California Consumer Privacy Act Notice

1. Privacy Notice for California Residents

This privacy notice for California residents supplements the Privacy Notice of the OAG Aviation Group (“we,” “us” or “our”) and applies solely to visitors, users and others who reside in the State of California (“consumers” or “you”). We provide this notice 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 notice.

2. Information We Collect

We have collected the following categories of personal information from consumers within the preceding twelve (12) months:

Category	Examples	Collected
A. Identifiers	Real name, alias, postal address, email address, unique personal or online identifier, Internet Protocol (IP) address, account name, telephone number	Yes
B. Personal information listed in the California Customer Records statute (Cal. Civ. Code §1798.80(e))	Name, address, telephone number, education, employment, employment history, financial information. Some personal information included in this category may overlap with other categories.	Yes
C. Characteristics of protected classifications under California or federal law	Race, religion, gender, color, creed, national origin, sexual orientation, age (age 40 or older), disability, genetic information	No
D. Commercial information	Products or services purchased, obtained or considered; or other purchasing or consuming histories or tendencies	Yes
E. Biometric information	Fingerprints, faceprints, voiceprints	No
F. Internet or other electronic network activity information	Browsing history, search history, information regarding a consumer’s interaction with a website, application or advertisement	Yes
G. Geolocation data	Device location	Yes
H. Sensory data	Audio, electronic, visual, thermal, olfactory or similar information	Yes
I. Professional or employment-related information	Job title, work experience, work history as part of managing business relationships with our customers and in connection with marketing collateral and testimonials for our products/services	Yes
J. Non-public education information (under the Federal Family Educational Rights and Privacy Act (FERPA)	Student records	No
K. Inferences drawn from any of the above personal information categories	Profile reflecting a consumer’s preferences, characteristics, predispositions, behavior, attitudes	Yes

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

• Directly from you, by filling out forms or by corresponding with us by post, phone, email or otherwise.
• Automated technologies as you interact with our website and use our mobile apps, by using cookies, server logs and other similar technologies.

3. Use of Personal Information

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

• To perform a contract we have entered into with you and to enforce our rights under that contract
• To provide you with information that you request from us
• To fulfill the specific purpose for which you provided the information
• As described to you at the time we collect the personal information from you or as otherwise permitted under the CCPA
• To manage our relationship with you, which will include notifying you about changes to our terms or privacy notice
• To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data and in the context of a business reorganization or group restructuring or sale)
• To use our data analytics to improve our websites, products/services, customer relationships and experiences
• To comply with a legal or regulatory obligation and respond to law enforcement requests
• For any other purpose where you have given your consent

4. Sharing Personal Information

We may disclose your personal information to a third party for a business purpose and in accordance with the law. All such third parties are only permitted to process your personal information for specified purposes and in accordance with our instructions.

In the preceding twelve (12) months we have disclosed your personal information for a business purpose to the following categories of third parties:

• To other companies in the OAG Aviation Group
• Service providers
• Professional advisers

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months we have disclosed the following categories of personal information for a business purpose:

• Category A: Identifiers
• Category B. Personal information listed in the California Customer Records statute
• Category D: Commercial information
• Category F: Internet or other electronic network activity information
• Category G: Geolocation data

Sales of Personal Information

We do not currently sell personal information. In the preceding twelve (12) months we did “sell” personal information as defined under the CCPA, solely through the use of third-party ad network cookies at our website and mobile flight tracking apps to provide targeted third-party advertising to you.

In the preceding twelve (12) months we have sold the following categories of personal information:

• Category A: Identifiers
• Category F: Internet or other electronic network activity information
• Category G: Geolocation data

5. Your Legal Rights and Choices

The CCPA provides you with the following specific rights regarding your personal information:

• Access to specific information and data portability rights. You have the right to request that we disclose to you certain information about our collection and use of your personal information during the prior twelve (12) months as described below:
• the categories of personal information we have collected about you;
• the categories of sources from which we collected such personal information;
• the business or commercial purpose for collecting or selling the personal information about you;
• the categories of third parties with whom we share such personal information;
• if we sold your personal information or disclosed it for a business purpose, two separate lists detailing: (i) for sales, the personal information categories that each category of recipient purchased; and (ii) for disclosures for a business purpose, the personal information categories that each category of recipient obtained; and
• the specific pieces of personal information we collected about you in a portable format.
• Deletion of your information collected by us. You have the right to request that we (and our service providers) delete your personal information that we have collected, subject to certain exceptions.

  To make either of the requests described above, please submit a verifiable consumer request to us by any of the following methods:

  • Emailing us at privacy@oag.com or
  • Calling us at +1 (800) 342-5624 or
  • Mailing us at 1 Capability Green, Luton, Bedfordshire, LU1 3LU, United Kingdom
  A verifiable consumer request must provide sufficient information to allow us to verify that the person making the request is the person about whom we collected personal information or an authorized representative to act on your behalf. We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we need more time (up to an additional 45 days), we will inform you in writing of the extension needed and the reason for the delay.
• Nondiscrimination. You have the right to not be discriminated against because you exercise any of your rights under the CCPA. Unless permitted under the CCPA, if you choose to exercise any such rights, we will not, for example: (i) deny you products or services; (ii) charge you different prices (including offering discounts to those who do not opt out); (iii) vary the level or quality of products or services provided to you; or (iv) suggest that you will receive a different price for products or services or a different level or quality of products or services.

6. Changes to This Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on this page and update the notice effective date.

Last updated: July 1, 2020