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NetJets Inc. California Privacy Notice

Effective Date: January 1, 2021

This California Privacy Notice (“Notice”) applies to “Consumers” as defined by the California Consumer Privacy Act (together with amendments thereto and regulations thereunder, the “CCPA”) as a supplement to other privacy policies or notices published by NetJets Inc. and its subsidiaries and affiliates (“NetJets” “us” “we” “our”). In the event of a conflict between any other NetJets policy, statement, or notice and this Notice, this Notice will prevail as to California Consumers and their rights under the CCPA. Please see also any privacy policy or notice of general applicability posted or referenced on our websites, apps, products, or services.

This Notice covers the collection, use, disclosure, and sale of California Consumers’ “Personal Information” (“PI”) as defined by the CCPA, except to the extent such PI is exempt from the notice obligations of the CCPA. This Notice also covers rights California Consumers have under the CCPA. 

Consistent with the CCPA, job applicants, current and former employees, and independent contractors (“Personnel”), and subjects of certain business-to-business communications acting solely in their capacity as representatives of another business, are not considered “Consumers” for purposes of this California Privacy Notice or the rights described herein. While we have included our data practices regarding Personnel in our disclosures in Section 1 (PI We Collect) and Section 2 (Sharing of PI), Personnel will not have the rights described in Section 3 (California Privacy Rights). Publicly available information is also not treated as PI under the CCPA, so this Notice is not intended to apply to that data, and your Consumer privacy rights do not apply to that data.  Consistent with the CCPA, Sections 1 and 2 reflect our practices in calendar year 2020.  Consult our privacy policy or other notices, such as may be provided at the time of PI collection, for information on more current practices.

To aid in readability, in some places we have abbreviated or summarized CCPA terms or language, but a full copy of the CCPA is available here for your review. Terms defined in the CCPA that are used in this Notice shall have the same meaning as in the CCPA. 

1. PI WE COLLECT

In 2020 we collected, retained, used, and disclosed PI about California Consumers as follows:

 
Category of PI Categories of Recipients and Purposes for Disclosure

1. Identifiers

This may include but is not limited to, a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

Business Purposes:

  • Provided to service providers (FBOs, caterers, ground transportation, marketing, IT vendors, etc.)
  • Provided to banks for processing of payments
  • Provided to government agencies (customs and border clearance) to assist in providing the services
  • Passenger-related information is disclosed to aircraft owners
  • Employment-related information is provided to various unions representing NetJets employees

Sale:

  • Certain cookie and/or pixel information is shared with IT and social media vendors related to internet-based advertising and other internet services used by NetJets

2. Personal Records

This may include information such as: physical characteristics or description, signature, telephone number, education, employment, employment history, insurance policy number, bank account number, credit card number, debit card number, or any other financial information medical information, or health insurance information.

Business Purposes:

  • Provided to service providers (FBOs, caterers, ground transportation, IT vendors, etc.)
  • Provided to banks for processing of payments
  • Provided to government agencies (customs and border clearance) to assist in providing the services
  • Passenger-related information is disclosed to aircraft owners

Sale: Not Sold

3. Personal Characteristics or Traits

This may include, but is not limited to, sex, marital status, religion, veteran status, familial status, race, disability, gender identity, and creed.

Business Purposes:

  • Provided to service providers (FBOs, caterers, ground transportation, IT vendors, etc.)
  • Passenger-related information is disclosed to aircraft owners

Sale: Not Sold

4. Customer Account Details /Commercial Information

This may include, but is not limited to, records of personal property; products or services purchased, obtained, or considered; or other purchasing or consuming histories or tendencies.

Business Purposes:

  • Provided to service providers (FBOs, caterers, ground transportation, IT vendors, etc.)
  • Provided to banks for processing of payments
  • Passenger-related information is disclosed to aircraft owners

Sale:

  • Certain cookie and/or pixel information is shared with IT and social media vendors related to internet-based advertising and other internet services used by NetJets

5. Internet Usage Information

This may include, but is not limited to, browsing history, search history, and information regarding your interaction with an internet website, application, or advertisement.

Business Purposes:

  • Provided to service providers (FBOs, caterers, ground transportation, IT vendors, etc.)

Sale:

  • Certain cookie and/or pixel information is shared with IT and social media vendors related to internet-based advertising and other internet services used by NetJets

6. Geolocation Data

This may include, but is not limited to, precise physical location or movements and travel patterns.

Business Purposes:

  • Provided to service providers (FBOs, caterers, ground transportation, IT vendors, etc.)
  • Provided to government agencies (customs and border clearance) to assist in providing the services
  • Passenger-related information is disclosed to aircraft owners
  • Employment-related information is provided to various unions representing NetJets employees

Sale: Not Sold

7. Professional or Employment Information

This may include, but is not limited to, professional, educational, or employment-related information.

Business Purposes:

  • Provided to service providers (IT vendors, etc.)
  • Provided to government agencies (pilot qualifications)

Sale: Not Sold

8. Non-public Education Records

This may include, but is not limited to, education records directly related to a student and maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Business Purposes:

  • Provided to service providers (IT vendors, etc.)

Sale: Not Sold

As permitted by applicable law, we do not treat deidentified data or aggregate consumer information as PI, and we reserve the right to convert, or permit others to convert, your PI into deidentified data or aggregate consumer information. We have no obligation to re-identify such information or keep it longer than we need it to respond to your requests. This helps us practice data minimization, which we consider to be a privacy best practice consistent with our mission to respect our customers.

A. Sources of PI

We may have collected your PI directly from you or from NetJets-generated data related to services provided to you, your devices, other consumers, service providers such as analytics companies, joint marketing providers, and network security vendors, data providers, affiliates, NetJets flight records, as well as public sources of data such as government databases. For more specifics tied to each category of PI, see the chart above. 

B. Use of PI

Generally, we collect, retain, use, and disclose your PI to provide you services and as otherwise related to the operation of our business. For more specific detail on our collection of PI, see the chart above at PI WE COLLECT. For more detail on our disclosures of PI, see the next section Sharing of PI. 

We may collect, use, and disclose the PI we collect for one or more of the following business purposes:
  • Performing services;
  • Security;
  • Auditing interactions with Consumers;
  • Short-term or Transient Use;
  • Undertaking Internal Research;
  • Quality Assurance;
  • Debugging.

Additional business purposes include sharing PI with third parties for other than a sale or one of the foregoing business purposes as required or permitted by applicable law, such as to our vendors that perform services for us, to the government or private parties to comply with law or legal process, to the consumer or other parties at the consumer’s request, and for the additional purposes explained in our Privacy Policy, and  to assignees as part of a merger or asset sale (“Other Business Purposes”).

Subject to restrictions and obligations of the CCPA, our service providers may also use your PI for some or all of the above listed business purposes. Our vendors may themselves engage service providers or subcontractors to enable our vendors to perform services for us, which sub-processing is, for purposes of certainty, an Other Business Purpose for which we are providing you notice.

We may collect, use, and disclose your PI for commercial purposes, such as for interest-based advertising.
In addition, we may collect, use, and disclose your PI as required or permitted by applicable law, which we also consider a business purpose.

For more specifics tied to each category of PI, see the chart above.

2. Sharing of PI

In 2020 we disclosed PI about California Consumers to our service providers, other vendors (including those that facilitate interest-based and other advertising and marketing), and/or affiliates as set forth in the chart above.  If you direct us to share PI we may, and that is not a Sale. Also, disclosures amongst the entities that constitute NetJets as defined above are not a Sale. 

We, however, may Sell your PI (as the term “Sell” is defined by the CCPA) as set forth in the chart above. Although there is not yet a consensus, we treat the collection of PI via third party cookies and tracking technologies, other than by our service providers that limit their use of the PI, as a sale even though we are not paid for that data and we share it in order to improve the data sets they use for us and others. To exercise your Do Not Sell rights, click the "Do Not Sell My Personal Information" link at the bottom of the NetJets website.

See Section 3.B below for more information on how this works.

3. CALIFORNIA PRIVACY RIGHTS

The CCPA is a new law and there remain differing interpretations of it and the regulations that implement it. Accordingly, we may from time-to-time update information in our notices regarding our data practices and your rights, modify our methods for you to make and for us to respond to your requests, and/or supplement our response(s) to your requests, as we continue to develop our compliance program to reflect the evolution of the law and our understanding of how it relates to our data practices. 

We provide California Consumers the privacy rights described in this section. You have the right to exercise these rights via an authorized agent who meets the agency requirements of the CCPA and related regulations. As permitted by the CCPA, any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”). We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI consistent with regulatory standards. Please follow the instructions below and respond to any follow-up inquires we may make, which may require you to provide us with additional information. 

Some PI we maintain about Consumers is not sufficiently associated with enough PI about the Consumer for us to be able to reasonably verify that it is a particular Consumer’s PI (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA we do not include that PI in response to those requests. If we cannot comply with a request, we will explain the reasons in our response. You are not required to create an account with us to make a Verifiable Consumer Request. We will use PI provided in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document request responses, unless you also gave it to us for another purpose.

We will make commercially reasonable efforts to identify Consumer PI that we collect, process, store, disclose, and otherwise use and to respond to your California Consumer privacy rights requests. We reserve the right to direct you to where you may access and copy responsive PI yourself. We will typically not charge a fee to fully respond to your requests; however, we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome. If we determine that the request warrants a fee, or that we may refuse it, we will give you notice explaining why we made that decision. You will be provided a cost estimate and the opportunity to accept such fees before we will charge you for responding to your request.
Consistent with the CCPA and our interest in the security of your PI, we will not deliver to you your Social Security number, driver’s license number, or other government-issued ID number, financial account number, any health or medical identification number, an account password, or security questions or answers in response to a CCPA request.

Your California Consumer privacy rights are as follows:

A. The Right to Know:

i. Information Rights:

You have the right to send us a request, no more than twice in a 12-month period, for any of the following for the period that is 12 months prior to the request date:
  • The categories of PI we have collected about you
  • The categories of sources from which we collected your PI
  • The business or commercial purposes for our collecting or selling your PI
  • The categories of third parties to whom we have shared your PI
  • How to request the specific pieces of PI we have collected about you
  • A list of the categories of PI disclosed for a business purpose in the prior 12 months, and the corresponding categories of recipient, or that no disclosure occurred
  • A list of the categories of PI sold about you in the prior 12 months, and the corresponding categories of recipient, or that no sale occurred. 

To make a request, please complete our data privacy request form.  If you are not able to make your request through our dedicated form, you may send an email to NJUS-DataProtectionOfficer@netjets.com or call us at 1-855-689-2391. Your email or voicemail should include the following information:
  • Your first and last name and, if you are acting as an agent for another individual, the first and last name of the individual who is the subject of the request and your relationship to that individual
  • Contact information for follow-up, including a phone number or email address
  • Explanation of your connection to NetJets (Owner, employee, vendor, etc.)
  • Your residential address
  • Explanation of your request related to your PI

Upon making a request you should follow the instructions that we send you regarding verification. Upon receiving your request, a NetJets representative will contact you to let you know that we have received your request and to verify that you are eligible to receive the requested information. For your specific pieces of information, as required by the CCPA, we will apply the heightened verification standards set forth in subsection (ii) below. 

Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.

ii. Obtaining Copies of PI:

You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have collected in the period that is 12 months prior to the request date and are maintaining. To make a request, please complete our data privacy request form.  If you are not able to make your request through our dedicated form, you may send an email to NJUS-DataProtectionOfficer@netjets.com or call us at 1-855-689-2391. Your email or voicemail should include the following information:
  • Your first and last name and, if you are acting as an agent for another individual, the first and last name of the individual who is the subject of the request and your relationship to that individual
    Contact information for follow-up, including a phone number or email address
    Explanation of your connection to NetJets (Owner, employee, vendor, etc.)
    Your residential address
    Explanation of your request related to your personal information
Upon making a request you should follow the instructions that we send you regarding verification.  Upon receiving your request, a NetJets representative will contact you to let you know that we have received your request and to verify that you are eligible to receive the requested information. Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.

B. Do Not Sell:

We do not Sell PI for monetary consideration.  However, the CCPA’s definition of “Sale” could be interpreted to include certain sharing of PI for the benefit of multiple parties, such as is common in the digital advertising.  NetJets’ Sale of personal information, as that term is potentially defined by CCPA, is limited to certain cookie and/or pixel information that is hosted on our website or mobile application and shared with IT and social media companies related to internet-based advertising and other internet services used by NetJets. You have the right to direct us to not Sell your PI by clicking on the Do Not Sell My Personal Information link on the bottom of our website. If you click on the “Do Not Sell My Personal Information” link, we will add a cookie to your browser to identify your selection. For browsers with our “Do Not Sell My Personal Information” cookie enabled, we will disable all third-party cookies with tracking technologies other than by our service providers that limit their use of the PI to not include a Sale. Because we manage our “Do Not Sell My Personal Information” tracking through cookies, your selection is based on the browser you are using to make the selection and will not apply to every browser/device that you may use. Also, if you clear your browser cookies, we may no longer retain your selection. In the future we may add signals to tell third parties to restrict cookie data processing to service provider purposes. However, we are not responsible for how any such third party looks for or responds to these signals. 

We do not knowingly Sell the PI of Consumers we know are younger than 16 years of age. If you think we may have unknowingly collected PI for Sale of yourself or of your child under the age of 13 years, or if you are at least 13 years old but under 16 years old, exercising the opt-out will stop our Selling of the PI.

We may disclose your PI for the following purposes, which are not a Sale: (i) if you direct us to share PI; (ii) to comply with your requests under the CCPA; (iii) disclosures amongst the entities that constitute NetJets as defined above, or as part of a merger or asset sale; and (iv) as otherwise required or permitted by applicable law.

C. Delete:

Except to the extent we have a basis for retention under CCPA, you may request that we delete your PI that we have collected directly from you and are maintaining. Our retention rights include, without limitation, to complete transactions and service you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes, including maintaining business records, to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement. Note also that we are not required to delete your PI that we did not collect directly from you. To make a request, please complete our data privacy request form.  If you are not able to make your request through our dedicated form, you may send an email to NJUS-DataProtectionOfficer@netjets.com or call us at 1-855-689-2391. Your email or voicemail should include the following information:
  • Your first and last name and, if you are acting as an agent for another individual, the first and last name of the individual who is the subject of the request and your relationship to that individual
    Contact information for follow up, including a phone number or email address
    Explanation of your connection to NetJets (Owner, employee, vendor, etc.)
    Your residential address
    Explanation of your request related to your personal information
Upon making a request you should follow the instructions that we send you regarding verification.  We will inform you if we are unable to verify you, in which case you can still exercise your “Do Not Sell” rights, and if we retain some of your data following a verified deletion request, we will explain our retention purpose and limit use to those purposes and shall delete the PI when the purposes end.

D. Non-Discrimination and Financial Incentive Programs:

We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. 

E. Authorized Agents:

An authorized agent may make a request on your behalf by submitting the information requested in the sections above, subject to our verification of you and your agent. 

F. Limitation on Rights:

Notwithstanding anything to the contrary, we may collect, use, and disclose your PI as required or permitted by applicable law and this may override your CCPA rights. In addition, we need not honor any of your requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law.  If this is the case, we will explain the limitation, and the basis for it, in our response to your request.

4. ADDITIONAL CALIFORNIA NOTICES

In addition to CCPA rights, certain Californians are entitled to certain other notices, including:

A. Third-Party Marketing and Your California Privacy Rights:

California's "Shine the Light" law permits California residents to request certain information regarding our disclosure of PI to third parties for their own direct marketing purposes.

We do not share personal information as defined by California Civil Code § 1798.83 (“Shine the Light” law) with third parties for their direct marketing purposes without your express consent. If you are a California resident, you may request information about our compliance with the “Shine the Light” law by contacting us here or by sending a letter to 4111 Bridgeway Avenue, Columbus, OH 43219, (Attention: Legal Department). Any such request must include “California Shine the Light Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year.

B. Online Privacy Practices:

For more information about our online practices and your California rights specific to our online services, see our online ​​​​​Privacy Policy. Without limitation, Californians who visit our online services and seek or acquire goods, services, money, or credit for personal, family, or household purposes are entitled to the following notices of their rights:

C. Tracking and Targeting:

When you visit our online services, we and third parties may use tracking technologies to collect usage information based on your device for a variety of purposes, including serving you advertising, based on your having visited our services or your activities across time and third-party locations. Some browsers may enable you to turn on or off a so-called “Do Not Track” signal. Because there is no industry consensus on what these signals should mean and how they should operate, we do not look for or respond to “Do Not Track” signals. For more information on tracking and targeting and your choices regarding these practices, see our online Privacy Policy.

5. Contact Us

For more information on your California privacy rights, contact us here

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