Privacy Policy

ACASS Canada Ltd – Privacy Policy for Website visitors, Flight Crew Staffing and CrewBase users

Introduction

ACASS Canada Ltd, including CrewBase (“ACASS”, “we”, “us”, “our”) respects your right to privacy. As such, we want to inform you of what happens to the Personal Information (as defined below) collected from website visitors and from both aviation professionals and aircraft owners and operators¹ in the course of providing our flight crew staffing services, including through www.acass.com and www.crewbase.com (including our mobile site) and through our App CrewBase available for Apple™ and Android™ products (collectively, the website, mobile site and CrewBase App referred to herein as the “Site”) for our various services offerings on the Site (collectively, the “Service”).

We feel it is important that you fully understand the type of information we collect from you when providing the Service, along with when and why it is collected and its intended use. Please read the following sections carefully before submitting any of your Personal Information to us.

This Privacy Policy contains important information on our commitment to the protection of your Personal Information, including:

• What we mean by “Personal Information”
• When we collect your Personal Information
• What Personal Information we collect from you
• The purposes for which we collect and use your Personal Information
• The Internet technologies we may use to collect and process your Personal Information
• To whom we may disclose your Personal Information, and the location in which your Personal Information may be stored
• The manner and location in which we may retain your Personal Information
• The ways that we protect your Personal Information
• How to access, correct or update your Personal Information
• How to contact us about privacy issues

Please note that by agreeing to this Privacy Policy, or by using the Site or App, or otherwise submitting information to us, you are authorizing ACASS to collect, store, transfer and use your Personal Information in accordance with this Privacy Policy. Except as required or permitted by law, ACASS will not use or disclose your Personal Information for any additional purposes without obtaining your further consent.

We also strongly suggest that you refer to this section periodically for changes or updates. Please be assured that ACASS will not collect any Personal Information without your prior consent.

What is Personal Information?

For the purposes of this Privacy Policy, and in accordance with applicable privacy laws, the term “Personal Information” refers to any information that may be used to identify you, including information that may be generated through the use of the Service such as, but not limited to your name, e-mail address and postal address, certifications, professional experience, etc. (as further described below). Personal Information does not include aggregated or de-identified information that cannot be used to identify you.

When do we collect Personal Information?

We may collect Personal Information in a number of circumstances. For example, we collect Personal Information from you when you:

• Visit the Site or use our app;
• Create a professional profile or apply for a position;
• Register to receive alerts, newsletters or other information;
• Participate in a contest or promotion;
• Engage us to provide you with flight crew staffing services, or otherwise do business with us;
• Contact us to request a quote, obtain information, or for any other reason
• What Personal Information do we collect from you?

The type and quantity of Personal Information that we may collect about you varies according to the nature of your interaction with ACASS, but will generally include contact details such as you name, postal address, telephone numbers and email addresses.

If you communicate with us, we will also collect information about the nature of your inquiry or the subject matter of the communication, as well as any other Personal Information that you provide to us.

Where you create a professional profile or apply for a position, we will request and collect a range of information about your qualifications and experience, as well as information about the travel documents/authorizations you hold, your immunization records and your medical fitness for duty.

When you engage us to provide services, we will also collect payment information, such as credit card, debit card, or checking account information (including credit card number and expiration date).

When you visit our Site or use our app, we may also collect your IP address, device identifier, information about the websites you visit and your trends as a user, as further explained below, in the Electronic technologies section.

How do we use your Personal Information?

The collection of Personal Information generally allows ACASS to provide services relevant to your needs and to contact you.

      1. Primary purposes

The primary purposes for which we may collect your Personal Information include:

• To enable the use of the services made available on the Site and the app;
• To verify qualifications, experience and other representations made in a profile or application;
• To confirm, process and track any transactions;
• To provide the services for which you have engaged us, including providing after sales services;
• To administer billing and payment for services;
• To administer the Site and app;
• To improve your browsing or user experience;
• To monitor and analyze usage of our Site and app and identify trends;
• To customize, measure and improve our services and site and app content;
• To communicate with you with respect to your use of our Site, app or services; and to respond to your submitted comments or queries
• To send statements and invoices to you, and collect payments from you;
• As otherwise required or permitted by law

      2. Secondary purposes

As permitted by law, we may also use some of your Personal Information for purposes not directly connected to your use of our Site, app or the Service, as set out below. In some cases, you may choose not to participate in such activities, or to refrain from providing us with your Personal Information. In other cases, you may opt-out of the use of your Personal Information for secondary purposes by contacting us, as set out below under Contact. For completeness, we also note below a number of practices that involve only the collection and use of aggregated information.

a. Marketing Communications

Where permitted by law, we may communicate with you by postal mail, telephone (including through automatic dialing-announcing devices), fax, e-mail, sms, mms, or any other communications means about ACASS news, services or offers which may be of interest to you, unless you have opted to be excluded from these communications. You can inform us at any time if you no longer wish to receive such information by advising us of your preference during the communication in question, using the unsubscribe feature of any electronic communication, or by contacting us as set out below under Contact.

b. Online Advertising

ACASS licenses technology to serve advertisements on its own Site and within its content as that content is served across the Internet. In addition, we may use third party network advertisers to serve advertisements based on your use of the Site, the app, and any viewing of our content. We do not share Personal Information with these third parties, but ad network providers, the advertisers and/or the sponsors may set and access their own cookies, pixel tags and similar technologies on your device and they may otherwise collect or have access to information about you, including information about your web usage. Our network advertisers and we may target advertisements for products and services in which you might be interested based on your visits to both the Sites and other web sites. We may use a variety of companies to serve advertisements.

If you prefer to not receive targeted advertising, you can opt out of certain network advertising programs through the Digital Advertising Alliance of Canada opt-out page at www.youradchoices.ca. Please note that even if you choose to opt-out from interest-based ads, you will still see advertisements while you’re browsing online; however, the advertisements you see may be less relevant to you and your interests. As described further below, you may also prevent the tracking of your web usage by disabling cookies in your browser.

c. Website Usage and Analytics

ACASS collects certain information about visitors to the Site through various Internet technologies, such as through log files, cookies, web beacons and similar technologies. We use this information to better understand the way our Site is used, such as to identify repeat visitors and to track the number of unique visits to our Site, the number of views to particular pages, and time of day patterns.

We may use third party analytics vendors to evaluate and provide us with information about the use of the Site and viewing of our content. We do not share Personal Information with these third parties, but analytics service providers may set and access their own cookies, pixel tags and similar technologies on your device and they may otherwise collect or have access to information about you, including information about your web usage.

As described further below, you may also prevent the tracking of your web usage by disabling cookies in your browser.

d. User-Submitted Content

From time to time, users of our Site, app and the Service may submit testimonials, photographs or other writings. As further explained in our Terms and Conditions of Use by providing such submissions, users consent to ACASS using such submissions together with the user’s name and location in any and all media.

e. Contests and Surveys

To participate in certain services-related promotions, including, but not limited to, contests, sweepstakes and surveys, there may be a separate registration process, which may require the submission of Personal Information (including your name, email address, mailing address, telephone number, etc.). We will use the information you provide solely for the purpose of conducting the promotion (for example, to contact you if you have won), and for the purposes stated in the registration form. You may also have the opportunity to opt-in to receive special promotions or offers from our advertisers as a result of your use of the Site and/or the Service. In some cases, users may also be given the choice of providing their name and location when responding to customer satisfaction surveys.

Electronic technologies

An IP (Internet Protocol) address is a number designated for your computer by your Internet service provider to provide access to the Internet.  We may use your IP address to gather aggregate information on use. But we will only be able to identify you individually if we have the means of linking the IP address to you as a particular user. This usually requires access to additional information which we do not seek.

When you view our websites we, or advertising and analytics companies we may retain, may store information on the hard drive of your computer, tablet or mobile device in the form of a “cookie”. Cookies are small text files stored on your device that identify your browser/IP address – but not you as a named individual – to our computers each time you visit our Site or other sites on the web. Cookies do not allow us access to the rest of your computer. More information about cookies can be found at www.en.wikipedia.org/wiki/HTTP_cookie.

Cookies allow us to tailor our Site to your interests and preferences. For example, a cookie might contain information about the web pages you have visited on the website, which could allow us to customize your next visit to the websites. We may also use cookies to collect aggregated statistical information. Most Internet browsers enable you to delete cookies or to receive a warning before a cookie is stored on your hard drive. Please refer to your browser instructions or help screen to learn more about how to do this. However, should you decide to disable any cookies we place on your computer you may not be able to use certain services or facilities on the Site.

In order to analyze the success of our marketing campaigns, we also implement other technologies such as web beacons. A web beacon (https://en.wikipedia.org/wiki/Web_beacon) is a small transparent graphic image that allows us to record simple user actions related to our Site and to email communications received from us, which assist us in determining the usage and effectiveness of our Site and communications. These “images” are automatically loaded to your browser/device when you visit the Site or open an html format email message from us, thereby letting us know if a certain page was visited or an email message was opened.

We use third-party web beacons to help analyze where visitors go and what they do while visiting our website. Such third parties may also use anonymous information about your visits to this and other websites in order to improve its products and services and provide advertisements about goods and services of interest to you.

Log files are records of all visits to our Site, which are automatically generated by our servers or Site hosts. Our server creates log files of information such as the IP address from your network, what pages were explored and the length of your visit.  We study visitor trends since we are interested in the successful dissemination of information through the websites. Analysis software is used to generate reports which help us to learn more about how we can enhance your experience with the websites. This information is not used to develop a personal profile of you. The log files are regularly purged.

With whom may we share your Personal Information and why?

It is important to note that ACASS will not disclose your Personal Information with sponsors, advertisers, partners and other clients, without your consent. Your Personal Information can only be accessed by ACASS and its affiliated companies. If ever we request information for another purpose, you will be automatically and explicitly informed at the time such information is requested.

We may share Personal Information collected via the website with third party service providers who perform services on our behalf, based on our instructions, such as to help us to operate the Site or app, process your transactions and queries, provide identity verification or background checks, or otherwise manage the customer relationship between you and us. We will limit our disclosure of your Personal Information to such third parties to that, which is reasonably necessary for the purpose or service for which the third-party service provider is engaged. We will use contractual and other means to provide a comparable level of protection while the information is being processed by such third parties, including limiting such providers to using your Personal Information solely to provide ACASS with the specific service for which they were engaged, and for no other purpose. You can obtain more information about our policies and practices with respect to the use of Personal Information by third party service providers by contacting us, as set out below under Contact.

We may share or transfer your Personal Information where reasonably required in the context of a sale, merger or amalgamation of all or part of our business or the insurance of securitization of our assets. In any such case, the recipient parties will be contractually required to keep the information confidential and use it only for the purposes of the transaction, or proposed transaction, in question. In the event a business transaction is affected, assignees or successors of ACASS or our business or assets, or those of our affiliated entities, may use and disclose Personal Information only for the purposes as set out this Privacy Policy, unless further consent is obtained.

Otherwise, we will only disclose Personal Information, as required or permitted by law:

• To government bodies and law enforcement agencies
• In order to protect the personal safety of ACASS users or the safety of the general public
• In connection with any legal proceedings or prospective legal proceedings involving ACASS
• To otherwise establish, exercise or defend our legal rights (including providing information to third parties for the purposes of fraud prevention and reducing credit risk as permitted by law)

Upon request, we will inform you about the disclosure and the entity we disclosed your Personal Information to, unless prohibited by law.

We may also share with third parties aggregated or de-identified information, which cannot reasonably be used to identify a particular individual.

Linking to other websites

ACASS contains links to third-party websites; these are provided solely for your convenience. Clicking on these links will take you outside of ACASS. Please be advised that ACASS has no control over these third-party sites and, while ACASS may feature such links, ACASS will not, at any time, accept liability for these sites.

Consequently, Personal Information that you provide to a Web site outside of ACASS is subject to the privacy protection policies of the given third-party site. In the event of abuse by such sites, ACASS cannot, at any time, be held responsible. Therefore, we strongly urge you to carefully read the privacy protection policies of all third-party sites you choose to enter.

Retention and storage of Personal Information

We will retain your Personal Information for only so long as is necessary to fulfill the purposes for which it was collected, and for such periods of time as may be required to comply with applicable law.

When your Personal Information is no longer required, we will make all reasonable efforts to ensure all electronic and hard copies of such information are securely destroyed and irreversibly deleted from our systems.

Your Personal Information may be stored or processed by ACASS or its third party service providers outside of your home country, where it may be subject to the legal requirements of the foreign country in which it is stored or processed.

How do we keep your information secure?

ACASS takes commercially reasonable security measures to protect against unauthorized access to, or unauthorized use, alteration or disclosure of, Personal Information that you share and we collect and store. These security measures may include practices such as keeping your Personal Information on a secured server behind a firewall, transmitting sensitive information (such as a credit card numbers) entered on our site using secure socket layer technology (SSL), internal reviews of our data collection practices and policies, as well as physical security measures to guard against unauthorized access to systems where we store your information. Other safeguards include physical measures (such as locked filing cabinets and restricted access to offices), organizational measures (such as security clearances and limiting access to a “need-to-know” basis) and technological measures (such as the use of passwords and encryption).

Your rights concerning your Personal Information

In accordance with applicable law, you have the right to request access to the Personal Information that we hold on you and to have any errors in that information corrected. You may also request that the Personal Information be deleted as well as object to the processing of your Personal Information for direct marketing purposes. Please address your written request to our Chief Privacy Officer as set out below under Contact.

Without limiting the generality of the foregoing, here are 7 key rights to your Personal Information, as dictated by the General Data Protection Regulations (“GDPR”) and other applicable private information protection laws, and that you can request from our Chief Privacy Officer as set out below under Contact.

#1 I want your company to delete my personal data (‘right to be forgotten’)

You may request deletion of your account/personal information by simply sending an email to: privacy@acass.com from the unique identifier email. COULD BE AN AUTOMATIC RESPONSE I.E. IF YOU WANT ALL INFORMATION REMOVED, CLICK. Upon receipt of your request, your account and personal information will be immediately removed from the site within 24 hours and permanently deleted from our database within 30 business days.

#2 I want your company to transfer my data to me

You may request the transfer of your personal data by simply sending an email to: privacy@acass.com . You will receive a confirmation email that we have received your request followed by a final email specifying that your personal information has been transferred to you in a readable excel file. (Please allow 5 business days to process your request from the date you send in the request.)

#3 I want to know how your company is using my personal data

Please see How do we use your Personal Information? Section, herein above.

#4 I want to rectify incorrect data your company has about me

As a user of the site, you have control over the accuracy and correction of your data. To view your profile page and correct any incorrect data, login to your account, click on profile and click on ‘edit’. You can then update any information and save changes once completed.

#5 I want your company to stop using my information for direct marketing and profiling

You may request for your personal information not to be included in any direct marketing/marketing profiling activities by emailing your request to privacy@acass.com and including the following information:

• First name
• Last name
• Mailing address
• Email address
• Specifically mention “Please stop using my information for direct marketing and profiling’.

#6 I want your company to keep my data but stop processing it

You may request for your personal information to be kept on file but not to be processed by emailing your request to privacy@acass.com and including the following information:

• First name
• Last name
• Mailing address
• Email address
• Specifically mention “Please keep my personal information but do not process it”.

#7 I want to object to the way your company is using my personal information / I want to signal a data breach

The protection of your personal data is of utmost priority. We have taken stringent security steps to ensure the personal information you share on CrewBase is secured and protected. However, in the rare case where you believe your person data has been compromised, please send us an email including detailed information on how you believe your personal information has been compromised to privacy@acass.com. We will respond immediately with action steps on resolution. Please make sure to include:

• First Name
• Last Name
• Mailing address
• Email address
• Detailed description of how you believe their information has been misused or compromised.

Contact for privacy issues

Please contact our Chief Privacy Officer should you have any questions, complaints or comments in connection with this Privacy Policy and/or the collection, storing, transfer and use of your Personal Information by ACASS/CrewBase. You may also contact our Chief Privacy Officer to obtain more information about our policies and practices relating to the collection, storing, transfer and use of Personal Information.

Chief Privacy Officer

ACASS Canada Ltd, including CrewBase

6700 Côte de Liesse, suite 206,

Montreal (QC)
H4T 2B5 Canada

p. (514) 636-1099

f. (514) 636-9881

privacy@acass.com

Note that only privacy-related inquiries or requests may be sent to the above address.  For other matter, please direct your communications to either info@acass.com or info@crewbase.com.