Web-site Privacy Statement:

This is the privacy statement (the “Privacy Statement”) that governs how SOAR LP (“SOAR”) collects, uses, discloses, and otherwise processes Personal Data (defined below) in connection with www.soar.aero (the “Site”) and any other website that links to this Privacy Statement.

SOAR is a professional, business to business, aviation services company that does not provide on-line services or sales to the general public. SOAR does not collect Personal Data as a function of the data it does collect.

➠Please review the SOAR Data Processing Addendum to its Terms of Service, for more information on SOAR’s role as a processor.

As used herein, the terms “you” or “your” shall apply to individual users of the Site. If you have any questions or comments regarding this Privacy Statement, please contact us at

Webmaster@soar.aero.

1. What is Personal Data?

As used in this Privacy Statement, “Personal Data” means any information relating to an identified or identifiable natural person. An identifiable natural person is 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. When SOAR combines other information (i.e., information that does not, on its own, identify you) with your Personal Data, SOAR treats the combined information as Personal Data.
Specifically excluded from “Personal Data” are companies, business entities, and virtual entities.

2. When Personal Data is Collected.

SOAR’s Site may collect the following types of information:

➠Website Comments. If you choose to post comments on the SOAR web-site, SOAR requires you to provide your name and your email address (SOAR does not publish your email address). By posting a comment, you consent to SOAR’s publication and storage of your blog comment. You may withdraw your consent by submitting a request to remove the post to Webmaster@soar.aero. Please be aware that whenever you voluntarily disclose Personal Data online, the information you post becomes public and can be collected and used by others and indexed in search engines (even if SOAR subsequently removes the post).

• IP Address and Header Information. SOAR automatically collects certain information when you visit our Site, such as IP address and Header Information. “Header Information” is information such as browser type, geolocation, operating system, language, screen resolution, referring URL, etc. provided to our web server by your browser. SOAR has a legitimate interest in using such information to assist in log-in, systems administration purposes, information security and abuse prevention, and to track user trends.

• Traffic Data. SOAR generates certain anonymous information about visitors’ use of the Site such as pages visited, the visitor’s mouse movements and clicks, keystroke data, HTML data on a page visited by a visitor if such HTML data includes Personal Data (collectively, “Traffic Data”). SOAR uses Traffic Data to further our legitimate business interests in analyzing the effectiveness of the Site and to improve the look, function and content of the Site. SOAR only collects keystroke data when you provide your consent to such collection. You can also ➠opt-out of our processing of your Traffic Data by clicking the “Do not track me“ button near the top of this page.

➠F. Contact Information. As a visitor to the Site, SOAR may collect your name, email, and free form text entry if you choose to contact us through our “Contact Us” page. SOAR processes this Personal Data to address your comments or questions and SOAR may send you commercial or transactional emails as a result. You can opt-out of commercial emails any time by following the process set forth in Section 6.

3. How SOAR Uses Cookies and Similar Technology

To help operate the Site, enhance your experience, and collect information about online activity,
SOAR places small data files on your device known as “cookies,” or other similar technologies (e.g., pixel tags, web beacons, local shared objects). These technologies may allow SOAR and its Customers to store and manage your preferences and settings; measure and analyze how you use the Site and effectiveness of SOAR communications; and help SOAR improve its products, services, and security.

The table below explains the types of cookies SOAR uses on its websites and why they are used. Also provided are examples of the cookies set by SOAR, with explanations of their purpose. Please note that this is not an exhaustive list, but rather aims to be a representative summary.

Cookie
Description

Essential and Strictly Necessary

These cookies are essential for the website and services to perform their basic functions. These include those required to allow registered users to authenticate and perform account-related functions.

Functionality

These cookies are used to store preferences set by users such as account name, language, and location.

Security

SOAR use these cookies to help identify and prevent potential security risks.

Analytics and Performance

Performance cookies collect information on how visitors interact with SOAR websites, including what pages are visited most, as well as other analytical data. SOAR uses these details to improve how the websites function and to understand how visitors interact with them.

Advertising

These cookies are used to display relevant advertising to users who use our services or visitors that visit websites SOAR provides, as well as to understand and report on the efficacy of ads served on SOAR websites. They track details such as the number of unique visitors, the number of times particular ads have been displayed, and the number of clicks the ads have received. They are also used to build visitor profiles, including showing you ads based on products you’ve viewed or acts you have taken on SOAR (and other) websites. These are set by SOAR and trusted third-party networks and are generally persistent in nature.

Third Party / Embedded Content

These cookies may be set by third parties (such as social media sites), and used by them to track your online activity. SOAR has no direct control over the information that is collected by these cookies.

You may wish to restrict the use of cookies or completely prevent them from being set. If you disable cookies though, please be aware that some of the features of the SOAR Site may not function correctly. Most modern browsers allow you to change your cookie settings. You can usually find these settings in the options or preferences menu of your browser.

To find out more on how to manage and delete cookies, visit https://aboutcookies.org/. For more details on your choices regarding use of your web browsing activity for interest-based advertising you may visit the following sites:

networkadvertising.org
optout.aboutads.info
youradchoices.com
youronlinechoices.eu

On a mobile device, you may also be to adjust your settings to limit ad tracking.

➠You may see a “banner” on our websites that asks for your consent to place cookies or to use other technologies that collect Personal Data. If you consent to the use of cookies or other technologies, SOAR and its advertising partners may set cookies on the site you are visiting and on other of our websites, dashboards, and services. SOAR will display the banner to you periodically just in case you change your mind.

SOAR uses Google Analytics and Lucky Orange, both of which are analytics services, to help analyze the traffic on the Site. For more information on Google Analytics’ processing of Personal Data, please see “How Google uses data when you use SOAR partners sites or apps.” You can opt out of Google Analytics by installing Google’s opt-out browser add-on. The Lucky Orange Privacy Statement may be found here: https://www.luckyorange.com/legal/privacy

4. The Purposes and Use of Personal Data
If you submit or SOAR collects Personal Data through the Site, then such Personal Data may be used to:
• Provide, analyze, administer, improve, and personalize the Site;
• Identify and authenticate your access to the parts of the Site that you are authorized to access;
• For recruiting and human resources administration purposes; and
• Protect SOAR rights and/or property and to ensure the technical functionality and security of the Site.

5. To Whom Personal Data Is Disclosed
SOAR will not disclose Personal Data except as set forth in this Privacy Statement or with your consent and SOAR does not sell, lease, or exchange your Personal Data. This Section 5 describes to whom SOAR discloses Personal Data, and for what purposes:

• Our Service Providers. SOAR employs service providers to perform tasks on its behalf and to assist in providing the Site. For example, SOAR may share your Personal Data with service providers who assist in the performance of core Site functions (such as hosting, data storage, and security) related to the operation of the Site and/or by making certain interactive tools available to you. SOAR also uses third parties for technical and customer support, application development, tracking and reporting functions, quality assurance, and other services. SOAR uses commercially reasonable efforts to only engage with third parties that post a publicly available privacy notice.

• Advertising. SOAR engages advertising services to assist in advertising its Site. From time to time, those services target advertisements on third-party websites based on cookies or other information indicating previous interaction with the Site.

• Companies Involved in Mergers and Acquisition Transactions or Change of Control. In some cases, SOAR may choose to buy or sell assets. In these types of transactions, user data (including Personal Data) is typically one of the business assets transferred. If SOAR were to sell all or substantially all of its assets or is otherwise acquired under a change of control event, Personal Data would be one of the assets that is reviewed and transferred or acquired by a third party. SOAR may transfer or assign this Privacy Statement and any Personal Data to a third party entity in the event of some other change of control (such as the result of a bankruptcy proceeding).

• Law Enforcement, Government Agencies, and Courts. SOAR may disclose Personal Data at the request of law enforcement or government agencies or in response to subpoenas, court orders, or other legal process to establish, protect, or exercise our legal or other rights or to defend against a legal claim or as otherwise required or allowed by law, or to protect the rights, property, or safety of
any other person. SOAR may also disclose Personal Data to investigate or prevent a violation by you of any contractual or other relationship with SOAR (such as a violation of the Terms of Service) or your illegal or harmful activity.

6. How You Can Opt-Out
➠ (we would prefer to use a button/slider switch instead of requiring an email) You may choose not to receive future promotional or advertising emails from SOAR by selecting an unsubscribe link at the bottom of any email that you receive from SOAR. Additionally, you may send a request specifying your communications preferences to Webmaster@soar.aero Please note that even if you opt out of receiving the foregoing emails, SOAR may still send you a response to any “Contact” request as well as administrative, maintenance and operational emails (for example, in connection with a password reset request).

At the top of this page and in the link provided here, SOAR provides access to a data privacy management tool that allows you to opt out of being tracked by the SOAR’s technologies.

7. Personal Data from Children
SOAR does not knowingly collect the Personal Data of children under the age of sixteen (16). If SOAR learns that it has collected Personal Data from children, and there is no lawful basis or parental consent to process such Personal Data, SOAR will use commercially reasonable efforts to delete all such Personal Data.

8. Retention of Personal Data
SOAR will retain your Personal Data for the period necessary to fulfill the purposes for which your Personal Data has been collected as outlined in this Privacy Statement, unless a longer retention period is required by law. Where feasible, SOAR disposes of data, including Personal Data, on a regular schedule.

9. How We Protect the Confidentiality and Integrity of Your Personal Data
SOAR has implemented security measures to protect Personal Data from loss, misuse, and alteration. SOAR uses industry- standard practices such as encrypted storage, firewalls, and password protection systems to safeguard the confidentiality of Personal Data. SOAR takes steps to help ensure its employees and contractors are aware of their information security obligations, and further restricts employee and contractor access to Personal Data. Despite efforts to store Personal Data in a secure operating environment that is not available to the public, SOAR does not and cannot guarantee the security of Personal Data during its transmission or storage on our systems. Further, while SOAR attempts to ensure the integrity and security of Personal Data, it does not and cannot guarantee that the security measures will prevent third parties such as hackers from illegally obtaining access to Personal Data. SOAR does not represent or warrant that Personal Data about you will be protected against, loss, misuse, or alteration by third parties.

10. Links to Third Party Websites
The Site may contain links to third party websites. Please be aware that SOAR is not responsible for the privacy practices of third party websites you choose to visit. If you provide any information directly to parties other than SOAR, different rules may apply to the use or disclosure of that information. SOAR encourages you to investigate and ask questions before disclosing your Personal Data to third parties.

11. Your California Privacy Rights.
This Section 11 applies to our collection and use of Personal Information if you are a resident of California, as required by the California Consumer Privacy Act of 2018 and its implementing regulations, as amended by the California Privacy Rights Act (the “CPRA”). This Section 11 describes (1) the categories of Personal Information, collected and disclosed by us, subject to CPRA, (2) your privacy rights under CPRA, and (3) how to exercise your rights. When we use the term “Personal Information” in the context of the CPRA, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household.

We will retain your Personal Information for as long as we need it to provide you with our products and services. Because the length of your use of our services are not foreseeable, we cannot provide you with an exact timeframe for how long we retain your information. Our legal obligations may also require us to maintain your Personal Information for longer periods of time if your Personal Information becomes subject to such legal obligations.

B. Your California Privacy Rights
For a description of these rights, see Section 11(B) above. In addition, you have the right to opt out of targeted advertising and profiling, to the extent that profiling makes decisions that produce legal or similarly significant effects concerning you. To exercise any of these rights available to you, see Section 13 below.

12. Exercising Your Individual Privacy Rights
To exercise any of the privacy rights afforded to you under applicable data protection law, please submit a request to us by one of the following methods:
• E-mailing us at Webmaster@soar.aero
• Selecting the “Opt Out” buttons offered on the site

Verification: We must verify your identity before fulfilling your requests. If we cannot initially verify your identity, we may request additional information to complete the verification process. We will only use Personal Information provided in a request to verify the requestor’s identity. If you are an authorized agent making a request on behalf of a California consumer, we will also need to verify your identity, which may require proof of your written authorization or evidence of a power of attorney.

We endeavor to respond to requests within the time period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us.

We may deny certain requests, or only fulfill some in part, as permitted or required by law. For example, if you request to delete Personal Information, we may retain Personal Information that we need to retain for legal purposes

13. GDPR and UK GDPR Policy (for European Data Subjects only).
This Section 13 explains how SOAR collects and processes Personal Data about you if you are a data subject located in the European Economic Area (“EEA”) or the United Kingdom (“UK”) under the General Data Protection Regulation (“GDPR”) or the United Kingdom GDPR, as applicable. As used in this Section 13, a “data subject” is an identified or identifiable person, and “process” or “processing” means any operation or set of operations which is performed on Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

A. SOAR’s Basis for Processing.
The following sets out the lawful basis under the GDPR to which SOAR may your Personal Data, which may include a cross-border transfer:

Basis
Your Consent
To Perform a Contract
Comply with the Law
Legitimate Interests

Description
Where you have given SOAR consent to process your Personal Data for one or more specified purposes, such as to provide our Site and other services as requested by you.
Where the processing is necessary for the performance of contract to which you are a party and to which SOAR is acting as a processor or sub-processor.
Where the processing is necessary for compliance with a legal obligation to which SOAR is subject.
Where the processing is necessary for the purposes of the legitimate interests pursued by SOAR or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of Personal Data.

B. Data Subject Privacy Rights.
In certain circumstances, local data protection laws and certain local laws (including the GDPR) may give you rights with respect to Personal Data if you are located in the EEA. These rights differ by country/region, but may include access, amend, erase, export (i.e., data portability), or object to or restrict the processing of Personal Data collected via the Site. You may exercise these rights at any time by:
➠ E-mailing us at Webmaster@soar.aero
➠ Selecting the “Opt Out” buttons offered on the site

14. Changes to the Privacy Statement
SOAR may revise and update this Privacy Statement at any time and will post the updated Privacy Statement to the Site. If these changes are material (i.e., changes believed to be of importance to you), SOAR will post notice of material changes on the Site. Where required by applicable law, SOAR will obtain your consent. UNLESS OTHERWISE INDICATED, ANY CHANGES TO THIS PRIVACY STATEMENT SHALL BE EFFECTIVE IMMEDIATELY UPON POSTING TO THE SITE.

15. Contact
If there are any questions regarding this Privacy Statement you may contact SOAR using the information below:
➠ E-mail us at Webmaster@soar.aero

+1-949-764-9246 | soar.aero