Privacy Notice

Effective: May 25, 2018

1. OVERVIEW

Gulfstream Aerospace Corporation and its affiliates ("Gulfstream," "we," "us," "our") respects your privacy and is committed to protecting the personal data we hold about you. If you have questions, comments, or concerns about this Privacy Notice or our processing of personal data, please see the bottom of this Privacy Notice for information about how to contact us. Gulfstream is the data controller of the personal data collected, and is responsible for the processing of your personal data.

This Privacy Notice explains our practices with respect to personal data we collect and process in connection with your relationship with us. This includes information we collect through, or in association with, websites we own that link to this Privacy Notice, any related apps that we may provide, together with all products and services we may offer from time to time via our website and/or related apps, our related social media sites, or otherwise through your interactions with us (the website, apps, products, services, and social media pages, collectively, the "Services").

Please review the following to understand how we process and safeguard personal data about you. By using any of our Services, whether by visiting our website or otherwise, and/or by voluntarily providing personal data to us, you acknowledge that you have read and understand the practices contained in this Privacy Notice. This Privacy Notice may be revised from time to time, so please ensure that you check this Privacy Notice periodically to remain fully informed.

2. PRIVACY NOTICE ADDENDA

This Privacy Notice describes the processing activities common to the Services. Certain Services may process additional personal data, or may involve other processing activities. Consult the applicable "Privacy Notice Addendum" (each an "Addendum," collectively "Addenda") for each Service for more information about such activities. In the event of a conflict or discrepancy between this Privacy Notice and any Addendum for a given Service, the Addendum shall control.

3. WHAT INFORMATION DO WE COLLECT?

We collect a variety of personal data from and about you through the Services, including:

  • When you provide it to us directly;
  • Automatically through logging and analytics tools, cookies, and as a result of your use of and access to the Services; and
  • From third-party sources, including from app stores; service providers such as payment processors, aircraft maintenance providers, and analytics providers; and through your interactions with us on social media websites.

You have choices about certain information we collect. When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary to provide any aspect of our Services, you may not be able to use those Services. In addition, as noted below in the section captioned "YOUR CHOICES", it is possible to change your browser settings to block the automatic collection of certain information.

Finally, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, and is not personal data. To the extent this data is stored or associated with personal data, it will be treated as personal data; otherwise, the data is not subject to this notice.

Information You Share With Us. We collect personal data from you when you provide it to us, including through website forms; when you request or provide information to create a MyGulfstream account; ordering or purchasing goods, support, or services; interacting with us on social media, or contacting us with questions or comments.

For example, if you order products and/or services from us directly through the Services, you must provide us with information to process that request, including but not limited to email address, first and last name, billing address, shipping address (if applicable), payment information, and any other information you may optionally provide, such as telephone number or aircraft tail number.

If you request a MyGulfstream account for yourself or your organization, you will need to provide us with certain information about yourself and, in certain circumstances, information about others in your organization, including name, title, email address, telephone number, postal address, username and password, information about aircraft you have responsibility for (which may include registration or serial number), role within the organization, and other information you may optionally provide such as birthday, nickname, and other comments.

If you contact us with questions, requests, or concerns, or to exercise your legal rights, we collect personal data sufficient to answer your questions, address your requests, and/or handle your concerns, as applicable. In certain situations, we may also require you to provide personal data to authenticate your identity in order to carry out your requests.

We also collect information from you that, depending on applicable law, may not constitute personal data.

Information Collected Automatically. When you browse or use the Services, we utilize commonly-used logging and analytics tools, including Google Analytics (and, for our mobile applications, AppSee), to collect information about your device, the network used to access the Services, and information about your use of the Services (such as how you navigate and move around the Services).

We also use certain technologies on the Services, including cookies and pixel tags, that allow us, our service providers, and other third parties to store information locally on your device, identify your device, track your interactions with other sites or with our email campaigns, and track activity over time and across websites.

Information collected automatically includes the software and hardware attributes of the device you use to access the Services, unique device ID information, regional and language settings, performance data about the Services, network provider, and IP address (a number assigned to your device when you use the Internet). In addition, information is collected passively in the form of log files and third-party analytics that record activity on websites and mobile applications. For example, log file entries and analytics data are generated every time you visit a particular page on our website, and track the dates and times that you use the Services, the pages you visit, the amount of time spent on specific pages, and other similar usage information, and general data (including the name of the web page from which you entered our website).

  • Location Information: If you permit certain Services (such as our mobile applications) to access information about your location (including global positioning system ("GPS") or general location information derived from the network you use to access the Services), we collect the precise or general location information provided by your device for the purposes listed in the Addenda for those Services. See the "YOUR CHOICES" section below for more information about how to disable or limit the collection of GPS data.
  • Cookies, Web Tracking, and Advertising. We use cookies and pixel tags to personalize and enhance your experience in regard to our Services, to collect data about your visit to our Services, to help diagnose problems with our servers, to administer the Services, to evaluate the effectiveness of our marketing and advertising campaigns, to permit analytics providers to gather information about your visit to the Services, and to gather broad demographic information about our users.
  • Please see our Cookie Notice and the "YOUR CHOICES" section of this Privacy Notice for more information about cookies and other web tracking technologies on the Services; for information about how you can reject, delete, or prevent cookies from being placed on your system; and how you can opt out of, limit, or prevent certain web tracking technologies and/or advertising providers from collecting information about you.

Information Obtained from Third Parties. We receive personal data from third parties that we have engaged to provide services to us and to you, including payment processors, providers of aircraft maintenance services, as well as from third parties that provide web and application analytics and usage information to us such as Google Analytics. We may also obtain personal data when you request that third parties provide it to us and from government and/or regulatory records, such as the Federal Aviation Administration ("FAA") Registry.

In addition, if you choose to interact with us or our partners on social media by posting to our pages, tagging us (or using certain hashtags or other identifiers) in posts, or participating in activities, we may collect certain information from the social media account you use to interact with us, including the name associated with the account, the account handle, recent activity, the content of any posts in which we are tagged, and other information that may be contained on your social media profile to allow us to respond to the posts and understand and engage with our audience.

For the purposes of this Privacy Notice, "partners" means affiliates, service providers, licensors, vendors, manufacturers, distributors, or other third parties with which we have a business relationship.

4. HOW DO WE PROCESS PERSONAL DATA?

We process personal data for two general purposes, pursuant to various legal bases:

  • For our business operations (including communicating with you, fulfilling orders, providing information about our products and services, improving the Services, and complying with applicable legal requirements); and
  • To market and promote our, and our partners’, products and offerings.

We disclose personal data to our service providers to allow them to provide services to us and assist in carrying out your requests.

In addition, we may disclose information we maintain, including personal data: when permitted or required to do so by law; in response to a request from a law enforcement agency or authority or any regulatory authority; and/or to protect the integrity of the Services or our interests, rights, property, or safety, and/or that of our users and others.

See the "YOUR CHOICES" section below for information about how you can make decisions about how we process personal data, including how to opt out of certain marketing communications.

Legal Bases for Processing. We process personal data for, or based on, one or more of the following legal bases:

  • Performance of a Contract. We may use personal data to enter into, or perform under, the agreement between us, including processing payment and billing information as part of a purchase or sale, to conduct due diligence on customers and potential customers, and providing customer service and support.
  • Legitimate Interests. We may use personal data for our legitimate interests, including improving service; providing information about our products and/or services; to the extent necessary and proportionate for the purposes of ensuring the security of our premises, network, and information; and for administrative, fraud detection, and legal compliance purposes.
  • Compliance with Legal Obligations and Protection of Individuals. We may use personal data to comply with the law and our legal obligations, as well as to protect you and other individuals from certain harms.
  • Your Consent. We process certain personal data because you have given us your consent to process it in that manner.

Operational Uses. We process your personal data as part of our operations, which include:

  • Providing you with information tailored to your requests, responding to inquiries, and delivering services and products;
  • Operating, maintaining, and improving the quality of the Services and such content, products and/or services as we may make available through the Services;
  • Communicating with you by email, mail, telephone, push notification, and other methods of communication, in each case with your consent, if such consent is required in accordance with applicable laws, about products, services, order status, and other topics;
  • Compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies;
  • Endeavoring to protect our and our partners’ rights, property, or safety, and the rights, property, and safety of our users and other third parties; and
  • For other purposes, as permitted or required by law.

Marketing Uses. We process your personal data to send messages to you about us, our partners, and the products and services we and our partners offer, which may from time to time include contests, rewards, events, and special offers for products and services. These communications are tailored based on the communications preferences you select when providing us with your information and will only occur with your prior consent, if such consent is required in accordance with applicable laws. We process personal data collected through social media platforms and web tracking technologies to market to and understand our audience.

Sharing of Personal Data. Some of the above processing involves sharing collected personal data with third parties, including service providers, affiliates, and other partners.

  • We share personal data with third parties when you ask us to do so;
  • We share personal data among our affiliated entities;
  • We share personal data with our service providers, including those that provide aircraft support services such as maintenance and scheduling; payment processors; software and Web developers, customer relations management (CRM) services; communications services; order processing and fulfillment services; commercial mail/email providers; security consultants; data hosting services; and other vendors we engage so that they may provide services to you, to us, or on our behalf; and
  • We share personal data with third parties when we believe it is required by, or necessary to comply with, applicable law.

5. PROTECTING PERSONAL DATA

We employ reasonable and appropriate physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of personal data. Those safeguards include: (i) the pseudonymization and encryption of personal data where we deem appropriate; (ii) taking steps to ensure personal data is backed up and remains available in the event of a security incident; and (iii) periodic testing, assessment, and evaluation of the effectiveness of our safeguards.

However, no method of safeguarding information is completely secure. While we use measures designed to protect personal data, we cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that Internet data transmission is not always secure, and we cannot warrant that information you transmit utilizing the Services is or will be secure.

6. RETENTION OF PERSONAL DATA.

We retain personal data for a period of time depending on the type and sensitivity of the personal data, the purpose for which it is processed, and to the extent we deem necessary to carry out the processing activities described above, including but not limited to compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, and to the extent we reasonably deem necessary to protect our and our partners’ rights, property, or safety, and the rights, property, and safety of our users and other third parties. We consider multiple factors, including legal requirements, the scope and nature of the personal data, and potential risk of harm to data subjects from a data breach, in determining the appropriate retention period.

For example, we generally retain personal data about our customers for the duration of the customer relationship plus a number of years afterwards that depends on the sensitivity of the information and the purpose for which it is processed (for example, personal data processed for the purposes of ensuring security of Gulfstream facilities during customer visits is held for a shorter period of time than personal data processed as part of customer service or sales contract activities).

If you have a specific question regarding retention of your personal data, you may contact us as described in the "Additional Information and Assistance" section below.

7. YOUR RIGHTS REGARDING PERSONAL DATA

You have a variety of legal rights regarding the collection and processing of personal data. You may exercise these rights, to the extent they apply to you, by contacting us at data.privacy@gulfstream.com, as provided at the end of this Privacy Notice, or by following instructions provided in this Privacy Notice or in communications sent to you. Please be prepared to provide reasonable information to identify yourself and authenticate your requests.

Note, however, that we may request certain reasonable additional information (that may include personal data) to help us authenticate the request and/or to clarify or understand the scope of such requests.

These rights vary depending on the particular laws of the jurisdiction applicable to you, but may include:

  • The right to know whether, and for what purposes, we process personal data about you;
  • The right to be informed about the personal data we collect and/or process about you;
  • The right to learn the source of personal data about you we process, where we obtain that personal data from a source other than you;
  • The right to access, modify, and correct personal data about you (as set forth in more detail below under "Accessing, Modifying, Rectifying, and Correcting Collected Personal Data");
  • The right to know with whom we have shared personal data about you, for what purposes, and what personal data has been shared (including whether personal data was disclosed to third parties for their own direct marketing purposes);
  • Where processing of personal data about you is based on consent, the right to withdraw your consent to such processing; and
  • The right to lodge a complaint with a supervisory authority located in the jurisdiction of your habitual residence, place of work, or where an alleged violation of law occurred.

See "Your California Privacy Rights" and "Your Privacy Rights for more information about certain legal rights that you may have depending on applicable law.

Accessing, Modifying, Rectifying, and Correcting Collected Personal Data. We strive to maintain the accuracy of any personal data collected from you, and will use commercially reasonable efforts to respond promptly to update our database when you tell us the information in our database is not accurate. However, we must rely upon you to ensure that the information you provide to us is complete, accurate, and up-to-date, and to inform us of any changes. Please review all of your information carefully before submitting it to us, and notify us as soon as possible of any updates or corrections.

In accordance with applicable law, you may obtain from us certain personal data in our records. If you wish to access, review, or make any changes to personal data you have provided to us through the Services, you may do so at any time by contacting us as provided below or, for certain information, through your account on the Services. Please note, however, that we reserve the right to deny access as permitted or required by applicable law.

Your California Privacy Rights. California Civil Code Section 1798.83, known as the "Shine the Light" law, permits our users who are California residents to request and obtain from us a list of what personal data (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once per year per person, must be sent to the email address below, and are free of charge.

We do not disclose personal data protected under the "Shine the Light" law to third parties for their own direct marketing purposes.

Your Privacy Rights. In addition to the above-listed rights, certain privacy laws may provide certain individuals with enhanced rights in respect of their personal data, depending on the jurisdictions, persons, and data involved. These rights may include, depending on the circumstances surrounding the processing of personal data:

  • The right to object to decisions based on profiling or automated decisionmaking that produce legal or similarly significant effects on you;
  • The right to request restriction of processing of personal data or object to processing of personal data carried out pursuant to (i) a legitimate interest or (ii) performance of a task in the public interest (including, but not limited to, processing for direct marketing purposes);
  • In certain circumstances, the right to data portability, which means that you can request that we provide certain personal data we hold about you in a machine-readable format; and
  • In certain circumstances, the right to erasure and/or the right to be forgotten, which means that you can request deletion or removal of certain personal data we process about you.

Note that we may need to request additional information from you to validate your request. To exercise any of the rights above, please contact us at data.privacy@gulfstream.com.

8. YOUR CHOICES

In addition to your choices with respect to the collection of personal data (see "WHAT INFORMATION DO WE COLLECT?" above), you have the ability to make certain choices about how we communicate with you, and how we process certain personal data.

Communications Opt-Out. You may opt out of receiving marketing or other communications from us at any time through a given communications channel (such as email or telephone) by following the opt-out link or other unsubscribe instructions provided in any email message received, by contacting us as provided at the end of this Privacy Notice, or by informing our customer service representatives of your desire to opt out. If you wish to opt out by sending us an email to the address provided below, please include "Opt Out" in the email’s subject line and include your name and the email address (and, if applicable, telephone number) you used to sign up for communications in the body of the email.

Note that if you do business with us in the future, you may not, subject to applicable law, opt out of certain automated notifications, such as order or subscription confirmations, based on business transactions (e.g., e-commerce).

Location Information.

If you want to limit or prevent our ability to receive location information from you for certain Services, you can deny or remove the permission for those Services to access location information or deactivate location services on your device. Please refer to your device manufacturer or operating system instructions for instructions on how to do this.

Cookies, Web Tracking, and Advertising. Consult our Cookie Notice for more information about how to control and/or opt out of certain web tracking technologies.

9. OTHER IMPORTANT INFORMATION ABOUT PERSONAL DATA AND THE SERVICES.

Our Privacy Notice also includes information about other practices with respect to personal data, including:

  • Collection of personal data from children;
  • Links and references to third-party websites and services on our Services:
  • What happens to personal data in the event we sell or transfer some or all of our business;
  • How we respond to "Do Not Track" requests; and
  • Information about where we process and transfer personal data.

Collection of Personal Data from Children. Children under 16 years of age are not permitted to use the Services, and we do not knowingly collect information from children under the age of 16. By using the Services, you represent that you are 18 years of age or older, or are 16 years of age or older and have valid parental consent to do so.

Third-Party Websites and Services. As a convenience, we may reference or provide links to third-party websites and services, including those of unaffiliated third parties, our affiliates, service providers, and third parties with which we do business. When you access these third-party services, you leave our Services, and we are not responsible for, and do not control, the content, security, or privacy practices employed by any third-party websites and services. You access these third-party services at your own risk. This Privacy Notice does not apply to any third-party services; please refer to the Privacy Notices or policies for such third-party services for information about how they collect, use, and process personal data.

Business Transfer. We may, in the future, sell or otherwise transfer some or all of our business, operations or assets to a third party, whether by merger, acquisition or otherwise. Personal data we obtain from or about you via the Services may be disclosed to any potential or actual third-party acquirers and may be among those assets transferred.

Do Not Track. We use analytics systems and providers that process personal data about your online activities over time and across third-party websites or online services, and these systems and providers may provide some of this information to us. We do not currently process or comply with any web browser’s "do not track" signal or similar mechanisms.

Note, however, that you may find information about how to opt out of Google Analytics and/or block or reject certain tracking technologies in our Cookie Notice.

International Data Transfers. Your personal data will be stored and processed in the European Economic Area, the United States, and other locations where we have operations and/or have engaged service providers. By your use of the Services you acknowledge that we will transfer your data to, and store your personal data in, the United States and other jurisdictions, which may have different data protection rules than in your country, and personal data may become accessible as permitted by law in the United States, including to law enforcement and/or national security authorities in the United States. For transfers of personal data out of the European Economic Area, pursuant to Article 46 of the General Data Protection Regulation, we use standard data protection clauses to provide appropriate safeguards.

10. MODIFICATIONS AND UPDATES TO THIS PRIVACY NOTICE

This Privacy Notice replaces all previous disclosures we may have provided to you about our information practices with respect to the Services. We reserve the right, at any time, to modify, alter, and/or update this Privacy Notice, and any such modifications, alterations, or updates will be effective upon our posting of the revised Privacy Notice. We will use reasonable efforts to notify you in the event material changes are made to our processing activities and/or this Privacy Notice, such as by posting a notice on the applicable Services for a period of time, or sending you an email. Your continued use of the Services following our posting of any revised Privacy Notice will constitute your acknowledgement of the amended Privacy Notice.

11. APPLICABILITY OF THIS PRIVACY NOTICE

This Privacy Notice is subject to any Addenda that apply to the applicable Services, as well as any agreements, including the Terms of Use and any Additional Terms that govern your use of the applicable Services. This Privacy Notice applies regardless of the means used to access or provide information through the Services.

This Privacy Notice does not apply to information from or about you collected by any third-party services, applications, or advertisements associated with, or websites linked from, the Services. The collection or receipt of your information by such third parties is subject to their own privacy policies, statements, and practices, and under no circumstances are we responsible or liable for any third party’s compliance therewith.

12. ADDITIONAL INFORMATION AND ASSISTANCE

If you have any questions or concerns about this Privacy Notice and/or how we process personal data, or would like to exercise any of the legal rights set forth above, please contact us at:

Gulfstream Aerospace Corporation
Legal Department
500 Gulfstream Road, Mail Stop B-06
Savannah, GA 31408
data.privacy@gulfstream.com

If you are located in the European Union or European Economic Area, and you wish to raise a concern regarding our use of your personal data, you have the right to do so with our lead supervisory authority, the U.K. Information Commissioner’s Office (the "ICO") at www.ico.org.uk, or your local supervisory authority. We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO, so please contact us in the first instance.