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S & T Aircraft Accessories, Inc. Privacy Policy (Last Rev 12/21/2020)

S & T Aircraft Accessories, Inc. (hereafter referred to as S & T Aircraft, we, us or our) collects, uses, process and discloses information in different ways. This Privacy Policy is designed to provide guidance to End Users about how S & T Aircraft uses this information. In this Privacy Policy, these individuals and entities are referred to collectively as “Users”. This Privacy Policy is part of S & T Aircraft’s contract with its customers. If you are a customer, you must review all of our contracts to fully understand how this Privacy Policy fits with these contracts. Our contracts are set out here.

1. S & T Aircraft's Privacy Statement

S & T Aircraft does not offer for sale, share or lease any information given to S & T Aircraft by an individual or entity subject to this Privacy Policy, except as provided in it. S & T Aircraft is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). If you have questions about how S & T Aircraft may use information provided to it, and that question is not covered by this Privacy Policy, please contact us at the address provided in paragraph 15 prior to providing the information to S & T Aircraft.

S & T Aircraft’s services are for individuals over the age of eighteen. S & T Aircraft does not knowingly market to individuals under that age.

2. Third Parties May Have Different Privacy Policies from S & T Aircraft

This Privacy Policy only applies to information provided to S & T Aircraft. S & T Aircraft services may incorporate products provided by third parties (Third Party Products). To the extent this incorporation is transparent to S & T Aircraft’s customers, the privacy policies of the providers of Third Party Products have been incorporated into this Privacy Policy. However, if a customer has the option of choosing a Third Party Product, or incorporates it into S & T Aircraft’s services on its own, those privacy policies are specifically excluded from this Privacy Policy. It is a customer’s obligation to determine how the privacy policies of Third Party Products not covered by this Privacy Policy affect their information, and that of their End Users.

3. S & T Aircraft complies with EU-US Privacy Shield and Swiss-US Privacy Shield Frameworks

S & T Aircraft complies with the EU-US Privacy Shield and Swiss-US Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. S & T Aircraft has certified that it adheres to the Privacy Shield Principles. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

In compliance with the Privacy Shield Principles, S & T Aircraft commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact S & T Aircraft using the address specified in paragraph 15.

S & T Aircraft has further committed to refer unresolved privacy complaints under the Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

4. How S & T Aircraft Collects Information

Depending on their use of S & T Aircraft’s services, S & T Aircraft collects information from Users in the following ways:

  1. From S & T Aircraft’s web server
  2. Using temporary internet files such as cookies, transparent gifs, and other similar tools (Identification Tools)
  3. Directly from Users.

5. Information S & T Aircraft Collects from Web Server Logs

S & T Aircraft’s web servers collect information from visitors to the websites linked to this Privacy Policy. Because each User’s computer and browser configurations are different, S & T Aircraft may collect some, or all, of the following information during a User’s visit:

  1. Internet protocol address
  2. The type of browser or computer used
  3. The number of links clicked within S & T Aircraft’s website
  4. The state or country from which our website was accessed
  5. The date and time of visit
  6. The name of internet service provider used to access S & T Aircraft’s website
  7. The web page visited prior to coming to S & T Aircraft’s website
  8. The pages viewed on S & T Aircraft’s website

6. Information Collected by S & T Aircraft Directly from Users

a. Registration Information

To purchase services from S & T Aircraft, Users must provide detailed information including contact information to S & T Aircraft, including names, email addresses, physical addresses, and phone numbers. Users are required to provide this information to S & T Aircraft in order to purchase S & T Aircraft services. During the purchase process, Users may provide optional information to S & T Aircraft. If that information is provided, it is covered by this Privacy Policy; however, providing it is voluntary. This information is a subset of Identification Tools, and is referred to individually as “Registration Information.”

b. Identification Tools

S & T Aircraft may use automated Identification Tools like cookies and Google Analytics. Each of these Identification Tools work differently, however, they all collect information related to the website you came to S & T Aircraft from, a User’s operating system, browser type, where Users go on S & T Aircraft’s website, length of time on S & T Aircraft’s website, and where a User goes after visiting S & T Aircraft’s website. In addition, Identification Tools may keep Users logged into S & T Aircraft’s system. From time-to-time, S & T Aircraft may use Identification Tools that will be used to serve advertising and other information to Users after they visit S & T Aircraft’s website. Because the technologies underlying Identification Tools differ, Users may, or may not, be able to choose not to provide information to them.

c. Support Information

When Users contact S & T Aircraft for support for their services they may be asked to match certain information that is in their Registration Information. This information will be used to identify them personally. In the course of providing support to Users, S & T Aircraft may annotate the Registration Information with information disclosed while providing support (Support Information).

d. FAQ and Forum Information

S & T Aircraft offers Users the ability to exchange information about its services, and their experiences with these services (Forum Information). Forum Information is publicly accessible and may be indexed by search engines and other tools. Users are not required to disclose information that will identify them personally in order to participate in these tools. All Forum Information may be accessed and used by third parties for purposes known and unknown to S & T Aircraft.

7. Security Monitoring

S & T Aircraft takes the security of its network very seriously. To ensure network security, data integrity and privacy, S & T Aircraft uses programs that monitor network traffic and access to its network. These programs collect information regarding User’s use of S & T Aircraft’s services, website and network (Traffic Information).

8. How S & T Aircraft Uses Information Covered by this Privacy Policy

a. Generally

  1. S & T Aircraft is required to comply with relevant laws, regulations and judicial orders. Information covered by this Privacy Policy may be disclosed outside S & T Aircraft if S & T Aircraft determines, in its sole discretion, that such a disclosure is necessary or required. S & T Aircraft may also disclose this information if, in its sole discretion, such disclosure is necessary or required to protect its interests or the interests of its customers.
  2. S & T Aircraft may disclose information covered by this Privacy Policy in connection with the sale of its business.
  3. S & T Aircraft may aggregate information covered by this Privacy Policy and disclose it outside its business. This information will not identify Users individually.
  4. S & T Aircraft may use information covered by this Privacy Policy to contact you directly to respond to questions, provide its services to you, manage your account or to inform you of service announcements.
  5. S & T Aircraft may use information covered by this Privacy Policy to inform you of new products and services. In informing you of new products and services, S & T Aircraft may include third party products and services. While S & T Aircraft may use information that identifies you individually to market these third party products and services, that information is not disclosed to the third parties. In this use of User information, third parties will only receive aggregate information. However, should a User respond to a marketing announcement, third parties will become aware of the User individually. Users may opt-out of receiving this information by clicking “unsubscribe” in any marketing material, or unsubscribe from your AvSys profile. Only the email address from that communication will be removed from marketing lists.

b. Specific Information

  1. Web Server Logs (described in paragraph 5). Information collected from Web Server Logs is not disclosed beyond S & T Aircraft except as set out in paragraph 5 in this Privacy Policy.
  2. Registration Information (described in paragraph 6). S & T Aircraft will use Registration Information throughout its business and will pass Registration Information on to third parties for processing and use as necessary to provide S & T Aircraft’s services to Users. S & T Aircraft requires these third parties to limit their use of Registration Information to those uses that facilitate providing S & T Aircraft’s services to Users.
  3. Identification Tools (described in paragraph 6). Information collected using Identification Tools, other than Registration Information, may identify Users individually. This information will be used to provide S & T Aircraft’s marketing information to Users. Users may enter or delete email addresses in the “Account” interface to control marketing messages. Third parties may use this information in the aggregate; however, they are contractually prohibited from using this information to identify Users individually. S & T Aircraft uses cookies to save User’s preferences and login information, and provide personalized functionality.
  4. Support Information (described in paragraph 6). Support Information may identify Users individually. In addition to providing support to Users, S & T Aircraft may disclose Support Information to third party vendors in order to provide the support requested by the User. These third parties may disclose and use Support Information to improve their business processes and for marketing. Unless necessary to provide support to Users, S & T Aircraft will not disclose Support Information containing information that identifies Users individually to these third parties. During a support request, Users may request that S & T Aircraft not disclose Support Information to third parties. This request will prevent S & T Aircraft from providing support to Users.
  5. Traffic Information (described in paragraph 7). Traffic Information may identify Users individually. S & T Aircraft will only use Traffic Information to ensure the integrity of its network, and for no other purpose. Traffic Information may be disclosed by S & T Aircraft to comply with its legal obligations and to law enforcement upon when obligated to do so. We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

9. How S & T Aircraft Protects your Information

S & T Aircraft uses technical security measures to prevent the loss, misuse, alternation or unauthorized disclosure of information under our control. S & T Aircraft uses security measures including and not limited to: firewalls, nonpublic facing systems, complex passwords, anti-virus, and mitigation and detection software. When S & T Aircraft asks Users to provide financial information (such as a credit card number) that data is protected using Secure Sockets Layer (SSL) technology. Electronic communication, such as email that Users may send S & T Aircraft may not be secure unless S & T Aircraft advises a User in advance that security measures will be in place prior to transmitting the information. Users should not send confidential information such as financial information, social security numbers or passwords to S & T Aircraft through unsecured electronic communication.

10. How Users can Access and Correct Information Covered by this Privacy Policy

S & T Aircraft acknowledges the individual’s right to access their personal data for the purpose of review, correction, updating and deletion. If a User wishes to access and/or update the information S & T Aircraft has collected, the User may either login to S & T Aircraft’s website or client systems and view and change its information or contact S & T Aircraft’s accounting team. Information covered by this Privacy Policy may be deleted upon a User’s request. However, we reserve the right to retain information necessary to protect our interests, and are required to retain certain information under federal law. Unless specifically set out herein, information covered by this Privacy Policy will be retained by S & T Aircraft following termination of a User’s Agreement.

We will provide an individual opt-out or opt-in choice before we share their data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized.

To limit the use and disclosure of your personal information, please submit a written request to legal@st.aero.

11. Users May Transfer Information Covered by this Privacy Policy to Third Parties

Users may transfer their accounts to a third party by submitting a request to our accounting team. S & T Aircraft will respond with a transfer form. Once the form is received and verified, the account will be transferred. The new owner will be bound by this Privacy Policy and the agreements set out in paragraph 2.

12. Liability

In cases of onward transfer to third parties of data of EU and/or Swiss individuals received pursuant to the EU-US and/or Swiss-US Privacy Shield Frameworks, S & T Aircraft may be potentially liable.

13. How and When this Privacy Policy is Modified

S & T Aircraft may modify this Privacy Policy at any time. Users will be notified of any change, other than a typographical change, by a notice on the front page of S & T Aircraft’s website and by a notice in the User’s account. Modifications are effective as set out in the notification.

14. How S & T Aircraft Assesses its Compliance with the Privacy Policy

S & T Aircraft uses a self-assessment approach to ensure compliance with this Privacy Policy and regularly verifies that the Privacy Policy is accurate, displayed, accessible and within the guidelines of the Privacy Shield Principles for both the EU and Switzerland.

15. Contacting S & T Aircraft about this Privacy Policy

If Users have any questions, comments or feedback regarding this Privacy Policy or the use and disclosure of personal information, please contact S & T Aircraft via email at legal@st.aero and S & T Aircraft will respond within a timely manner.

You may also contact us in writing at:

S & T Aircraft Accessories, Inc.
Attn: Legal Department
310 FM 483
New Braunfels, TX 78130
United States of America

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