Satcom Direct, Inc.®/Satcom Direct Communications, Inc.®’s and its affiliates (hereinafter collectively “SD”) Privacy Commitment to Our Customer
Effective: September 2018
Our Privacy Commitment
“Account Information” means Personal Information that we may collect during registration for a Service that we provide or the purchase of a product, including names, e-mail addresses, e-mail preferences, account passwords, mailing addresses, and billing addresses. In cases where service subscriptions relate to maritime or aero usage, we will also request information about the vessel or aircraft, including the name, call sign, country of registry, type and IMSI of the vessel or aircraft; and, registration number, country of registry, manufacturer, model and fuselage/airframe number of the aircraft.
“Anonymous Information” means information that we do not link to Personal Information and does not enable contact with any identifiable person.
“Data Protection Laws” means laws relating to data protection, privacy, and/or information security, including all such laws governing use of Personal Information.
“Personal Information” is any information relating to an identified or identifiable individual, such as your name, address, email address, telephone number, job title, job industry, company/organization name, and any other information you voluntarily provide or any other non-public information that we associate with your contact information and that can identify you as an individual.
Additionally, you acknowledge by your use of our Services that you understand your Personal Information may be processed in countries (including the United States) where Data Protection Laws may be different or less stringent than in your home jurisdiction.
Finally, you acknowledge that your Personal Information may become accessible as permitted by law in the United States, including to law enforcement and/or national security authorities.
Personal Information You Provide to Us
We collect Personal Information when you, or others on your behalf, provide it to us. For example, when you register for a Service we provide, we collect Account Information. In addition, depending on the Services used, we may collect flying preference information, including the type of plane on which SD products or Services are provided, and passenger-specific details, including departure and arrival locations, dietary preferences, and governmental-issued identification numbers, such as passport numbers.
When you contact us to inquire about certain products or Services, you must provide your certain Personal Information, including your name, email address, phone number, and other information necessary for us to respond to your inquiry. Likewise, when you leave us feedback, we collect any information that is contained in your feedback. When you contact us by sending us an e-mail, fax, or letter, we will collect your address, fax number, or e-mail address and any Personal Information contained in the e-mail, fax, or letter you send us.
Personal Information Collected via Technology
We use tools that passively collect certain information when you access our Website. These tools include Cookies and web beacons, and they allow us, our service providers, and other third parties to identify your device, track your interactions with other websites, and track activity over time and across websites by storing information locally on your device.
For example, Cookies store a small text file on your computer or device that tracks certain information about you and your activities on our Websites. We use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer or device until you delete them). If you register for a Service provided by us, we may include web beacons with the content and ads that we deliver to you as a part of that service, which we use to collect information regarding your interaction with such content and ads.
The information that these tools collect include your internet protocol address, unique device identification information, regional and language settings, browser type, and operating system, the network used to access our Website, and information about your use of our Website (such as how you navigate and move around the Website). Depending on applicable Data Protection Laws, this information may be considered Personal Information.
Personal Information from Other Sources
We may receive Personal Information about you from other third-party sources, including our service providers, analytics providers (including Google Analytics), and our business partners. Such information may include demographic information, itinerary details, dietary preferences, browsing preferences, language preferences, and other personal preferences. We may associate this information with the other Personal Information we have collected about you.
Legal Bases for Processing Personal Information
To the extent applicable under Data Protection Laws, we process Personal Information for, or based on, one or more of the following legal bases:
Performance of a Contract. We may use Personal Information to enter into, or perform under, an agreement between us, including: to complete a purchase; process payment; ship or provide goods or Services; and provide customer support.
Legitimate Interests. We may use Personal Information for our legitimate interests to the extent it does not infringe on any data subject’s fundamental rights and freedoms, including: improve our Services; providing information about our products and/or Services; to the extent necessary and proportionate for the purposes of ensuring network and information security; and for administrative, fraud detection, and legal compliance purposes.
Compliance with Legal Obligations and Protection of Individuals. We may use Personal Information to comply with the law and our legal obligations, as well as to protect you and other individuals from certain harms.
Your Consent. From time to time, and as required by applicable Data Protection Laws, we may seek your consent to collect and process your Personal Information, as well as communicate with you to provide information that may be useful or interesting.
How We Use Information That We Collect From You
SD uses Account Information and Personal Information for a variety of purposes, such as:
- To deliver products and Service to our customers;
- To establish and maintain customer relationships, including keeping records of the relationship designed to facilitate timely and accurate invoicing and to administer our billing and accounting systems;
- To answer billing, account, or technical inquiries from our customers;
- To activate, deactivate, suspend, un-suspend, bar, or un-bar your satellite terminal;
- To establish and maintain supplier relationships to support the acquisition of communications products and services required for the delivery and provision of SD’s products and Services;
- To measure and improve the effectiveness of our products, Services, and marketing efforts;
- To communicate with our customers about additional SD products and Services that may be of interest to them or to send other special interest customer communications;
- To provide you with accurate and high-quality customer service, including responding to customer inquiries and troubleshooting technical issues;
- To research and develop new products, services, or programs to better serve the needs of our customers;
- To endeavor to protect our business partners’ rights, property, or safety, and the rights, property, and safety of our customers, users, and other third parties; and
- To meet legal and regulatory requirements.
We may also use your Personal Information to create Anonymous Information by removing information that makes the information personally identifiable to you (such as your name or email address). We may use these records, and other Anonymous Information, to analyze usage patterns in order to enhance our Services and tailor them to your preferences.
How We Disclose Your Personal Information to Third Parties
We do not sell Personal Information or Anonymous Information, and it is SD’s policy not to share Personal Information outside of SD except as provided herein.
In order to effectively and efficiently continue operations, Personal Information that you provide to a SD affiliate is shared amongst the other companies within the SD family, including Satcom Direct, Inc., Satcom Direct Communications, Inc., Satcom Direct Avionics, ULC, Satcom Direct International, Ltd., and COMSAT, Inc. and other regional affiliates.
We share Personal Information with third parties to assist us in providing Services or products, or for other business purposes provided that disclosure is made on a confidential basis. Such third parties and purposes include:
- Agents acting on behalf of SD, such as our authorized SD dealers or distributors, or companies hired to perform installation, maintenance, warranty work, or billing functions;
- To third parties to whom you ask us to send Personal Information;
- A person who, in the reasonable judgment of SD, is acting as an agent of a customer;
- Other communications service providers or commissioning entities in order to provide efficient and effective communication services (e.g., to terminate a satellite call on a terrestrial line or to activate, deactivate, suspend, un-suspend, bar, or un-bar service on your satellite terminal);
- Companies providing services to your aircraft’s satellite communication system, including the manufacturer, installation and repair centers, and trip planners;
- Delivery companies in order to deliver our products or Services to our customers;
- Information technology or other professional consultants and service providers in order to improve our Services, systems, and processes;
- Other companies and professional advisors in conjunction with an amalgamation or sale of corporate assets or interests; and
- To our parent company, subsidiaries, affiliates, or joint ventures;
- As may otherwise be required by local and foreign law.
We will use reasonable efforts, using contractual or—where applicable—other arrangements, to ensure that third parties use Personal Information in a manner that is consistent with this policy. Should a customer not wish us to disclose Personal Information to third parties, we may be unable to process an application or transaction, communicate with you about products or Services that may be of interest, or provide other benefits or Services.
As well, there are special circumstances where we may disclose your Personal Information without prior consent or notice. These situations include: (1) where information is forwarded to a collection agency for the collection of past due bills; (2) where it would be reasonably in the best interest of an individual but where consent cannot be obtained in a timely manner; (3) where the life, health, or security of an individual is threatened or otherwise at risk; (4) where the purpose is related to the detection or prevention of fraud or for law enforcement; (5) where disclosure is to our legal counsel or other advisors; or (6) as may otherwise be required or permitted by law.
Third Party Content and Ads
If you register for a Service that we provide, we may enable certain third parties to deliver content and ads on our Website. These third parties may collect (via tracking technologies like cookies or web beacons as described in the section, Personal Information Collected via Technology) and use information regarding your interaction with the content or ads that they deliver and with which you interact.
Law Enforcement Compliance
If you have registered for a Service that we provide, we may be required by law, or by law enforcement officers acting under the color of law, to record some or all communications on or through that Service. In addition, we may disclose Personal Information (including Account Information and Anonymous Information) and communications through that Service if required by law or by law enforcement officers acting under the color of law, or if we believe in good faith that such disclosure is necessary to: (a) comply with relevant laws or to respond to subpoenas or warrants served on us; or (b) to protect or defend the rights, property, or safety of SD, you, other users, or third parties (especially in emergency situations).
Your Choices Regarding Your Personal Information
When you receive promotional communications from us, you may indicate a preference to stop receiving further promotional communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the promotional e-mail you receive or by contacting us directly (please see contact information below).
Your Rights Regarding Personal Information
You have a variety of legal rights regarding the collection and processing of your Personal Information. You may exercise these rights, to the extent they apply to you under applicable Data Protection Laws, by contacting us as provided in the section, Contact Us.
You may request deletion of your Account Information or Personal Information by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete Personal Information, we will delete it from our active databases but the information may remain in our archives or disaster recovery systems.
Note, however, that we may request certain reasonable, additional information (that may include Personal Information) to help us authenticate your request and/or to clarify or understand the scope of such requests.
These rights vary depending on applicable Data Protection Law, but may include:
- The right to know whether, and for what purposes, we process Personal Information about you;
- The right to be informed about the Personal Information we collect and/or process about you;
- The right to learn the source of Personal Information about you that we process, and whether we obtain that Personal Information from a source other than you.
- The right to access, modify, and correct Personal Information about you (as set forth in more detail below under the section, Accessing, Modifying, Rectifying, and Correcting Collected Personal Information).
- The right to know with whom we have shared Personal Information about you, for what purpose, and what Personal Information has been shared (including whether Personal Information was disclosed to third parties for their own direct marketing purposes);
- Where processing of Personal Information about you is based on consent, the right to withdraw your consent to such processing; and
- The right to lodge a complaint with a supervisory authority located in the jurisdiction of your habitual residence, place of work, or where an alleged violation of law occurred.
For additional information about specific legal rights, please reference the following sections: Your California Privacy Rights, Your European Union Privacy Rights, and Your Canadian Privacy Rights.
Accessing, Modifying, Rectifying, and Correcting Collected Personal Information
We strive to maintain the accuracy of any Personal Information collected from you, and will use commercially reasonable efforts to respond promptly to update our records when you tell us your information is not accurate. However, we must rely on you to ensure that the information you provide to us is complete, accurate, and up-to-date, and to inform us of any changes. Please review all of your information carefully before submitting it to us, and notify us as soon as possible of any updates or corrections as outlined in the section, Contact Us.
In accordance with applicable Data Protection Laws, you may obtain from us certain Personal Information in our records. If you wish to access, review, or make any changes to Personal Information we hold about you, you may contact us as provided below in the section, Contact Us, or—for certain information—through your account on the Services. Please note, however, that we reserve the right to deny access as permitted or required by applicable Data Protection Laws.
Your California Privacy Rights
California Civil Code Section 1798.83, known as the “Shine the Light” law, permits our users who are California residents to request and obtain from us a list of what Personal Information (if any) we have disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once per year per person, must be sent to the email address in the section, Contact Us, and are free of charge.
Notwithstanding this right, we do not disclose Personal Information to third parties for their own direct marketing purposes.
Your European Union Privacy Rights
In addition to the above-listed rights, European Union privacy law provides individuals with enhanced rights with respect to their Personal Information. Depending on the circumstances surrounding the processing of Personal Information, these rights may include:
- The right to object to decisions based on profiling or automated decision-making that produce legal or similarly significant effects on you;
- The right to request restriction of processing of Personal Information or object to processing of Personal Information carried out pursuant to (i) a legitimate interest or (ii) performance of a task in the public interest (including, but not limited to, processing for direct marketing purposes);
- In certain circumstances, the right to data portability (which means that you can request that we provide certain Personal Information we hold about you in a machine-readable format); and
- In certain circumstances, the right to erasure and/or the right to be forgotten (which means that you can request deletion or removal of certain Personal Information we process about you).
Please note that we may need to request additional information from you to validate your request.
Your Canadian Privacy Rights
Residents of Canada can request and obtain from us information relating to the existence, use, and disclosure of their Personal Information, as well as access to that information (subject to certain exceptions pursuant to applicable Data Protection Laws). Without limiting the above, residents of Canada will, upon request:
- Be informed of whether we hold Personal Information about you;
- Be provided with an account of third parties to which we have disclosed your Personal Information;
- Be able to challenge the accuracy and completeness of your Personal Information and have it amended as appropriate; and
- Be provided with information about our policies and practices with respect to the management of Personal Information, including: the name, title, and address of the person who is accountable for our privacy policies and practices; the means of gaining access to Personal Information; a description of the type of Personal Information held by us, including a general account of its use; a copy of any brochures or other information that explain our policies, standards, or codes; and what Personal Information is made available to related organizations.
Children under the age of 18 are not permitted to use our Websites, and we do not knowingly gather Personal Information from people who are under the age of 18. By using the Services, you represent that you are 18 years of age or older, or are 16 years of age or older and have valid parental consent to do so.
Our Commitment to Maintaining Your Privacy
We employ reasonable physical, technical, and organizational measures designed to safeguard the confidentiality, integrity, availability, and resilience of your Personal Information, whether stored electronically or in paper format. Information is maintained in secure facilities, protected from unauthorized access, and retained only as long as is reasonably required. Electronic files are backed up for redundancy and password-protected to ensure access only by authorized employees. We encrypt Personal Information where we deem appropriate, and we periodically test, assess, and evaluate the effectiveness of our safeguards.
No method of safeguarding information, however, is completely secure. While we use measures designed to protect Personal Information, we cannot guarantee that our safeguards will be unconditionally effective or sufficient. In addition, you should be aware that internet data transmission is not always secure, and we cannot warrant that information you transmit utilizing our Services is or will be completely secure.
Retention of Your Personal Information
Unless otherwise required by law or to the extent we reasonably deem necessary to protect our rights, property, or safety, and the rights, property, and safety of our users, we will delete Personal Information when: (1) it is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (2) when you withdraw your consent (where lawfulness of processing was based on your consent) and there is no other legal ground for the processing; (3) when you object to the processing and there are no overriding legitimate grounds for the processing; and (4) when it is necessary to comply with legal obligations.
Do Not Track
We use analytics systems and providers that process Personal Information about your online activities over time and across third-party websites or online services, and these systems and providers may provide some of this information to us. We do not currently process or comply with any web browser’s “do not track” signal or similar mechanisms.
Satcom Direct, Inc.®
1050 Satcom Lane
Melbourne, FL 32940, USA
We will respond to your request or investigate your concern as quickly as possible.