PRIVACY POLICY (AMERICA)

Introduction

When you use any of our BCDA products, you trust us with your information. We are committed to keeping that trust. That starts with helping you understand our privacy practices.

The following privacy policy (hereinafter, the “Privacy Policy”) explains in detail the way in which way we collect your personal data, the reason why we collect it, the purpose for collection, and how we store said data – always in concordance with the services offered by BCDA AERONAUTICAL SOLUTIONS LLC (hereinafter, “BCDA”).

Last Modified: 14/12/2019

Effective Date: 02/01/2020

By accessing our website or applications and using our services, you acknowledge that you have read and understood this Privacy Policy, as well as the information collection and processing practices described herein.

This privacy statement describes how BCDA collects and uses the personal information you provide on the domain umbrella of

  • http://bcdaero.com
  • jetmanpay.com
  • https://jetmanpay.com/
  • our mobile sites and mobile applications, and any other application or access point we make available to you (collectively, our “Web Properties”). It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.
  • Software development partner GP Nauticals LLC (3250 NE 1st Ave suite 305, Miami Florida 33137).

It specifically applies to:

  • Clients: Airline companies, private operators and pilots that use BCDA to manage their aviation o nautical related services.
  • Operators: users who provide aviation or nautical related services (landing fees, passenger fees, fuel, handling, overflight services, or others related to aviation or nautical facilities and authorities worldwide.
  • Reviewers: users that are designated by clients to approve the settlement of pending invoices or services posted by operators.
  • Staff: users that have limited access to information for technical and client support.

This policy also applies to those who provide information to BCDA in connection with an application to use our services, or whose information BCDA otherwise receives in connection with its services. All those subject to this policy are referred to as “users” for purposes of this policy.

What information do we collect?

When you use BCDA products, we may collect your data in the following ways:

  • Information that you provide to BCDA, such as when you create your account.
  • Information created when you use our services, such as airport location, passengers per flight, etc.
  • Information from other sources, such as BCDA partners and third parties that use BCDA

We collect certain personal information that you provide directly to us. For example, we collect the following personal information from you:

  • User information such as your first and last name, contact information, date of birth, email address, passport information and expiration date.
  • Equipment and flight information such as Airplane Tail number, operating company, passenger information, flight route and other aviation related information.
  • Payment information such as credit card details and financial information that may be necessary to facilitate the payment of airport services in the United States or other countries around the world.
  • Photographs or scanned documents (registration, airworthiness, over flights, pilot certificates, medical certificates, airplane and engine logbooks, operating handbooks, quick reference guides, manuals, ID’s, third party contracts for engines, parts or Apu’s).
  • Additional Contact Information about the customer that we may obtain through third parties with whom we do business (e.g. Fixed Based Operators, Airport facilities and other web sites).

How We Use Your Information

BCDA collects and uses information to enable an efficient platform that connects airports or ports and clients for aviation or nautical related services. Specifically, we use the information we collect from you to:

  • Facilitate the transactions per your requests (paying for port services, over flight permits, parking, fuel, flight plans, and other aviation or nautical related services).
  • Assist you through our Apps with record keeping purposes and send emails and notifications when documents or records are about to expire.
  • Provide you with offers, aviation products and other information that may be in their interest.
  • Compile statistics and conduct analysis about your use of our products in order to provide a better service, and to create new features and functions to the present and future users.
  • Administer your account.
  • Assess the needs of your business to determine suitable products and services.
  • Fulfill your order for our services.
  • Link or combine with other information we receive from third parties to help understand your needs, provide you with better service and for marketing purposes.
  • Monitor and analyze activity on our Web Properties.
  • Provide, improve, maintain and operate our services.
  • Send you administrative messages, invoices, order confirmations, security alerts, support messages, technical notices, and updates.
  • Investigate and respond to illegal activities or fraudulent transactions and/or fraudulent usage of our Web Properties.
  • Respond to customer service requests and provide support.
  • Respond to your comments, concerns and questions.
  • Send you requested information and for other purposes which we have notified you about.

We also use the information we collect:

  • To enhance the safety and security of our users and services
  • For customer support
  • For research and development
  • In connection with legal proceedings

BCDA does not sell or share your personal information to third parties for third party direct marketing purposes.

GDPR for EU individuals

In accordance with applicable law on data protection and, more specifically (but not limited thereto), General Data Protection Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, (hereinafter, the “GDPR”), the identifying information for our company’s Data Controller is as follows:

  • Data Controller: BCDA Aeronautical Solutions LLC
  • EIN: 81-1601776
  • Email: info@bcdaero.com
  • Address: 14200 NW 42nd AVE, suite 188 Opa Locka Florida USA 33054
  • Telephone: +1 954 892 43 61

How can you exercise your rights and what rights do you have?

In accordance with current data protection law, you are entitled to the following rights:

Right to access: Users have the right to request, at any time, that BCDA tells them what personal information belonging thereto is currently stored in the BCDA database. In this way, Users can then proceed to modify said information, update it, or delete it.

Right to rectify: Users have the right to request rectification of their personal data held by BCDA if said personal data is inaccurate or incomplete. In the event that a user’s data is shared with a third party, and depending upon the user’s request, we will share the request to rectify the data with said third party – unless this requires a disproportionate amount of effort.

Right to cancel or delete data: Users have the right to request that their personal data be deleted from our database. In this situation, the user must be conscious of the fact that the deletion of his/her personal data brings about the closing of his/her account on the BCDA platform and, as a result, he/she will not be able to benefit from all of the services and advantages that an account with us entails. Remember that once an account is closed, you will no longer be able to log in or access your personal information. Having said that, you can open a new account at any time.

Right to oppose: This right allows Users to oppose the processing of their personal data if we undertake said processing for one of the four reasons listed below: i) as a result of our legitimate interests; ii) as a result of an authorization for us to carry out a task that is in the public interest and/or to exercise official authority; iii) as a result of an interest in sending direct marketing materials; and iv) for scientific, historical, research, or statistical purposes.

Right to withdraw consent: Users, after having given us their express consent to process their data for a series of specific purposes, may oppose the processing of their data for a series of purposes (for example: marketing, profiling, data transfer to a specific third party, etc.). In this case, the user may withdraw their consent at any time so that BCDA stops processing said data for the purposes indicated by the user.

Right to limit consent: In certain situations, Users have the right to ask us to limit the processing of their personal data, which means that we can only continue to store said data and we cannot undertake any other processing activity until: i) one of the circumstances set forth below is resolved; ii) consent is granted; or iii) further processing is needed – whether for formulation, exercise, or defense in legal proceedings, in order to protect the rights of another natural person, or for important reasons of public interest relating with the European Union or a certain Member State.

Users have the right to limit their consent to processing under the following circumstances:

  • If the accuracy of the personal data being processed by BCDA is subject to doubt.
  • If the user opposes the processing of his/her data for our legitimate interests.
  • If the processing of the data is unlawful.
  • If the user feels that we no longer need to continue to process his/her data.

Right to data portability: Users have the right to request data portability to another data controller. In this case, the member will be provided with a digital dossier of all the data held by BCDA so that said data can be transferred to the new data controller.

What are our legal grounds for personal data processing?

The GDPR requires that companies processing the personal data of EU users do so on the basis of specific legal grounds. As described below, BCDA processes the information of EU users based on one or more of the grounds specified under the GDPR:

  • a. The processing is necessary to provide the services and features you request
    • BCDA must collect and use certain information in order to provide its services. This includes:
      • User profile information that is necessary to establish and maintain your account, including to verify your identity; enable communications with you about your aviation services, orders and accounts; and to enable you to make payments for such services.
      • Transaction information, which is necessary to generate and maintain in connection with your use of BCDA’s services.
      • Usage information, which is necessary to maintain, optimize and enhance BCDA’s services, including to determine, sometimes in combination with other information.
    • Collection and use of this information are a requirement for using BCDA’s apps.
  • b. The processing is necessary for BCDA’s legitimate interests
    • BCDA collects and uses personal information to the extent necessary for its legitimate interests. This includes collecting and using information:
      • To maintain and enhance our users’ safety and security. For example, we collect background check information (where permitted by law) to prevent unsafe users from providing services through our apps. We also use personal information to prevent use of our services by users who have engaged in inappropriate or dangerous behavior, such as by retaining information of banned users to prevent their use of BCDA’s apps.
      • To prevent, detect and combat fraud in connection with the use of our services. For example, BCDA uses user profile and usage information, to identify and prevent circumstances when users attempt to defraud BCDA or other users.
      • To inform law enforcement officials regarding criminal acts or threats to public safety.
      • To provide customer support.
      • To optimize our service and develop new services.
      • For research and analytical purposes. This includes, for example, analyzing usage trends to improve the user experience and enhance the safety and security of our services.
      • To enforce BCDA’s Terms of Use.
  • e Consent
    • BCDA may collect and use your information on the basis of your consent. As stated in section above, you may revoke your consent at any time. If you revoke your consent, you will not be able to use any service or feature that requires collection or use of the information we collected or used on the basis of consent.

BCDA relies on consent in connection with data collections or uses that are necessary to enhance the user experience, to enable optional services or features, or to communicate with you

Who do we share your information with?

We may collect and transmit to a third-party partner for the provision of the Services. This type of information is sent complying with the GDPR.

Except as provided for in our Terms of use (or other subscription agreement you entered into with us, if any) and this Policy, we do not disclose your personal information to third parties without your consent.

We do not sell any of your personal information to third parties or allow third parties to use it for their marketing purposes. BCDA uses third-party intermediaries to manage payment processing. These intermediaries are solely links in the distribution chain, and are not permitted to store, retain, or use the information provided except for purposes of payment processing.

We may share your information with third party vendors, consultants and other service providers who are working on our behalf and require access to your information to carry out that work, such as to process billing, provide customer support, etc. For example, we may use third party data centers to host our Web Properties or to store documents uploaded to our application. We obtain appropriate contractual and technical protections to limit these service providers’ use and disclosure of your personal information.

We release personal information if we believe we must do so to comply with the law, to comply with a subpoena, bankruptcy proceedings, or similar legal process, to enforce our User Agreement (or other subscription agreement you entered into with us, if any), or to protect the rights and safety of BCDA, our customers, our individual users and the general public.

If BCDA is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via a prominent notice on our Web site of any change in ownership that affects your personal information, as well as any choices you may have regarding your personal information.

Additional Policy Information

Privacy Shield Policy

BCDA and software development partner GP NAUTICALS LLC (3250 NE 1st Ave suite 305, Miami Florida 33137), comply with the EU-U.S. Privacy Shield Frameworkas set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Unionto the United States. BCDA,has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

You can view our certification at www.privacyshield.gov/list

BCDA is subject to investigatory and enforcement powers of the U.S. Federal Trade Commission. EU Persons may have the option to select binding arbitration under the Privacy Shield Panel for the resolution of your complaint under certain circumstances. For further information, please see the Privacy Shield website. To learn more about the Privacy Shield Framework at https://www.privacyshield.gov.

Accountability for Onward Transfer:

Pursuant to the Privacy Shield Principles, BCDA. remains accountable for Personal Data that it receives under the Privacy Shield and subsequently transfers to a third-party service provider involved in services BCDA provides. In particular, BCDA remains responsible and liable under the Privacy Shield Principles if third-party provider that it engages to process the personal data on its behalf do so in a manner inconsistent with the Privacy Shield Principles, unless BCDA proves that it is not responsible for the event giving rise to the damage.

Recourse Mechanism

In compliance with the Privacy Shield Principles, BCDAcommits to resolve complaints about our collection or use of your personal information. EUindividuals with inquiries or complaints regarding our Privacy Shield policy should first contactBCDA at:

  • BCDA Aeronautical Solutions LLC
  • Email: info@bcdaero.com
  • Address: 14200 NW 42nd AVE, suite 188 Opa Locka Florida USA 33054
  • Telephone: +1 954 892 43 61

or filling out the contact us form in the website www.bcdaero.com

BCDA has further committed to refer unresolved Privacy Shield complaints to JAMS EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Framework, an alternative dispute resolution provider located in the [United States]. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim for more information or to file a complaint. The services of JAMS EU-U.S. Privacy Shield Privacy Shield Framework are provided at no cost to you.

Blogs/Community

Our website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at info@bcdaero.com . In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Data Retention

We will retain your personal information that you provide to us for as long as needed to provide you services or as described in our User Agreement (or other subscription agreement you entered into with us, if any). We will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Links to Other Websites

Our Web Properties include links to other websites whose privacy practices may differ from those of BCDA. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.

Security

When we collect personal information directly from you, we follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. When you enter sensitive information (such as a credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL/TLS). We make every reasonable effort to protect your personal information, but no company, including BCDA, can guarantee the absolute security of Internet communications. If you have any questions, please contact us a info@bcdaero.com.

Choice/Opt-Out for Communications from Us

Customers can opt out of being contacted by us by following the opt-out instructions located in the e-mails we may send you, by changing your privacy settings in the Service, or by contacting us at any time.

Testimonials

We post customer testimonials on our website which may contain personally identifiable information such as the customer’s name. We obtain the customer’s consent prior to posting the testimonial to post their name along with their testimonial. If you want to remove your personal information that is being displayed on our website under public pages, please send your request to info@bcdaero.com.

Updates and Access to Personally Identifiable Information

If your personally identifiable information changes, or if you no longer desire our Service, you may correct, update, amend, delete/remove or deactivate it using the Account Administration settings, contacting an administrator of your organization’s BCDA Account, by emailing info@bcdaero.com or by contacting us by telephone or postal mail at the contact information listed below. We will respond to your request to access within 5 days.

Notification of Privacy Statement Changes

We may update this privacy statement to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on our Web Properties prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Information

Questions regarding our Policy or the practices concerning our Web Properties should be directed info@bcdaero.com as a security question.

This document was last updated on 02/01/2020.

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