CCL Software, LLC
BidNav Software As A Service
Privacy Policy

CCL Software, LLC ("CCL") respects your privacy. When you use our software as a service ("SAAS") on our website (the "BidNav Services"), CCL collects certain information in order to provide the BidNav Services and for internal use to support and enhance our relationship with you. Our Privacy Policy is centered around five simple principles:

1. Personal Data – You have a right to know what kind of personal information about you is collected by CCL.
2. Control – You have a right to access, edit, and review the information provided to CCL as part of your registration to use the BidNav Services and your license to use our SaaS.
3. Non-Use – You have a right to know how to contact CCL to ask that CCL no longer use your registration information and to have CCL reasonably comply with your request.
4. Safety – Airline and passenger safety must be a factor in considering how CCL uses information that you provide to CCL.
5. If you are from the European Economic Area ("EEA"), the use and transfer of your Personal Data will comply with the General Data Protection Regulation of the European Union ("GDPR").

Consent

BY CLICKING ON THE LINK FOLLOWING THESE POLICIES AND THEN BY SUBMITTING PERSONAL DATA TO CCL, YOU AFFIRMATIVELY CONSENT TO THESE POLICIES AND THE USE OF YOUR PERSONAL DATA.

Personal Data and Registration

While using the BidNav Services, you will be asked to provide certain personally identifiable information that can be used in coordination with the BidNav Services, to identify you, and/or to contact you ("Personal Data"). Personal Data may include, but is not limited to:

• First name and last name
• Email address
• Phone number
• Address, City, State, Province, Region, and Postal Code
• Scheduling information including, but not limited to, routes, locations, dates, time, and airlines

Our SaaS will use your Personal Data to provide the BidNav Services and to assist you in scheduling routes. CCL only collects personal data it actually needs for its specified purposes.

CCL may also use your Personal Data to contact you, send you newsletters, update you on key events, and to help CCL customize your online experience. You may opt out of receiving any, or all, of these communications from CCL by following the unsubscribe link or the instructions provided in any email CCL sends.

Automatic Collection of Information and Usage Information

Like many websites, CCL automatically tracks certain information about visits to, and use of, our Website. Primarily, CCL tracks IP Addresses (a unique identifier of your computer or network). CCL may also collect click-stream data, HTTP protocol elements, access logs, cookies, search strings, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, browser type, browser version, the number of visits to our Website per IP Address or user, unique device identifiers, and other diagnostic data ("Usage Data").

Cookies

Cookies are used to track visitors to our site, so CCL can better understand your use of our Website. Cookies are a technology which can be used to provide you with tailored information from a website. A cookie is an element of data that a website can send to your browser, which may then store it on your system. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it. If our Website uses cookies, they are used to identify users logged in to our Website, pseudo-anonymous navigation analysis, and pseudo-anonymous decision-making. Cookies and other electronic tools may also be used to track Usage Data.

Payment

The BidNav Services are provided on a fee basis. CCL will not store or collect your payment card details but will provide it directly to third-party payment processors whose use of your Personal Data is governed by their privacy policy; however, third parties may also rely on your consent to these Privacy Policies. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors CCL works with include:
      Authorize.net
      Their Privacy Policy can be viewed at https://www.authorize.net/about-us/privacy/

Sharing and Use of Information

CCL does not resell or share information, collaborate, or have special relationships with any ad server companies. From time-to-time, CCL may use your information for new and currently unanticipated uses not previously disclosed in our Privacy Policy, provided that:

• The new purpose is compatible with the original purpose;
• You provide your specific consent for the new purpose; or
• There is a clear legal provision requiring or allowing the new processing in the public interest – for example, a new function for a public authority.

Airline Safety

CCL supports efforts to improve airline and passenger safety. Notwithstanding anything in this Policy to the contrary, CCL may, in its sole discretion, share any information obtained during, or implied by, your use of the SaaS, or obtained during conversations with CCL, that may affect safety. The sharing of this information includes, but is not limited to, contacting the Peer Advisory Network (PAN), and responding to questions of, and providing data requested by, your airline or any governmental agency, to further airline or industry safety programs, cooperate with accident investigations, promote pilot fitness for duty, and enhance aircraft reliability.

Basis for Processing Personal Data - GDPR

If you are from EEA, the legal basis for collecting and using your Personal Data described in this Privacy Policy depends on the Personal Data that CCL collects and the specific context in which CCL collects it.

CCL may process your Personal Data because:

• It needs to perform a contract with you and provide the BidNav Services
• You have given CCL permission to do so
• The processing is in the legitimate interests of CCL and it is not overridden by your rights
• Your Personal Data will be used for payment processing purposes
• Your Personal Data is necessary in order to comply with the law

Automated Processing

The BidNav Services provide certain automated decisions (making a decision solely by automated means without any human involvement) regarding rout selection and profiling (automated processing of personal data to evaluate certain things about an individual). Profiling can be part of an automated decision-making process. This automated decision-making process is necessary to provide the BidNav Services.

You have the right to request human intervention, express your point of view regarding the automated process, obtain an explanation of, make a challenge to, the routing decisions made by the automated process.

Transfer of Personal Data - GDPR

Your information, including Personal Data, may be transferred by CCL to British Airways and/or Jeppson Strict Security. Your Personal Data may then be maintained on their computers that may be located outside of your country where the data protection laws may differ from those of your jurisdiction.

If you are located outside of the United States and choose to provide information to CCL, please note that CCL transfers the data, including Personal Data, to the United States and processes it there.

CCL will take all the steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy and the GDPR. No transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your Data and other Personal Data.

Your Data Protection Rights Under the GDPR

If you are a resident of the EEA, you have certain data protection rights. CCL will take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data by CCL.

If you wish to be informed about what Personal Data that CCL holds about you or if you want it to be removed from our systems, please contact CCL.

In certain circumstances, you have the following data protection rights:

• The right to access, update or delete the information CCL has on you. Whenever possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact CCL to assist you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Data.
• The right of restriction. You have the right to request that CCL restrict the processing of your Personal Data.
• Right of Erasure. You have the right to have Personal Data erased (also known as the “right to be forgotten”) under certain circumstances.
• Right to Restrict Processing. You have the right to restrict the processing of your Personal Data in certain circumstances. This means that you can limit the way that CCL uses your Personal Data.
• The right to data portability. You have the right to be provided with a copy of the information CCL has on you in a structured, machine-readable, and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent to process your Personal Data any time.

Please note that CCL may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the EEA.

How to Exercise You Rights Under the GDPR

To exercise your Data Protection rights, you may call, email, or write CCL at:

Phone:	+1 844 4243628
Email:	uksupport@cclsoftware.com or cynthia@cclsoftware.com
Address:	6630 W Prentice Ave, Littleton, CO 80123

You will receive a response from CCL within one month.

Retention of Personal Data

CCL will retain and use your Personal Data for internal analysis purposes and to the extent necessary to comply with our legal obligations (for example, if CCL is required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. CCL periodically reviews the Personal Data CCL holds and deletes anything it doesn’t need. CCL may also delete your Personal Data when you stop using the BidNav System. If CCL does and you decide to later use the BidNav System, you will be asked again to provide Personal Data and to consent to these Privacy Policies.

Security

CCL uses appropriate security measures in order to protect our Website against misuse or alteration of information. However, Internet attacks cannot be completely eliminated, and CCL cannot guarantee information will not be accessed by unauthorized parties.