Effective date: January 2023
Who is Butler America Aerospace, LLC. (“BAA”)
BAA is the Data Controller of your personal information as described in this Privacy Statement, unless otherwise specified.
BAA is committed to protecting your personal information and respecting your privacy and your rights, and this statement is intended to provide you with information on how your personal information is processed.
What does this Privacy Statement cover?
This Privacy Statement applies to any personal information that BAA may process about you that may be collected directly from you when you interact with BAA or from third parties, such as when you:
- Visit our public-facing BAA branded websites and other online services including social media pages;
- Send or receive communications from/to BAA, including emails, phone calls, texts or faxes;
- Use BAA products and services (for example, as an employee of one of our customers who provided you with access to our products or services) to the extent that BAA is acting as a controller of your personal data. You should be aware that processing of personal data is required for receiving certain products or services;
- Access downloadable applications from mobile devices with respect to which this Privacy Statement is linked;
- Register for, attend, or take part in activities such as events, webinars, training, campaigns, or contests;
- Visit BAA offices
For further information on what cookies BAA uses on our BAA branded websites please visit our Cookie Policy.
This Privacy Statement will be available via link on all sites which it covers. Other BAA websites, apps, or online services may collect and use personal data about you for different purposes and will accordingly publish a separate policy statement/ terms and conditions specific to the processing activity. BAA websites and services may contain links to other websites, applications and services not owned by BAA, and BAA does not control the content or privacy practices of those sites. The information practices of other services, or of social media platforms that host BAA branded social media pages, are governed by their privacy statements, which you should review to better understand their privacy practices.
BAA websites and offerings are directed to people in their business or professional capacities. They are not intended for children under 16 years of age. BAA does not knowingly solicit information online from, or market online to, children under 16 years of age. If you are a parent or guardian and believe your child has provided BAA with personal data without your consent, please contact BAA as indicated below and BAA will take steps to delete their personal data from its systems.
This Privacy Statement does not apply to the extent BAA processes personal data in the role of a data processor or service provider, including personal data processed on behalf of our customers.
What personal information does BAA process?
For the purposes of this Statement, ‘Personal Information’ means any information about you from which you can be identified, whether derived from that information on its own or when combined with other information, that BAA or another party may hold about you.
Types of personal information and/or sensitive personal information:
- Identifiers, such as name, government-issued identifier (e.g., Social Security number), and unique identifiers (e.g., employee ID);
- Personal information, such as legal name, signature, social security number and/or card, address, telephone number, passport number, driver’s license or state identification card number, federal identification authorizing work in the United States, birth certificate, access, insurance policy number, education, employment, employment history, bank account number, other financial information, medical information, or health insurance information;
- Characteristics of protected classifications under California or federal law, such as age, marital status, gender, sex, race, color, disability, citizenship, primary language, immigration status, military/veteran status, disability, request for leave, and medical conditions;
- Transaction information and purchase history (e.g., in connection with company travel or other reimbursements);
- Internet or network activity information from a BAA asset, such as browsing history and interactions with our online systems and websites and any personal information that you provide while accessing the Company’s computer systems, such as personal credit card information and passwords;
- Professional or employment-related information, such as work history and prior employer;
- Non-public education information; and
- Inferences drawn from any of the Personal and Sensitive Personal Information listed above to create a profile or summary about an individual.
Depending on the nature of your interaction with us, this information may include business contact details (such as name, title, company, email address or telephone number), the content of your communication, information about how you use BAA’s website and products or services, your feedback, interests in BAA products and services, and any publicly available information relevant from a business-to-business perspective. In addition, this may include information about your computer and about your visits to and usage of this site, such as your Internet Protocol (IP) address, your computer’s operating system and browser type, and information collected via cookies.
This may also include collecting personal data about you from a third party who is authorized to act on your behalf or from third party services that you use to interact with BAA services. BAA may also collect your personal data from other sources such as public databases, joint marketing partners, and social media platforms, to the extent permitted by applicable laws.
If you provide BAA with any personal data relating to other individuals, you represent that you have the authority to do so and, where required, you have obtained any necessary consent. You acknowledge that this personal data may be used in accordance with this Privacy Statement.
When using a Mobile App published by BAA, in addition to contact information, BAA or its service providers (such as mobile operating system and platform providers) may also collect information relating to your device, including your device model, operating system, browser type, unique device identifier, IP address, mobile phone number, mobile network carrier, and location.
Why does BAA process your personal information?
BAA processes your personal information for specified and lawful purposes only and in accordance with the applicable data protection laws.
Your personal and sensitive personal information will be processed by BAA for the following purposes:
- To operate, manage, and maintain BAA’s business;
- For evaluation, hiring, retention, and employment purposes;
- To otherwise accomplish BAA’s business purposes and objectives, including, for example:
- Conducting research, analytics, and data analysis;
- Maintaining our facilities and infrastructure;
- Quality and safety assurance measures;
- Conducting risk and security controls and monitoring;
- Protecting confidential and trade secret information;
- Detecting and preventing fraud;
- Performing identity verification;
- Performing accounting, audit, and other internal functions, such as internal investigations;
- Complying with the law, legal process, and internal policies;
- Maintaining records;
- Claims processing;
- Responding to legal requests for information and subpoenas; and
- Exercising and defending legal claims.
- Any other purposes authorized by applicable law including, for example, the California Privacy Protection Agency, California or Federal law.
| Legal basis as applicable per the Privacy & Data Protection Laws | Why We process your data |
|---|---|
| Legitimate interest |
|
| For taking steps at your request prior to entering into a contract and/or for performance of a contract |
|
| Compliance with Legal Obligations | To comply with legal obligations to which BAA is subject, such as keeping records for tax, employment, social security and immigration law purposes, or providing information to a public body or law enforcement or government agencies |
| Consent |
|
How long does BAA retain your personal information?
Unless BAA has de-identified or deleted your personal information in response to a request to delete, BAA retains your personal information for as long as necessary to fulfill the purposes for which it was collected, subject to applicable Company record retention guidelines. BAA may retain your personal information for longer if it is necessary to comply with BAA’s legal, contractual or reporting obligations, or as otherwise permitted or required by applicable law. BAA may also retain your personal information in a de-identified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your personal information, BAA considers various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which BAA processes your personal information; and applicable legal requirements.
What are your rights and how can you exercise them?
Depending on your relationship with BAA and in line with local data protection laws, you may have several rights in relation to your Personal Information such as access, rectification, erasure, restriction of processing, objection, withdrawal of consent, not to be subject to decisions based on automated processing, opt out of marketing communications, etc. Please note, these rights are subject to exemptions and may not apply in all circumstances. If you wish to exercise these rights, BAA will provide you with the requested information or will address your request within one month after receipt of your verified request, subject to any extensions that may be required and communicated to you.
You can use the following channels to exercise your rights or request more information about your rights:
- If you have any requests, comments or inquiries, you may contact BAA via privacyinfo@butler.com.
- If you are a California resident, please review the following attachment for more details about your rights.
With whom does BAA share your personal information?
BAA may transfer or share your Personal Information with third parties such as our service providers and vendors, business partners, professional and corporate advisors, public or government authorities including law enforcement, network providers, third party websites, and BAA affiliates or subsidiaries.
BAA may also transfer your Personal Information to any of its global affiliated entities or subsidiaries. Unless you are otherwise notified, any transfers of your personal data from within the European Economic Area (EEA) to third parties outside the EEA will be based on an adequacy decision or as governed by the standard contractual clauses (a copy of which can be obtained through the contact information included below). Any other non-EEA related transfers of your personal data will take place in accordance with the appropriate international data transfer mechanisms and standards.
When required, BAA may disclose your Personal Information to external law enforcement bodies or regulatory authorities, in order to comply with legal obligations. BAA may also disclose your Personal Information where mandated by law and as further required when it believes in good faith that disclosure is necessary to protect its rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
If BAA is involved in a merger, reorganization, dissolution or other fundamental corporate change, BAA may need to share your information with a third party, in compliance with applicable laws.
How does BAA safeguard your Personal Information?
BAA uses a range of security measures to protect your personal information from unauthorized or unlawful access, loss, disclosure, or alteration, including technical, organizational and physical measures.
How can you contact BAA if you have any questions?
If you have any questions about this Privacy Statement, you can contact BAA via privacyinfo@butler.com.
If you have an unresolved privacy or data use concerns that BAA has not addressed satisfactorily, please contact privacyinfo@butler.com.
How will BAA update this Privacy Statement?
BAA may amend this Privacy Statement from time to time. If BAA materially changes its Privacy Statement, BAA will update the “Effective Date” at the top of the Privacy Statement and BAA may provide notice prior to the update taking effect by posting a notice on its website or, where required by law, by providing you with notice of such updates.
CONFIDENTIAL: These policies are the property of Butler America Aerospace, LLC and its affiliates. They may not be copied, reproduced or otherwise used without the express written permission of BAA.
