NJASAP

NJASAP SMARTPHONE APP

REV 08.29.23

The NetJets Association of Shared Aircraft Pilots (“NJASAP,” “Union,” “Association”) Privacy Policy describes how and why the Union might collect, store, use, and/or share (“process”) member information when using its services, such as when a member downloads and uses the NJASAP Smartphone Application (“App,” “resource”) or any other online resource that links to this Privacy Policy.

Questions or concerns? Reading this Privacy Policy will help members understand their privacy rights and choices. Please direct related questions and/or concerns to the NJASAP Legal Team via email, legal@njasap.com.

SUMMARY OF KEY POINTS

This summary provides key points from the NJASAP Privacy Policy. Additional details about any of these topics are provided in the full policy.

What personal information does NJASAP process? When members visit, use, or navigate the services, NJASAP may process personal information depending on how a member interacts with the resource and uses related features.

Does NJASAP process sensitive personal information? The App does not process or request sensitive personal information.

Does NJASAP receive any information from third parties? NJASAP receives information from NetJets Aviation, Inc., (“NetJets,” “employer), including, but not limited to, address information, wage information, job and/or leave status information.

How does NJASAP process member information? NJASAP processes member information to provide, improve, and administer its services, to communicate with members, to engage in fraud prevention, and to comply with applicable state and federal laws. The Union may also process member information for other purposes with member consent. NJASAP processes member information only when it has a valid legal reason to do so.

In what situations and with which parties does NJASAP share personal information? NJASAP may share information in specific situations and with specific third parties who have signed non-disclosure agreements with the Union.

How does NJASAP keep member information safe? NJASAP has organizational and technical processes and procedures in place to protect member personal information. However, no electronic transmission across the internet or information storage technology can be guaranteed to be 100% secure, making it impossible to promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat the Union’s advanced security protocols and to improperly collect, access, steal, or modify member information.

What are a member’s rights? Depending on a member’s country and state of residence, applicable privacy laws may afford certain rights regarding a member’s personal information.

How does a member exercise their rights? A member can request more information about this process by visiting https://www.njasap.com/contact, or by sending an email to legal@njasap.com.

For additional insight into the treatment of the information we collect, please review the NJASAP Smartphone App Privacy Policy in full.

NJASAP SMARTPHONE APP

TABLE OF CONTENTS

What information does NJASAP collect?

How does NJASAP process member information?

On what legal basis does NJASAP rely to process member information?

When and with whom does NJASAP share personal information?

How long does NJASAP retain information?

How does NJASAP keep information safe?

What are a member’s privacy rights?

What controls does NJASAP use to support “do-not-track” features?

Do California residents have specific privacy rights?

On what cadence does the Union update the NJASAP Smartphone App Privacy Policy?

Who should NJASAP members contact with questions about the policy?

How can a member review and manage their profile data on file with NJASAP?

1) What information does NJASAP collect?

In Short: NJASAP collects personal information provided by members.

NJASAP collects personal information that its members voluntarily provide when they register to use the App, express an interest in obtaining information about the App, interact with the resources provided in the App and/or otherwise engage with the App.

Personal Information Members Provide. NJASAP collects the personal information necessary to facilitate access to the App, which NJASAP provides to the Membership in furtherance of its obligations as the National Mediation Board-recognized bargaining agent of the professional flight deck crewmembers employed by NetJets. Such information includes, but is not limited to, a member’s name, mobile phone number(s), email address(s), mailing address(s), username, password and contact preferences.

Sensitive Information. The App does not store personal information.

Application Data. When using the App, the Union may also collect the following information if a member opts to provide the requested access or permission:

Mobile Device Data. NJASAP automatically collects device information (e.g., mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). NJASAP may also collect information about the phone network associated with a member’s mobile device, its operating system or platform, the type of mobile device used, the mobile device’s unique device ID, and information about the features a member accessed.

Push Notifications. NJASAP members may choose to receive push notifications by toggling that setting in the App.

Information automatically collected.

In Short: Some information — such as a member’s Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when they use the App.

NJASAP may automatically collect certain information when a member visits, uses, or navigates the App. This information may include device and usage information, including a member’s IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when a member uses the App, and other technical information. This information is primarily needed to maintain the security and operation of the App as well as for internal analytics and reporting purposes.

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information NJASAP servers automatically collect when a member accesses or uses the App, which is recorded in log files. Depending on how a member interact with the App, the log data may include the member’s IP address, device information, browser type, and settings and information about their activity in the Services (such as the date/time stamps associated with usage, pages and files viewed, searches, and other actions inside the App), device event information (such as system activity, error reports (sometimes called “crash dumps”) and hardware settings).

2) How does NJASAP process member information?

In Short: NJASAP processes member information to provide, improve, and administer the App, to communicate with members, to reaffirm security and fraud prevention protocols and to comply with applicable state and federal law. NJASAP may also process a member’s information for other purposes with their consent.

NJASAP processes member personal information for various reasons, depending on how they interact with the App, including:

To facilitate account creation and authentication and otherwise manage user accounts. NJASAP will process member information in support of the single-sign-on protocol that facilitates access to the App and allows members to manage their account.

To deliver and facilitate delivery of services to the user. NJASAP will process information in a way that ensures timely, relevant information is provided to the Membership via App.

To respond to user inquiries/offer support to users. NJASAP may process member information in response to inquiries and to solve any potential issue(s) a member might experience with the App.

To request feedback. NJASAP may process information when necessary to facilitate communication between the member and Union via App.

To evaluate and improve App-based resources and user experience. NJASAP may process member information to assess App usability and effectiveness.

To identify usage trends. NJASAP may process information about how members use the App to understand how to enhance it in a way that increases its utility.

To comply with legal obligations. NJASAP may process member information to comply with its legal obligations, to respond to contract compliance and legal inquiries, and to exercise, establish, and defend a member’s legal rights.

3) On what legal basis does NJASAP rely to process member information?

In Short: NJASAP only processes a member’s personal information when it believes it is necessary and has a valid legal reason (e.g., to comply with state and/or federal law(s), to provide representational services, to protect member rights, and/or to fulfill a legitimate administrative interest) to do so under applicable law with member consent.

In some exceptional cases, NJASAP may be legally permitted under applicable law to process information without a member’s consent, including, for example:

if collection is clearly in the interests of an individual and consent cannot be obtained in a timely way;

for investigations and fraud detection and prevention;

if disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records;

if it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced;

if the information is publicly available and is specified by the regulations.

4) When and with whom does NJASAP share personal information?

In Short: NJASAP may share information in specific situations described in this section and/or with the following third parties.

In the context of management App access, NJASAP may need to share personal information in the event of a change in the NMB-recognized bargaining agent for the pilots employed by NetJets Aviation, Inc.

5) How long does NJASAP retain information?

In Short: NJASAP retains information for as long as necessary to fulfill the purposes outlined in this policy unless otherwise required by law.

NJASAP’s member information retention responsibilities are set forth by the U.S. Department of Labor.

6) How does NJASAP keep information safe?

In Short: NJASAP works to protect member personal information through a system of organizational and technical security measures.

NJASAP has implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information it processes. However, despite safeguards and efforts to secure information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. To that end, NJASAP cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat its security and improperly collect, access, steal, or modify member information. Although the Union does its best to protect its members’ personal information, transmission of personal information to and from the App is at a member’s own risk. Members should only access the App within a secure environment.

7) What are a member’s privacy rights?

In Short: In some regions, such as Canada, members have rights that afford greater access to and control over their personal information. Members may review, change or delete their account with NJASAP at any time.

In some regions, members have certain rights under applicable data protection laws. These may include the right to request and to obtain a copy of personal information and to request rectification.

Account Information

A member may review and/or update the information stored in their profile as detailed below:

Log in to the NJASAP Online Community (NOC) , www.njasap.com, click Connect in the upper right-hand side of the screen and choose Manage Profile from the dropdown list. Make any changes necessary and click Save in the bottom right-hand corner of the screen.

For as long as a NetJets pilot is a member of NJASAP, he or she will maintain access to the Union’s full complement of digital resources, including the App. A member’s access to the App is based on their job status with NetJets. NJASAP retains information in its App database to prevent fraud, to troubleshoot problems, to assist with any investigations, to enforce legal terms and/or to comply with applicable legal requirements.

Questions or comments about privacy rights should be emailed to legal@njasap.com.

8) What controls does NJASAP use to support Do-Not-Track features?

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting that users can activate to signal their privacy preference not to have data about their online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, NJASAP does not currently respond to DNT browser signals or any other mechanism that automatically communicates the choice not to be tracked online. If a standard for online tracking is adopted that NJASAP is obliged to follow in the future, the Union will inform the Membership and update this policy accordingly.

9) On what cadence does the Union update the NJASAP Smartphone App Privacy Policy?

In Short: NJASAP will update the policy as necessary to maintain compliance with relevant laws.

NJASAP will update this policy from time to time. The updated version will be indicated by an updated revised date, and the updated version will be effective as soon as it is accessible. If NJASAP makes material changes to the policy, it will notify the Membership via email. NJASAP encourages its member to review the policy to understand how the Union protects their information.

Who should NJASAP members contact with questions about the policy?

Questions or comments about the policy may be emailed to legal@njasap.com or sent us via U.S. Postal Service to NJASAP, 2740 Airport Dr., Ste. 330, Columbus, OH 43219.

How can a member review and manage their profile data on file with NJASAP?

Members may review and manage their data in one of three ways:

Login to the NOC to confirm the information reflected in their profile stored in Connect is accurate [Connect > Manage Profile]; see Section 7a for more information.

Send an email to contact@njasap.com to request assistance.