Last Modified: July 21, 2023

TRAX USA CORP dba TRAX is the world’s leading aviation maintenance mobile and cloud solutions provider. We respect your privacy and are committed to protecting your Personal Data. This Privacy Notice explains the types of Personal Data we collect when you use this website or its hosted applications, how we use your Personal Data, how we protect and share it, and how you can control it.

By accessing or using our websites, services, and/or disclosing your Personal Data to us in furtherance of our business relationship with you, you consent to the practices described in this Privacy Notice.

For the avoidance of doubt, the terms below shall have the following definitions:

• The “products” include the software and hardware we sell or license to our clients.
• The “services” mean post/after sale services and other services of the products under the control of us, either online or offline including the use of the https://www.trax.aero website operated by TRAX and other private websites hosted by TRAX.
• “Personal Data” means any information that alone or when in combination with other information may be used to directly or indirectly identify, contact, or locate you, including but not limited to your name, address, email address, IP address, or phone number. Personal Data does not include information that has been fully anonymized.
• “Cookies” means small pieces of information that are stored by your browser on your computer’s hard drive which enables us to recognize your computer when you return to our online services.

Table of Contents

• To whom does this Privacy Notice apply?
• What information do we collect about you?
• Why do we need your data?
• How long will we store your data?
• Marketing
• Children’s Privacy
• Links to Other Sites
• Changes to this Policy
• U.S. Citizens & Residents
• UK or E.U. Citizens & Residents
• Contact Us

This Notice applies to every natural person for whom TRAX collects and processes their Personal Data as a data controller, which generally includes:

• Our clients and their employees,
• Visitors to our website, and
• Third parties that communicate with us.

We collect information about you when you email us directly. We also collect information when you voluntarily comment on our blog posts, provide feedback, and participate in surveys. Website usage information is collected using cookies, google analytics, and email.

The information we collect about you may include: your name, email address, address, phone number, IP address, location, company name, sex, your chosen internet browser and service provider, your device, plus any information you supply voluntarily. We will NEVER collect any Personal Data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or any other sensitive data defined by applicable data protection legislation.

If you call the TRAX office, your call may be recorded for training and monitoring purposes. TRAX’s policy states that all call recordings are stored securely for 30 days and then deleted; however, if a call is needed for further analysis, it may be saved and stored securely for longer than 30 days.

If you email anyone at TRAX, your email message will be stored securely on our chosen email provider, Microsoft Office 365, and may be shared with the TRAX team unless you have stated that the email is confidential. You can read MS Office 365’s privacy policy here: https://privacy.microsoft.com/en-us/PrivacyStatement . Everyone who works at TRAX has an email address ending in @trax.aero or @emro.com that assures they are active & authenticated to the TRAX network. For your security, never correspond via email with someone at TRAX if their messages arrive from a different domain.

If you have opted in to receive email updates and newsletters from TRAX, we distribute all our emails through Constant Contact, allowing you to opt-out at any time. You can review their privacy policy here: https://www.constantcontact.com/legal/privacy-statement.

We may use Google Analytics, a web analytics service provided by Google, Inc. that tracks and reports website traffic. Google Analytics uses cookies or other similar technologies to collect and store your information which is made anonymous and non-personal. Google uses the data collected to track and monitor the use of our service.

This data may be shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can read Google Analytics’ privacy policy at https://www.google.com/intl/en/policies/privacy/ for more information.

You can opt-out of having your activity on the service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visit activity.

We collect information about you to provide services and fulfil your requests. For example, if you request information via email, we use your information to contact you directly, process your order, manage your account and, if you agree, to email you about other products, services, and information we think may be of interest to you. We may contact you directly to follow up on the service and user support we provide. We use your information collected from the website to personalize your repeat visits to our website or optimize our sites for an improved user experience. We DO NOT sell or share your personal information with third parties!

We will take cautionary measure to ensure we do not collect any Personal Data from you that we do not need in order to provide and oversee the above services to you.

If TRAX provides any paid-for services to you, we are required under law to keep your basic Personal Data (name, address, contact details) for a minimum of 6 years or 1 year after the termination of services at which time it will be destroyed, whichever period is longer. Your information we use for marketing purposes will be kept with us until you notify us that you no longer wish to receive this information or we are no longer using it for this purpose.

We would like to send you updates and information about products and services of ours and other partners/companies which may be of interest to you. If you have consented to receive marketing, you may opt out at any time. You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other parties. If you no longer wish to be contacted for marketing purposes please notify us via email at sales@trax.aero so we may cease further marketing notices to you. That said, TRAX does not trade, rent or sell your Personal Data to third parties unless they are a partner that renders services in conjunction with our line of business with you.

Our Service does not address anyone under the age of 18.

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your minor child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Our service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

We may update our Privacy Notice from time to time. We will notify you of any changes by posting the new Privacy Notice on this page.

If we make any material changes to the way we collect, use, and/or share Personal Data, we will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective .

You are advised to review this Privacy Notice periodically for any changes. Changes to this Privacy Notice are effective when they are posted on this page.

Various U.S. state laws provide their residents with additional rights over their Personal Data. You may have the right to control your Personal Data in various ways:

1. Right to know. You may have the right to request us to inform you of your Personal Data which we hold.
2. Right to correct. You may have the right to request us to correct your Personal Data if it is inaccurate.
3. Right to delete. You may have the right to request us to delete your Personal Data. If you choose to delete your Personal Data, you should be aware that we may retain some of your Personal Data to the extent required to prevent fraud and abuse and/or to comply with legal requirements as permitted by law.
4. Right to opt-out of sale or sharing. Trax does not sell your Personal Data to third parties. Trax may share your Personal Data with its affiliates and with third parties providing services to Trax. For example, Personal Data may be shared with the following categories of service providers to process data for Trax: tax, security or compliance administration; external recruiters; consultants; identity verification and background check providers.
5. Right to limit use and disclosure of sensitive Personal Data. You may also have the right to object to the processing or limit the use of your Personal Data. We will discontinue the processing if it is required by law to do so. We will continue with the processing if there are justified imperative grounds to do so that outweigh your interests, rights, and freedoms or that are related to bringing, exercising, or substantiating a legal action.
6. Right to opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.
7. Right to opt-out of Personal Data processing for targeted advertising and sales.

Everyone has the right to unsubscribe to emails and messages from us at any time and at no cost, if you no longer wish to receive them.

Trax will not discriminate against you for exercising your Personal Data rights.

California Residents:

*We may not collect each type of information described.

If you are located in the United Kingdom (UK) or European Economic Area (EEA), you may have additional rights with respect to your Personal Data under data protection legislation including the General Data Protection Regulation (GDPR). This section applies if you are subject to this legislation and is designed to be read together with the rest of our Privacy Notice.

TRAX is a “controller” of your Personal Data that we collect. This means that we are responsible for deciding how we hold and use the Personal Information we collect about you. We are required under data protection legislation to notify you of the information contained in this Privacy Notice.

The tabs at the side of this page will take you to more detailed information about:

• your individual rights under data protection laws;
• how to exercise those rights for yourself; and
• how to raise a concerns about these rights or this policy.

By using our websites and services, you acknowledge the collection and use of information in accordance with this Notice. Unless otherwise defined in this Privacy Notice, the terms used in this Privacy Notice have the same meanings as in our Terms and Conditions, accessible from https://www.trax.aero

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our service, we may ask you to provide us with certain Personal Data. This may include, but is not limited to:

• • • Email address
    • First name and last name
    • Phone number
    • Address, State or Province, ZIP or Postal code, City
    • Other as required for the service you intend to use.

WE WILL NOT use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you, unless you have given your consent.

Usage Information

We may also collect information on how the service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (IP address), browser type, browser version, the pages of our service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. These are standard data sets typically used to track activity and possibly identify sources of attacks or malware.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our service and we hold certain information(including with Google Analytics as set out above).

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information that improves your Service experience.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may find your Service experience a little less desirable.

Examples of Cookies we use:

• • • Session Cookies. We use Session Cookies to operate our Service.
    • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
    • Security Cookies. We use Security Cookies for security purposes to reduce the number of times you have to login.

Use of Data

TRAX uses the collected information for various purposes:

• • • To provide and maintain our service,
    • To provide customer support,
    • To gather analysis or valuable information so that we can protect & support our service,
    • To monitor the usage of our service, and
    • To detect, prevent and address technical issues.

Legal Basis for Processing Personal Data under the GDPR

TRAX legal basis under applicable data protection laws for collecting and using the personal information described in this Privacy Notice depends on the Personal Data we collect and the specific context in which we collect it, as set out in the table below.

TRAX may process your Personal Data because:

• • • We need to perform a contract with you or your employer,
    • You have given us consent to do so,
    • The processing is in our legitimate interests and it is not overridden by your rights, and/or
    • To comply with the law.

Retention of Data

TRAX will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Notice. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

For example:

• • • Call recordings are stored securely for 30 days and then deleted unless a call is needed for further analysis.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of the UK and EEA where the data protection laws may differ from those of your jurisdiction. In particular, we (and our group companies) are located in the US, and we use data centers in the EEA.

Some of our Service Providers are also located outside of the UK and EEA, including:

The US is not deemed by the UK or by countries in the EEA to have an adequate level of protection according to the GDPR, so we have put in place appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects UK and EU law on data protection. For further information about these measures please contact us (see the Contact Us section)..

Disclosure of Data

Service Providers

We use third party service providers to provide the service, including:

• • • AWS cloud storage services;

Business Transaction

If TRAX is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice if your Personal Data is transferred and becomes subject to a different privacy policy.

Disclosure for Law Enforcement

Under certain circumstances, TRAX may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

Legal Requirements

TRAX may disclose your Personal Data in the good faith belief that such action is necessary to:

• • • To comply with a legal obligation,
    • To protect and defend the rights or property of TRAX,
    • To prevent or investigate possible wrongdoing in connection with the service,
    • To protect the personal safety of users of the service or the public, and/or
    • To protect against legal liability.

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use appropriate means to protect your Personal Data, we cannot guarantee its absolute security.

Your Data Protection Rights under the GDPR

TRAX aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please scroll to the Contact Us section  and send us your request.

In certain circumstances, you have the following data protection rights:

• • • The right to access, update or delete the Personal Data we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
    • The right of rectification. You have the right to have your Personal Data rectified if that information is inaccurate or incomplete.
    • The right to object. You have the right to object to our processing of your Personal Data.
    • The right of restriction. You have the right to request that we restrict the processing of your Personal Data.
    • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
    • The right to withdraw consent. You also have the right to withdraw your consent at any time where TRAX relied on your consent to process your Personal Data.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the EEA or the UK Information Commissioner if you are in the UK (who you can contact at https://ico.org.uk/global/contact-us/).

European Representative

Pursuant to Article 27 of the GDPR, Trax USA Corp has appointed European Data Protection Office (EDPO) as its GDPR representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR:

• • • by using EDPO’s online request form: https://edpo.com/gdpr-data-request/
    • by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium

View our EDPO Compliance Certificate..

Trax has also appointed a Data Protection Officer.

• • • Henry Parra, DPO         privacy@trax.aero

Contact Us

If you have any questions about this Privacy Notice, please contact us:

• • • By email: privacy@trax.aero
    • By phone number: +1-305-662-7400
    • By mail:

TRAX

ATTN: DPO

2811 Ponce de Leon Blvd.

Suite 300

Coral Gables, FL 33134