1. INTRODUCTION

Aviair LLC, a company registered in Lewes DE, with its Registered Office at 16192 Coastal Highway, Lewes, Delaware, 19958, County of Sussex (“Aviair”, “we”, “us”, “our”), is committed to protecting the privacy of individuals and to complying with applicable personal data protection laws and regulations. Aviair may be contacted by telephone at: +12312598960 or via email at: dataprotection@aviair.info.

We want you to feel comfortable about how we collect, process, secure and share your personal data. This Privacy Policy details the types of personal data we collect, how we use your personal data, who we share it with and how you can control its use. The Data Subject is under no legal obligation to provide Aviair  Personal Data; however, should the Data Subject choose not to do so, Aviair may be unable to provide the Data Subject with its service.

This Privacy Policy applies to the main Personal Data processing activities Aviair performs, in relation to the Data Subjects which are users of the www.aviairllc.com website (the “Website“)including, inter alia, customers or potential customers, business partners, collaborators, employees or potential employees, business partners and any other user that may use the Website or the Services portrayed on the Website and as defined below. It should be noted that this Privacy Policy will not derogate from any other privacy policy and/or privacy notice which may apply in relation to Aviair regarding any Data Subject’s Personal Data, including, inter alia, the Cookie Policy, employee’s privacy policy and/or job candidates privacy policy and any additional policy if such policies apply.

Aviair processing of Personal Data will be in accordance with the applicable law, inter alia, the Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”), if applicable; and/ or Israel’s Protection of Privacy Law, 5741-1981, and the regulations under it, including but not limited to the Protection of Privacy (Data Security) Regulations, 5717-2017 and any guidance issued by Israel’s Privacy Protection Authority (“Israel’s Data Protection Laws“), if applicable, and/ or any other relevant regulation.

In the event of a conflict between the applicable law and the provisions specified in this Privacy Policy, the applicable law will prevail. Even if stated otherwise in this Privacy Policy – (1) Aviair will act and/or grant rights to the Data Subjects, regarding the collection, processing, securing and/or sharing of the Personal Data, in accordance with the applicable law, and/or if such actions and/or rights are required by the applicable law; (2) Aviair will not be obliged to any commitments regarding the collection, processing, securing and/or sharing of the Personal Data, other than those in which it is obligated in accordance with the applicable law.

In the following sections, you will find relevant information on how we process your personal data.

2. DEFINITIONS

• Personal Data means any information relating to an identified or identifiable natural person;
• Data Subject means a user of the Website (including, inter alia, a customer or a potential customer, business partners, contractors, suppliers, agents, service providers,collaborators, an employee or a potential employee and anyone on behalf of the abovementioned who is an identifiable natural person, and/or one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
• Usage Data represents data collected automatically either generated by the use of the Website or from the Website infrastructure itself (for example, the duration of a page visit);
• Data Controller: Data Controller means the natural or legal person who (either alone or jointly with others) determines the purposes and means of the processing of personal data. For the purpose of this Privacy Policy, Aviair is the Data Controller of your Personal Data.
• Services means all the products, content, and offerings made available through the Website, including but not limited to [Aircraft Parts Management; Flight Data Monitoring; Maintenance Services; Bell Helicopter Vibration Monitoring; Airmen Services and any other additional functionalities or services introduced on any platform on behalf of Aviair].

3. WHAT PERSONAL DATA DO WE USE?

Depending on the nature of your relationship with Aviair, we collect, use and process the following categories of Personal Data:

Identification data such as name, sure name, contact information (e-mail address, telephone number), , postal address, ID number;

Economic and financial data such as banking details and credit related information, payment history, purchase history;

Services Data – such as information relating to Aviair’s aircraft parts management services, flight data monitoring services, maintenance management services, training services, safety services and airman assignment services. Service Data shall include all information resulting from the above services such as: acquisition history, flights information and history, , aircraft  and part usage, trainee recordes and/ or staffing information and location information (in connection with your requested service).

Usage Data that may include information such as your computer’s Internet Protocol address, browser type, browser version, the time and date of your visit on our Website, the time spent on the Website, unique device identifiers and other diagnostic data;

Cookies – Please see our separate dedicated section about cookies (Section 11).

We may collect the abovementioned Personal Data:

• directly from you, when you provide us such information; and/or
• indirectly through the organisation you are working for or anyone on such organisations behalf if needed for a purpose listed below or information made publicly available; and/ or through third parties to whom you provided such information for the purpose of delivering it to us (such as employment agencies and/ or third party employment websites); and /or through third party vendors who may offer Aviair’s Services on its behalf and/ or a licenced credit reference agencies and/or our related companies and/ or through the use of our Services.

4. WHAT ARE THE PURPOSES OF THE COLLECTION AND/OR OF THE PROCESSING OF YOUR PERSONAL DATA?

Aviair may process your Personal Data for the following purposes:

• Website /Administration

We may use your Personal Data for administrative purposes, including to manage and administer the products and the Services we provide to businesses, contractors, suppliers, partners, and other parties; to help us better understand how Data Subjects access and use our Websites and Services; to provide reports to business partners or potential business partners, service providers, regulators, and others; to implement and maintain security, anti-piracy, fraud prevention, and other Services designed to protect our customers, business partners and us and to enforce our policies, directives and processes.

• Marketing and Events

Under the conditions permitted by law and when relevant, your personal information may also be used or disclosed in the course of us advising you, or the business that you represent, of products and Services that may be of interest to you or that business or in inviting you or others to attend events organised by us. We may also use your Personal Data for conducting market research and/ or for prospecting and marketing purposes, including communications through e-mail or equivalent electronic means. For example, we may use your Personal Data, such as your e-mail address or telephone number, to send news and newsletters regarding our products or to otherwise contact you about Services or information we think will interest you, subject to the law and to receiving your specific consent to receive such mailings (if such consent is required by law).

• Communication

We may use your Personal Data to communicate with you, including for the purposes of direct mail, as defined under the Israeli Protection of Privacy Law, 5741-1981,  commercial electronic messages to assist us with delivering our Services to you, commercial electronic messages to assist us to undertake market research and deliver product updates, and commercial electronic messages that we believe may be of interest to you, responding to requests for assistance and/or regarding our Services and/ or job applications made by you or regarding to other job positions you may be interested in, at Aviair, subject to your consent if needed according to applicable law. We can communicate with you in a variety of ways, including e-mail, telephone and/or text messages, and subject to law.

• Performance of Aviair business activities and Customer services

We may use your Personal Data for Aviair sales and customer services activities, including customer relationship management, for technical support or other similar purposes and to establish and maintain customer accounts.

We may process your Personal Data in the course of Aviair procurement activities such as new products or Services contracts and supplier management.

• Research and development

We may use your Personal Data for research and development purposes, including improving our Website, products, Services, customer experience and for other research and analytical purposes dedicated to improving our products, Services, businesses, operations and processes.

• To comply with legal obligations

We may use your Personal Data to comply with applicable legal obligations, including responding to an authority or court order or discovery requests.

• To protect us and others

Where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of policies, terms, and other policies.

We will use your Personal Data for the above purposes only, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose (for preserving particular evidence or in the context of legal statutes of limitation for example). If we need to use your Personal Data for an unrelated purpose, we will notify you prior to this further Personal Data processing and provide you with the relevant privacy information notice.

5. WHAT IS THE LEGAL BASIS FOR THE PROCESSING OF YOUR PERSONAL DATA?

Subject to the applicable law, we process your Personal Data under the following legal basis:

• To comply with contractual obligations. Following a contractual agreement between us, to provide you with our products or Services, processing of Personal Data is necessary in order to fulfil our commitments in accordance with the contractual agreement;
• As a result of your consent. For example, if you have agreed to receive marketing communications.
• Within the scope of a legitimate interest. On occasion, taking into account the minimum privacy impact for you, the processing of your Personal Data might be necessary:
• For the administration, management and performance of our business relationship, if any, including performance of our Services;
• For the analysis and optimisation of our Website or Services;
• For ensuring IT security (to detect security threats, frauds or other malicious or criminal activities) and the IT operation of Aviair;
• For prevention and investigation of criminal acts;
• For communication purposes to keep you up-to-date on the latest information about our Services and/or business activities, events, marketing campaigns, market analysis or other promotional activities and for analysis and improving the quality of our products and Services and communications with you (subject to the law and to receiving your specific consent to receive such information, if such consent is required by law);
• For monitoring the compliance with our policies and standards;
• On the basis of Aviair legal obligations or in the public interest. Aviair, as any other company, is subject to legal obligations and regulations. In some cases, the processing of your Personal Data will be necessary for Aviair in order to fulfil these legal obligations.

6. WHO WILL RECEIVE YOUR PERSONAL DATA?

Subject to the applicable law, we may disclose your Personal Data to the following recipient(s), on a need-to-know basis:

• Authorised persons working for or on behalf of Aviair, including our agents, service providers and advisers providing the variety of products and services we need (including IT, procurement, communication, compliance, security services, marketing service providers, payment processors), and for the purpose of providing such products and/or services to Aviair or to you;
• From time to time, we share personal information with our related bodies corporates (such as: parent, daughter, or sister companies).
• Aviair business partners in connection with Aviairs activities, law firms, auditors, consultants, insurance companies), and for the purpose of performing Aviair relevant activities (for example, recruitment, legal advice and/ or auditing);
• Other authorised third parties in connection with any merger, reorganisation, sale of Aviair or its assets, or a financing or acquisition of our business by another company, and for the purpose of such merger, reorganisation, sale and/or acquisition, and/or for examining the feasibility of such action;
• Courts, law enforcement, regulatory or other government ministries, agencies and authorities, or to other third parties, and for the purpose of complying with legal, regulatory, professional regulations or national security obligations or requests.
• Any and all entities within the Aviair Group, including, but not limited to, subsidiaries of Aviair.

7. TRANSFER OF PERSONAL DATA

Personal Data may be transferred to third countries or to international organizations, in accordance with the applicable law. To the extent that, in the context of the processing activities described above, your Personal Data may be transferred abroad, to states located in the EEA or outside the EEA (where the level of data protection may be lower than that required by Israeli law), any transfer performed by Aviair will observe the relevant legal requirements. In such circumstances, we shall take appropriate safeguards to ensure the protection of your Personal Data and to provide that enforceable Data Subject rights and effective legal remedies for Data Subjects are available, if such safeguards are required by the applicable law.

8. DATA RETENTION

We will retain your Personal Data for only as long as it is necessary for the uses set out in this Privacy Policy and/or to meet legal and regulatory requirements, and/or for as long as permitted by the applicable law. After this period, we will securely erase Personal Data. If data is needed after this period for analytical or other legitimate business purposes, we will take appropriate measures to anonymise this data.

For marketing activities, we will process your Personal Data until you unsubscribe. We may be contacted for this purpose at: marketing@aviair.info.     

9. YOUR DATA PROTECTION RIGHTS UNDER GDPR

You may have certain rights with respect to your Personal Data under the GDPR, if applicable, as detailed below, and in accordance with the current applicable law:

• Right of Access: You may be able to ask for confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, access to the Personal Data.
• Right to Rectification: You may have the right to obtain from us the rectification of inaccurate Personal Data concerning you.
• Right to Erasure: Under certain circumstances, you may have the right to obtain from us the erasure of Personal Data concerning you.
• Right to Restriction of Processing: Under certain circumstances, you may be able to ask us to restrict the processing of your Personal Data.
• Right to Data Portability: Under certain circumstances, you may have the right to receive Personal Data concerning you in a structured, commonly used and machine-readable format and may have the right to transmit those data to another controller.
• Right to Object: Under certain circumstances, you may have the right to object to the processing of Personal Data concerning you.
• Right to lodge a complaint with your local supervisory authority: You may have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your Personal Data.

You may exercise the aforementioned rights, if applicable, by submitting a request to Aviair using at the following e-mail address: dataprotection@aviair.info.

In case of doubt of your identity, we may ask you to justify it by enclosing a copy of any identity document, subject to the applicable law.

10. SECURITY

In accordance with the applicable law, we may implement appropriate technical and organizational measures to ensure an appropriate level of security to Personal Data, taking into account the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored, or otherwise processed.  We do not guarantee however, that it will not be subject to a security event. We may be required, due to legal or other obligations outside our control, to transfer the Personal Data about you to third parties, such as public authorities. In such circumstances, we have limited control over the level of protection provided to the Personal Data by such third parties. Any transfer of Personal Data via the internet cannot be fully secured.

11. COOKIES

As mentioned above, we may collect Usage Data and Personal Data via Cookies. In general, Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. For information about our collection of Usage Data and Personal Data via Cookies and similar tracking technologies, and the choices you have regarding our use of Cookies and related information collection, please see our Cookie Statement, in the following link: https://www.aviairllc.com/privacy-policy/.

12. PERSONAL DATA OF THIRD PARTIES

If you provide Aviair with Personal Data of third parties, you warrant and represent that you will provide such Personal Data in accordance with the applicable law, inter alia, provide all appropriate notices required under the applicable law, if required; And/or obtain all required informed consents and/or establish any and all ongoing legal bases, if required by applicable law, for allowing Aviair and/or its affiliates, third-party vendors and other entities to use and process Personal Data in accordance with this Privacy Policy, for the purposes detailed in this Privacy Policy.

13. LINK AND HYPERLINKS

The Website may offer links, hyperlinks or banners to other websites that Aviair does not monitor or check their reliability and legality, and everything related to their security and privacy protection policy.

The Company shall not be responsible for the use made by you of the links appearing on the Website, on pages that are not located on the Website or that are displayed through other websites, and you undertake to comply with the provisions and conditions of those websites or web pages and to contact the providers of such websites or pages directly in connection with any issues that may arise in connection with privacy, access, browsing use, etc.

Therefore, the Company will not bear any responsibility, of any kind, in connection with the other websites, including in relation to the collection, use, transfer of information on the other websites, the content that will be published on the pages of the other websites, and more.

14. CHANGES TO THE PRIVACY POLICY

We may modify or amend this Privacy Policy from time to time at our discretion. When we make changes to this Privacy Policy, we will amend the revision date at the bottom of this page and such modified or amended Privacy Policy shall be effective as to you and your information as of that revision date.

We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

Last updated: June 2025