Last revision on April 3, 2019

About this privacy statement

Your privacy is important to us. Camber Aviation Management Ltd. and all its business segments, divisions and subsidiaries (collectively “Camber”, “we” or “our”) are committed to conducting business in a way that complies with applicable data protection laws and regulations in every country in which Camber operates. We are committed to protecting personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at solutions@camberaviation.com.

We seek to explain to you in the clearest way possible what information we collect, store, use and safeguard personal information and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important.

Generally, the Camber entity that operates the site you visit or the entity that you interact with offline is the entity that acts as controller of any personal data collected through your interaction and is the entity that is primarily responsible for how your personal data is used. Camber also acts as data controller in respect of certain centralized data processing activities.

For your information and convenience, our Site(s) may contain links to other websites (e.g. YouTube) or apps run by other organizations, which we do not control. This privacy statement does not apply to those other websites and apps‚ so we encourage you to read their privacy statements to stay informed of how they use your personal data.

We comply with the terms of the EU General Data Protection Regulation n° 2016/679 (the “GDPR”).

What information do we collect?

In Short: We collect personal information that you provide to us such as name, address, contact information, security data, and payment information.

The personal data we collect depends on the ways in which you interact with Camber and it may include the following: Name, Contact and General Data.

The personal data we collect depends on the ways in which you interact with Camber and it may include the following:

• Your name, address and contact details, including email address, telephone number, and other similar contact information.
• Your occupation level of education, age, gender, country, income, preferred language, and similar demographic information.
• Your location, including the location derived from your IP address.
• Your interests and preferences including the languages or cities you prefer, your preferred services and products, and other similar data that help us build up a picture of your interests and preferences.
• Data about your device (including device identifiers) and how you and your device interact with our site(s).
• Data about your device (including device identifiers) and how you and your device interact with our site(s).
• Other information you provide to us and the content of messages you send to us when you make personal data inquiries or request services.

We do not knowingly collect personal data from anyone under the age of 16. How we collect your personal data?

In Short: Some information – such as IP address and / or browser and device characteristics – is collected automatically when you visit our Sites. We may collect limited data from public databases, marketing partners, and other outside sources.

• Data obtained from you directly: You provide personal data to us when you purchase our services, submit a message to us via our website, interact with us on social media (e.g. LinkedIn), provide a testimonial, comment on posts or articles featured on our Site(s)
• Data obtained from third parties: We may obtain information about you from other sources, such as public databases, joint marketing partners, as well as from other third parties. Examples of the information we receive from other sources include social media profile information, marketing leads and search results and links, including paid listings (such as sponsored links).
• Data obtained through cookies: We also collect personal data about you by using cookies to record how you interact with our site(s). You can learn more about cookies and how we use them in our Cookie Policy.

How do we process your information?

In Short: We process your information for purposes based on legitimate business interest, the fulfillment of our contract with you, compliance with our legal obligations, and /or your consent.

Camber processes your personal data for different purposes, during and after the end of your relationship with us.
These purposes include:

• Providing you the site(s) and offline interactions.
• Enabling or administering our business, including administering customer accounts, responding to supplier inquiries and monitoring quality assurance.
• Understanding and improving our business or customer relationship generally with a view to improving our products and services and developing new ones.
• Protecting you, us or others from threats, such as security threats or fraud.
• Managing corporate transactions

We will only use your personal data where we have lawful bases for doing so. Lawful bases include, among others, each one of the following:

• Consent (where you have given consent).
• Contract (where using your personal data is necessary for the performance of a contract with you).
• Legal obligation (where using your personal data is necessary for compliance with laws that apply to us).
• Vital interests (where using your personal data is necessary to provide urgent safety notices or product recalls).
• Legitimate interests (where we have legitimate interests and they do not outweigh your privacy rights).

Where we rely on your consent to use your personal data, you have the right to withdraw or decline your consent at any time. Please see the ‘Your rights regarding your personal data’ section for further details on how you can do this.

If you have any questions about, or objections to, the lawful bases upon which we use your personal data, please contact our office in any of the ways described at the end of this privacy statement.

Marketing and Advertising

You may receive marketing communications from us, or from third parties used by us to send marketing communication on our behalf, if you have opted in to receive such material. Our marketing communications will always include the option for you to unsubscribe from receiving any further marketing communications.
If you have previously agreed to us using your information for direct marketing purposes, you may change your mind at any time by writing to us at solutions@camberaviation.com.

We may share your personal data with our third-party advertising partners in order to serve you targeted ads on our site(s) or on third party websites and online services.

Our advertising partners may then use cookies to measure the effectiveness of the ads.

For more information on how to reject targeted advertising or interest-based advertising cookies please read our Cookie Policy.

Most web browsers and some mobile operating systems and mobile applications 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 signal has been finalized. As such, we do not currently respond to SNT browser signals or any other mechanism that automatically communicates to 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.

You have the right to object to our use of your personal data for marketing and advertising purposes, or – where we rely on your consent to use your personal data for marketing and advertising purposes – to withdraw your consent. Please see the ‘Your rights regarding your personal data’ section for more details.

How we store, process, transfer and protect your personal data

In Short: We may transfer, store, and process your information in countries other than your own. We keep your information for as long as necessary to fulfill the purposes outlined in his privacy policy unless otherwise required by law. We aim to protect your personal information through a system of organizational and technical security measures.

The personal data we collect about you will be stored in a range of different places, including on our server, in our CRS systems and databases.

Because we perform business across the globe, we may process your personal data in different geographical locations (including outside the European Economic Area).

We only share your personal data on a need-to-know basis as follows:

• Internally, with various Camber departments, including, for example sales, marketing, communications, finance, legal, procurement and information technology (“IT”).
• Externally, with third parties that help us run our business, including, for example, third parties that manage our IT systems, serve advertisements, collect customer accounts and verify customer credit.

To ensure that your personal data is adequately protected no matter where it is processed, we have internal policies and controls in place to prevent your personal data from being lost, accidentally destroyed, misused, unintentionally disclosed, or accessed other than by our employees or third parties hired by Camber.

For example, we request that Camber team members familiarize themselves with our IT policies governing data security. When we engage third parties to process personal data on our behalf, we require that they do so based on Camber’s written instructions, under a duty of confidentiality, and in accordance with technical and organizational measures that are appropriate to ensure the security of your personal data.

What are your privacy rights?

In Short: In some regions such as the European Economic area, you have rights that allow you greater access to and control over your personal information. You may review, change or erase your information at any time.

You have several rights regarding your personal data. You may also have additional rights depending on your jurisdiction.

• Accessing your personal data. You can request a copy of the personal data we hold about you.
• Updating and correcting your personal data. You can ask us to update or correct your personal data at any time if you discover that any of it is inaccurate or out of date.
• Erasing your personal data. You can require Camber to erase personal data in certain circumstances and we will take reasonable steps to inform other controllers that are processing the data that you have requested the erasure of any links to, copies or replication of the data. Your personal data will be removed from Camber’s systems within a reasonable time and will be deleted. However, Camber may retain a copy of your personal data (i) if and as long as required by law, regulation, administrative or court order or for internal auditing purposes, or (ii) as electronic data stored due to automatic archiving and back-up procedures. Please note that in the event of a legal dispute between you and Camber, your personal data may be retained until final settlement of the legal dispute.
• Objecting to or restricting the processing of your personal data. If you would like us to stop Processing your Personal Information, you can request this by contacting us as set forth under “How Can You Contact Us?” below. We will assess your request and deter-mine, under applicable law, whether we have any justification for the continued Processing.
• Withdrawing your consent. Where we rely on your consent as the legal basis for processing your personal data, you can withdraw your consent at any time, and you can prevent further processing if there is no other legal basis upon which Camber can process your personal data.
• Transferring your personal data. You can ask us to transfer the personal data that we hold about you to a third party electronically.

If you would like to exercise any of these rights, please advise Camber by sending us an email at: solutions@camberaviation.com. You can also raise a complaint about our data processing practices with the data protection regulator in your jurisdiction. Please see the ‘How you can contact us about this privacy statement or make a complaint’ section below.

Notice to California Residents: Your California Privacy Rights: If you are a resident of California, California Civil Code Section 1798.83 allows you to request information regarding the Personal Information we collected during the preceding calendar year. To make such a request, please send an email tosolutions@camberaviation.com or send a letter to: Camber Aviation Management Ltd. , PDS – Tina Szylowski, #301 37989 Cleveland Avenue, Squamish, British Columbia V8B 0A3.

How long we keep your personal data

The period for which your personal data is held is determined by several factors including the purpose for which we use that personal data and our legal obligations. We do not generally retain personal data in an identifiable form for longer than is necessary, though in some cases we may choose to retain certain personal data in a depersonalized or aggregated form.

Do we make updates to this policy?

In Short: yes, we will update this policy as necessary to stay compliant with relevant laws. We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to the privacy policy, we may inform you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

How you can contact us about this policy?

If you have any questions or suggestions about this privacy statement or about how we use your personal data, please contact our office at:

Camber Aviation Management Ltd.
301 37989 Cleveland Avenue
Squamish, British Columbia, V8B0A3
Canada

solutions@camberaviation.com