IFCC Privacy Policy 

Last Modified: October 5, 2022 

We at IFCC and our affiliates are committed to protecting your privacy. This Privacy Policy applies to the information and data collected by IFCC when you interact with our websites, products and services, and any other sites or services that link to this Privacy Policy. This includes when you: 

  • 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  
  • when you use any other sites or services that link to this Privacy Policy. 

This Privacy Policy describes how we collect, receive, use, store, share, transfer, and process your Personal Data. It also describes your choices and rights with respect to your personal data, including your rights of access and correction of your personal data. For the purposes of this Privacy Policy “personal data” means any information relating to an identified or identifiable individual. If you do not agree with this Privacy Policy, you should not use our websites, products and services, or any other sites or services that link to this Privacy Policy.  

We update this Privacy Policy from time to time and we encourage you to review this Privacy Policy periodically.  

If you have any questions about this Privacy Policy or our treatment of your personal data, or to exercise your rights to delete or modify your personal data, please email us at privacy@inflightcrewconnections.com. 

  1.      What Information We Collect About You 
  2.      How We Use Your Information 
  3.      How We Share Information We Collect
  4.      How We Transfer Information We Collect Internationally
  5.      How We Store and Secure Your Information 
  6.      Cookies and Similar Technologies 
  7.      How to Access & Control Your Personal Data 
  8.      California Privacy Rights 
  9.      Data Protection Officer 
  10.    Other Important Privacy Information   
  1. WHAT INFORMATION WE COLLECT ABOUT YOU
          a. INFORMATION YOU PROVIDE TO IFCC

When you interact with us via our websites or any sites or services that link to this Privacy Policy or use the services, we may collect personal data and other information from you, as further described below. 

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.  

Payment Information  

We collect payment and billing information when you register for paid products or services. For example, we may ask you to provide a billing address, or a billing contact for your IFCC account. If you give us payment information, we use it solely as authorized by you in accordance with this Privacy Policy.  

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.   

Customer Testimonials  

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

Usage Data  

We do not use cookies or collect usage data for visitors to our website. We collect information concerning clients’ usage of services pursuant to the Client Portal, the delivery of services pursuant thereto, and other Client service indicators. 

Mobile  

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

IFCC Partners  

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. 

Third Parties  

We may receive information from third party service providers, from related companies, and from our business and solution partners. 

Personal Information from Different Sources 

We may combine the personal information we collect from you with personal information we receive from other sources, such as third-party providers of business information and publicly available sources (like social media platforms). This may include physical mail addresses, job titles, email addresses, phone numbers, IP addresses, and social media profiles. This helps us to update and improve our records, identify new customers, create more personalized advertising, suggest products and services that may interest you, deliver personalized communications and promote events. The collection of your personal data by these other third-party providers is governed by the provider’s privacy policy. 

Log Files  

Like most websites and technology services delivered over the Internet, we have the capability to automatically collect and store information about your computer hardware and software when you visit our websites, use our product and services, or visit other sites or services that link to this Privacy Policy. This information can include your IP address, browser type, domain names, internet service provider (ISP), and the files viewed on our websites (e.g., HTML pages, graphics, etc.), the files viewed on our, or our customer’s websites (if those websites are hosted on IFCC e.g., HTML pages or, graphics etc.), your operating system, access times and referring website addresses. We do not collect or store this information at this time. 

Social Media Features 

Our websites may include social media features (such as the Facebook ‘like’ button) and widgets (such as the share button or interactive mini programs) that run on our websites. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our websites. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them. 

Other IFCC Companies 

We may receive information about you from other companies that are owned or operated by IFCC. 

  1. 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.  

We receive information from third party service providers and other sources such as third-party providers of business information and publicly available sources. We may receive and use this information from these service providers and other sources in combination with other information we collect through other means described in this Privacy Policy for the purposes of providing you with updates and an improved Services, like personalized communications, event promotion, and tailoring the websites or product to improve user experience.  

       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. 

  1. 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. 

        b. PARTNERS 

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.   

  1. HOW WE TRANSFER DATA WE COLLECT INTERNATIONAL
          a. INTERNATIONAL TRANSFERS

This Privacy Policy will apply even if we transfer personal data to other countries. We have taken appropriate safeguards to require that your personal data will remain protected wherever it is transferred. 
      b.
INTERNATIONAL TRANSFERS TO THIRD PARTIES

Some of the third parties described in this Privacy Policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we share personal data of individuals with third parties, we make use of a variety of legal mechanisms to safeguard the transfer including approved standard contractual clauses, as well as additional safeguards where appropriate.  

  1. 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.   

 

  1. COOKIES AND SIMILAR TECHNOLOGIES
         a. COOKIES
    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).
         b. ADVERTISING

We partner with third party ad networks to manage our advertising (such as for employment opportunities) on other sites. Our ad network partner may use cookies and web beacons to collect information about your activities on this and other websites to provide you targeted advertising based upon your interests.  If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by using these services: https://optout.networkadvertising.org/ or https://optout.aboutads.info/ (or if located in the European Union, by clicking here: http://www.youronlinechoices.eu/). Please note this does not opt you out of being served advertising you will continue to receive generic ads.
     c.
THIRD PARTY TRACKING TECHNOLOGIES

The use of cookies and web beacons by any tracking utility company is not covered by our Privacy Policy or Cookie Policy.  

  1. 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 privacy@inflightcrewconnections.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.  

    1. 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.  

    If you are unable to access this Privacy Policy due to a disability or any physical or mental impairment, please contact us and we will arrange to supply you with the information you need in an alternative format that you can access.
         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.  
    • Inferences.  
    • 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.  

    The business and commercial purposes for which we collect this information are described in section 2 of this Privacy Policy. The categories of third parties to whom we “disclose” this information for a business purpose are described in section 3 of this Privacy Policy. 

         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. 
    1. DATA PROTECTION OFFICER

    If you have any questions about this Privacy Policy or our privacy practices, or if you have a disability and need to access this notice in a different format, please email us at privacy@inflightcrewconnections.com: 

    • You may also contact us by postal mail for all IFCC brands at: 

    General Counsel 

    In-Flight Crew Connections, Inc.
    4325 Morris Park Drive 

    Charlotte, North Carolina 28227 USA 

     

    1. 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.