inaccuracy or incompleteness. Upon request, we will correct inaccurate personal information about you and, taking into account the purposes of the processing, update any incomplete personal information, which may include the provision of a supplementary statement.

 

  • You have the right to have your personal information erased, which means the deletion of your personal information by us and, where possible, any other controller to whom your data has previously been disclosed. However, your right to erasure is subject to statutory limits and prerequisites (e.g., where your personal information is no longer necessary in relation to the initial purposes for which it was processed, your personal information was processed unlawfully).

 

  • Restriction of Processing. You have the right to obtain the restriction of the processing of your personal information, which means that we suspend the processing of your personal information for a certain period of time. Circumstances which may give rise to this right include situations where the accuracy of your personal information is contested, but we need time to verify the inaccuracy (if any) of your personal information.

 

  • Data Portability. You have the right to request us to provide you with your personal information in a structured, commonly used and machine-readable format and to have such data transmitted directly to another controller, where technically feasible.

 

  • Right to Object. You have the right to object to the processing of your personal information, which means you may request us to no longer process your personal information. This only applies in case the “legitimate interests” ground (including profiling) constitutes the legal basis for processing (see below “Legal Basis for Processing”). However, at any time (and free of charge) you can object to having your personal information processed for direct marketing purposes.

 

  • Withdrawing Consent. You also may withdraw your consent at any time if we are solely relying on your consent for the processing of your personal information. However, this will not impact our legal basis to process such personal information prior to the withdrawal of your consent.

 

To exercise any of these data privacy rights, please contact us, or have your designated agent contact us, in accordance with the “Contact Us” section listed below. To the extent permitted by law, we will need to verify your identity (or the identity of your agent) and ensure the authenticity of your request.

 

Legal Basis for Processing. We process your personal information in accordance with the legal bases set forth in law. For example, our processing of personal information (as described herein) is justified based on the following legal grounds:

 

  • Processing is based on your consent (e.g., you register to receive our marketing materials, you voluntarily contact us).

 

  • Legitimate Interests. Processing is necessary for our legitimate interests as set out herein (e.g., monitoring your use of the Site and your compliance with the terms and conditions governing the same, improving our Services).

 

  • Contract Undertaking. Processing is necessary for the performance of a contract to which you are a party (e.g., you purchase or consider purchasing our Services).

 

  • Legal Compliance. Processing is required to comply with a legal or statutory obligation (e.g., tax disclosures).

 

Complaints. In the event you have concerns about our data processing, you have the right to file a complaint with your data protection authority.  For data protection authorities in the EU, please see here: https://edpb.europa.eu/about-edpb/about-edpb/members_en. For the data protection authority in Switzerland, please contact the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home.html). For the data protection authority in the UK, please contact the Information Commissioner’s Office (www.ico.org.uk). We would, however, appreciate the opportunity to deal with your concerns before you approach a data protection authority with a complaint, and invite you to contact us in the first instance.

Persons with Disabilities. Unifi strives to ensure that every person has access to information related to our products and services, including this Policy. Please contact us if you would like this Policy provided in an alternative format and we will seek to meet your needs

 Do-Not-Track Features.  Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

Nevada Privacy Disclaimer.  Pursuant to Nevada law, a Nevada “consumer” (as the term is defined therein), may, at any time, submit a verified request through a designated request address to an “operator” directing the operator not to make any sale of his or her personal information that the operator has collected or will collect about the consumer. For clarity purposes, Unifi does not sell or exchange your personal information for monetary consideration to a third party for the third party to license or sell the information to additional persons or parties.

 CONTACT US

If you have questions or comments about this Privacy Policy, please contact us here. You may also write to us at the following:

Unifi Aviation, LLC.

ATTN: Data Privacy

950 E Paces Ferry, Suite 2000

Atlanta, GA 30326

United States

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