Privacy shield statement

We invite you to read our Privacy Shield Statement to learn more about CAMP Systems' EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework certifications and about how we collect, use, disclose, transfer and store your information.

Last Updated: July 30, 2020

 

INTRODUCTION

CAMP Systems International, Inc. (“CAMP Systems”, “we”, “us”, and “our”) participates in the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (collectively, the “Privacy Shield”) set forth by the U.S. Department of Commerce, the European Commission and the Swiss Administration with respect to certain Services (as defined below).

 

SCOPE

CAMP Systems adheres to the Privacy Shield Principles with respect to personal information from the EEA, Switzerland, and United Kingdom submitted through and in relation to the Services (as defined below) we provide to our Customers. This Privacy Shield Statement describes how CAMP Systems implements the Privacy Shield Principles (as defined below). If there is any conflict between the terms of this Privacy Shield Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

For the purposes of this Privacy Shield Statement:

“EEA and Switzerland” means the European Union, United Kingdom, Switzerland, Iceland, Liechtenstein and Norway.

“Customer” means any entity or individual that has agreed by contract or otherwise to purchase, license or use any CAMP Systems Services.

“Services” means (a) the CAMP Systems website available at www.campsystems.com (the “Site”), (b) the iCAMP and CAMP imsMOBILE apps and (c) 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), Flight Scheduling, Avtrak, CESCOM, CMP, Turbine Tracker and WebECTM. The Services also include our call center and technical and maintenance support services.

“Privacy Shield Principles” means the Principles and Supplemental Principles of the Privacy Shield.

 

INFORMATION WE OBTAIN

CAMP Systems provides the Services to Customers for Customers’ aviation management purposes, including airplane systems maintenance, inventory management, monitoring of systems and engines and logging of maintenance, repair and operations activities. Customers decide to whom they may want to grant access to the Services. Typically this includes Customers’ employees and other representatives who register to use the Services and other individuals who input information such as maintenance, repair and operations staff (collectively, “Users”).

CAMP Systems also obtains information about Users and about other relevant individuals which is provided by Customers or Users. This typically includes information about owners and operators of an aircraft and other individuals associated with the maintenance, repair and operations of the relevant aircraft. CAMP Systems is a data processor for all personal information which Customers and their respective Users maintain and otherwise process using the Services.

In addition, CAMP Systems obtains personal information about its customers’ representatives, including Users, as part of the contracting process, for CAMP Systems’ marketing purposes and during the ordinary course of business. CAMP Systems is a data controller for this type of personal information.

CAMP Systems also de-identifies and/or aggregates the personal information and other data obtained (the “De-identified Data”). The requirements and limitations described in this Privacy Shield Statement and Privacy 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 an individual.

Information Obtained About Users
The personal information CAMP Systems obtains about Users from the EEA, United Kingdom and Switzerland includes:

• Contact information (e.g., name, email address, job title, company name and address).
• Registration information (e.g., username for the relevant Services).
• Other information Users choose to provide through the Services (e.g., information inputted into the “Notes” field of forms).
• Personal information shared by Users in connection with calls to the call center or CAMP Systems’ technical and maintenance support services.

Information Obtained About Other Relevant Individuals
The personal information CAMP Systems obtains about other relevant individuals from the EEA, United Kingdom and Switzerland includes:

• Contact information (e.g., name, email address, job title, company name and address).
• Other information Users choose to provide through the Services (e.g., 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 and its authorized Users, 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.

Information Automatically Collected
The Services may automatically log certain information about the use of the Services such as the number and frequency of visitors, technical information about browsers and devices used to access the Services and information about technical issues.

 

HOW WE USE INFORMATION WE OBTAIN

CAMP Systems uses personal information of EEA, United Kingdom, and Swiss individuals for a number of purposes, including:

• Making the Site and the Services available, responding to 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 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 Privacy Shield Statement, 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).

We may also send communications, including email or other communications marketing and advertising CAMP Systems or our affiliates’ products, services and other offerings to Users and Customers or potential Customers’ representatives.

 

HOW WE SHARE INFORMATION

CAMP Systems shares personal information of EEA, United Kingdom and Swiss individuals we obtain:

• With 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, or other individuals and entities.

We also reserve the right to transfer personal information of EEA, United Kingdom and Swiss individuals 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 with third parties the personal information of EEA, United Kingdom, and Swiss individuals who consent to or request such sharing.

Please note that CAMP Systems may also be required to disclose personal information of EEA, United Kingdom, and Swiss individuals in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

 

NOTICE

CAMP Systems provides information in this Privacy Shield Statement and in our Site Privacy Notice about the personal information we obtain, how we use it, the types of third parties to which we disclose personal information and our reasons for doing so, the rights and choices available for limiting the use and disclosure of personal information and how to contact us about our practices concerning personal information.

 

CHOICE

With respect to the personal information for which CAMP Systems acts as a data controller, if such personal information of EEA, United Kingdom, and Swiss individuals is to be used by CAMP Systems for a new purpose that is materially different from that for which it was originally collected or subsequently authorized, or is to be disclosed by CAMP Systems to a third party who is not providing services or handling transactions on our behalf, CAMP Systems will provide individuals with an opportunity to choose whether to have their personal information so used or disclosed. Requests to opt out of such uses or disclosures of personal information should be sent to CAMP Systems using the contact details provided below.

 

ACCOUNTABILITY FOR ONWARD TRANSFER

Where transfers of personal information of EEA, United Kingdom and Swiss individuals are made to third parties that provide services or handle transactions on our behalf, CAMP Systems enters into a contract with the relevant third party to transfer data for limited and specified purposes, obligates the third party to provide the personal information with at least the same level of privacy protection as is required by the Privacy Shield Principles, requires the third party to notify CAMP Systems if the third party determines that it can no longer meet its obligations to provide the same level of protection as is required by the Privacy Shield Principles. Upon such notice, CAMP Systems takes reasonable and appropriate steps to stop and remediate unauthorized processing of the relevant personal information of EEA, United Kingdom and Swiss individuals. In accordance with the Privacy Shield Principles, CAMP Systems remains liable for any processing of personal data of EEA, United Kingdom and Swiss individuals by third parties that provide services or handle transactions on our behalf where such processing is inconsistent with the Privacy Shield Principles, unless CAMP Systems was not responsible for the event giving rise to any alleged damage.

 

SECURITY

CAMP Systems uses a variety of security technologies and procedures to help protect personal information from unauthorized access, use or disclosure.

 

DATA INTEGRITY AND PURPOSE LIMITATION

CAMP Systems processes personal information of EEA, United Kingdom and Swiss individuals on behalf of our Customers. We rely on Customers to verify that personal information is reliable for its intended use, accurate, complete and current. We use personal information of EEA, United Kingdom and Swiss individuals to perform our contractual obligations with the relevant Customer for the purposes requested by each Customer and as described in this Privacy Shield Statement. Subject to applicable law, CAMP Systems retains personal information for as long as needed to serve the purposes for which it was obtained.

EEA, United Kingdom and Swiss individuals have rights to access personal information about them and to limit use and disclosure of such information. EEA, United Kingdom and Swiss individuals who wish to request access to, limit the use of, or limit disclosures of their personal information we process on behalf of a Customer can contact the relevant Customer who is the controller of that information. CAMP Systems cooperates with Customers to address relevant requests of EEA, United Kingdom and Swiss individuals and supports Customers as needed to respond to the request.

 

ACCESS

CAMP Systems provides Users with reasonable access to the personal information maintained about them. CAMP Systems also provides a reasonable opportunity for individuals to correct, amend or delete the information as appropriate where it is inaccurate or has been processed in violation of the Privacy Shield Principles. CAMP Systems cooperates with Customers to address EEA, United Kingdom, and Swiss individuals’ requests in relation to the personal information we process on behalf of each Customer and supports Customers as needed to respond to the request.

 

RECOURSE, ENFORCEMENT AND LIABILITY

CAMP Systems has mechanisms in place designed to help assure compliance with the Privacy Shield Principles. EEA and Swiss individuals with inquiries or complaints with regard to any issues in this Privacy Shield Statement should first contact us at support@campsystems.com.

We have further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. Where a privacy complaint or dispute cannot be resolved through our internal processes, EEA and Swiss individuals should visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to the claimant.

In certain circumstances, the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks provide the right to invoke binding arbitration to resolve complaints not resolved by other means, as described in Annex I to the Privacy Shield Principles.

Regulatory Oversight
CAMP Systems’ commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

 

CONTACT US

EEA, United Kingdom and Swiss individuals contact CAMP Systems with regard to any issues under this Privacy Shield Statement, please write to our Privacy Officer by e-mail at support@campsystems.com or by postal mail at:

Attn: Privacy Officer
CAMP Systems International, Inc.
11 Continental Boulevard, Suite C Merrimack, NH 03054 USA