ACI Jet (the “Company” or “we”) developed this privacy policy out of respect for the privacy of our clients, visitors to our website, employees, and job applicants. This policy describes the personal information we collect, use, and disclose about individual clients, consumers, employees, applicants, and contractors who visit or interact with this website, visit any of our offices, facilities or locations, purchase or inquire about any of our products or services, contract with us to provide services, apply for a position of employment, are hired for a position of employment, or otherwise interact or do business with us.

Whenever you visit our website, we will collect some information from you automatically, simply by your visit and navigation through the site, and some voluntarily when you submit information using a form on the website, enroll in or subscribe to our marketing communications, request information, or use any of the other interactive portions of our website. Through this website, we will collect information that may be able to identify you and/or your activity.

Additionally, whenever you communicate, interact, or do business with us, whether online or at any of our locations, we will collect personal information from you or about you in the course of our interaction or dealings with you. This includes applying for a position of employment and completing employment-related forms during your onboarding after you are hired. Additional personal information may be gathered from you for employee benefits-related purposes during the term of your employment.

Please know that we do NOT and will not sell your personal information in exchange for monetary or other valuable consideration. We also do not share your personal information for cross-context behavioral advertising.

Consent to Terms and Conditions

By using this website, you consent to all terms and conditions expressed in this Privacy Policy and Notice at Collection.

Collection of Personal Information and Sensitive Personal Information

The table below lists the categories of personal information we collect and process about you based on your specific transactions and interactions with our website, including the personal information collected and processed in the last 12 months.

Category	Examples	Disclosed in Last 12 Months to	Retention Period
Personal Identifiers	Name, alias, social security number, date of birth, driver’s license or state identification card number, passport number.	Service providers that we use to support our business and operations (e.g., financial institutions, insurers, contractors, agents, data storage, technical support, advertising, analytics, media and marketing, promotions, campaigns and contest-related services) Third-party payment processors, including in connection with transactions where we require credit or debit card account information such as credit or payment card account information (including card number, expiration date, and security code); Third parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests.	We will retain your Personal Information for as long as it is necessary to fulfill the purposes outlined in this Policy and as otherwise needed to comply with applicable law and internal company policies.
Sensitive Personal Information	Personal identification numbers, including, driver’s license, passport, or state ID card numbers; account or debit or credit card numbers; consumer’s geolocation;	Service providers that we use to support our business and operations (e.g., financial institutions, insurers, contractors, agents, data storage, technical support. Third-party payment processors, including in connection with transactions where we require credit or debit card account information such as credit or payment card account information (including card number, expiration date, and security code); Third parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests.	We will retain your Personal Information for as long as it is necessary to fulfill the purposes outlined in this Policy and as otherwise needed to comply with applicable law and internal company policies.
Internet/Network Activity	IP address, your device information, domain name, browsers you used to access our site and services, web pages viewed, time spent on webpages, links clicked, transactions entered into and site-navigation patterns.	Service providers that we use to support our business and operations; Third-party companies we work with who help to gather information from you or help us to communicate with you, including for purposes of data analytics; and Third-parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests.	Internet/Network activity is retained for 14 months.
Business-to-Business (“B2B”) Information	Name, phone number, address, email address and other contact and relationship information consistent with your role in facilitating the business relationship.	We do not disclose B2B Information outside our business relationship without your consent.	We will retain your Personal Information for as long as it is necessary to fulfill the purposes outlined in this Policy and as otherwise needed to comply with applicable law and internal company policies.

Of the above categories of Personal Information, the following are categories of Sensitive Personal Information ACI Jet may collect from or about consumers, applicants, or employees:

1. Personal Identifiers (social security number, driver’s license or state identification card number, passport number);
2. Account Information (your account log-in, in combination with any required security or access code, password, or credentials allowing access to the account);
3. Protected Classifications (racial or ethnic origin, religious or philosophical beliefs, union membership, or sexual orientation);
4. Medical and Health Information; and
5. Geolocation Data (IP address and/or GPS location, latitude & longitude).

Personal information does not include:

1. Publicly available information from government records;
2. Information that a business has a reasonable basis to believe is lawfully made available to the general public by the consumer, independent contractor, or applicant, or from widely distributed media;
3. Information made available by a person to whom the consumer, independent contractor, or applicant has disclosed the information if the consumer, independent contractor, or applicant has not restricted the information to a specific audience; and/or
4. Deidentified or aggregated information.

We may collect your personal information from the following sources:

1. You as the consumer, employee, or job applicant, when you visit the website and voluntarily submit information through forms on the website or social media, when you visit any of our physical locations, when you purchase or inquire about any of our products or services, when you enter into a contract to perform services for us, when you apply for a position of employment, or during the course of your employment with the Company;
2. Our employees when you interact with them;
3. Our clients and visitors, when you interact with them or when they observe you;
4. We utilize cookies to automatically collect information about our website visitors;
5. Lead generators and referral sources;
6. Credit and consumer reporting agencies;
7. Recruiters;
8. Social media platforms;
9. Company-issued computers and electronic devices; and/or
10. Company systems, networks, software applications, and databases you log into or use.

We may disclose your personal information to the following categories of service providers or third parties, where it is lawful to do so for the business purposes identified below, including for purposes of providing services to our clients, and without disclosing any privileged information:

1. Financial institutions;
2. Product manufacturers/administrators;
3. Government agencies;
4. Support vendors for marketing, managing or hosting the website;
5. Transaction support vendors (e.g., check guarantee, payment processors);
6. Data analytics vendors;
7. Professional employer organizations;
8. Consumer reporting agencies or credit reporting agencies;
9. Employee tracking and talent management systems;
10. Security and risk management vendors; and/or
11. Software and cloud service providers.

We may collect your personal information for the following business purposes:

1. To fulfill or meet the purpose for which you provided the information;
2. To process, complete, and maintain records on transactions;
3. To retain your selection for Text opt in/opt out to ensure customers who opted out are not sent any text messages;
4. To schedule, manage and keep track of customer appointments;
5. To respond to consumer inquiries, including requests for information, customer support online, phone calls, and in-office inquiries;
6. To improve user experience on our website;
7. To understand the demographics of our website visitors;
8. To detect security incidents;
9. To debug, identify, and repair errors that impair existing intended functionality of our website;
10. To protect against malicious or illegal activity and prosecute those responsible;
11. To verify and respond to consumer requests; and
12. JOB APPLICANT AND EMPLOYEE PURPOSES:
    1. To fulfill or meet the purpose for which you provided the information. For example, if you share your name and contact information to apply for a job with ACI Jet, we will use that Personal Information in connection with your candidacy for employment;
    2. To comply with local, state, and federal law and regulations requiring employers to maintain certain records, as well as local, state, and federal law, regulations, ordinances, guidelines, and orders, such as those, for example, relating to infectious diseases, pandemics, outbreaks, and public health emergencies, including applicable reporting requirements;
    3. To verify your right to work in the United States;
    4. To evaluate your job application and candidacy for employment;
    5. To obtain and verify background check and references;
    6. To communicate with you regarding your candidacy for employment;
    7. To administer group benefit plans and/or individual benefits plans in which you are eligible or are a participant;
    8. To administer claims for workers’ compensation benefits under our workers’ compensation insurance policy;
    9. To implement reasonable accommodations, to assess the feasibility of reasonable accommodations, or to engage in the interactive process regarding reasonable accommodations in your workplace, as may be required by law; and
    10. To comply with local, state, and federal law and regulations requiring employers to provide information regarding unemployment insurance benefits, state disability insurance benefits, tax liens, withholding orders, qualified domestic relations orders, or compensation verification

We may disclose your personal information for any of the business purposes identified above.

We do NOT and will not sell your personal information in exchange for monetary or other valuable consideration. We do not share your personal information for cross-context behavioral advertising.

We do not and will not use or disclose your sensitive personal information for purposes other than the following:

1. To perform the services reasonably expected by an average employee who requests those services.
2. To detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information.
3. To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions.
4. To ensure the physical safety of natural persons.
5. For short-term, transient use.
6. To perform services on behalf of ACI Jet.
7. To verify or maintain the quality or safety of a product, service or device that is owned, manufactured, manufactured for, or controlled by the Company, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by the Company.
8. For purposes that do not involve inferring characteristics about the consumers and applicants.

Retention & Disposal

We retain information as long as necessary to fulfill the purposes for which we collected it, for legitimate business reasons, or as required by law. We may need to keep your data for longer than our specified retention periods to honor your requests, including to continue keeping you opted out of marketing emails, or to comply with legal or other obligations. When we dispose of information, we use secure means, such as either physically or electronically erasing information or making it anonymous in a non-recoverable manner.

Business Transfers

In the event we sell or transfer all or a particular portion of our business assets, information of consumers and applicants may be one of the business assets transferred as part of the transaction. If substantially all of our assets are acquired, information of consumers and applicants may be transferred as part of the acquisition.

Compliance with Law and Safety

We may disclose specific personal and/or sensitive personal information based on a good faith belief that such disclosure is necessary to comply with or conform to the law or that such disclosure is necessary to protect our employees or the public.

Use of Cookies and Other Tracking Technologies

Cookies are small files that a website may transfer to a user’s computer that reside there for either the duration of the browsing session (session cookies) or on a permanent, until deleted, basis (persistent cookies) that may be used to identify a user, a user’s machine, or a user’s behavior. We make use of cookies under the following circumstances and for the following reasons:

• Provide you with services available through the website and to enable you to use some of its features
• Authenticate users and prevent fraudulent use of user accounts
• Identify if users have accepted the use of cookies on the website
• Compile data about website traffic and how users use the website to offer a better website experience
• Understand and save visitor preferences for future visits, such as remembering your login details or language preference, to provide you with a more personal experience and to avoid you having to reenter your preferences every time you use the website

You may delete cookies from your web browser at any time or block cookies on your equipment, but this may affect the functioning of or even block the website. You can prevent saving of cookies (disable and delete them) by changing your browser settings accordingly at any time. It is possible that some functions will not be available on our website when use of cookies is deactivated. Check the settings of your browser. Below you can find some guidance:

• Safari
• Opera
• Internet Explorer
• Google Chrome
• Mozilla

Do Not Track (DNT) is a privacy preference that users can set if they do not want web services to collect information about their online activity. We do not respond to DNT signals.

External Links

Our website contains links to other sites. We are not responsible for the privacy practices or the content of such websites. To help ensure the protection of your privacy, we recommend that you review the Privacy Policy of any site you visit via a link from our website.

Google Analytics

When someone visits our Websites, we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behavior patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. Based on GDPR guidelines, we do not make and do not allow Google to make any attempt to find out the identities of those visiting our website. Learn more about Google’s privacy policy here.

Passwords

The personal data record created through your registration with our website can only be accessed with the unique password associated with that record. To protect the integrity of the information contained in this record, you should not disclose or otherwise reveal your password to third parties.

Children Under the Age of 16

We do not knowingly sell or share the personal information of consumers under 16 years of age.

How We Protect the Information that We Collect

The protection of the information that we collect about visitors to this website is of the utmost importance to us and we take every reasonable measure to ensure that protection, including:

• We use internal encryption on all data stores that house voluntarily captured data.
• We use commercially reasonable tools and techniques to protect against unauthorized access to our systems.
• We restrict access to private information to those who need such access in the course of their duties for us.

The California Privacy Rights Act (“CPRA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of information about them, as well as rights to know/access, delete, and limit sharing of personal information. You have the right to be free from discrimination based on your exercise of your CPRA rights. If you are a California resident and receive our Services solely as a private individual – in other words, not as a member or representative of a company or other organization – you are entitled to the privacy rights listed below.

• Right to Know. You have the right to request to know
  • the specific pieces of personal information we have about you;
  • the categories of personal information we have collected about you;
  • the categories of sources from which that personal information was collected;
  • the categories of your personal information that we sold or shared, or disclosed to a third party for a business purpose;
  • the categories of third parties to whom your personal information was sold or shared (and the category(ies) of personal information sold or shared with each category of third parties), or disclosed for a business purpose; and
  • the business or commercial purpose for collecting, selling or sharing your personal information.
• Right to Opt-out of Sale or Sharing of Personal Information. We do not sell or share your personal information. Please note that your right to opt out does not apply to our sharing of personal information with Service Providers, as described in this Notice.
• Right to Deletion. You have the right to request that we delete the personal information we have collected or maintained about you. We may deny your request under certain circumstances, such as if we need that personal information to comply with our legal obligations or complete a transaction for which your personal information was collected. If we deny your request for deletion, we will let you know the reason why.
• Right to No Retaliation. If you choose to exercise any of these rights, ACI Jet will not discriminate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features of ACI Jet’s websites or services.
• Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right, at any time, to direct us to limit the use of your sensitive personal information to what is necessary to perform the services reasonably expected by an average consumer, internal purposes, including to ensure the security and integrity of personal information, and as authorized by regulations.
• Right to Correction. You have the right to request that we correct inaccurate personal information that we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.

To exercise your rights, please complete the form found here or contact us at dataprivacy@acijet.com or (844) 600-9715. Prior to processing your request, we will attempt to verify your identity, taking into account the sensitivity of the personal information involved and the nature of the request. We may do this by requesting additional information from you. We will inform you if we are unable to verify your identity, in which case we will not be able to complete your request.

If You Have an Authorized Agent:

If you are a California resident, you can authorize someone else as an authorized agent who can submit a request on your behalf. To do so, you must either (a) execute a valid, verifiable, and notarized power of attorney or (b) provide other written, signed authorization that we can then verify. When we receive a request submitted on your behalf by an authorized agent who does not have a power of attorney, that person will be asked to provide written proof that they have your permission to act on your behalf, and we will also contact you and ask you for information to verify your own identity directly with us and not through your authorized agent. We may deny a request from an authorized agent if the agent does not provide your signed permission demonstrating that they have been authorized by you to act on your behalf.

Changes to Our Privacy Policy

As our services evolve and we perceive the need or desirability of using information collected in other ways, we may from time to time amend this Privacy Policy. We encourage you to check our website frequently to see the current Privacy Policy in effect and any changes that may have been made to them. If we make material changes to this Privacy Policy, we will post the revised Privacy Policy and the revised effective date on this website. Please check back here periodically or contact us at the address listed at the end of this Privacy Policy.

Consumers With Disabilities

This policy is in a form that is accessible to consumers with disabilities.

Questions About the Policy

This website is owned and operated by ACI Jet. If you have any questions about this Privacy Policy, please contact us at dataprivacy@acijet.com or call (844) 600-9715.

**This policy was last updated June 7, 2024.