Effective Date: September 1, 2021
DATA WE COLLECT
We collect personal data from you directly and from third parties. We collect personal data directly from you when you fill out any online or hard-copy forms including for account applications, credit applications, our online flight planning and data link tool, our crew member identification card program, training and educational programs, airport data licensing, surveys and promotion entries, event registrations, and other registrations and web forms, or otherwise when you communicate with us via blog posts or online comments, or by telephone, email, postal mail, or facsimile.
In some cases, we may also collect certain personal data from third parties such as credit reporting agencies, airlines and travel agencies, companies that monitor Specially Designated Nationals lists and our other business customers and partners.
We also collect personal data when you visit or use our websites, mobile application and products or services. This personal data may include information about your device and usage such as your operating system, browser, geographical location, IP address, and page views and clicks.
USE OF YOUR DATA AND LEGAL BASIS FOR PROCESSING
We use your data:
Universal uses “cookies” to obtain certain types of data when your web browser accesses our website. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser to enable our system to recognize your browser, to provide various types of functionality, to better understand how you interact with our website, to monitor aggregate usage, and to optimize web traffic routing on our website. The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Certain areas or features of the website may not be available or fully-functional if you choose to disable cookies.
DISCLOSURE OF YOUR DATA
We do not sell your personal data to any third parties. We may share your personal data as needed to fulfill the purposes described in the “USE OF YOUR DATA” section above, including:
We require such third parties to take reasonable security measures to protect your personal data, and third parties are instructed not to use your data other than pursuant to our instructions or as stated in our contract. We remain liable for protection of your personal data in case of any onward transfer to third parties, subject to any terms in our contract with you.
DATA CONTROLLER AND DATA PROCESSOR
When we use your data for our own purposes, we act as the data controller, as that term is used in applicable privacy laws, for any personal data that we collect from you. When we collect data from or on behalf of our customers (e.g., charter aircraft operators, corporate aviation departments), those customers are the data controller for and we are the data processor. If we are acting as the data processor, we will only process the relevant data in accordance with instructions from the data controller.
DATA RETENTION, ACCESS, CORRECTION, DELETION AND PORTABILITY
Universal may retain your data so long as we can reasonably foresee the data may be required in connection with our business relationship with you. In some cases, we will retain the data for a longer period as necessary to comply with our legal obligations, follow records retention policies, resolve disputes, and enforce our agreements.
EUROPEAN AND SWISS RESIDENTS
Universal Weather and Aviation, LLC, Air Culinaire Worldwide, LLC, Universal Private Transport, LLC, Air2Ground Concierge, LLC, Universal Drivania Ground Transportation, LLC, Universal Airways, Inc. and Universal Mission Support Company, LLC (collectively, the “Universal Entities”) are based in the United States, and personal data collected by the Universal Entities worldwide (including within the EU and Switzerland) may be transferred to the United States, India, Brazil, the United Kingdom, Hong Kong or any location in the world that is necessary to facilitate a trip for you. By using the Universal Entities’ services or submitting personal data to the Universal Entities, you consent to the transmission of your information outside your own country.
The Universal Entities rely upon Article 46(2)(d) (the Standard Contractual Clauses) or Article 49(1)(b) (necessity for the performance of a contract) as the legal basis for the transfer of personal data to a third country.
You have the right to lodge an inquiry or compliant with a supervisory authority in your member country.
CALIFORNIA PRIVACY RIGHTS
We do not sell your personal information to third parties. California law entitles California residents to certain additional protections regarding personal information. For purposes of this section alone, “personal information” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. California residents have the right to request:
We will not discriminate against you if you choose to exercise any of these rights. To make any of the above requests, please contact us as set forth at the end of this policy. We may require verification of your identity before further processing your request. In certain instances, we may be permitted by law to decline some or all of such request.
Universal is very concerned with safeguarding your personal data. The integrity and availability of your personal data are critical to the provision of superior products and services to you. We employ administrative, physical, procedural, and technological measures designed to protect your data from unauthorized access or alteration and loss or misuse. We have implemented a multi-layered approach to protect electronic information through a comprehensive Information Technology (IT) Security program. Our IT Security program is designed to safeguard electronic information by proactively providing leadership and support for areas related to network security, system security, risk assessment, remediation tracking, and adherence to security compliance mandates. Universal employees work as a team so that information is protected against unintentional disclosure and are guided by compliance objectives, standard operating procedures, and acceptable usage policies.
TRANSFER OF BUSINESS
Universal Weather and Aviation, LLC
Attn: Legal Department and Data Protection Officer
1150 Gemini Street
Houston, Texas 77058
Phone (North America): +1 (800) 793-1295
Phone (Other): +1 (713)-947-5576