Effective on: August 30, 2022
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States and the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and we are responsible as “controller” of that personal information for the purposes of those laws.
Key Terms. It would be helpful to start by explaining some key terms used in this policy:
| We, us, our | Wingware Corporation |
| Our representative |
Information Security Manager 5720 Lyndon B. Johnson Fwy. Suite 630, Dallas, Texas 75240 support@wing-ware.com |
| Personal information | Any information relating to an identified or identifiable individual |
| Jet Fuel QC | Means our system as accessed through www.jetfuelqc.com or through our mobile app found in the Apple Store or Google Play Store. |
Personal Information We Collect About You. We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
| Categories of Personal Information | Specific Types of Personal Information Collected |
|---|---|
| Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers) | Name, email address, face photo |
| Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to: | Signature, telephone number, employer, geolocation, records of data entry, time when work was performed |
| Characteristics of protected classifications under California or federal law. | Color, sex, age, religion, national origin, disability, citizenship status, and genetic information of maintenance workers |
| Internet or other electronic network activity information: (e.g., | use history, search history, and information regarding a consumer’s interaction with an www.jetfuelqc.com, interaction with the application Jet Fuel QC. |
| Geolocation data | Latitude and Longitude |
| Audio, electronic, visual, thermal, olfactory, or similar information | Visual data collected by a handheld device when certain functions are performed by a user |
| Professional or employment-related information | Date of user activation, date of user deactivation, task performance trends, training, safety performance, performance, behavior, movement through geolocation when logged into Jet Fuel QC |
This personal information is required to allow you to use Jet Fuel QC. If you do not provide personal information we ask for, it may delay or prevent us from Jet Fuel QC to you.
How Your Personal Information is Collected. We collect most of this personal information directly from you when you log in and create a profile, or if your information is provided to us by your employer or other third party, we may enter some of the information into Jet Fuel QC to allow you to use Jet Fuel QC. We also collect some of this information when you use Jet Fuel QC. However, we may also collect information:
From cookies on our website; and
Via our IT systems, including:
How and Why We Use Your Personal Information. Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.,:
To comply with our legal and regulatory obligations;
For the performance of our contract with you or to take steps at your request before entering into a contract;
For our legitimate interests or those of a third party; or
Where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
| What we use your personal information for | Our reasons |
|---|---|
| To provide access to Jet Fuel QC to you and enable you to use Jet Fuel QC | For the performance of our contract with you or a third party or to take steps before entering into a contract |
| Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
| Ensuring business policies and contracts are adhered to, e.g. policies covering security and internet use; number of users allowed in the system | For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you and to ensure that the contract is under compliance |
| Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price |
| Ensuring the confidentiality of commercially sensitive information |
For our legitimate interests or those of a third party, i.e. to
protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obligations |
| Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range, product functionality, user safety and performance, user trends, or other efficiency measures | For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price |
| Preventing unauthorized access and modifications to systems |
For our legitimate interests or those of a third party, i.e. to
prevent and detect criminal activity that could be damaging for us and
for you To comply with our legal and regulatory obligations |
| Updating and enhancing customer records, making data accessible to customers, providing an efficient and cutting-edge product in the industry |
For the performance of our contract with you or a third party or to
take steps before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products |
| Statutory returns | To comply with our legal and regulatory obligations, which may include response to a subpoena or other legal documentation |
| Record working practices, staff administration and performance |
To collect data that assists our customer with the review of their
staff performance and safety issues, to assist our customer with staff
administration, such as tasks performed, time per task, tasks
completed, timeliness, speed per task, completion of tasks, and
general performance measured with the data recorded by you in
Jet Fuel QC For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
| External audits and quality checks, e.g. for ISO or other accreditation or audit of our accounts |
For our legitimate interests or a those of a third party, i.e. to
maintain our accreditations so we can demonstrate we operate at the
highest standards To comply with our legal and regulatory obligations |
The above table does not apply to special category personal information, which we will only process with your explicit consent.
Promotional Communications. We may use your personal information to send you updates (by email, text message, telephone or post) about Jet Fuel QC, including updates to Jet Fuel QC.
We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell OR share it with other organizations for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
Contacting us at support@wing-ware.com; or
Using the “unsubscribe” link in emails or “STOP” number in texts;
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who We Share Your Personal Information With. We routinely share personal information with:
Our affiliates, including companies related to Wingware Corporation;
Our customer or potential customer;
Service providers we use to help deliver Jet Fuel QC to you, such as payment service providers, cloud providers, third party websites that interact with Jet Fuel QC;
Other third parties we use to help us run our business, such as website hosts;
Our professional advisors, on a need-to-know basis when they provide a service to us;
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We will not share your personal information with any other third party.
Where Your Personal Information is Held. Information may be held at our offices and agents as described above (see above: “Who We Share Your Personal Information With”).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”.
Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us and/or while we are providing access to JetFuelQC to you or the customer. Thereafter, we will keep your personal information for as long as is necessary:
To respond to any questions, complaints or claims made by you or the customer or on your behalf or the customer’s;
To show that we treated you fairly; or
As stated in the contract with the customer;
To keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
Category 1: Identifiers, Information capable of being associated with a particular individual, characteristics of protected classifications, and some professional or employment-related information.
Category 2: Internet activity information, geolocation data, audio, electronic, visual, thermal, olfactory, or similar information, and some professional or employment-related information related directly to maintenance.
Category 1 information will be retained as long as necessary during the employment of the individual, and after employment as long as is required under local employment law regulations. Category 2 information will be retained as long as necessary and required under Federal Aviation Agency, or similar regulatory body or regulations.
When it is no longer necessary to retain your personal information, we will delete or anonymize it.
Transferring Your Personal Information Out of the EEA. To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:
With our offices outside the EEA;
With your employer and our service providers located outside the EEA;
If you are based outside the EEA; or
Where there is an international dimension to the services we are providing to you.
These transfers are subject to special rules under European and UK data protection law.
The following countries to which we may transfer personal information have been assessed by the European Commission as providing an adequate level of protection for personal information: Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Republic of Korea, Switzerland, The United Kingdom, and Uruguay.
Non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. To obtain a copy of those clauses you can contact us.
If you would like further information, please see “How To Contact Us” below.
Your Rights Under the GDPR.
| Right to Access | The right to be provided with a copy of your personal information (the right of access) |
| Right to Rectification | The right to require us to correct any mistakes in your personal information |
| Right to be Forgotten | The right to require us to delete your personal information—in certain situations |
| Right to Restriction of Processing | The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data |
| Right to Object |
The right to object:
|
| Right Not to be Subject to Automated Individual Decision-Making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the General Data Protection Regulation.
Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, please:
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
Because you cannot use Jet Fuel QC without providing a minimum amount of Personal Information, if you ask us to erase or remove certain of your Personal Information, you may be discontinued by your employer or other third party who asked you to access Jet Fuel QC and your access and use license may be terminated.
How to File a GDPR Complaint. We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
Changes to This Privacy Notice.
We reserve the right to modify and update this Privacy Policy at any time at our sole discretion. We will provide all users with notification of any material revisions at least thirty (30) days in advance of their effective date (other than with respect to changes that must be made sooner than that to comply with applicable law). Notification will be provided via email either through the account associated with user’s use of the Service or to the personal email address associated with the user’s account. Except as otherwise provided by the us, updates will be effective upon the date indicated at the top of this Privacy Policy. The updated version of the Privacy Policy will supersede all prior versions. Note that our failure to enforce this policy in any instance and for whatever reason shall not be construed as a waiver of our right to do so at any other time.
How to Contact Us. Please contact us and/or by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.
Our contact details are shown below:
Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).