Last Updated: February 20, 2021

PilotsGlobal Website Privacy Policy

This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your personal information when you use the Service and tells you about your privacy rights and how the law protects You.

We, PilotsGlobal, don’t sell your personal information but use your personal data to provide and improve the Service. We may update this policy from time to time.

By using the Service, you agree to the collection and use of information in accordance with this Policy. If you are a resident of California, our CCPA Privacy Notice, found below, also applies to you. If you are located in the European Economic Area, the United Kingdom, or Switzerland (collectively “EEA+”), our EEA+ Privacy Notice, found below, also applies to you. If you are located in Brazil, our LGPD Notice, found below, also applies to you.

If you are under 18 years of age, please do not access or use our website. We do not knowingly collect or maintain personal information from people under 18, and if we find out that personal information of people under 18 has been collected on or through our website, we will delete it.

For the purposes of this Policy the following definitions shall have the same meaning regardless of whether they appear in singular or in plural and/or with or without the initial letter capitalized:

• PilotsGlobal (referred to as either “PilotsGlobal”, "the Company", "We", "Us" or "Our" in this Cookies Policy) refers to:
  • PilotsGlobal, Inc., a Delaware corporation with office at 1007 North Orange Street, 4th Fl #105, Wilmington, Delaware, 19801, USA.
• Cookies means small files that are placed on Your computer, mobile device or any other device by a website, containing details of your browsing history on that website among its many uses.
• Website refers to PilotsGlobal.com, an asset of PilotsGlobal, accessible from https://pilotsglobal.com .
• Service refers to the Website.
• You means the individual accessing or using the Website, or a company, or any legal entity on behalf of which such individual is accessing or using the Website, as applicable.
• First-Party refers to PilotsGlobal.
• Third-Party means any individual or entity other than the PilotsGlobal that is involved in providing services to us.

1. Data Controller

PilotsGlobal, Inc., is the controller and responsible for your personal data globally.

For information about how to contact us or our representatives, please see the “Contact Us” section below.

2. Personal Information We Collect

Depending on how you interact with our Website, we may collect the following personal information about you, which we have grouped together as follows:

Data type	Description
Identity	May include your first name, last name.
Contact	May include your postal address, email address, and telephone numbers.
Profile	May include: username and password; region / country of your location; Pilot Job Seeker specific information, such as flight time, aircrafts flown, type rating, license, job preferences, other qualifications, professional or employment-related information and job search related data etc; Employer specific information, such as title, position, organization represented. customer service requests.
Technical	Includes your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, and operating system and platform.
Usage	Includes information about how you use our website.
Marketing and Communications	Includes your preferences in receiving marketing and non-marketing communications from us.

3. How We Collect Personal Information

We may collect personal information about you from the following sources:

• From you, such as when you subscribe to our email alerts / create profile, request marketing to be sent to you, complete a form in regards to one of our products or services, post a job advertisment or correspond with us by any means. As you interact with our website, we will also automatically collect Usage and Technical Data about your equipment, browsing and job search related actions and patterns. We collect this personal data by using cookies, server logs, database entries and other similar technologies.
• Publicly available sources, such as information that you or your organization make publicly available online.

4. How We Use Personal Information

We have set out below a description of the purposes for which we may use personal information.

For each purpose, we identify the groups of personal information we use for that purpose (please refer to Section 2 above).

Purpose of Use	Group of Personal Information Concerned
To manage our relationship with you which will include: (a) Communicating with you about our services, including notifying you about changes to our terms or privacy policy; (b) Asking you to take a survey (c) To process and deliver customer orders; (d) to manage payments, fees and charges; (e) To communicate about our goods and services and provide customer service.	Identity Contact Marketing and Communications Financial Profile
To enable you to participate in a recognition program, competition or complete a survey To understand what may be of interest to you, deliver relevant website content to you and measure or understand the effectiveness of the content we serve to you, in accordance with applicable law	Identity Contact Marketing and Communications Profile
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) To detect, prevent, or otherwise address fraud or security issues To comply with legal obligations that apply to us, monitor and ensure compliance with our terms, and defend our legal interests in the event of a potential dispute	Identity Contact Technical Usage Marketing and Communications Financial Profile
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical Usage Profile
To defend our interests in the event of a dispute and comply in good faith with applicable laws, legal processes, and lawful government requests	Identity Contact Financial

5. Personal Data Retention

We store your personal data / information only so long as we need it to provide the Service to you and fulfill the purposes described in this Policy. This is also the case for anyone that we share your personal information with and who carries out services on our behalf. Retention periods can vary significantly based on the type of information and how it is used. Our retention periods are based on criteria that include legally mandated retention periods, pending or potential litigation, our intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving. When we no longer need to use your personal information and there is no need for us to keep it to comply with our legal or regulatory obligations, resolve disputes and enforce our agreements, we’ll either remove it from our systems or depersonalize it so that we can't identify you.

6. Personal Information Sharing and Disclosure

We may share your personal information with the following categories of third parties:

• Our Service Providers: We may transfer your personal information to our service providers, some of which may include our affiliates, as necessary for them to provide services to us in connection with our fulfilment of the purpose set out above. For example, we may rely on service providers to host and maintain our website, perform backup and storage services, process payments, collect debts, provide customer service, transmit communications, deliver products, and perform analytics services. Our service providers are located and process personal information in the United States.
• Government Agencies, Regulators and Professional Advisors: Where permitted or required by applicable law, we may also need to transfer your personal data to government agencies and regulators (e.g. courts and government authorities) to comply with our legal obligations, and to external professional advisors as necessary to defend our legal interests.
• Organizations Involved in Business Transfers: In the event of a merger, reorganization, dissolution or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal information, will be transferred to the surviving entity in a merger or the acquiring entity. Such information will be transferred in accordance with applicable law.

7. How We Protect Personal Information

We maintain physical, administrative and technological safeguards intended to prevent personal information from accidental or unauthorized loss, alteration access or use. We have put in place procedures to deal with any suspected breach of personal information and will notify individuals and any applicable regulator of a breach where we are legally required to do so.

8. The Legal Basis on Which PilotsGlobal Processes Your Personal Data

We rely on the following legal bases to process your personal data, as appropriate:

• necessary for us to perform a contract with you or take steps at your request prior to entering into a contract (“Contract Performance Legal Basis”);
• necessary for us to comply with an applicable legal obligation (“Legal Obligations Legal Basis”);
• necessary for us to realize a legitimate interest based on an assessment of that interest and your privacy and other fundamental interests (“Legitimate Interest Legal Basis”);
• is performed according to your consent (“Consent Legal Basis”).

9. Your Privacy Rights

Under applicable laws, you may have rights to access, update, rectify, port or erase certain personal information that we have about you or restrict or object to certain activities in which we engage with respect to your personal information. If you have such rights and your request complies with the requirements under applicable laws, we will give effect to your rights as required by law.

To exercise any rights you may have under applicable privacy laws, please contact us using the details in the “Contact Us” section below. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

10. Links to Other Websites

Our website may contain links to other websites, which may have privacy policies or notices that differ from ours. We are not responsible for the collection, processing or disclosure of personal information collected through other websites (such as when you apply for a job on an employer website). We are also not responsible for any information or content contained on such websites. Links to other websites are provided solely for convenience. Your usage and browsing on any such website is subject to that website’s own policies. Please review the privacy notices posted on other websites that you may access through our website. We may provide you with additional or different privacy notices in specific instances which describe how your personal information is collected and used for a specific service.

11. Contact Us

If you have questions or concerns regarding our privacy policy or practices, you may contact us:

• Email address: privacy @ pilotsglobal.com (remove spaces when sending an email).
• Postal address: ATTN: Privacy/Legal, PilotsGlobal, Inc., 1007 N Orange Str, 4th Fl #105, Wilmington, DE 19801, USA.

Last Updated: Februaryt 20, 2021

SUPPLEMENTAL CCPA PRIVACY NOTICE

As mentioned in our other privacy disclosures, we don’t sell your personal information, but the privacy laws of California, including the California Consumer Protection Act of 2018 (“CCPA”), require us to provide some information about our data processing practices to California residents.

If you are a resident of California, this Supplemental CCPA Privacy Policy applies to you. However, this Privacy Policy does not reflect our collection, use or disclosure of California residents’ personal information where an exception under the CCPA applies.

1. Your Personal Information: Right to Know, Request Deletion, and Opt-Out

As a California resident, you have the right to request that we disclose what PI we collect, use, and disclose about you specifically (“right to know”), and the right to ask that it be deleted. To submit a request to exercise the right to know or to delete, please submit a request, with the details you would like to know or delete, by:

• Email to privacy @ pilotsglobal.com (remove spaces when sending an email) and include “California Request to Know or Delete” in the subject line, or by
• Mail to ATTN: Privacy/Legal, PilotsGlobal, Inc., 1007 N Orange Str, 4th Fl #105, Wilmington, DE 19801, USA.

We may need to verify your identity, and/or ask you to confirm your request. If we deny your request, we will explain why.

You also have the right to opt-out of the sale of your personal information by a business. We do not sell personal information, so there is no need to opt-out. We do not have actual knowledge that we sell or collect the personal information of minors under 18 years of age.

2. Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

You have a right not to receive discriminatory treatment by us for the exercise of your privacy rights under the CCPA.

3. Right to Be Informed of Financial Incentives

We do not currently offer any financial incentives in exchange for the retention or sale of California residents’ personal information.

4. Authorized Agent

You can designate an authorized agent to make a request under the CCPA on your behalf if your authorized agent is a natural person or a business entity registered with the Secretary of State of California, and you sign a written declaration that you authorize the authorized agent to act on your behalf. If you use an authorized agent to submit a request under the CCPA, please have the authorized agent take the following steps in addition to the steps described in Section 1 above:

1. Mail a notarized copy of your written declaration authorizing the agent to act on your behalf to the address listed in our “Contact Us” section below; and
2. Provide any information we request from you to verify your identity and that you provided the authorized agent permission to submit a request under the CCPA on your behalf.

5. What We Collect

Collection of Personal Information

We have set out below the categories of personal information we may collect about California residents as well as the sources of this information. We may collect this information directly from California residents who use our website or subscribe for our services. If a California resident uses their organization’s subscription, we may collect some of this information from their organization. We may also collect some information about a California resident’s interests and preferences from a third party source where they or their organization make such information publicly available, such as on their organization’s public website.

We use this personal information for purposes outlined in Section 4 of our Privacy Policy .

6. The CCPA Categories of Personal Information We Share for a “Business Purpose”

While we do not sell your personal information, we may share it to support our own operational purposes in providing Services to you, as described in our Privacy Policy. These operational purposes, known as “business purposes” under the CCPA, are described below...

6.1 Auditing Interactions

We may share the types of personal information listed in Section 5 with partners, service providers and related companies, in order to audit our Services.

6.2 Security Purposes

In order to secure our Services, including to detect, prevent and investigate security incidents or violations of our Professional Community Policies or applicable laws, we may share the types of personal information listed in Section 5 with our partners, service providers, law enforcement and related companies.

6.3 Service Improvements

In order to improve our Services (such as to identify bugs, repair errors or ensure that services function as intended) or conduct internal research and analysis to improve our technology, we may share the types of personal information listed in Section 5 with our partners, service providers and related companies

6.4 Service Providers and Other Notified Purposes

We may share the types of personal information listed in Section 5 with Service Providers, as defined by the CCPA, in order to have them perform services specified by a written contract or with others for a notified purpose permitted by the CCPA (e.g., to respond to law enforcement requests).

7. Contact Us

If you have questions or concerns regarding our privacy policy or practices, you may contact us:

• Email address: privacy @ pilotsglobal.com (remove spaces when sending an email).
• Postal address: ATTN: Privacy/Legal, PilotsGlobal, Inc., 1007 N Orange Str, 4th Fl #105, Wilmington, DE 19801, USA.

Last Updated: Februaryt 20, 2021

SUPPLEMENTAL EEA+ PRIVACY NOTICE

If you are located in the European Economic Area, the United Kingdom, or Switzerland (collectively EEA+), and access our website, this Supplemental EEA+ Privacy Notice applies to you.

As mentioned in the PilotsGlobal Privacy Policy, we don’t sell your personal information, but the data protection laws of the EEA+, including the General Data Protection Regulation and the so-called UK GDPR (together, “GDPR”), require us to provide information about our data processing practices certain people in the EEA+.

1. Data Controller

PilotsGlobal, Inc., is the controller and responsible for your personal data globally.

For information about how to contact us or our representatives, please see the “Contact Us” section below.

2. What We Collect

Collection of Personal Information

We the personal information we may collect about you please refer to the Section 2 of our Privacy Policy.

We use this personal information for purposes outlined in Section 4 of our Privacy Policy.

3. The Legal Basis on Which PilotsGlobal Processes Your Personal Data

We rely on the following legal bases to process your personal data, as appropriate:

• necessary for us to perform a contract with you or take steps at your request prior to entering into a contract (“Contract Performance Legal Basis”);
• necessary for us to comply with an applicable legal obligation (“Legal Obligations Legal Basis”);
• necessary for us to realize a legitimate interest based on an assessment of that interest and your privacy and other fundamental interests (“Legitimate Interest Legal Basis”);
• is performed according to your consent (“Consent Legal Basis”).

4. International Data Transfers under GDPR and Data Security

The Services are provided to you by PilotsGlobal from the United States.Therefore, PilotsGlobal needs to carry out International Transfers of your personal data from EEA+ to the United States and may transfer your data to other countries for the proper operation of the Services if necessary. Therefore, the international transfers of all EEA+ users' personal data are based upon contractual necessity, as provided by GDPR.

We may also rely on other appropriate means permitted by GDPR Ch. V, which establishes that data recipients will provide an adequate level of data protection and that appropriate technical and organizational security measures are in place to protect personal data against accidental or unlawful destruction, loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing.

5. Personal Data Retention

We store your personal data only so long as we need it to provide the Service to you and fulfill the purposes described in our Privacy Policy. This is also the case for anyone that we share your personal information with and who carries out services on our behalf. Retention periods can vary significantly based on the type of information and how it is used. Our retention periods are based on criteria that include legally mandated retention periods, pending or potential litigation, our intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving. When we no longer need to use your personal information and there is no need for us to keep it to comply with our legal or regulatory obligations, resolve disputes and enforce our agreements, we’ll either remove it from our systems or depersonalize it so that we can't identify you.

6. Your Rights

Regarding your personal data, You may have the right to:

• Request access (commonly known as a "data subject access request") - enables you to receive a copy of the personal data we hold about you and information about how it is processed.
• Request correction - enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure - enables you to ask us to delete or remove personal data where there is no lawful reason for us continuing to store or process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.
• Object to processing - where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
• Request restriction of processing - enables you to ask us to suspend the processing of your personal data if, (i) you want us to establish the data's accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

To exercise these rights, please contact us using the contact details below.

Although we urge you to contact us first to find a solution for every concern you may have, you always have the right to lodge a complaint with your competent data protection authority.

7. Your Choices

You are not required to provide personal data to us but if you do not provide any personal data to us, you may not be able to use our website or we may not be able to authenticate and assist you with your orders, inquiries or requests, and we generally will not be able to provide you with most of our products and services.

8. Contact Us

If you have questions or concerns regarding our privacy policy or practices, you may contact us:

• Email address: privacy @ pilotsglobal.com (remove spaces when sending an email).
• Postal address: ATTN: Privacy/Legal, PilotsGlobal, Inc., 1007 N Orange Str, 4th Fl #105, Wilmington, DE 19801, USA.

Last Updated: Februaryt 20, 2021

SUPPLEMENTAL LGPD PRIVACY NOTICE

This Privacy Notice for users located in Brazil supplements the information contained in the PilotsGlobal Privacy Policy and applies solely to visitors, users and others who reside in Brazil (“consumers” or “you”). We adopt this notice to comply with the Brazilian Data Protection Law Lei Geral de Proteção de Dados Pessoais (Law No. 13,709/2018) ("LGPD").

In addition to the rights outlined in the PilotsGlobal Privacy Policy, as a user located in Brazil, you may be able to exercise the following rights with respect to your personal information that we have collected, subject to certain limitations:

• The right to confirmation of the existence of the processing. You have the right to ask that we confirm whether we process your personal data.
• The right to access the data. You have the right to access the personal data we hold about you and certain information about how we use it and who we share it with, including information about any public and private entities we have shared your personal data with.
• The right to correct incomplete, inaccurate or out-of-date data.
• The right to anonymize, block, or delete unnecessary or excessive data or data that is not being processed in compliance with the LGPD. Please note that, depending on the request, this may result in a suspension or discontinuation of certain services and is also governed by legal and/or contractual retention guidelines.
• The right to the portability of data to another service or product provider, by means of an express request. We provide you with the ability to move any of your account data to a third party.
• The right to delete personal data processed with the consent of the data subject. You have a right to request the permanent deletion of your data, subject to certain exceptions. However, please note that exercising this right may result in a suspension or discontinuation of services and is also governed by legal and/or contractual retention guidelines.
• The right to information about the possibility of not giving consent and about the consequences of the refusal. You have the right to ask us to provide information about the possibility of not giving consent for the processing of your personal data and the consequences of such refusal.
• The right to revoke consent.

Please note that not all of these rights listed above are absolute, and limitations/exceptions apply in some cases. For example, we may not be able to fully comply with your request if we are bound by certain legal restrictions or contractual requirements, but in those circumstances, we will still respond to notify you of such a decision.

To exercise these rights, please contact us using the details in the “Contact Us” section below. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Contact Us

If you have questions or concerns regarding our privacy policy or practices, you may contact us:

• Email address: privacy @ pilotsglobal.com (remove spaces when sending an email).
• Postal address: ATTN: Privacy/Legal, PilotsGlobal, Inc., 1007 N Orange Str, 4th Fl #105, Wilmington, DE 19801, USA.