VSE Aviation, Inc. with its headquarter located at 8578 NW 23rd Street, Doral, Florida 33122, USA (“VSE”, “us”, “we”, or “our”) operates http://www.vseaviation.com (the “Website”). This Privacy Policy (“Policy”) applies to information about you which we process (“Personal Information”) through the Website.
We respect the privacy of your information. We provide this explanation about our online information practices as a show of our commitment to protect your privacy.
We do not sell or rent Personal Information collected during your use of our Website without your permission.
1. The Personal Information We Collect
At the time you visit our Website, or you send us a communication, we collect and store such Personal Information as you may provide by filling in forms or data fields on our Website, or by corresponding with us by phone, email or otherwise. This includes Personal Information you provide to us when you complete a contact or a submission form, register for events, pay a bill or subscribe to VSE communications. This (depending on the circumstances) can include your name, address, telephone number, e-mail address, payment information, bank information, VAT number, EORI number, certifications (FAA or EASA), billing address, shipping address, sales tax certifications and other Personal Information.
In addition, we automatically gather general statistical information about our Website and its visitors, such as IP addresses, browsers, pages viewed, number of visitors, etc., but in doing so we do not reference you by individual name, e-mail address, home address, or telephone number. We use this data in the aggregate to determine how much our customers use parts of the Website and so we can improve the Website. We may provide this statistical information to third parties, but when we do so we do not provide any personally-identifying information without your consent.
If you use a mobile device to access our Website or online resources, we may collect information about your device, including your device ID and device type, as well as usage information about your device and your use of our mobile Website.
We engage service providers who provide us with technical services, including related to payment processing, data analytics, and advertising, from whom we receive and process Personal Information about you. We may also receive Personal Information about you from business associations and credit agencies.
In addition, we may collect Personal Information about you from our affiliates and our partners and their service providers and contractors. For example, this may include your current job position, business address, company name, and position title provided by your employer. We also may obtain information you have made publicly available, including from websites and online services you use, consumer research platforms, and/or business contact databases. WE DO NOT CONTROL AND ARE NOT RESPONSIBLE FOR ANY ACTIONS OR POLICIES OF SUCH THIRD PARTIES.
2. The Way We Use Information
We use your Personal Information for legitimate business purposes and in accordance with the legal bases further described in this Policy in Section 3, and in accordance with applicable data protection laws, including the European General Data Protection Regulation (“GDPR”) and its UK equivalent (“UK GDPR”).
We may use your Personal Information:
- to provide you with the information, goods and services that you request from us;
- to deliver information to you that, in some cases, is targeted to your interests, such as e-mail alerts and news updates;
- to notify you about changes to our products or services, or changes to regulatory requirements that may affect our products or services or your use of them;
- to provide you with the possibility to pay online for the goods or services you have requested from us; and
- to administer your account.
We may ask you to provide us voluntarily with additional Personal Information regarding your personal or business interests, experience or requests which we may use to customize our service for you.
We use your e-mail address, your mailing address, and phone number to contact you regarding administrative notices and communications relevant to your use of the Website. We will not send you promotions or announcements unless you permit us to do so. You can opt-out of receiving such contact by so indicating in your registration/preferences file.
We (or a third party designated by us) use Personal Information collected from your computer or electronic device as follows:
- to improve our Website and ensure that content is presented in the most effective manner for you and your computer or device;
- to help diagnose problems with our server, to manage the Website and to enhance our Website based on the usage pattern data we receive;
- to measure or understand the effectiveness of advertising we deliver to you and others, and to deliver relevant advertising to you; and
- to make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them.
We may also use or disclose Personal Information to resolve disputes, investigate problems, or enforce our Terms of Use or Terms and Conditions. At times, we may review the status or activity of multiple users to do so. We may disclose or access Personal Information whenever we believe in good faith that the law so requires or if we otherwise consider it necessary to do so to maintain service and improve our products and services.
3. Legal Basis
We process your Personal Information on the following legal basis:
- If it is necessary for pursuit of, or to safeguard, the legitimate interests of VSE, provided that these interests are not overridden by your interests or fundamental rights and freedoms.
- If it is necessary to fulfill our contractual obligations. The extent and purpose of our use of your Personal Information depends on the contract that we have concluded with you.
- If it is required to comply with our legal obligations. These obligations may arise from applicable provisions of national or regional (European) laws or regulations, including regarding commerce, trade, and tax.
- If you consent to our use of your Personal Information. If you have given us your prior consent, we will use your Personal Information in a manner consistent with the scope of that consent.
4. When and How We Share Information with Others
If permitted pursuant to our contractual obligations with you, we may share your Personal Information with other VSE affiliates. We make your Personal Information available to our affiliates as necessary to fulfil our legal and contractual obligations. For example, where permitted, we share your Personal Information with our affiliates to facilitate the provision of centralized supplier or customer management services, centralized IT services, and internal finance and accounting shared services.
We may also share your Personal Information with third-party service providers used to support our business in order to fulfil certain of our contractual and legal obligations as well, including:
- Providers of marketing related services and solutions for our own goods and services;
- Public authorities and national administrations;
- Providers of auditing services;
- Providers of IT related services and solutions;
- Providers of banking services and solutions;
We will also disclose your Personal Information to third parties:
- In the event we sell or buy any business or assets in connection with an acquisition, merger into another entity or consolidation, share exchange, combination, bankruptcy or reorganization proceeding, in which case we may disclose and transfer your Personal Information to the prospective seller or buyer of such business or assets;
- If VSE or substantially all or some of its assets are acquired by a third party, in which case Personal Information held by it about its customers may be one of the transferred assets;
If we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation or to protect the rights, property, or safety of VSE, our customers, or others. This includes sharing Personal Information with public authorities (including judicial and police authorities) in the event of, for example, a cyber security incident.
5. International Transfer of Your Personal Information
If you are based in the European Economic Area (“EEA”) or the UK, we may transfer your Personal Information to a destination outside the EEA/UK, which includes transfers to the USA. Such transfers can be performed, if appropriate to (i) achieve any of the purposes set out in Section 2., or (ii) disclose your Personal Information to a third party, in accordance with Section 4.
These transfers are secured by appropriate safeguards (such as EU Standard Contractual Clauses) where required.
VSE also enters into data processing agreements and appropriate safeguards with its service providers whenever feasible and appropriate.
Specifically with regard to Personal Information collected via cookies, please note that in some cases cookie information may also be processed by our service providers or by the providers of third-party cookies in countries outside the EEA/UK, which do not offer a level of data protection comparable to the EEA/UK (as applicable). The transfer is also usually secured by appropriate safeguards (such as EU Standard Contractual Clauses and where necessary the UK Addendum or the IDTA). Some service providers or providers of third-party cookies may also have certified themselves under the EU-US Data Privacy Framework and its UK Extension.
If you wish to receive more information relating to the transfers of such information originating from the EEA/UK or the safeguards that have been implemented (including on how to receive a copy thereof), you can contact us as set out in Section 18 below.
6. Information for EEA/UK Residents
If you are a resident of the EEA/UK (or if the GDPR or the UK GDPR are otherwise applicable to you), this section describes our practices and your rights under the GDPR und the UK GDPR, whereby references to the GDPR in this section include the UK GDPR. This section provides rights and other terms relating to your Personal Information that are in addition to those provided in this Policy. These additional rights and other terms are only available to EEA/UK residents (or individuals to whom the GDPR is otherwise applicable) whose Personal Information we are processing.
6.1 Overview of the Processing of Your Personal Information
We provide this overview to summarize the processing of your Personal Information as described in the foregoing sections and to connect in particular the purpose of the processing with the relevant data categories and legal bases.
| Processing Purpose | Data Categories | Legal Basis |
|---|---|---|
| Providing goods and services you have requested | Purchase information, contact information, shipping/billing information, bank account information, credit card information | Performance of a contract (Art. 6 (1) lit. b GDPR; references to the GDPR in this Section include the UK GDPR) |
| Providing the information you have requested | Contact information | Performance of a contract (Art. 6 (1) lit. b GDPR) or legitimate interest in replying to your query (Art. 6 (1) lit. f GDPR) |
| Providing you information about goods or services | IP address, email address, full name, phone number, contact information | Consent (Art. 6 (1) lit. a GDPR) or legitimate interest in promoting our business (Art. 6 (1) lit. f GDPR) |
| Administering warranties | IP address, email address, full name, type of business, VAT number, EORI number, certifications (FAA or EASA), phone number, billing address, shipping address, contact information, bank information, bank account number, routing number, sales tax certifications, purchase information | Performance of a contract (Art. 6 (1) lit. b GDPR) |
| Administering your account | IP address, email address, full name, phone number, contact information, bank account number, routing number, payment details | Performance of a contract (Art. 6 (1) lit. b GDPR) |
| Improving our Website | IP address, User ID, tracking history | Consent (Art. 6 (1) lit. a GDPR) or legitimate interest in improving our services (Art. 6 (1) lit. f GDPR) |
| Enabling operation, maintaining the safety and security of our Website | IP address, tracking history | Legitimate interest in the security of our Website (Art. 6 (1) lit. f GDPR) |
| Strictly necessary cookies | IP address, tracking history | Legitimate interest in providing our Website as requested by you (Art. 6 (1) lit. f GDPR) |
| Performance cookies and targeting cookies | IP address, User ID, tracking history | Consent (Art. 6 (1) lit. a GDPR) |
6.2 Your EEA/UK Resident Specific Rights
If you are a resident of the EEA/UK (or if the GDPR or the UK GDPR are otherwise applicable to you), you have certain rights regarding the Personal Information we hold about you.
- You have the right to object to certain types of processing of your Personal Information, including processing for direct marketing purposes.
- You have the right to access your Personal Information and to request a copy of the Personal Information undergoing processing.
- You have the right, under certain circumstances, to block or restrict our processing of your Personal Information.
- If your Personal Information is inaccurate or incomplete, you have the right to request rectification or completion of your Personal Information.
- You have the right, under certain circumstances, to request the erasure of your Personal Information from our systems.
- You have the right to obtain from us, under certain circumstances, your Personal Information in a structured, commonly used and machine-readable format so you can reuse it for your own purposes and across different services (right to data portability).
- If our processing of your Personal Information is based on your consent, you have the right to withdraw that consent at any time with effect for the future.
- We do not engage in any automated decision making with your Personal Information.
If you would like to exercise or discuss any of these rights, please contact us as set forth in Section 18, below.
If you are unsatisfied with our handling of your Personal Information, you also have the right to lodge a complaint with the competent data protection authority. A list of the relevant data protection authorities can be found here.
7. Information For California Residents
If you are a resident of California, this section describes our practices and your rights under the California Consumer Privacy Act of 2018, as amended (“California Law”). This section provides rights and other terms relating to your Personal Information that are in addition to those provided in this Policy. These additional rights and other terms are only available to California residents about whom we collect Personal Information.
7.1 What Personal Information We Collect
When you choose to contact us or otherwise interact with us, including in the context of your business relationship with us, we may collect or receive information about you as described in Section 1.
7.2 How We Collect Your Personal Information
We collect your Personal Information in the ways described in Section 1.
7.3 How We Use Your Personal Information
We may use each of the categories of Personal Information described above for one or more of the following purposes consistent with Section 6 above.
7.4 How We Disclose, Share or Sell Your Personal Information
We may disclose your Personal Information to third parties for a business or commercial purpose. In the past 12 months, we may have disclosed your Personal Information to third parties as set forth under Section 4 above.
We do not sell or share your Personal Information as defined by California Law. We do not knowingly sell or share the Personal Information of consumers under 16 years of age.
7.5 Your Rights and Choices under California Law
Below is a description of key rights California consumers have under the California Law and an explanation of how to exercise those rights with us.
Right to Know. You have the right to request that we disclose certain information to you about our collection and use of your Personal Information.
Right to Delete. You have the right to request that we delete any of your Personal Information that we collected from you and retained, unless an exception under California Law applies. For example, the information may be excluded or not constitute Personal Information under California Law. We may also deny your deletion request if the Personal Information is required to complete the transaction for which the information was collected or to provide you with requested goods or services.
Right to Correct Inaccurate Personal Information. You have the right to request that we correct any of your Personal Information that we maintain about you.
7.6 Exercising Your California Law Privacy Rights
You do not need to create an account with us to exercise your California Law privacy rights. To exercise the rights described above, please submit a request to us by either: (i) visiting our Privacy Preference Center or (ii) emailing us at DPO@VSECorp.COM or calling +1 833-641-2699.
To exercise your right to know, delete, or correct your Personal Information as described above, we need to verify your identity or authority to make the request and confirm the Personal Information relates to you. We may deny your request if we are unable to verify your identity. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit adequate proof that you authorized them to act for you.
We will not provide discriminatory treatment against anyone that exercises any of their rights.
8. Security
We have implemented security features throughout our Website to prevent the unauthorized release of, or access to, Personal Information we collect and receive from you.
However, no data transmission over the Internet or any wireless network can be guaranteed to be perfectly secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. Any Personal Information you transmit to us is done at your own risk.
9. How You Can Update, Correct or Delete Your Information
Notwithstanding your rights under Sections 7 and 8, you can access the Personal Information that we collect online and maintain through normal updating methods. To update, correct or delete this Personal Information, you can contact us by emailing us here at DPO@vsecorp.com. Your account can be deleted or deactivated, but doing so will result in your not being able to access member services.
10. Retention of Your Personal Information
We do not keep your Personal Information longer than necessary to achieve the purposes stated in this Policy, subject to applicable legal obligations for the retention of documents, including laws and regulations related to the maintenance of commercial and tax documentation and evidence. The retention period for your Personal Information is determined based on several criteria, including:
- Time elapsed since your last interaction with us;
- End of your contractual relationship with us;
- Sensitivity of the Personal Information;
- Security reasons;
- Applicable statutes of limitation;
- Ongoing or potential litigation or dispute (e.g., we need this information to establish or defend legal claims);
- Applicable regulatory or legal obligations.
11. Children Under 16
We have no way of distinguishing the age of individuals who access our Website, and so we carry out the same Policy for individuals of all ages. Our services are not directed to children under 16. If a child has provided us with Personal Information without parental or guardian consent, the parent or guardian should contact us to remove the information.
12. Cookies
A cookie is a small text file that is stored by your web browser when you visit a website. Almost every website uses cookie technology. Cookies may store certain information such as your IP address, information about the content you view, information about the content you provide so that you do not have to re-enter it each time you visit our website, and your preferences and settings. Cookies also help us provide you with customized content, speed navigation through our website, and allow us to learn about your visit and your use of online services. We use three types of cookies: strictly necessary cookies, performance cookies and targeting cookies. For more information on these types of cookies, including the type, duration and description of the cookie, please visit our Privacy Preference Center.
You can manage or disable cookies at any time by adjusting your browser settings and at our Privacy Preference Center. However, if you do not accept cookies, you may not be able to use some portions of our Website. Strictly necessary cookies cannot be disabled, nor can the Privacy Preference Center be used to block cookies on third party websites linked from our Website.
Where the placement of cookies involves the processing of Personal Information, the legal basis for processing Personal Information in connection with strictly necessary cookies is our legitimate interest in the functioning of our Website. For the processing of Personal Information in connection with performance cookies and targeting cookies we obtain your consent via our Privacy Preference Center where required by applicable law. You can revoke your consent at any time with effect for the future by accessing the cookie at our Privacy Preference Center and changing your preferences.
13. Google Analytics
Subject to your consent, the Website uses Google Analytics to allow us to analyze and regularly improve the use of our Website. Google Analytics is a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA. The responsible service provider in the EU is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google“). For analyzing the use of our Website with Google Analytics, cookies are stored on your device.
When using our Website, the following Personal Information will be collected:
- the pages you call up, your “click behavior”
- first-time use of our Website
- achievement of “website goals” (conversions, e.g., newsletter registrations, downloads)
- your user behavior (e.g., clicks, scrolls, time spent, bounce rates, links used; interaction with videos; search requests, downloads, language settings)
- your approximate location (region)
- your IP address (in abbreviated form)
- technical information about your browser and the end devices you use (e.g., language settings, screen resolution)
- your internet provider
- the referrer URL (via which website/advertising medium you came to our Website).
IP address anonymization is enabled by default when using Google Analytics on our Website. This means your IP address will be shortened by Google within Member States of the EEA before any storage or processing takes place. Only in exceptional cases the whole IP address will first be transferred to a server in the USA and truncated there.
Google will use this information on our behalf to evaluate your pseudonymous use of our Website and to compile reports on the activities. The reports provided by Google Analytics are used to analyze the performance of our Website.
Access by Google LLC, Alphabet Inc., 1600 Amphitheatre Parkway Mountain View, CA 94043, USA and/or US authorities to the data stored by Google cannot be ruled out. To the extent Personal Information is processed in a country outside the EEA/UK that does not offer a level of data protection comparable to the EEA/UK (as applicable), such as for example currently the USA, we have entered into contractual safeguards based on EU Standard Contractual Clauses with Google. Google LLC has also certified itself under the EU-US Data Privacy Framework and its UK Extension Please see also the Section 5 “International Transfer of Your Personal Information”.
More information about the contractual arrangements for the processing of Personal Information with Google and the implemented safeguards can be found at: https://privacy.google.com/businesses/processorterms/ and https://privacy.google.com/businesses/controllerterms/.
We have also taken the following measures to protect, to the extent possible, the data collected through Google Analytics:
- We have concluded a data processing agreement with Google about how Google may process the data collected through Google Analytics, including EU Standard Contractual Clauses and including where necessary the UK Addendum (“UK Addendum“) or the UK International Data Transfer Agreement (“IDTA“) published by the Information Commissioner’s Office.
- We have configured Google Analytics to not share data with third parties.
- We do not use the function User-ID.
- We do not use other Google services in conjunction with Google Analytics.
- We have not activated the signals option.
The Personal Information sent by us to Google and associated with these cookies is deleted after 14 months.
Under the GDPR/UK GDPR, the legal basis for such processing is your consent pursuant to Art. 6 (1) lit. a GDPR/UK GDPR, which you can withdraw at any time with effect for the future by way of contacting us as set forth in Section 18 below. Your consent is voluntary and will not affect the functionality of your use of our Website.
You can prevent the collection of data related to your use of our Website (including your IP address) to Google and the processing of this data by Google:
- by rejecting the Google Analytics cookies or all cookies at our Privacy Preference Center as described above in Section 12;
- for website-based use, downloading and installing the browser add-on to disable Google Analytics HERE; or
- by configuring your browser software accordingly to reject (all) cookies. However, if you configure your browser to reject all cookies, this may limit functionality on this and other websites.
For more information about Google Analytics terms of use and Google’s privacy policy, please visit https://marketingplatform.google.com/about/analytics/terms/gb/ and https://policies.google.com/?hl=en.
14. Google Consent Mode
We use the so-called Google Consent Mode when using Google services such as Google Analytics. Google Consent Mode works together with our Consent Management Platform (CPM) and our cookie consent banner (also referred to as Privacy Preference Center). Google Consent Mode takes the user’s consent options from our cookie banner and transfers them to Google. If you give your consent for Google Analytics, for example, this decision will also be transmitted to Google. As a so-called “Gatekeeper” pursuant to the EU Digital Markets Act (“DMA”) Google must ensure that users have consented to the processing of their Personal Information by Google, before Personal Information of users is processed for personalized advertising. We currently use the “advanced consent mode”. You can find more information about Google Consent Mode and how Google uses your data here: https://support.google.com/google-ads/answer/10000067?hl=en.
15. Third-Party Practices
Our Website may, from time to time, contain links to third-party websites. The privacy policy of third-party websites may differ from ours. We encourage you to read that policy before submit information to third party websites. VSE is not responsible for the privacy practices of third-party Website.
16. Changes to Our Policy
Any changes to our Policy will be communicated through our Website at least fifteen days in advance of its effective date. Information collected before changes are made will be secured according to the previous Policy. Your continued use of the Website after we post any modifications to the Policy on this Website will constitute your acknowledgment and acceptance of the modifications.
17. Contact Details
VSE has appointed a data protection officer for you to contact if you have any questions or concerns about the VSE’s Personal Information policies or practices. If you would like to exercise your privacy rights, please direct your query to the VSE’s data protection officer at dpo@vseaviation.com.