Global Data Privacy Notice

JETRAXX LLC (collectively “Jetraxx,” “we,” “us,” “our”), are committed to upholding best practices concerning data protection and ensuring that all Personal Information is treated in accordance with applicable law.  In order to ensure a consistent approach to the handling of Personal Information throughout the company, Jetraxx satisfies the requirements of the European Union’s General Data Protection Regulation (“GDPR”) across all its global operations, while also complying with all other local laws and regulations.

This Privacy Notice describes our standards and procedures for handling Personal Information across the globe, including information transferred from the European Economic Area (“EEA”), the United Kingdom or Switzerland.  With respect to Personal Information belonging to individuals residing in the EEA, United Kingdom, or Switzerland, Jetraxx LLC have subscribed and will adhere to the principles set forth in the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework.[1]

More information about the Privacy Shield can be found at www.privacyshield.gov, and Jetraxx’s Privacy Shield certification can be found at www.privacyshield.gov/list.

Types of Personal Information We Process

Jetraxx processes Personal Information for a number of purposes, including legitimate business purposes and in order to comply with our contractual and legal obligations.  The types of Personal Information we process, and the purpose of the processing, varies based on the nature of your relationship with Jetraxx.

Personal Information” means any data relating to an identifiable individual, including name, address, telephone number, passport number, driver’s license number, and e-mail address. 

Processing” means any operation performed on Personal Information, including collection, use, management, consultation, or disclosure.

The Purpose and Lawful Basis of the Processing

Jetraxx processes Personal Information from a variety of individuals, including customers, suppliers, visitors and prospective employees. We process Personal Information primarily for the following reasons:

As required by GDPR, Jetraxx has a lawful basis for processing the above information.  This lawful basis includes one or more of the following:

The Legitimate Interests for the Processing

Where Jetraxx has a legitimate interest in processing your Personal Information, we have carefully balanced our need to process this data with your rights and freedoms and have determined that the processing is reasonable, proportionate, and has minimal privacy impact.  The types of processing Jetraxx does based on its legitimate interest include:

Protection of Personal Information

We take the security of Personal Information very seriously and have put in place proper technical and organizational measures to ensure Personal Information is not lost, stolen, misused, or improperly disclosed, altered, or destroyed.  We periodically audit these technical and organizational measures to ensure we are upholding best practices.

Transfer of Personal Information

It may become necessary to transfer your Personal Information to a third-party service provider who will process your Personal Information for the purpose or purposes set forth above, including, for example, signature verification, contract fulfilment, and security monitoring.  We understand our obligation to ensure that third parties take the security of your Personal Information seriously.  We therefore require third parties that receive Personal Information to certify that they (1) have adequate data protection measures in place; and (2) process information confidentially and in accordance with Jetraxx’s written instructions.

As part of our business operations, we may transfer your Personal Information to a party in a country other than the country in which you reside.  When Jetraxx transfers your Personal Information to another company within Jetraxx, we do so in accordance with the terms set forth in the EU Standard Contractual Clauses, which apply to extra-territorial data transfers.  When Jetraxx transfers your Personal Information to third-party in another country, we require the third-party to adhere those same terms.

Your Rights Under GDPR

Jetraxx is committed to the fair and transparent processing of Personal Information.  You have the following rights with respect to your Personal Information:

After Jetraxx has fully responded to a complaint regarding your Personal Information, you have the right to lodge a complaint with the applicable supervisory authority.  Information regarding the relevant supervisory authorities is as follows:

United KingdomCommissioner’s Officehttps://ico.org.uk/
NorwayData Protection Authorityhttps://www.datatilsynet.no
CanadaOffice of the Privacy Commissionerhttps://www.priv.gc.ca/en/
IrelandData Protection Commissionerhttps://www.dataprotection.ie/
United StatesFederal Trade Commission or state attorney generalhttps://www.ftc.gov/
AustraliaThe Privacy Commissionerhttps://www.oaic.gov.au/
BrazilNational Data Protection AuthorityWebsite forthcoming
PolandPersonal Information Protection Officehttps://uodo.gov.pl/en
NetherlandsData Protection Authorityhttps://autoriteitpersoonsgegevens.nl/en

Privacy Shield Frameworks

Jetraxx complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom, and Switzerland to the United States in reliance on Privacy Shield. Jetraxx has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under 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/    

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Jetraxx is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.

Pursuant to the Privacy Shield Frameworks, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to sstringfellow@jetraxx.com. If requested to remove data, we will respond within a reasonable timeframe. 

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your 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 request to limit the use and disclosure of your personal information, please submit a written request to sstringfellow@jetraxx.com.  

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. 

Jetraxx’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Jetraxx remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Jetraxx proves that it is not responsible for the event giving rise to the damage. 

In compliance with the Privacy Shield Principles, Jetraxx commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union, United Kingdom, and Swiss individuals with Privacy Shield inquiries or complaints should first contact Jetraxx by email at sstringfellow@jetraxx.com

Jetraxx has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. 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. This service is provided free of charge to you.  

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

Requirement to Disclose

We may disclose Personal Information when we believe in good faith that such action is necessary to comply with legal obligations, including contract obligations, or to respond to lawful requests by public authorities.

Additional Questions

Jetraxx’s global headquarters are located at 1505 Wallace Dr Suite 122, Carrollton, TX 75006 USA. If you have any concerns about this Privacy Notice, please contact Shane Stringfellow at sstringfellow@jetraxx.com

 

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