Hilton Software Privacy Policy

Hilton Software Privacy Policy
Last Modified: September 1, 2023

Hilton Software LLC (“Hilton Software,” “we,” “us” or “our”) respects and protects the privacy of visitors to our websites and our customers who use our services. To ensure transparency this Privacy Policy (the “Policy”) explains our information handling practices when you access or use our website at hiltonsoftware.com or any other websites, pages, features, or content we own or operate (collectively, the “Site(s)”) and/or when you use the WingX mobile app (referred to collectively hereinafter as “Services”). We may refer to users and customers collectively as “you” within this Policy.

1. ACCEPTANCE
Before using WingX, please read our End User License Agreement (EULA). By accepting the EULA, you agree with our privacy practices as described in this Policy. If you do not agree with this Policy or the EULA, please stop accessing or using our Services and our Site.

2. CHANGES TO POLICY
We may modify or update this Policy from time to time by posting a revised version and updating the “Last Modified” date above. We may provide you with additional forms of notice as appropriate under the circumstances, such as email notices to the most recent email address we have on file for you. Your continued use of our Services after any modification to this Policy will constitute your acceptance of such modification. In addition, we may provide you with “just-in-time” disclosures or additional information about the data handling practices of specific parts of our Services. Such notices may supplement this Policy or provide you with additional choices about how we process your personal information. Hilton Software Privacy Policy

3. INFORMATION WE COLLECT
Personal information is any information that identifies you or makes you identifiable. We need to collect your personal information to provide you with our Services or support.

We may collect the following types of information:

Information You Provide to Us. We collect any information that you voluntarily provide to us, such as your account registration information or any other actions performed by you on our Services.
Information About Your Use of the Services. We collect information about your use of the Services, such as your Internet Protocol (“IP”) address, browser attributes and type, mobile device and operating system, the pages you visit on our Services, the content you view on the Services, the date and time of your visits, and other clickstream data that helps us understand how you interact with the Services. We may collect this information through third-party analytics tools.
Geolocation Information. If you set our Services to record your precise geolocation data, we will record and save your geolocation information on your device, and you can export this data to a GPX file to review your flight in other applications. We do not share this information with third parties. Our Services will not transmit your recorded geolocation information over any network including the Internet.
Routes, User-Defined Waypoints, Aircraft Information. Our Services store routes, user-defined waypoints, and aircraft information to provide the Services.
Cookie Information. We use cookies on our Services. Such cookies collect information about you, such as your IP address, user ID, and how you interact on our Services. Please see the Cookie section below for more information.

4. HOW WE USE YOUR INFORMATION
We do not rent, sell, or share your personal information with other people or non-affiliated companies for their direct marketing purposes, unless we have your permission. We may use information that we receive to:

Provide the Services. When accessing our website or otherwise using our Services, we collect certain information about you to be able to support your requests. For example, we collect your account information so that you can access our Services securely. We cannot provide you with our Services without processing your personal information.
Provide Service-Related Communications. If you have purchased our Services, we will send you administrative or service-related information. Such communications may include confirmation of your transactions, technical notices, security updates, or other relevant information. Service-related communications are not promotional in nature; therefore, they are not marketing communications. You cannot unsubscribe from service-related communications because they are important and can affect the way you use the Services.
Enforce our Terms, Agreements or Policies. We process your personal information to enforce certain terms, agreements, and policies relevant to our relationship with you, including any agreements with third-party partners. We may collect fees based on your use of the Services, and actively monitor, investigate, prevent, or mitigate any alleged or actual prohibited, illicit or illegal activities on our Services. This process allows us to maintain a trusted environment for you. We cannot perform the Services without such processing.
Provide Customer Support. Whenever you contact us for customer support or any other reason (e.g., diagnose or fix technology problems, to provide feedback, notify us of a dispute, etc.), we process any information you provide to us and any information we already have about you. Without processing your personal information for such purposes, we cannot respond to you or ensure your continued use and enjoyment of the Services.
Provide Secure Services. We are committed to ensuring your personal information is processed securely on our Services. To maintain the security of our Services, we may process your personal information to investigate, detect, prevent, or report fraud, misrepresentation, security incidents or breaches, spam, malware, malicious activities or other prohibited or illegal activities. In addition, we process your personal information to improve the security of our Services. We cannot provide the Services securely without such processing.
Conduct Research and Product Development. We may process your personal information to improve, optimize or expand our Services or features of our Services. We do so by processing information about your use of the Services, any information you provide to us, and by measuring, tracking and analyzing trends and usage in connection to your use or the performance of our Services. We take additional security measures when processing your personal information for such purposes, such as by de-identifying (or “pseudonymizing”) your personal information and limiting access to our personnel to such data. Without processing your information for such purposes, we may not be able to ensure your continued enjoyment of part or all our Services.
Engage in Marketing Activities. We engage in marketing activities with individuals that may be interested in our products and services. When engaging in marketing activities, we may process personal information to: send you marketing communications; run contests, special offers or other events or activities; send you information about opportunities, products, services, contests, promotions, discounts, incentives, surveys, and rewards offered by us and select partners; or otherwise market our products and services, including targeted marketing. When you share your friends’ or business partners’ contact information with us, we may reach out to them on your behalf in accordance with applicable laws. You can unsubscribe from marketing communications at any time and without charge.
Maintain Legal or Regulatory Compliance. We may be required to process your personal information under certain laws and regulations, such as tax laws or other business obligations, or as otherwise required by applicable law. We cannot provide the Services to you without such processing.

We will disclose any other purposes to you in connection with our Services prior to processing your personal information for such purposes. You may choose not to allow us to process your personal information for any purposes that are not compatible with the purposes for which we originally collected your personal information or subsequently obtained your consent. However, you should be aware that if you choose to limit how we use your personal information, some or all our Services may not be available to you.

5. SHARING OF YOUR INFORMATION
We may share your information as follows.

Affiliated Businesses. We may share your personal information with group companies and affiliates. Affiliated businesses may use your information to help provide, understand, and improve the Services and Affiliates’ own services.
Our Service Providers, Business Partners and Others. We may share your personal information with our service providers, business partners or third-party organizations that help us provide the Services to you. Such entities will be given access to your information as is reasonably necessary to provide the Service under contractual obligations at least as protective as this Policy.
Change of Control. We may share your personal information with a subsequent owner, co-owner, or operator of our Services, or in connection with a corporate merger, consolidation, or restructuring; financing, acquisition, divestiture, or dissolution of all or some portion of our business; or other corporate change. We will notify you with any choices you may have regarding your information.
Safety and Legal Compliance. We may share your personal information if we believe that such disclosure is necessary to: comply with any applicable laws, regulations, legal processes, or requests by public authorities (e.g., law enforcement, tax authorities, etc.); protect you, us or our other users’ rights or property, or to protect our Services; comply or enforce our terms, agreements, or policies.

6. MARKETING CHOICES
Our customers or prospects can unsubscribe from marketing email communications from us by clicking on the “unsubscribe link” provided in such communications. Also, you may not opt out of Service-related communications (e.g. account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices).

7. TRANSFER OF YOUR INFORMATION
We offer our Services only in the United States and we do not target or seek business from individuals located in the European Union. However, if you are not a United States resident, and you access or use our Services, please note that your information could be processed in the United States or any other country in which Hilton Software, its affiliates or service providers maintain facilities. Such countries or jurisdictions may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. If you do not want your information transferred to, processed, or maintained outside of the country or jurisdiction where you are located, you should immediately stop using the Services.

8. ACCESS AND MODIFICATION
You may access and update the information we have about you by contacting us directly at support@hiltonsoftware.com. We may need to verify your identity before we grant access or otherwise modify the information, we have on file for you.

9. SECURITY
We use commercially reasonable safeguards to keep your personal information safe and require our service providers to do the same. However, the internet is not a secure environment, and we cannot guarantee that your personal information is 100% safe. Please recognize that you play a vital role in protecting your own personal information. When registering with our Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third parties, and to immediately notify us if you become aware of any unauthorized access to or use of your account.

10. RETENTION
We generally retain your personal information as long as necessary to fulfill the purposes of collection or to comply with applicable law. Otherwise, we will try to delete your personal information upon your request or when we no longer need it for the purposes it was originally collected. We will not delete any personal information that you share with other users unless such other users also wish to delete their personal information at the same time.

11. LINKS TO THIRD PARTIES
We are not responsible for the practices employed by any websites or services linked to or from our Service, including the information or content contained within them. Please remember that when you use a link to go from our Service to another website or service, our Privacy Policy does not apply to those third-party websites or services, even if they are offered within or through our Services.

12. COOKIES
Cookies are small data files that we transfer to your device to collect information about your use of our Services. Cookies can be recognized by the website that downloaded them or other websites that use the same cookies. This helps websites know if your browsing device has visited them before.

We generally treat information collected by cookies and other tracking technologies as non-personal information. However, to the extent that IP addresses or similar identifiers are considered personal information by local law, we also treat cookie information with identifiers as personal information. If we combine non-personal information with personal information, then the combined information will be treated as your personal information for as long as it remains combined.

Purposes for Cookie Collection: Cookies can be useful in many ways, and we use cookies for a variety of purposes. We use cookies to help it understand how the Services are being used, such as whether you spent more time on a certain part of the Services, whether you experienced any technical issues, and more. Some of the functions performed by cookies are strictly necessary for us to be able to offer you our Services, while other cookies provide us with valuable insight about how we can improve our Services or help us with marketing our products and services to you based on your interests and preferences.
Who Owns Cookie Data: We use both first-party and third-party cookies on our Services. First-party cookies are cookies that are placed on your device by us, while third-party cookies are set by parties other than Hilton Software. Third-party cookies are operated by third parties that can recognize your device both when it visits our Services and when it visits other websites or mobile apps. Hilton Software does not control how third-party cookies are used, and we encourage you to check the websites of any third-party cookie providers for more information about how they use cookie information.
How to Manage Cookies

First-Party Cookies: You can enable, disable, or delete cookies via your browser settings. To do this, follow the instructions provided by your browser, usually located within the “Help”, “Tools” or “Edit” settings of your browser. Please be aware that if you set disable cookies on your browser, you may not be able to access secure areas of the Services and parts of the Services may also not work properly (e.g., referral links, preferences, etc.).
Third-Party Cookies: Any cookies that are placed on your browsing device by a third party can be managed through your browser (as described above) or by checking the third party’s website for more information about cookie management and how to “opt-out” of receiving cookies from them. For Google Analytics, you may opt out by going to: https://tools.google.com/dlpage/gaoptout (requires you to install a browser add-on).

13. CHILDREN’S PRIVACY
We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of the Services is directed to children Hilton Software under the age of 13. If you learn that your child has provided us with personal information without your consent, you may alert us at support@hiltonsoftware.com. If we learn that we have collected any personal information from children under 13 in a manner that is inconsistent with the U.S. Children’s Online Privacy Protection Act, we will promptly take steps to delete such information and terminate the child’s account as soon as practicable.

14. “DO-NOT-TRACK” SIGNALS
Do-Not-Track is an optional browser setting that allows you to express your preferences about online tracking across websites. We do not have a way to respond to Do-Not-Track signals.

15. YOUR CALIFORNIA PRIVACY RIGHTS
California law permits California residents to ask us for a notice identifying the categories of personal information which we share with our affiliates and/or third parties for marketing purposes and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to us at the address provided under the “Contact Us” section.

16. HOW TO CONTACT US
If you have any questions about this Privacy Policy or our Services, please contact us at: Privacy Manager, Hilton Software, 2730 N University Drive, Coral Springs, FL 33065, or you can contact us with email at support@hiltonsoftware.com.