BLR AEROSPACE PRIVACY POLICY

Last updated: January 1, 2023

Thank you for visiting the BLR Aerospace’s website (“BLR Website”). BLR Aerospace, LLC (“BLR,” “we,” “our,” “us”) is committed to protecting and respecting your privacy while you are using our websites. Please read this Privacy Policy carefully to understand t types of information we collect, how we use the information, whether we share the information with anyone else and how you may contact us about our Privacy Policy.

If you are a resident of the State of California, our privacy practices comply with the California Consumer Privacy Act of 2018, as amended (“CCPA”) and any CCPA-specific information is identified in this Privacy Policy.

If you are a resident of the European Economic Area (“EEA”), this Privacy Policy also outlines additional policies applicable to our collection and processing of your personal information. Non-EEA countries do not have the same data protection laws as the EEA. We will, however, take steps to ensure that any transfer of personal information will comply with applicable data protection laws.

As our services evolve, we may amend this Privacy Policy from time to time. The effective date appears at the top, below the title of this document. We encourage you to check our BLR Website frequently to review the current Privacy Policy in effect and any changes that may have been made to it.

By providing your Personal Information to us in any format, and/or continuing to use any of our services or visiting our BLR Website, you accept and consent to the practices described in this Privacy Policy. If you do not understand the Terms of Use or this Privacy Policy, do not agree to be bound by the Terms of Use or this Privacy Policy, or if your jurisdiction will not honor them, you must immediately leave the website and refrain from using it. Each time you use the website, the then-current version of this Privacy Policy will apply.

1.DEFINITIONS

“Personal Information” means information (whether stored electronically or in physical filing systems) relating to a Covered Person who can be identified from that data (or from that data and other information in our possession).  Personal Information can be factual (such as a name, address, date of birth, social security number or driver’s license number), Sensitive Personal Information as described below, or it can be an opinion (such as a performance appraisal). It can even include a simple e-mail address. The categories of Personal Information as defined by the California Consumer Privacy Act of 2018 (“CCPA”) that pertain to this Policy include:

Identifiers	Name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers
Other Data	Financial information, medical information, health insurance information, signature, physical characteristics or description, telephone number, geolocation
Protected Classes	Race, color, sex, age (40 and older), religion, national origin, citizenship status, genetic information, sexual orientation, gender identity or gender expression, ancestry, AIDS/HIV, disability, marital status, familial status, military or veteran status, political affiliations or activities, status as victim of domestic violence, assault, stalking, or any other classification protected under California or federal law
Biometric Information	Fingerprints, retina scans, face prints, DNA
Internet Activity	Browsing history, search history, website interactions
Geolocation Data	Data which allows for determining, with reasonable precision, the location of any person or object
Sensory Data	Audio, electronic, visual, thermal, olfactory, or similar
Professional Data	CV, resume, employment history, licenses, certificates
Education Data	Educational background, grades, scores
Inferences	Profiles about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities drawn from other Personal Information

“Processing”, “Process” or “Processed” is any activity that involves use of the Personal Information. It includes obtaining, recording or holding the Personal Information, or organizing, amending, retrieving, using, disclosing, erasing or destroying it including by automated means. Processing also includes transferring Personal Information to third parties.

2. WHAT PERSONAL INFORMATION DO WE COLLECT?

We only collect Personal Information that is relevant for the purposes for which we request the data.

We collect information directly from you when you fill out a contact form with BLR Website, or otherwise provide information directly to us. We may also collect certain non-public, personal information about you from documents you provide to us and may also information from other sources. With will only obtain such information from third parties with your express consent, as permitted by law.

a). Personal Information collected from and about customers and vendors

We collect that information in the course of our business dealings:

• If you or the company you work for are a customer or supplier of ours.
• If you or the company you work for use our Services or provide them to us.
• If you are someone, or you work for someone, to whom we want to advertise or market our Services.
• From your employer in connection with your role and its relation to services we provide or receive from you.
• From third parties we work with closely, such as business partners, and introductions from other individuals or companies.

We may collect the following categories of Personal Information from our customers and vendors:

• Identifiers: name, address, email, phone, social security number, federal tax ID number, passport, driver’s license, or other relevant identifiers, as applicable.
• Protected Classes: gender, race, sexual orientation, and citizenship information, as necessary.
• Professional Data: we may occasionally collect professional data such as C.V., salary history, and education history, as necessary.
• Sensory Data: we employ video surveillance at certain of our facilities for security purposes.
• Other Data: Financial information such as credit card and account numbers; financial records, such as tax information, and securities filings.

b). Information we collect about visitors to BLR Website

When you visit our BLR Website, our web server automatically collects the following Internet Activity:

• Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
• Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), pages on our Site you viewed; page response times, download errors, duration of page visits, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number.
• We may also determine the approximate location of your device from your IP address. We collect and use this information to determine statistics about our website, including how many people visit our website from certain geographic regions.
• Our Site uses cookies and pixel tags to collect this information.
• You can block our use of cookies through settings in your browser. Because these settings are different in different browsers, we recommend that you visit All About Cookies at www.allaboutcookies.org, where you can find comprehensive information on cookie management and blocking for a wide variety of browsers.

c). Information from other sources

We receive information about you if you use the other websites we operate or the other services we provide. We work closely with third parties including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers and search information providers. We will inform you when we collect data if we intend to share the data or combine it with data we collect directly. We also will tell you the purpose for sharing and combining your data. We will notify you when we receive information about you from other parties and the purposes for which we intend to use that information.

3. HOW DO WE USE INFORMATION WE COLLECT?

We use information held about you in the following ways:

a). Information you give to us. We will use this information:

• To provide you with the information, products, and services that you request from us;
• To send you direct marketing and promotional materials, or other communications;
• To respond to requests for information, services, or email notifications, or to respond to other enquiries;
• For training purposes, quality assurance, and to record details about the products and services you order from, or supply to, us;
• To comply with applicable laws and regulations;
• To carry out our obligations arising from any contracts entered into between you and us, or between you and our vendors or distributors;
• To provide you with information about other goods and services we offer, or that are offered by our affiliates or third party vendors, that are similar to those that you have already purchased or enquired about;
• To notify you about changes to our service;
• To make inquiries about you for credit reference purposes;
• To perform data analyses (including anonymization and aggregation of Personal Data);
• For prospective employees, to respond to your job application.

b). Information we collect automatically.

We will use this information:

• To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes;
• To improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• As part of our efforts to keep our site safe and secure.

c). Information we receive from other sources.

We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

4. SECURITY OF CUSTOMER INFORMATION

We do not sell, trade, or rent your Personal Information to others. We may share Personal Information with our affiliates and service providers who perform services on our behalf. When we share information, we require our affiliate and service providers to agree to use your Personal Information only as we instruct them and in compliance with all applicable laws. You agree that we have the right to share your Personal Information with selected third parties, including:

• Business partners, distributors, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• Analytics and search engine providers that assist us in the improvement and optimization of our site.
• We may disclose your personal information to third parties in the following circumstances:
• You request or authorize it;
• The information is provided to help complete a transaction for you;
• The information is provided to comply with the law, applicable regulations, court orders or subpoenas, to enforce our Terms of Use or other agreements, or to protect our rights, property, or safety or the rights, property, or safety of you or others;
• The disclosure is part of a purchase, transfer or sale of services or assets (for example, if another party acquires our business or assets);
• The information is provided to our agents, outside vendors, or service providers to perform functions on our behalf (e.g. analyzing data, providing marketing assistance, providing customer service, processing orders, etc.);
• Disclosing your Personal Information is necessary as part of actual or threatened legal proceeding or dispute resolution proceeding, in which case we disclose only the information necessary to file, pursue, or defend against the proceeding, and take reasonable precautions to ensure that the information disclosed does not become a matter of public record;
• If we are under a duty to disclose your Personal Information to comply with any legal obligation, or any lawful request by public authorities (including to meet national security or law enforcement requirements), or to enforce or apply our Terms of Use and other agreements; or to protect the rights, property, or safety of us, our customers, or others; or
• If we believe disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected or actual espionage, cybersecurity events, or other fraudulent or illegal activity.

We take every reasonable precaution to protect your Personal Information from loss, misuse, and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing undertaken and the nature of the Personal Information we collect. We maintain physical, administrative, and technological safeguards designed to protect your Personal Information against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.

Unfortunately, however, no data transmission over the Internet and no method of data storage can be guaranteed to be 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its security. Any transmission is at your own risk. Once we have received your information, we will use the procedures and security features to try to prevent authorized access.

5. HOW LONG WE STORE YOUR PERSONAL INFORMATION

We will keep your Personal Information for as long as we need it, or as otherwise prescribed by law, for the purposes set out above. This period will vary depending on your interactions with us. We may also keep a record of correspondence with you (for example if you have made a complaint about a product or service) for as long as is necessary to respond to a legal claim. In some cases, there is a legal requirement to keep Personal Information for a minimum period of time. Unless this is the case, we do not keep your Personal Information for any longer than is necessary for the purposes for which the Personal Information was collected or for which it is to be further processed.

Please note that where you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in future.

6. ADDITIONAL POLICIES IN COMPLIANCE WITH THE CCPA

The CCPA affords California consumers the rights with respect to their Personal Information set forth in this section. These rights apply only to California residents, who are not otherwise exempt pursuant to the terms of the CCPA.

a)   Right to Know About Personal Information Collected, Used, or Disclosed

California consumers have the right to request that we disclose what personal information it has collected, used, or disclosed over the 12-month period preceding our receipt of such a request. To exercise this right, a California consumer must submit to us a verifiable request to know such information. This request can be submitted by following the procedures set forth in Section e below. We do not sell your Personal Information.

b)   Right to Correct Personal Information

California consumers have the right to request that any inaccurate or incomplete Personal Information maintained by us be corrected or supplemented.

c)   Right to Request Deletion of Personal Information

California consumers have the right to request the deletion of their Personal Information collected or maintained by us. To exercise this right, a California consumer must submit to us a verifiable request to delete such information. This request can be submitted by following the procedures set forth in Section e below.

All of these rights are subject to certain conditions and exemptions. For example, We are not required to delete your Personal Information if we need to retain it to respond to a legal claim or where we are required by law to retain the Personal Information.

d)   Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

California consumers have the right to not be discriminated against because the consumer exercised any of the consumer’s rights under the CCPA. That means that a company may not deny goods or services to the consumer, charge different rates for goods or services, or provide a different level or quality of goods or services if the consumer chooses to exercise their rights under the CCPA (unless the different rate or different level or quality is reasonably related to the value to the business of the consumer’s data). We will not deny you any services or charge you a different price, level or quality of services because you exercise any of your rights under the CCPA; however, we may not be able to provide the services if you refuse to provide us the Personal Information that is necessary for us to provide the Services, or if you ask us to delete your Personal Information.

e)   Submitting a CCPA Data Request

To submit a request to us, know about the Personal Information we collect about you as described in Section a, a request for deletion of your Personal Information as described in Section c, or to correct your Personal Information as described in Section b, please contact [email protected].

f)    We are required to verify the identity of the individual requesting access to a consumer’s data or requesting deletion of a consumer’s data. To verify your identity, we will rely upon information we have previously collected about you, such as phone calls received from a known phone number or emails received from a known email. We will also rely upon our personal relationship with our customers or vendors to verify the identity of a requester. If a request involves the disclosure of sensitive Personal Information, or deletion of Personal Information, we may ask you to provide more than one piece of information. We will not require you to provide any information that you have not previously provided to us.

g)   If the California consumer submitting a request is not the our client, such an individual who requested information through our website or a phone call to our “contact us” number, then we will verify identity by confirmation using the information we collected, such as phone number or email address.

h)   Authorized Agent

California consumers may designate an authorized agent to exercise a CCPA right on the consumer’s behalf. If a consumer utilizes an authorized agent to exercise a CCPA right, the following proof that the agent has been authorized to act on the consumer’s behalf will need to be provided:

• Proof of written permission by the consumer for the authorized agent to act on his or her behalf and separate verification of the consumer; or
• Proof that the authorized agent holds a power of attorney to act on the consumer’s behalf pursuant to Cal. Probate Code §§ 4000-4465.

i)    Exclusion for Financial Sector Data

Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act , the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and medical information under the Confidentiality of Medical Information Act (adopted under the Health Insurance Privacy Protection Act) are not subject to the CCPA. With respect to such information consumers do not have the enumerated rights under the CCPA set forth in this section.

7. ADDITIONAL POLICIES IN COMPLIANCE WITH THE EEA PRIVACY LAWS

In addition to the other policies described in this Privacy Policy, residents of the European Union or the EEA are afforded the following additional rights and protections as required by the General Data Privacy Regulation (“GDPR”). The additional rights and protections set forth in this section of this Policy apply only to residents of the European Union or the EEA.

This Personal Information can be combined with other types of information to identify or contact an individual, including combining it with interests, hobbies, photos, your brand preferences, your Facebook, Twitter or

a) GDPR Definitions

The following additional definitions apply to this Section of the Privacy Policy:

“Controller” means the company that is the organization that determines the purposes for which, and the manner in which, any Personal Information is Processed and used in its business.

“Processor” means any Person Processing Personal Information.

“Person” means a natural person, corporation, association, organization, partnership, or other legal entity.

“Processing” is any activity that involves use of the Personal Information. It includes, without limitation, obtaining, recording or holding the Personal Information, or carrying out any operation or set of operations on the Personal Information including organizing, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring Personal Information to third parties.

b)   The legal basis for processing your Personal Information

In order to comply with the GDPR, we are required to set out the legal basis for the processing of your Personal Information. In accordance with the purposes for which we collect and use your Personal Information, as set out above, the legal basis for processing your Personal Information will typically be one of the following:

• Our own legitimate business interests, or the legitimate business interests of our third party partners, promoters, affiliates, distributors, suppliers, vendors, and subcontractors, such as, for example, providing direct marketing to our customers of our products and services that we think would be of interest, permitting prospective employees to search and apply for job opportunities, handling inquiries from our promoters, affiliates, distributors, vendors, and customers, or other instances where we have carried out a legitimate interests assessment and have established an existing legitimate interest;
• The performance of a contract that we have in place with you;
• Your consent where appropriate; or
• Compliance with our legal obligations, including to meet national security or law enforcement requirements.

c)   Where we store your Personal Information

If you are located in the EEA, we will comply with applicable legal requirements providing adequate protection for the transfer of personal information to countries outside of the EEA, such as the United States. The data that we collect from you is stored on our servers and may be transferred within or outside the European Economic Area (“EEA”) to areas where privacy laws may be less strict than in the EEA. By submitting your personal information, you agree to this transfer and processing. We will take all reasonable steps necessary to ensure that your personal information is treated securely in accordance with this Privacy Policy and has the required adequate protection if it is processed or transferred outside the EEA.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

d)   Addendum to how long we store your Personal Information

In some cases, there is a legal requirement to keep Personal Information for a minimum period of time. Except in those circumstances, we do not keep your Personal Information for any longer than is necessary for the purposes for which the Personal Information was collected or for which it is to be further processed.

e)   Your rights with respect to your Personal Information

Subject to certain exceptions, you have the following rights with respect to your Personal Information:

• To receive or access a copy of the Personal Information that we hold about you;
• To request that any inaccurate or incomplete Personal Information be corrected or supplemented;
• To have your Personal Information erased, unless we have a legitimate reason to retain the Personal Information (such as if we are required to do so for legal reasons); and
• To ask us not to process your Personal Information for a particular purpose, including for marketing.

All of these rights are subject to certain conditions and exemptions. For example, we will not be obligated to erase your Personal Information if we need to retain it to protect ourselves in the event of a legal claim.

To exercise any of these rights, please submit a written request to us using the contact information set forth below. We reserve the right to charge a fee in dealing with such a request as permitted by applicable law and regulations.

8.  ACCESS TO YOUR PERSONAL INFORMATION

To check that any information you have provided to us is accurate and up to date, to inform us of any changes, or to learn what information we hold about you, please submit a written request to [email protected] or writing to us at the address provided in the Changes to the Privacy Policy and Contacting Us section of this policy. We reserve the right to charge a fee in dealing with such a request as permitted by applicable law and regulations.

You have the right, at any time, to object to the use of your Personal Information for direct marketing purposes and/or the receipt or further receipt of specific or all types of marketing information, or to object to the use of your Personal Information for any processing activity. To do so, you can direct your request by post to the address listed below or by e-mail.

9.  CHILDREN’S PRIVACY

Our Site is not designed nor intended to be used by children (those under the age of 18, “Minors”). We do not knowingly collect Personal Information from Minors. If you are under the age of 18, please do not submit any information to us.

10.  LINKS TO OTHER WEBSITES

Our BLR Website may include links to and from other websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites are not covered by this Privacy Policy. We are not responsible for the privacy practices of any third parties or the content of linked sites although we do encourage you to read the applicable privacy policies and terms and conditions of such parties or websites. This Privacy Policy only applies to how we deal with your Personal Information, and it does not apply to any other company or any other company’s websites even if you access them via our BLR Website. Please check these policies before you submit any Personal Information to these websites.

11.  CHANGES TO OUR PRIVACY POLICY AND CONTACTING US

Any changes we make to our Privacy Policy in the future will be posted on this page, where appropriate, notified to you by e-mail on our record, if you have provided one. Please check back frequently to see any updates or changes to our Privacy Policy.

BLR Website is owned and operated by BLR Aerospace LLC. If you have any questions or suggestions with respect to this Privacy Policy, please write to us at:

BLR Aerospace LLC

11002 29^th Ave WBldg C-19 Everett, WA 98204-1314

[email protected]

©BLR Aerospace LLC. All Rights Reserved

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