We are committed to your privacy and value your trust.
We invite you to read our Privacy Notice to understand how we collect, use, disclose, transfer and store your information.
Last Updated: July 30, 2020
This Privacy Notice (the “Notice”) describes how CAMP Systems International, Inc. (“CAMP Systems”, “we”, “our” or “us”) handle personal information in connection with the operation of the CAMP Systems website, available at www.campsystems.com (the “Site”). The Site is made available for informational and research purposes and is intended for users acting in a professional capacity.
This Notice also applies to the personal information CAMP Systems obtains through its products and services, which include the iCAMP and CAMP imsMOBILE apps and the following modules of the CAMP Systems products (including any alternate or legacy versions): CAMP Maintenance (MTX), CAMP Inventory Management System (IMS), Engine Health Monitoring (EHM), Avtrak, CESCOM, CMP, Turbine Tracker, WebECTM and Flight Scheduling (collectively the “Services”). The Services also include our call center and technical and maintenance support services. CAMP Systems provides the Services to customers for their fleet and aviation management purposes, including aircraft systems maintenance, inventory management, monitoring of systems and engines and logging of maintenance, repair and operations activities. CAMP Systems obtains information relevant to aircraft and aviation management which includes aircraft data (e.g., model specifications and usage metrics) and certain personal information of users of the Services and other relevant individuals associated with the aircraft.
This Notice describes how CAMP Systems uses the personal information obtained through the Site and the Services and with whom we may share it. If you are a European visitor or user, you may have additional rights with respect to your personal information we process. Please see the "Additional Information for European Visitors" section below for more information.
In addition, we de-identify and/or aggregate the personal information and other data we obtain through the Site and Services (the “De-identified Data”). The requirements and limitations described in this Notice on our collection, use, sharing, disclosure, transfer and retention of personal information do not apply to such De-identified Data as well as other information that cannot be used to identify you.
This Notice does not describe the data handling practices of the aircraft operators and other customers who use the Services. We encourage you to review the privacy notices and similar statements of the operators of such customer with whom you interact to learn about their privacy practices, including about the cookies and similar technologies they may use.
2. WHAT PERSONAL INFORMATION WE OBTAIN
CAMP Systems may obtain personal information when you use the Site. This personal information may be provided by you directly, such as when you complete a form on the Site or it may be automatically collected from your browser or mobile device using technologies such as cookies. CAMP Systems also obtains personal information in connection with our customers’ use of the Services. In addition, CAMP Systems obtains personal information about its customers’ representatives as part of the contracting process, for CAMP Systems’ marketing purposes and during the ordinary course of business.
a. Personal information we obtain from you through the Site:
We may ask you to provide your personal information when you use the Site. You may not be able to use certain features if you choose not to submit the requested personal information. The personal information we collect directly from you may include details such as:
- Contact information (e.g., name, email address, company name and address).
- Registration information (e.g., username for accessing the Services).
b. Personal information we obtain from customers (and their authorized users) in connection with the Services:
The personal information we obtain from our customers and their authorized users may include details such as:
- Contact information (e.g., name, email address, company name and address).
- Registration information (e.g., username for accessing the Services).
- Other personal information provided through the Services (e.g., personal information inputted into the "Notes" field of forms).
- Personal information shared in connection with calls to the call center or CAMP Systems' technical and maintenance support services.
When customers use the Services, we obtain personal information of individuals relevant to the aircraft which they input. This may include:
- Contact information (e.g., name, email address, job title, company name and address).
- Other information they choose to provide through the Services about such relevant individuals (e.g., personal information inputted into the "Notes" field of forms).
If a customer uses the Flight Scheduling module, we may obtain additional categories of information inputted voluntarily by the customer, including:
- Crew information (job title, qualifications, scheduling and trainings).
- Passenger information (contact information, demographic information).
- Government-issued identifiers, passport information and visa status for passengers and crew.
- Flight information (origin and destination airports, estimated travel time).
- Payment card information
c. Personal information we obtain from other sources:
We may combine personal information we obtain through the Site or in connection with the provision of the Services with other personal information we may have about you, including personal information obtained offline. In connection with the Services, we may obtain information and aircraft data from publicly or commercially available sources, such as the Federal Aviation Authority or national equivalent. If you are a representative of a customer or potential customer, we may obtain personal information about you from your organization, for example, through the contract negotiation process. We may obtain your personal information if you attend an industry conference or event. We may also obtain personal information from our affiliates.
d. Data automatically collected:
We and our service providers may automatically obtain certain information (some of which may constitute personal information), when you access the Site and the Services from your web browser or mobile device, such as data about the number and frequency of visitors, technical data about browsers and devices used to access the Site and the Services, and data about crashes or other technical issues. In addition, we and third parties may automatically collect certain data through automated means about your activities over time across the browsers and devices you use to access the Site and the Services as well as across third-party sites, apps or other media. These technologies may assign or collect a unique identifier on your browser or device, and may reside, among other places, on your computer or device, within webpages or mobile apps. We may use these technologies to administer the Site and the Services, understand usage of the Site and the Services and improve the content and offerings of the Site and the Services.
3. HOW WE USE PERSONAL INFORMATION WE OBTAIN
We use personal information we obtain in connection with the operation of the Site and the provision of the Services for a number of purposes, including, but not limited to:
- Making the Site and the Services available, responding to your requests or inquiries and providing customer support.
- Performing the Services contracted or requested by our customers, including enabling APIs, data exchanges with systems used by our customers, which may include our affiliates’ offerings and third-party offerings.
- Improving the Site, the Services and other CAMP Systems offerings and developing new products and services.
- Communicating with you about the Site, the Services and CAMP Systems’ and our affiliates’ products and services.
- Analyzing and customizing the user experience.
- Generating statistics, performing data analytics, anonymizing and/or aggregating data to prepare internal, customer and industry insights.
- Detecting, preventing, and responding to violations of this Notice, violations of law, or other misuse of the Site or the Services.
- Complying with and enforcing applicable contractual obligations or industry and legal requirements (including legal process such as court orders, warrants or subpoenas).
With respect to Site visitors and representatives of customers or potential customers, we may also use their contact information to send them communications, including email or other communications marketing and advertising CAMP Systems’ or our affiliates’ products, services and other offerings.
4. WITH WHOM WE SHARE PERSONAL INFORMATION
We may share personal information we obtain in connection with the operation of the Site and the Services:
- With our affiliates and subsidiaries.
- With business partners.
- With other entities, as instructed or requested by the relevant customer (for example, as a result of APIs or integrations).
- With third parties that provide services or handle transactions on our behalf.
- As we believe is necessary or appropriate to protect, enforce, or defend our legal rights, the privacy or safety of our employees, users of the Site and the Services or other individuals and entities, or to comply with or enforce applicable law or legal process, including responding to court orders, warrants, subpoenas and other requests from public and government authorities.
We also reserve the right to transfer any of the information (including personal information) we have about you to proceed with the consideration, negotiation, or completion of a sale or transfer of all or a portion of our business or assets to a third party, such as in the event of a merger, acquisition or other disposition, or in connection with a bankruptcy reorganization, dissolution, or liquidation.
In addition we may share your personal information with third parties when you consent to or request such sharing.
5. HOW WE PROTECT YOUR PERSONAL INFORMATION
We maintain reasonable administrative, technical and physical safeguards to protect the personal information we obtain through the Site and the Services. However, no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, while we make reasonable efforts to protect your personal information, we cannot guarantee its absolute security.
6. THIRD-PARTY LINKS AND FEATURES
The Site and the Services may contain links to third-party websites or features, including through APIs or other feeds. CAMP Systems is not responsible for the collection or use of your personal information by such third parties. We encourage you to review the privacy policies or other similar statements applicable to third-party websites or features.
7. DO NOT TRACK
CAMP Systems does not currently take steps to respond to browsers’ "Do Not Track" signals as no uniform standard to respond to such signals has been developed at this time.
8. INTERNATIONAL DATA TRANSFERS
CAMP Systems operates the Site and the Services in different regions, including the United States. Please note that the personal information we collect in connection with your use of the Site and the Services will be transferred to the United States and other countries. In such circumstances we put appropriate safeguards in place to protect your data. If you are located in the European Union, United Kingdom, Switzerland, Iceland, Liechtenstein or Norway (collectively, the “EEA and Switzerland”), we will comply with applicable legal requirements for the transfer of personal information to recipients in countries outside of the EEA and Switzerland. CAMP Systems is certified under the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework for certain activities. For more personal information, see our Privacy Shield Statement.
9. CHILDREN’S INFORMATION
The Site is not directed to, nor does CAMP Systems knowingly collect personal information from, children under the age of 13. If you become aware that your child or any child under your care has provided us with personal information without your consent, please contact us as indicated below.
10. CHANGES TO THIS PRIVACY NOTICE
We may update this Notice from time to time to reflect changes in our privacy practices or applicable laws. In accordance with applicable law, we may make such changes without prior notice. We will publish the updated version on the Site and indicate at the top of the Notice when it was most recently updated. Your use of the Site will be governed by the current version of this Notice.
11. CONTACT US
If you have any questions about this Notice or, in accordance with applicable laws, you would like to review or request changes to the personal information collected in connection with your use of the Site, please contact us at firstname.lastname@example.org.
12. ADDITIONAL INFORMATION FOR EUROPEAN VISITORS
a. Who is Responsible for Your Personal Information?
Each CAMP Systems customer is the responsible data controller for the personal information they collect and maintain using the Services. Individuals with concerns about the personal information obtained through the Services should contact the relevant customer with their concerns.
The data controller for personal information we obtain from representatives of customers or potential customers for our own business purposes is CAMP Systems International, Inc. The below information applies to our data processing activities as a data controller only. You can contact CAMP Systems International, Inc. at email@example.com.
b. Legal Bases for Using Your Personal Information
We process personal information for different purposes (as described in the “How We Use Information We Obtain” section, above) on the following legal bases:
- To provide the Services in performance of a contract. We process personal information to perform our contractual obligations when we make the Services available to you at the request of a customer. For example this includes when we obtain your registration information and manage your user account. We may share your personal information on this legal basis with our affiliates and subsidiaries, our service providers and as instructed by the relevant customer.
- To pursue our legitimate interests. We process your personal information to meet our legitimate interests when we use your personal information to provide you with the Site, to communicate with you about our offerings and for our advertising and marketing purposes. For example, our legitimate interests include making improvements to, customizing and understanding how you interact with the Site and the Services and sending you communications about products and services we think may be of interest to you. To accomplish our legitimate interests, we may share your information with our affiliates and subsidiaries and service providers (including for our advertising and marketing purposes), with business partners and in the context of a corporate transaction. We maintain safeguards to protect the information we process to pursue our legitimate interests.
- To comply with our legal obligations. We process and share your personal information as necessary to comply with our legal obligations when we use your information to protect our rights or the rights of others and when we share your information with other parties where required by law or as necessary to protect our rights.
- With your consent. We obtain your consent to process your personal information when we are required to do so by law. If consent is the legal basis on which we process your personal information, you can withdraw your consent at any time by contacting us using the information provided in the "Contact Us" section above.
c. Your Rights Over Your Personal Information
In certain circumstances, you have a right to access or object to the use of personal information we hold about you as a data controller. You can also ask us to rectify, update, erase, restrict or to share such information in a usable format with another company. Such requests are subject to applicable law. To exercise your rights in relation to personal information we hold about you as a data processor, you should contact the relevant customer.
We encourage you to contact us to update or correct your personal information if it changes or if the personal information we hold about you is inaccurate.
If you would like to discuss or exercise such rights, please contact us at firstname.lastname@example.org. We will contact you if we need additional information from you in order to honor your requests.
d. Storing Your Personal Information
We keep the personal information for which we are a data controller for as long as we have a relationship with you. After our relationship with you has ended, we retain your personal information as necessary and appropriate to enable us to:
- Maintain business records for analysis, understanding market trends and/or audit purposes and to improve the Site, the Services and other CAMP Systems offerings.
- Comply with record retention requirements under applicable laws or other relevant legal, regulatory or industry requirements.
- Defend, establish, exercise or bring any existing or potential legal claims.
- Carry out fraud detection and prevention.
- Deal with any complaints regarding the Site, the Services or other CAMP Systems’ and our affiliates’ offerings.
e. Contact, Questions and Complaints
European visitors can contact us at email@example.com. Individuals in the EEA, United Kingdom, and Switzerland whose personal information is processed by CAMP Systems as a data processor on behalf of a customer should contact the relevant customer with any requests or complaints.
We are committed to working with you to obtain a fair resolution in the event you have a complaint or concern about our data processing activities. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to a data protection authority.