Aero Connect, LLC (“Aero Connect,” “we” or “our”) is an online commercial aircraft and engine marketplace where owners of aircraft and engines list their assets available for sale or lease. Listings are then available to the public, including companies that operate, own or lease such assets.

In this Privacy Policy (“Policy”), we describe the information that we collect from visitors to our website, www.wordpress-932870-3239134.cloudwaysapps.com (the “Site”).  Unless expressly noted otherwise, this Policy applies our Site and our online products and services (collectively, “Services”).  By visiting our Sites or using any of our Services, you agree that your personal information will be handled as described in this Policy, which is incorporated by reference into the Aero Connect, LLC Terms and Conditions.

We may collect information about both businesses and individuals.  The information we collect from you allows you to log into our Site; register for Services; and provide our Services to you.  We also use this information to personalize and continually improve our Site and Services.  Generally, we collect information about you directly from you or your use of our Services, but in some cases we may collect information about you from third parties.

Account Information for our Sites.  You may browse our Site without creating an online account, but to access detailed reports regarding listed aircrafts and engines or post information regarding available aircrafts and engines, you must create an account.  When you create an account with us, we may collect the following:

• Your first and last name;
• Your Company name;
• Your email address and your desired password;
• Your mailing address;
• Your phone number;
• Whether your primary focus is aircrafts, engines or both
• Your areas of focus within the industry; and
• Payment information (if applicable).

Any information that you post to our Site may be viewable by other users, as well as visitors to our Site.  If you post content to our Site, we may collect and use that information. Aero Connect is not responsible for the privacy of any information that you choose to post to our Site or for the accuracy of any information contained in those postings.  Any information that you disclose becomes public information.  We cannot prevent such information from being used in a manner that may violate this Policy, the law or your personal privacy.  You should have no expectation of privacy in the information you post to the Site. Futhermore, we reserve the right to read any emails sent to you via the “Send Email to Owner/Rep” function of our website. We may use the information contained in these emails to our economic benefit.

We also may collect information, including personally identifiable information, about you from affiliated and non-affiliated third parties. For example, we may collect, from available databases, information regarding the lessees of aircrafts and engines. Where permitted by law, we may share information we collect about you among affiliated and non-affiliated third parties to identify products and services that we believe might be of interest to you.

We may use cookies, web beacons, and other automated devices to collect information, including personally identifiable information, about you when you visit our Sites and receive emails from us.  Specifically, we may collect the following information about your use of our Sites via these technologies:  your browser type and operating system; web pages you view; links you click; your IP address; your interaction with the Sites; length of time you are logged in to our Site; and websites visited before our Sites.  Please see the section “What About Cookies and Other Tracking Devices” below for more information about our use of cookies.  We may use the information gathered through these methods in anonymous or aggregated form to analyze ways to improve our Site or Services.  This information also is associated with your username and may be combined with other information, including personally identifiable information that we collect about you.

We use the information that we gather about you for the following purposes:

• To provide our Services to you and for internal business purposes, including billing, training, quality assurance, site administration and customer service;
• To provide information and other communications to you regarding our Sites and Services, including the Aero Connect Outlook, promotional emails and partner emails;
• To tailor the content and information that we may send or display to you, and to otherwise personalize your experiences while using our Site and Services;
• To improve our Site and Services, including by providing personalized experiences, location customization, personalized help and instructions;
• For research and product development purposes;
• For marketing and advertising purposes; for example, we may use your information to: display targeted advertisements to you on our Site, send advertisements or other marketing materials to you and to assist us in advertising our Services to third parties or on third party websites; and
• To better understand how users access and use our Site and Services, both on an aggregated and individualized basis.

We may share your information, including personally identifiable information, with other users and affiliated and non-affiliated third parties as described in this section.

• Users of Aero Connect Site.  Any information that you post to the Site, including without limitation pictures, comments and text, will be available to other users of our Site.  This information also will be searchable by users of our Site.  This information is publicly available upon posting.
• Affiliates.  We may disclose the information we collect from you to our affiliates or subsidiaries to assist us in providing our services to you and for marketing products and services that we believe would be of interest to you.
• Service Providers.  We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf.  For example, these providers may help us administer our Site.  These third parties have agreed to maintain the confidentiality, security and integrity of information, and to only use such information for the purposes for which they have been engaged by us.
• Other Non-Affiliated Third Parties.  We may disclose the information that we collect about you to non-affiliated third parties, such as promotional partners and others with whom we have marketing or other relationships.  Those third parties may use your information for marketing purposes, such as to market products and services that they believe would be of interest to you.  We also may combine the information that we collect about you with other information that we obtain from third parties.  This information may help us to determine what advertisements to direct to you, to place on our website, and where to advertise our Services.  As discussed in the advertising section below, you have the right to opt out of certain uses of your information.  You also have the ability to opt-into the receipt of certain information from us and non-affiliated third parties.  We may share your information to respond to your choices.

We also may share your information for the following reasons:

• Business Transfers.  If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the acquiring company.
• In Response to Legal Process.  We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order or other legal process, such as in response to a subpoena.
• To Protect Aero Connect and Others.  We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms and Conditions or this Policy.
• Aggregate and Anonymized Information.  We may share aggregate or anonymized information about users with third parties for marketing, advertising, research or similar purposes.  For example, if we display advertisements on behalf of a third party, we may share aggregate, demographic information with that third party about the users to whom we displayed the advertisements.

When you interact with the Site, we strive to make your experience easy and meaningful.  We or our third party service providers use cookies, web beacons (including clear GIFs), Flash LSOs, and similar technologies to track user activity and collect website and Application data.  We may combine this data with the personal information we have collected from you.

Cookies.  Cookies allow a web server to transfer data to a computer for recordkeeping and other purposes.  We and our third party service providers may use “cookies” on our Site to, among other things, better serve you with tailored information and facilitate your ongoing access to and use of the Site.  There are two types of cookies: session-based and persistent cookies. In addition, we also allow vendors to use cookies on our Site.

• Session Cookies.  Session cookies exist only during an online session.  They disappear from your computer when you close your browser or turn off your computer.  We use session cookies to allow our systems to uniquely identify you during a session or while you are logged in to the Site.  This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Sites.
• Persistent Cookies.  Persistent cookies remain on your computer after you have closed your browser or turned off your computer.  We use persistent cookies to track aggregate and statistical information about user activity, which may be combined with other user information.
• Third Party Cookies. We may also engage third parties to track and analyze non-personally and personally identifiable website data and to serve advertisements.  To do so, we may permit third parties to apply cookies to users of our Site, where permitted by law, and, subject to your right to opt-out through the Network Advertising Initiative and About Ads (as discussed below).  We use the data collected by such third parties to help us administer and improve the quality of the Site and to analyze site usage.  Such third parties may combine the information that we provide about you with other information that they have collected.  These third parties are required to use your information in accordance with this Policy.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in future.  The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.  Visitors to our Site who disable their web browsers’ ability to accept cookies will be able to browse the Site; however, many site features, such as the shopping cart, will not function if you disable cookies.

Local Storage Objects.  We and our third party service providers may use Flash Local Storage Objects (“Flash LSOs”) in order to store your Site preferences, to personalize your visit or to display content based upon what you view on our Site.  Flash LSOs are different from browser cookies because of the amount and type of data stored.  In addition, you cannot control, delete or disable the acceptance of Flash LSOs through your browser.  For more information on Flash LSOs, or to learn how to manage your settings for Flash cookies, go to the Adobe Flash Player Help Page, choose “Global Storage Settings Panel” and follow the instructions.  To see the Flash LSOs currently on your computer, choose “Website Storage Settings Panel” and follow the instructions to review and, if you choose, to delete any specific Flash LSO.

Web Beacons, Pixel Tags and Other Technologies.  We may use web beacons, such as clear GIFs, web bugs or pixel tags, which are tiny graphics with a unique identifier similar in function to cookies.  In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages.  We may use clear GIFs in connection with our Site to, among other things, track the activities of website visitors, help us manage content, and compile statistics about website usage.  We and our third party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, measure the success of our marketing campaigns, identify when our e-mails are viewed and track whether our e-mails are forwarded.

Site Analytics.  As noted, Aero Connect works with third party service providers who use the technologies described in this section to conduct website analytics to help us track and understand how visitors use our Site.  For example, we use a variety of third party web analytics, to help us improve our Site’s performance and user experiences.

Third-Party Ad Networks.  We may use third parties such as network advertisers to serve advertisements on our Site.  Please see the section entitled “Advertising” for additional information about our practices and your choices with regard to receiving such advertisements.

We display advertisements on our Site.  Some of the advertisements are based on the collection of personal information and others are based on the collection of aggregate information.  Please see the bottom of this section for opt-out information.

We use third parties such as network advertisers to serve advertisements on our Site.  Network advertisers are third parties that display advertisements based on your visits to our Sites and other websites you have visited.  This enables us and these third parties to target advertisements to you for products and services in which you might be interested.  Third party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other technologies to measure the effectiveness of their ads and to personalize advertising content to you.  These third party cookies and other technologies are governed by each third party’s specific privacy policy, not this one.  We may provide these third-party advertisers with information about your usage of our Sites and our Services, both personally identifiable and non-personally identifiable information.

You may opt-out of many third-party ad networks.  The website http://www.networkadvertising.org/optout_nonppii.asp provides information regarding this practice by Network Advertising Initiative (“NAI”) members, and your choices regarding having this information used by these companies, including how to “opt-out” of third-party ad networks operated by NAI members.  You also may contact About Ads at http://www.aboutads.info/choices/ for information about opting out of targeted advertising and your choices regarding having information used by About Ads member companies, including how to “opt-out” of third-party ad networks operated by About Ads members.  Opting out of one or more NAI members or About Ad members (many of which will be the same) only means that those members no longer will deliver targeted content or ads to you, but it does not mean you will no longer receive any targeted content or ads on our Site or other websites.  You may continue to receive advertisements, for example, based on the particular website that you are viewing.  Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your NAI or About Ad opt-out may no longer, be effective. Additional information is available on NAI’s and About Ad’s websites accessible by the above links.

At times, our Site may contain links to other third party websites.  Any access to and use of such linked websites is not governed by this Policy, but, instead, is governed by the privacy policies of those third party websites, and we are not responsible for the information practices of such third party websites.

We have implemented commercially reasonable precautions, including, where appropriate, password protection, encryption, and SSL to protect our Site and the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.  Please be aware that despite our best efforts, no data security measures can guarantee 100% security all of the time.

You should take steps to protect against unauthorized access to your password, computer, and web-enabled devices, among other things, by signing off after using a shared computer, inserting a password on your web-enabled device, choosing a password that nobody else knows or can easily guess, and keeping your password private.  You should never share your log-in information with others.  We are not responsible for any lost, stolen or compromised passwords, or for any activity on your account via unauthorized password activity.

You may modify any account information that you have submitted, by logging into your account and updating your information.  Please note that copies of information that you have updated or modified may continue to reside in our systems for a period of time.

If, at any time, you would like to stop receiving promotional e-mails from us, you may follow the opt-out instructions contained in any promotional e-mail you receive from us.  Please note that it may take up to 10 business days for us to process opt-out requests.  If you opt-out of receiving promotional emails from us, we still may send you e-mails about your account or any Services you have requested or received from us, or for other customer services purposes.

Your use our Site or Services, as well as any dispute over privacy, is subject to this Policy and our Terms and Conditions, http://www.wordpress-932870-3239134.cloudwaysapps.com/terms, including applicable limitations on damages and the resolution of disputes.

If you are located outside of the United States, please note that information we collect will be transferred to and processed in the United States.  By using our Site, you consent to the transfer and processing of your information in the United States, which does not have data protection laws that provide the same level of protection that exists in countries in the European Economic Area.  Your consent is voluntary.  If, however, you do not consent, then we may not be able to provide you with our Services.

California residents may request a list of all third parties to which Aero Connect has disclosed certain personally identifiable information about you for their direct marketing purposes.  You may make one request per calendar year.  In your request, please attest to the fact that you are a California resident and provide a current California address for your response.  You may request this information in writing by contacting us at:
Attn: Chief Executive Officer
1900 S. Norfolk, Suite 350
San Mateo, CA 94403-1171
Phone: 415-503.3671
Email: obrown@aeroconnect.com

If you have any questions, comments or concerns, please contact us at:
Attn: Chief Executive Officer
1900 S. Norfolk, Suite 350
San Mateo, CA 94403-1171
Phone: 415-503.3671
Email: obrown@aeroconnect.com

Our Site is not designed for children under 13.  Only those persons age 18 or older may create an account with us.

We may change this Policy from time to time, so be sure to check back periodically.  We will post any changes to our policy to our Site.  If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change, by highlighting the change on the Site or by sending an email to you at the email address that you have registered with us.

1/15/2021