BOMBARDIER AVIATION DATA AND PRIVACY POLICY

Last updated on January 29, 2021

1. Purpose

This Data and Privacy Policy describes how we at Bombardier Inc., including our business segments, divisions, subsidiaries and affiliates (collectively “Bombardier”, “we” or “our”) (for more details see http://bombardier.com/en/corporate/about-us/worldwide-presence) collect, store, use and safeguard data, including personal data, to support our business activities, including our products and services (collectively the “Bombardier Services”). The term “Personal Data” in this Policy refers to information that identifies or is capable of identifying you as an individual.

2. Our Commitment

Bombardier is committed to conducting business in a way that complies with applicable data protection laws and regulations in every country in which Bombardier operates. These laws govern the collection, storage, processing and use of personal data.

3. Which data we collect

In order to support our business activities and to provide Bombardier Services, we, together with our subcontractors and authorized third parties, must collect and process user-specific and user-generated data from users of those services.

The data we collect depends on the way in which you interact with Bombardier and it may include the following:

1. Information that you provide to Bombardier, including for purposes of enrollment, activation, account creation, ordering, payment, shipping, etc.;
2. Information generated or originating from your aircraft, including CAS notifications, engine data, aircraft and flight parameters, location, any aircraft information downloaded or uploaded via Wi-Fi, Cellular, ACARS or SATCOM to or from your aircraft including device identifiers, etc.;
3. Information about your usage of the Bombardier Services, including how you use Bombardier Services, content viewed, navigation history, while navigating the Bombardier portal and features used, actions taken, the time, frequency and duration of such activities, etc.;
4. Other information that you provide to us including the content of messages you send to us when you submit feedback or when you make inquiries, request products or services, contact customer support, make account information changes or complete surveys.
5. Your interests and preferences including your preferred products and services, and other similar data that helps us build up a picture of your interests and preferences.
   


4. How we collect your data

Bombardier collects data from you, from third parties and through cookies.

• Data obtained from you: You provide data directly to us when you purchase our products or register for our services, create an account on our Sites, interact with us on social media, click an advertising link that we put on someone else’s website, submit a query to us via our Sites, contact us for support, provide a testimonial, comment on blogs or articles featured on our Sites, register for our events (including webcast events), enter our competitions, sign up for our special offers, participate in our research panels or fill in our surveys.
• Data obtained from third parties: We obtain data from third parties, including:
  • data brokers from whom we purchase market intelligence
  • business partners who may send us information about you and products and services for which you signed-up.
  • service providers that help us determine a location based on your IP address in order to customize certain messaging to your location and publicly-available sources such as open government databases or other data in the public domain (e.g. on third party social media platforms, like Instagram, Facebook, Twitter, or LinkedIn).
• • Data obtained through cookies: We also collect data by using cookies to record how you interact with Bombardier Services. You can learn more about cookies and how we use them in our Cookie Policy.


5. Why we collect your data and our lawful bases for processing it

We use the data that we collect during and after the end of your relationship with us. Our uses of the data include:

1. To provide, personalize and improve the Bombardier Services;
2. For research and development relating to products and services;
3. To enable location-related features in Bombardier Services;
4. To enable measurements, analytics and other business services for internal use at Bombardier and for the benefit of our partners;
5. To improve safety and security of Bombardier Services;
6. To communicate with you and provide support;
7. To enable or administer our business, including administering customer accounts, responding to supplier inquiries and monitoring quality assurance;
8. For advertisement and marketing purposes;

We will only use your data where we have a lawful basis for doing so. Lawful bases include, among others, each one of the following:

• Consent (where you have given consent).
• Contract (where using your data is necessary for the performance of a contract with you).
• Legal obligation (where using your data is necessary for compliance with laws that apply to us).
• Vital interests (where using your data is necessary to provide urgent safety notices or product recalls).
• Legitimate interests (where we have legitimate interests and they do not outweigh your privacy rights).

Where we rely on your consent to use your personal data, you have the right to withdraw or decline your consent at any time. Please see the ‘Your rights regarding your data’ section for further details on how you can do this.

When we get your data from partners, we ensure our partners have a lawful basis for sharing your data with us.

If you have any questions about, or objections to, the lawful bases upon which we use your data, please contact our data privacy officer in any of the ways described in the ‘Your rights regarding your data’ section’

6. Marketing and advertising

We use your personal data to send you marketing information directly from us and/or our partners by post, email or SMS, where you gave your consent to such use (unless there is another lawful bases for using your personal data for marketing and advertising purposes in your jurisdiction, which does not require your consent). We also use your personal data and information inferred from your personal data to tailor ads to your interests and preferences. This allows us to improve the relevance of our ads to you.

We may share your personal data with our third party advertising partners in order to serve you targeted ads on our Sites or on third party websites and online services. Digital media agencies provide strategic and technical input to our advertising campaigns. To help us engage with specific target markets, they advise us how and where to advertise through online and print advertising and other forms of media management. We may also share your personal data with other categories of recipients; however, these do not process personal data under EU data protection laws. Our advertising partners may then use cookies to measure the effectiveness of the ads. For more information on how to reject targeted advertising or interest-based advertising cookies please read our Cookie Policy.

You have the right to object to our use of your personal data for marketing and advertising purposes, or – where we rely on your consent to use your personal data for marketing and advertising purposes – to withdraw your consent. Please see the ‘Your rights regarding your personal data’ section for further details.

7. How we store, process, share and protect your data

The data we collect will be stored in a range of different places, including on our servers or on our cloud providers’ servers. Because we are a global business, we may process data in different geographical locations (including outside the European Economic Area).

Bombardier occasionally shares data for the purposes described below.

1. With users to whom you’ve granted access to your Bombardier Services account;
2. Internally, with various Bombardier departments, including for example communications, marketing, sales, finance, legal, procurement and information technology;
3. With apps, websites and third party integrations using Bombardier Services: when you sign up to use third party apps, websites or other services that use, or are integrated with, Bombardier Services, they will receive the information that you’ve authorized them to collect, use and share. Any information collected by third parties is subject to their own terms and policies, not this Data Policy.
4. With third-party partners, we work with partners who:
• help us provide and improve Bombardier Services;
• have signed up to use our services to grow their business;
• have signed up to obtain information enabling them to provide products and services.
We impose strict limits on how partners may use the data that we provide. We allow partners to obtain aggregate statistics and insights on how users use Bombardier Services or their respective products and services.We also allow partners to obtain analytics and measurements reports. Only if you have specifically granted consent will personal data be shared with our third party partners.
5. With service providers who support Bombardier, such as those providing technical infrastructure and software solutions, advertisements, customer support, payment solutions, conducting surveys and studies on our behalf, etc.
6. To comply with law enforcement and legal requests.


8. Your rights regarding your personal data

You have a number of rights regarding your personal data depending on your jurisdiction.

• Accessing your personal data. You can request a copy of the personal data we hold about you.
• Correcting and updating your personal data. You can ask us to correct or update your personal data at any time if you discover that any of it is inaccurate or out of date.
• Erasing your personal data. You can require Bombardier to erase personal data in certain circumstances and we will take reasonable steps to inform other controllers that are processing the data that you have requested the erasure of any links to, copies or replication of the data. Your personal data will be removed from Bombardier systems within a reasonable time and will be deleted. However, Bombardier may retain a copy of your personal data (i) if and as long as required by law, regulation, administrative or court order or for internal auditing purposes, or (ii) as electronic data stored due to automatic archiving and back-up procedures. Please note that in the event of a legal dispute between you and Bombardier, your personal data may be retained until final settlement of the legal dispute.
• Objecting to or restricting the processing of your personal data. You can ask us to stop using all or some of your personal data (e.g. if we have no lawful basis to keep using it) or restrict how we process it.
• Withdrawing your consent. Where we rely on your consent as the legal basis for processing your personal data, you can withdraw your consent at any time and you can prevent further processing if there is no other legal basis upon which Bombardier can process your personal data.
• Porting your personal data. You can ask us to transfer the personal data that we hold about you to a third party electronically.

If you would like to exercise any of these rights, please advise Bombardier by sending us an email at: corporatelegalaffairs@bombardier.com. You can also raise a complaint about our data processing practices with the data protection regulator in your jurisdiction. Please see the ‘How you can contact us about this privacy statement or make a complaint section below.

You may also have additional rights depending on your jurisdiction.  If you are a California resident, you can find more details on your rights and how to exercise them here.

9. How long do we keep user data?

The period during which your data is held is determined by a number of factors including the purpose for which we use that data and our legal obligations. We do not generally retain data in an identifiable form for longer than is necessary, though in some cases we may choose to retain certain data in a depersonalized or aggregated form for extended periods of time.

10. How do we make changes to this Data Policy?

Should we elect to change this Data Policy, we will post the changes on the Bombardier Customer Portal (https://my.businessaircraft.bombardier.com/wps/myportal/bba/footer/privacy. Please check it from time to time to ensure that you are informed of any changes.

11. How do you contact us about this Data Policy?

If you have any questions or suggestions about this privacy statement or about how we use your personal data, please contact us at :

Corporate Legal Affairs
Phone: +1 (514) 855-5001
Email: corporatelegalaffairs@bombardier.com

Please let us know if you are unhappy with how we use your personal data. We will respond to your complaint within 30 days.