Introduction

Airspace Link, Inc. respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you or that you may provide when you download, install or use AirHub® Portal (as a mobile application or website application, our “Online Content”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect on or through our Online Content and in email, text, and other electronic messages between you and us. It does not apply to information collected by us offline or through any other means, including on any other website operated by us or any third party, or by or through any third party, including through any application or content (including advertising) that may link to or be accessible from or on our Online Content.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use, download or install our Online Content. By accessing or using any component of our Online Content, you agree to this privacy policy. This policy may change from time to time. Your continued use of the Online Content after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 16

Our Online Content is not intended for children under 16 years of age. No one under age 16 may provide any information to or on our Online Content. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on our Online Content or through any of its features, register on our Online Content, make any purchases through our Online Content, use any of the interactive or public comment features of our Online Content, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at our contact information specified below.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Online Content, including information by which you may be personally identified, such as name, postal address, email address, and telephone number. We collect this information:

• directly from you when you provide it to us; and
• automatically as you navigate through our Online Content.

Information collected automatically may include usage details, location data, IP addresses, and information collected through cookies and other tracking technologies.

Information You Provide to Us

The information we collect on or through our Online Content may include:

• information that you provide by filling in forms on our Online Content. This includes information provided at the time of registering to use our Online Content, posting material, or requesting further services. We may also ask you for information on or through our Online Content.
• records and copies of your correspondence (including email addresses), if you contact us.
• your responses to surveys that we might ask you to complete for research purposes.
• details of transactions you carry out through our Online Content and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Online Content.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of our Online Content, or transmitted to other users of our Online Content or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we may limit access to certain components of our Online Content, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of our Online Content with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Online Content, we may use automatic data collection technologies to collect certain information about, among other matters, your location, equipment, browsing actions, and patterns, including information about your computer, mobile device and internet connection, including your IP address, operating system, and browser type. The information we collect automatically helps us to improve our Online Content and to deliver a better and more personalized service, including by enabling us to:

• estimate our audience size and usage patterns;
• store information about your preferences, allowing us to customize our Online Content according to your individual interests;
• speed up your searches; and
• recognize you when you return to our Online Content.

The technologies we use for this automatic data collection may include:

• Cookies (or browser or mobile cookies). A cookie is a small file placed on the hard drive of your computer or smartphone. It may be possible to refuse to accept browser cookies by activating the appropriate setting on your browser and mobile cookies by activating the appropriate setting on your smartphone. However, if you select these settings, you may be unable to access certain components of our Online Content.
• Flash Cookies. Certain features of our Online Content may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Online Content. Flash cookies are not managed by the same browser or smartphone settings as are used for browser and mobile cookies.
• Web Beacons. Components of our Online Content and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related statistics (for example, recording the popularity of certain Online Content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on our Online Content are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Online Content. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• to present our Online Content and its contents to you;
• to provide you with information, products, or services that you request from us;
• to fulfill any other purpose for which you provide it;
• to provide you with notices about your purchases and subscriptions, including expiration and renewal notices;
• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• to notify you about changes to our Online Content or any products or services we offer or provide though it;
• to allow you to participate in interactive features on our Online Content;
• in any other way we may describe when you provide the information; and/or
• for any other purpose with your consent.

We may also use your email address to deliver our newsletter to you or to otherwise provide you with information about our products and services. Finally, we may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose personal information that we collect or you provide as described in this privacy policy:

• to our subsidiaries and affiliates;
• to contractors, service providers, and other third parties we use to support our business;
• to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Online Content users is among the assets transferred;
• to fulfill the purpose for which you provide it;
• to the FAA pursuant to law, federal regulation, our LAANC Memorandum of Agreement, or our Performance Rules relative to our Data Protection Plan;
• for any other purpose disclosed by us when you provide the information; and/or
• with your consent.

We may also disclose your personal information:

• to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• to enforce or apply our Terms of Service https://airspacelink.com/terms-conditions-portal and other agreements, including for billing and collection purposes; and/or
• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. So, we may offer certain mechanisms to provide you with control over your information, including the following:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some components of our Online Content may then be inaccessible or not function properly.
• Location Information. You may be able to choose whether or not to allow the Online Content to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some components of the Online Content may then be inaccessible or not function properly.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

Accessing and Correcting Your Information

You can review and change your personal information by logging into the particular Online Content component and visiting your account profile page.

You may also send us an email at privacy@airspacelink.com to request access to, correct or delete any personal information that you have provided to us; it being understood that we may retain your personal information until you request its deletion or until we are required to delete it by the FAA. We cannot delete your personal information except by also deleting your user account, and, in any event, we may retain a copy of your personal information as we deem reasonably necessary or desirable to comply with any court order, law, or legal process, including to respond to any government or regulatory request; to enforce or apply our Terms of Service https://airspacelink.com/terms-conditions-portal and other agreements, including for billing and collection purposes; and/or if we believe retention is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others. This includes retention for the purposes of fraud protection and credit risk reduction. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from our Online Content, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Online Content users.

Proper access and use of information provided on our Online Content, including User Contributions, is governed by our Terms of Service https://airspacelink.com/terms-conditions-portal.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. This section of our Privacy Policy applies solely to all visitors, users and others who reside in the State of California and is intended to comply with the California Consumer Privacy Act of 2018 (CCPA). Any terms defined in the CCPA have the same meaning when used in this section.

Information We Collect

Our Online Content collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, our Online Content has collected the following categories of personal information from its consumers within the last twelve (12) months:

A. YES - Identifiers: 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.

B. YES - Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

C. NO - Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

D. YES - Commercial information: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

E. NO - Biometric information: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

F. YES - Internet or other similar network activity: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

G. YES - Geolocation data: Physical location or movements.

H. NO - Sensory data: Audio, electronic, visual, thermal, olfactory, or similar information.

I. NO - Professional or employment-related information: Current or past job history or performance evaluations.

J. NO - Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)): Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

K. YES - Inferences drawn from other personal information: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Personal information does not include: publicly available information from government records; deidentified or aggregated consumer information; or information excluded from the CCPA’s scope, like:

• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; or
• personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Online Content.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our Online Content, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Online Content experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Online Content, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Online Content, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Online Content, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Online Content users is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

• Category A: Identifiers.
• Category B: California Customer Records personal information categories.
• Category D: Commercial information.
• Category F: Internet or other similar network activity.
• Category G: Geolocation data.
• Category K: Inferences drawn from other personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you.

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions, including, without limitation, those described in Accessing and Correcting Your Information above. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies and subject to Accessing and Correcting Your Information above.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us at privacy@airspacelink.com.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us at privacy@airspacelink.com with a subject line of “DO NOT SELL MY PERSONAL INFORMATION.”Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by sending us an email to that effect at privacy@airspacelink.com. You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not deny you goods or services; charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can resultin different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Online Content that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@airspacelink.com.

Data Security

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain components of our Online Content, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we try to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Online Content. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Online Content.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Site home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Site and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: privacy@airspacelink.com