In-Flight Crew Connections, Inc. California Consumer Privacy Notice
For Residents of California Only
Updated as of September 29, 2022
This Privacy Notice provides you with necessary information about the personal information we collect, how this information may be used by In-Flight Crew Connections, Inc. (“IFCC”), your privacy rights and IFCC’s obligations in accordance with the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”).
This Privacy Notice applies solely to natural persons residing in California (“Consumers”), and does not apply to individuals living elsewhere, businesses or other corporate entities.
IFCC’s General Counsel is responsible for maintaining, reviewing, and updating this Privacy Notice.
Consumer: As defined by the CCPA and CPRA, a consumer is a natural person who is a California resident, living in California for other than a temporary or transitory purpose, or individual domiciled in California.
Personal Information: Commonly referred to as Personally Identifiable Information (“PII”), Personal Information (“PI”) may be defined under various privacy laws, but, generally, is a fact about an individual which, if combined with one or more other facts about that individual, would enable others to determine the specific person to whom the facts apply.
Sensitive Personal Information: Sensitive Personal Information (“SPI”) is a subset of PI that requires greater security protections and standards of care in handling. SPI, also known as “special categories of information”, is defined as information that if lost, compromised, or disclosed could result in substantial harm, embarrassment, inconvenience, or unfairness to an individual.
IFCC: For the purposes of this Notice, we will refer to In-Flight Crew Connections, Inc., and our associated affiliates1 as “IFCC”, and collectively as “we”, “our”, or “us”.
1 Including N4325MP, LLC and Minti CoWork & Conference LLC, et al.
1. CONSUMER RIGHTS 1.1. RIGHT TO ACCESS
You have the right to access PI which we may collect or retain about you. If requested, we shall provide you with a copy of your PI which we collect as permitted by the CCPA/CPRA.
You also have the right to receive your PI in a structured and commonly used format so that it can be transferred to another entity (“data portability”).
1.2. RIGHT TO KNOW
You have the right to request that we disclose the following about your PI, as defined by the CCPA/CPRA:
- The specific PI we may collect.
- The categories of PI we may collect.
- The categories of sources from which we may collect your PI.
- The business purpose(s) for collecting or sharing your PI.
- The categories of PI we may disclose for business purposes.
- The categories of third parties to whom we may share your PI.
1.3. RIGHT TO OPT-OUT / DO NOT SELL MY PERSONAL INFORMATION
IFCC does not sell PI within the meaning of the CCPA/CPRA.
1.4. DO NOT SHARE OR DISCLOSE MY SENSITIVE PERSONAL INFORMATION
You have the right to limit how your SPI is disclosed or shared with third parties, as defined in the CCPA/CPRA.
1.5. RIGHT TO DELETION
In certain circumstances, you have the right to request the erasure of your PI. Upon verifying the validity of a deletion request, we will delete your PI from our records, and instruct any service providers or third parties to delete your information, when applicable.
1.6. RIGHT TO CORRECT/RIGHT TO RECTIFICATION
In certain circumstances, you have the right to request correction of any inaccurate PI. Upon verifying the validity of a verifiable consumer correction request, we will use commercially reasonable efforts to correct your PI as directed, taking into account the nature of the PI and the purposes of maintaining your PI.
1.7. Please note that the above rights are not absolute, and we may be entitled to refuse requests, wholly or partly, where exceptions under applicable law apply.
2. EXERCISING YOUR RIGHTS
If you are a California resident, you can exercise any of your rights as described in this Notice and under applicable privacy laws by using the contact information provided in this Notice. We will not discriminate against you for exercising such rights. Except as described in this Notice or provided for under applicable privacy laws, there is no charge to exercise of your legal rights.
However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may:
- Charge a reasonable fee taking in account the administrative costs of providing the information or taking the action requested; or
- Refuse to act on the request and notify you of the reason for refusing the request.
3. VERIFYING CONSUMER REQUESTS
When you make a request to us, we will require your name, e-mail, phone number, and address. We will attempt to match our records based on that information.
Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm their identity.
4. PERSONAL INFORMATION (PI) WE COLLECT
We collect PI as necessary to enable us to carry out your instructions, to manage and operate our business, and to comply with our legal and regulatory obligations.
The PI that we may collect in the course of our employment of you as a crewmember, placement of you as a temporary or part-time employee, or as your potential employer, may include, but is not limited to, the following:
- Your name.
- Your job title and company name.
- Your mailing address.
- Your contact details (such as telephone number and email address).
- Your employment and educational background and other relevant applicant information.
- Your training certifications issued by the Federal Aviation Administration and/or other regulatory bodies pursuant to authorization from the Federal Aviation Administration.
- Other PI contained in correspondence and documents which you may provide to us; and/or
- Information we obtain from our IT and communications monitoring.
This PI is required to enable us to provide our services to you. If you do not provide the PI we ask for, it may delay or prevent us from providing services to you.
You confirm that you are authorized to provide to us the PI which we shall collect on your behalf. Where the PI relates to your directors, shareholders, beneficial owners, employees, agents, associates, or family members, it is not reasonably practicable for us to provide to them the information set out in this Notice. Accordingly, where appropriate, you are responsible for providing this information to any such person.
5. SENSITIVE PERSONAL INFORMATION (SPI) WE COLLECT
We may also collect or process SPI as necessary to enable us to carry out your instructions, to manage and operate our business, and to comply with our legal and regulatory obligations.
You may also supply us with, or we may receive, the following SPI:
- Username and password.
- Financial, account or billing information, including tax identification number, social security number, or credit/debit card information.
- Proof of identification, including driver’s license number, or state/national government-issued identification.
- Diversity or demographic information, including race or ethnicity, gender, or gender identity, religious or philosophical beliefs, political affiliation, opinion or association, veteran or disability status, or sexual preference.
- Information IFCC has contractually agreed to manage under heightened confidentiality and security protocols, such as health and financial information or intellectual property.
- Information required to conduct background checks, client due diligence or conflict checks.
IFCC collects SPI on the basis of one or more of the following:
- You have given explicit consent to the collection for one or more specified purposes.
- Where the collection of SPI is manifestly made public by you; and/or
- Where the collection is necessary for the establishment, exercise, or defense of legal claims.
Where the collection is necessary for reasons of substantial public interest, in accordance with applicable law, IFCC may collect SPI for the following reasons:
- For the purposes of the prevention or detection of an unlawful act or for preventing fraud; and
- For the provision of confidential advice.
6. HOW PERSONAL INFORMATION IS COLLECTED
We collect most PI directly from you. However, we may also collect PI from the following:
- Publicly accessible sources.
- Directly from a third party for background checks or Know Your Client (“KYC”) due diligence providers.
- A third party, such as a bank, financial institution, or advisor, with your consent.
- Consultants and other professionals we may engage in relation to your services, with your consent.
- Our Information Technology (IT) systems, including:
- Video and audio call logging and recording software.
- Door entry systems and reception logs; and/or
- Email and other correspondence.
7. THE PURPOSE FOR WHICH PERSONAL INFORMATION IS COLLECTED
The purposes for which IFCC will collect or use your PI include:
- To provide professional services to you in connection with your requests as a client.
- To carry out our business operations and associated administration in connection with your matters or as your potential employer.
- To comply with our internal business processes and policies.
- To comply with our legal, regulatory, and professional obligations.
- For operational reasons, such as improving efficiency, training, and quality control.
- To prevent unauthorized access and modifications to our systems.
For updating client records:
- For marketing our professional services to you; and/or
- For the purpose of conducting due diligence and KYC checks to comply with anti-money laundering (“AML”) regulations to prevent money laundering and terrorist financing, as permitted by law.
8. DISCLOSURE OF PERSONAL INFORMATION
IFCC shall use a reasonable standard of care to store and protect from disclosure any PI collected using the principles of least-privileged access and by limiting access to PI and SPI to individuals with a ‘need to know’.
PI will be retained by us as set out in IFCC’s policies. IFCC may share your PI under the following circumstances:
- In the event that we sell or purchase any business or assets, or if all or substantially all of IFCC’s assets are acquired by a third party, in which we may disclose your PI to the prospective seller or buyer of such business or assets, solely for the purpose of permitting the due diligence required to decide whether to proceed with a transaction.
- If reasonably necessary to protect the vital interests of a person or IFCC.
- If we are subject to disclose or share your information in order to comply with any legal or regulatory obligation; or
- To enforce or apply our terms and conditions or to establish, exercise or defend the rights of IFCC, IFCC Personnel, clients, customers, or others.
Our third-party service providers are subject to security and confidentiality obligations and are only permitted to process information for a specified, legitimate business purpose and in accordance with our instructions.
We only share your information with the following third parties:
- Affiliated firms and advisors as necessary to carry out the purposes for which the information was supplied or collected; and/or
- Service providers that assist with providing services to you, including data hosting providers, IT and software providers, marketing database providers, accountants, and HR system providers, including benefits and payroll providers.
9. DATA STORAGE AND SECURITY
IFCC shall use a reasonable standard of care to store and protect your PI. We use appropriate physical, technical and organizational security measures, and procedures to protect PI from unauthorized use, loss, alteration, destruction, or modification. IFCC shall retain your PI until the initial purpose for collecting and retaining such data has been satisfied. If you subsequently agree to a new or additional purpose, your PI may be retained for that.
10. CONTACT INFORMATION
IFCC is not required to appoint a Data Protection Officer. However, we have appointed the following contact in the event you have any questions regarding this Notice, or any questions about your rights with respect to your Personal Information.
Irena E. Leigh
In-Flight Crew Connections, Inc.
4325 Morris Park Drive
Charlotte, North Carolina 28227
704.236.3647. ext. 704
11. MODIFICATIONS AND REVISIONS
We reserve the right to modify, revise, or otherwise amend this Privacy Notice at any time and in any manner. Any new version of this Notice will be posted on inflightcrewconnections.com. This Notice will be reviewed annually and updated, as necessary.