Last Modified: October 5, 2022
- interact with us on our websites or through other channels (for example, by communicating with us or attending one of our events),
- use our product and services (including the IFCC Service Portal); and
- What Information We Collect About You
- How We Use Your Information
- How We Share Information We Collect
- How We Transfer Information We Collect Internationally
- How We Store and Secure Your Information
- Cookies and Similar Technologies
- How to Access & Control Your Personal Data
- California Privacy Rights
- Data Protection Officer
- Other Important Privacy Information
- WHAT INFORMATION WE COLLECT ABOUT YOU
a. INFORMATION YOU PROVIDE TO IFCC
When You Visit Our Websites
We collect personal data from you when you submit web forms or interact with our websites, for example by requesting customer support. We may ask for your email address, first and last name, job title, and other similar business information. You are free to explore some of our websites without providing any personal data about yourself.
Account and User Information
We collect personal data when you register as a potential Employee/Crewmember (hereinafter, “Crew”), sign-up for an IFCC account, create or modify user information in the IFCC Client Portal, set preferences, or provide any other related information to access or utilize our services.
You may also provide payment information, such as a credit card number or bank account numbers, when purchasing our services. We use secure third-party payment service providers to manage payment processing, which is collected through a secure payment process.
We post Crew and/or Client testimonials and comments on our websites, which may contain personal data. We obtain each Client or Crewmember’s consent via email or through other agreements between them and IFCC prior to posting their name and testimonial.
b. INFORMATION WE PROCESS ON BEHALF OF CLIENTS WHEN THEY USE THE SERVICES
Our services allow our Clients to create and provide to us job, trip or sales orders, and customer service content for the purpose of providing the services. When clients use our products and services, they may collect personal data such as first and last name, email address, physical address, phone number, or other information about affected Crew.
Our Clients are prohibited by Confidentiality Agreements and applicable law from collecting or using your personal information in any way or for any purpose except as necessary to provide the services. We store our Clients’ information on our service providers’ servers but process it as a processor under our clients’ instructions and in accordance with our Master Service Agreements, which prohibit us from using the information except as necessary to provide the services and as required by law.
c. INFORMATION WE COLLECT AND PROCESS WHEN YOU USE SERVICES VIA THE CLIENT PORTAL OR SUBMIT A WEB FORM
When you access or use our website or submit Crewmember profile information via our mobile applications, we do not collect information on your device model, operating system, or device identifier.
Third Party Integrations
IFCC is unaware of the use of any third-party plug ins or applications that may be integrated with its website or the Client Portal.
d. INFORMATION WE COLLECT FROM OTHER SOURCES
We may receive information about you or other users of your IFCC account from our global network of partners. We may receive this data from our deal and lead registration process through our partners.
We may receive information from third party service providers, from related companies, and from our business and solution partners.
Personal Information from Different Sources
Social Media Features
Other IFCC Companies
We may receive information about you from other companies that are owned or operated by IFCC.
- HOW WE USE YOUR INFORMATION
a. TO COMMUNICATE WITH YOU ABOUT THE PRODUCT AND SERVICES
We use the account information you provide to IFCC when signing up as Crew or for the Services we provide to send you transactional emails or in-app notification about billing, account management, and other administrative matters. We may also send you updates regarding our Customer Terms of Service or other legal agreements and may also communicate with you about security incidents via email or in-app notification.
We use your information to provide customer support, such as resolving technical issues you encounter and analyzing product outages or bugs.
b. TO PROVIDE THE SERVICES
We use your account information and Client data to provide the products and services to you. For example, we use the email address you provide when signing up with us to create your user account, and we use your payment information to process payments for paid use of the services. We also use this information to authenticate you when you log in and to provide customer support.
c. TO IMPROVE AND DEVELOP OUR PRODUCT AND SERVICES
We collect usage data about how you or your users interact with our product and services. We use this data to develop and improve our products and services. For example, we use usage data to assess trends and usage across the product to help us determine what new features or integrations our users may be interested in.
d. TO SECURE AND PROTECT OUR PRODUCT AND IFCC USERS
We may use your account information to investigate and help prevent security incidents. We may also use this information to meet legal requirements. We may use your information to verify user accounts, new product sign-ups, and to detect and prevent product abuse. This includes enforcing our Acceptable Use Policy.
We may use log files to provide general statistics regarding use of the websites by you, including how you use our websites, what country you are logging in from (for analytics, export control and regulatory purposes) and to help improve the navigation experience. Your IP address is also collected and logged for security and debugging purposes, for example to track access patterns, investigate security events and incidents. For these purposes we may link this automatically collected data to other personal data provided by you such as name, email address, address, and phone number.
e. TO MARKET AND PROMOTE THE SERVICES
We use the information you provide to IFCC to market and promote the products, services, and other offerings. For example, we use the information, like your email or physical address, to send information or IFCC content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business. We use this information to promote the use of our services to you and share promotional and information content with you in accordance with your communication preferences.
We may also reach out to you via telephone to ask about other IFCC products or services you may be interested in. If you have a call scheduled with a IFCC representative, we may record and transcribe the call.
f. OTHER PURPOSES IF WE OBTAIN YOUR CONSENT
We share your data with third parties when you give us consent to do so.
g. LEGAL BASIS FOR PROCESSING PERSONAL DATA (EEA AND UK VISITORS ONLY)
Our legal basis for collecting and using the Personal Data described above will depend on the personal data concerned and the specific context in which we collect it. However, we will normally collect personal data from you only where we have your consent to do so, where we need the personal data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal data from you.
If we ask you to provide personal data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal data is mandatory or not (as well as of the possible consequences if you do not provide your personal data). Similarly, if we collect and use your personal data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
- HOW WE SHARE INFORMATION WE COLLECT
a. THIRD PARTY SERVICE PROVIDERS
We use third party service providers to support our websites, products, and services. For example, we use service providers for data hosting, application development, and marketing. We may need to share your information with service providers to provide information about products or services to you. Examples may include removing repetitive information from prospect lists, analyzing data, or performing statistical analysis on your use of the services or interactions on our websites, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, developing and improving the product and services, and providing customer service or support. These service providers are prohibited from using your personal data except for these purposes, and they are required to maintain the confidentiality of your information. In all cases where we share your information in this way, we explicitly require the third-party service providers to acknowledge and adhere to our privacy and data protection policies and standards.
We may share data with trusted IFCC partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide sales support, or provide customer support. Partners are prohibited from using your personal data except for these purposes, and they are required to maintain the confidentiality of your data.
c. CORPORATE EVENTS
If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by IFCC on the websites and the services. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal data, and choices you may have regarding your personal data.
d. PUBLIC FORUMS
Our websites may offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if you directly disclose any information through our public message boards, blogs, or forums (including profile information associated with the account you use to post the information) it may be read, collected, and used by any member of the public who accesses these websites. Your posts and certain profile information may remain even after you terminate your account. We urge you to consider the sensitivity of any information you may disclose in this way. We will correct or delete any information you have posted on the websites if you so request, as described in Section 7 “How to Access & Control Your Personal Data” below. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to and why.
e. C OMPELLED DISCLOSURE
We reserve the right to use or disclose your personal data if required by law or if we reasonably believe that use or disclosure is nece ssary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process. If you use the Services, Client Data is considered Confidential Information and is subject to the Confidentiality terms in the Master Service Agreement.
- HOW WE TRANSFER DATA WE COLLECT INTERNATIONAL
a. INTERNATIONAL TRANSFERS
b. INTERNATIONAL TRANSFERS TO THIRD PARTIES
- HOW WE STORE AND SECURE YOUR INFORMATION
a. DATA STORAGE AND SECURITY
We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure. We secure the personal data you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All personal data is protected using appropriate physical, technical and organizational measures. b. RETENTION OF PERSONAL DATA
How long we keep information we collect about you depends on the type of information and how we collect and store it. After a reasonable period of time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
We retain personal data that you provide to us where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements).
When we have no ongoing legitimate business need to process your personal data, we securely delete the information or anonymize it or, if this is not possible, securely store your personal data and isolate it from any further processing until deletion is possible. We will delete this information at an earlier date if you so request, as described in the section “How to Access & Control Your Personal Data” below.
If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your IFCC account.
- COOKIES AND SIMILAR TECHNOLOGIES
IFCC does not currently store or track cookies on our own website. Cookie Policies for the hosts of other IFCC-affiliated websites are the responsibility of their respective hosts (e.g., Instagram, Facebook, et al).
c. THIRD PARTY TRACKING TECHNOLOGIES
- HOW TO ACCESS & CONTROL YOUR PERSONAL DATA
a. REVIEWING, CORRECTING AND REMOVING YOUR PERSONAL DATA
You have the following data protection rights:
- You can request access, correction, updates, or deletion of your Personal Data.
- You can object to our processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data.
- If we have collected and processed your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal data.
- To exercise any of these rights, please email email@example.com.
- We will respond to your request to change, correct, or delete your data within a reasonable timeframe and notify you of the action we have taken.
b. ANTI-SPAM POLICY
Our Acceptable Use Policy applies to us and to our customers and, among other things, prohibits the sending of unsolicited commercial email in violation of applicable laws, and requires the inclusion in every email sent of an “opt-out” mechanism and other required information.
c. TO UNSUBSCRIBE FROM OUR COMMUNICATIONS
You may unsubscribe from our marketing communications through one of the following methods:
- by clicking on the “unsubscribe” link located on the bottom of our e-mails,
- updating your communication preferences
Customers cannot opt out of receiving transactional emails related to their account with us or their services.
- CALIFORNIA PRIVACY RIGHTS
a. APPLICABILITYThis section applies only to California consumers. For purposes of this section “personal information” has the meaning given in the California Consumer Privacy Act (“CCPA”). It describes how we collect, use, and share California consumers’ personal information in our role as a business, and the rights applicable to such residents. The California Consumer Privacy Act (“CCPA”) requires businesses to disclose whether they sell personal information. IFCC is a business and does not sell personal information. We may share personal information with third parties if those third parties are authorized service providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal information.
b. HOW WE COLLECT, USE, AND SHARE YOUR PERSONAL INFORMATION
We have collected the following statutory categories of personal information in the past twelve (12) months:
- Identifiers, such as name, e-mail address, mailing address, and phone number. We collect this information directly from you or from third party sources.
- Commercial information, such as subscription records. We collect this information directly from you.
- Financial information, such as payment information or financial account numbers in the process of providing you with a subscription. We collect this information from you.
- Other personal information, in instances when you interact with us online, by phone or mail in the context of receiving help through our help desks or other support channels; participation in customer surveys or contests; or in providing the services.
c. YOUR CALIFORNIA RIGHTS
You have certain rights regarding the personal information we collect or maintain about you. Please note these rights are not absolute, and there may be cases when we decline your request as permitted by law.
The right of access means that you have the right to request that we disclose what personal information we have collected, used, and disclosed about you in the past 12 months.
The right of deletion means that you have the right to request that we delete personal information collected or maintained by us, subject to certain exceptions.
The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights.
IFCC does not sell personal information to third parties (pursuant to California Civil Code §§ 1798.100–1798.199, also known as the California Consumer Privacy Act of 2018).
d. HOW TO EXERCISE YOUR CALIFORNIA RIGHTS
You can exercise your rights yourself or you can alternatively designate an authorized agent to exercise these rights on your behalf. Please note that to protect your personal information, we will verify your identity by a method appropriate to the type of request you are making. We may also request that your authorized agent have written permission from you to make requests on your behalf, and we may also need to verify your authorized agent’s identity to protect your personal information.
Please use the contact details below if you would like to:
- Access this policy in an alternative format,
- Exercise your rights,
- Learn more about your rights or our privacy practices; or
- Designate an authorized agent to make a request on your behalf.
- DATA PROTECTION OFFICER
- You may also contact us by postal mail for all IFCC brands at:
In-Flight Crew Connections, Inc.
4325 Morris Park Drive
Charlotte, North Carolina 28227 USA
- OTHER IMPORTANT PRIVACY INFORMATION a. WE NEVER SELL PERSONAL DATA
We will never sell your personal data to any third party.
b. INFORMATION ABOUT CHILDREN
The websites, product and services are not intended for or targeted at children under 16, and we do not knowingly or intentionally collect personal data about children under 16. If you believe that we have collected personal data about a child under 16, please contact us here, so that we may delete the information.