Data Privacy Policy

Effective Date: September 1, 2021

Universal Weather and Aviation, LLC and its worldwide subsidiaries (“Universal”, also referred to as “we”, “us”, “our”) are providing this privacy policy to inform you (“you” refers to any entity or person who is not a Universal employee) regarding our collection, use, disclosure, and storage of data about you that we collect via our websites, mobile applications, telephone, facsimile, email or otherwise. Our primary goals in collecting data are to provide superior products and services to our clients, to contact companies and individuals who have indicated an interest in Universal, and to enable effective use of an informative Universal® website.

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:

  • for the purposes for which you provided it to us (e.g., to process your credit application, create your user account, process requests in our flight planning tool, register you for programs and events, promotions, or newsletters, or provide you products and services that you have ordered, as applicable);
  • to respond to your inquiries and communications to us;
  • to improve, maintain, and operate our websites and our products and services;
  • to fulfill our obligations under our customer contracts (e.g., to provide flight planning services, trip support services, in-flight catering services, or other logistics services pursuant to our customer contracts);
  • to inform you about products and services in which you may be interested, if you have consented to such communications;
  • to screen you against lists of people, organizations and vessels with which certain countries  are prohibited from doing business; and
  • to comply with statutory and regulatory requirements, including responding to lawful requests for information by governmental authorities.

The legal basis for processing your data is consent, fulfillment of a contract or legitimate interests, depending upon the particular situation.  You can opt out of receiving promotional or marketing emails at any time by clicking the unsubscribe link at the bottom of any such emails. You may also revoke your consent to the use of your data for certain other purposes by contacting us as set forth at the end of this privacy policy; provided, however that if you do not provide certain personal data required by government agencies in order to facilitate a flight, we will not be able to provide trip support services. Your withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

BLOGS

If you participate in a Universal blog(s), you should be aware that such blogs are public and that any data you submit there, including personal data, can be read, collected, or used by third parties, and that those third parties could send you unsolicited messages. We are not responsible for the data, including personal data, you choose to submit in these blogs. To request removal of your data from our blog(s), please contact us as set forth at the end of this privacy policy. In some cases, we may not be able to remove your data, in which case we will let you know if we are unable to do so and why.

COOKIES

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:

  • with our suppliers and vendors to provide goods and services you have requested;
  • with our vendors in order to improve the services;
  • with global trip support providers to provide additional services to you;
  • with our service providers, such as credit agencies, companies that monitor Specially Designated Nationals lists and technical or customer support providers, who use the data on our behalf; and
  • as necessary in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

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.

You may request access, correction, erasure or portability of your personal data that we process.  We will grant such request except where an exception under the law would make it inappropriate to comply with all or some of the request To request access to, correction of, or erasure of your personal data, please contact us as set forth at the end of this privacy policy. In cases where we are not the data controller (such as when the personal data was collected from or on behalf of a charter aircraft operator, corporate aviation department or other customer), we may need to refer you or your request to the applicable data controller.

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:

  • information regarding your personal information we have collected in the past 12 months (including the categories of personal information we have collected, the categories of sources of such information, and the purposes for which we have collected such information);
  • notice of whether we have disclosed your personal information to third parties in the past 12 months (and if so, what categories of information we have disclosed, and what categories of third parties we have disclosed it to);
  • a copy of your personal information collected by us in the past 12 months; and
  • that your personal information be deleted.

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.

SECURITY

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

In the event of a merger, consolidation, sale, or transfer of all or substantially all of the assets or business of Universal, one of the assets which would generally be transferred is the data we have collected. We will advise a successor or successors in interest of the terms of this privacy policy and our expectation that the successor(s) in interest will adopt and maintain this policy until there is a notification of an amendment of this policy.

CHILDREN

Universal’s website is not directed toward children under 18. If a parent or guardian becomes aware that his or her child has provided us with personal data without their consent, please contact us as set forth at the end of this privacy policy and we will take reasonable steps to remove such data from our systems.

PRIVACY POLICY CHANGES

Universal and its successor(s) in interest reserve the right to and may revise this privacy policy from time to time. If we make a material change to this policy, we will post the updated privacy policy (with the date of change(s) noted in the policy) on the Universal homepage and other places we may deem appropriate, so that you are aware of what data we collect, how we use it, and under what circumstances, if any, we disclose it.

CONTACT

Universal Weather and Aviation, LLC
Attn: Legal Department and Data Protection Officer
1150 Gemini Street
Houston, Texas 77058
United States

Phone (North America): +1 (800) 793-1295
Phone (Other): +1 (713)-947-5576

Email: dataprivacy@univ-wea.com