Victor Sierra Aviation Holdings Privacy Policy 

Effective: August  8th, 2024

Victor Sierra Aviation Holdings (“VSAH”, “Company”, “we”, “our” or “us”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy (the “Policy”). The Site (hereinafter defined) is intended to be a safe environment for anyone who accesses and/or uses it. This Policy describes the types of information we may collect from you or that you may provide when you visit the Company’s website located at https://victor-sierra.com/ (our “Website”) and our practices for collecting, processing, using, retaining, protecting, and disclosing your information when you use the Website or our services and products available at our Website (collectively, the “Site”). 

By accessing the Site, you consent to the collection, processing, use, retention, protection and disclosure of your information by VSAH as described in this Policy. By accessing the Site, you accept and agree to be bound and abide by this Policy and our Terms of Use, located at https://victor-sierra.com/ (the “Terms of Use”), incorporated herein by reference. In addition, you agree to be bound by any other terms and conditions posted by VSAH on any part of the Site.

This Policy applies to the information we collect:

  • on the Site;
  • in email, text, and other electronic messages between you and the Site; and
  • in telephone communications between you and VSAH.

This Policy does not apply to information collected by:

  • Through any other means, including on any other website operated by Company or any third party; or
  • Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Site.

Your Acceptance of this Policy

THIS POLICY REQUIRES THE USE OF ARBITRATION (ON AN INDIVIDUAL BASIS ONLY; I.E., CASE CONSOLIDATIONS AND CLASS ACTIONS ARE NOT PERMITTED) IN ORDER TO RESOLVE DISPUTES. Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using any part of the Site, you agree to this Policy. If you do not agree to this Policy, you are directed to discontinue using and accessing the Site. VSAH reserves the right to change or update this Policy at any time and without prior notice to you. Your continued access or use of the Site after such changes or updates indicates your acceptance of the Policy as changed or updated.  It is your responsibility to review this Policy regularly for any changes or updates. 

‌Information We Collect About You 

When you use our Site, VSAH and/or our third party service providers collect certain information about you. Among the types of information from and about users of our Site that we collect includes:

  • Identifiers. This includes any information by which you may be personally identified, such as name, postal address, e-mail address, telephone number, birth date, zip code, or any other identifier by which you may be contacted online or offline; 
  • Communications Information. Including information that you provide during communications and interactions with us, which may include the content of email messages and phone calls. This may also include information that you provide by filling in forms on our Site. This may also include information you provide when you report a problem with our Site. 
  • Internet or other Electronic Network Activity Information. Including your Internet connection information such as your IP address, your operating system, and browser type, the equipment you use to access our Site, unique device identifiers, cookie identifiers, web beacons, device and browser settings and information, interactions with our Site, information about how and when you access our Site, such as the date and time of your visit or use, the website or URL to which you go upon leaving the Site, and other usage details.
  • Geolocation Information. Including device information when using our Site (if your device settings permit us to collect this information). 
  • Inferences. We may use information about or derived from the information above including technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). The information we collect automatically may include personal information or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Site and to deliver a better and more personalized service, including by enabling us to estimate our audience size and usage patterns.

(collectively, “personal information”). 

How We Collect Your Personal ‌Information 

We collect your personal information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the Site collected through cookies and other tracking technologies.
  • From third parties, for example, our business partners.

‌Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns (collectively, “Automatic Data”).

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
  • Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit VSAH, for example, to count users who have visited certain webpages and for other related statistics (for example, recording the popularity of certain content on the Website and verifying system and server integrity).
  • “Cookies”, “Flash Cookies” and “Web Beacons” (collectively, “User Attribution Devices”) help facilitate and enhance the Site’s communications and interactions with you. VSAH may share information collected via User Attribution Devices with third parties, including without limitation advertising, analytics and social media websites, platforms and applications, to inform, optimize and serve information and content to you, including without limitation advertisements. You may opt-out of collection and use of information by certain User Attribution Devices in connection with your use of the Site by: (i) visiting http://optout.aboutads.info/; and/or (ii) setting your Internet browser to refuse certain types of User Attribution Devices, such as cookies.
  • Some content, including without limitation advertisements, on the Site is served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies (alone or in conjunction with other User Attribution Devices) to collect information about you when you use our Site. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We may not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

‌How We Use Your Information

We may use information about our users, including without limitation any User Data, in aggregated, anonymized and/or non-personally identifiable form, without restriction (except to the extent prohibited by applicable law).

We may use information that we collect about you or that you provide to us as described in this Policy, including without limitation any User Data:

  • To personalize your experience on the Site.
  • To present our Site and its contents to you.
  • To provide you with information, products, or services that you request from us, including without limitation to provide you with updates regarding any order for products that you make.
  • To fulfill any other purpose for which you provide it.
  • To notify you about changes to our Site or any products we offer or provide though it.
  • To allow you to participate in interactive features on our Website.
  • To comply with legal processes and safety requirements, including to maintain the security of our customers, employees, and property, respond to court orders, lawsuits, subpoenas, and government requests, as well as to address legal and regulatory compliance purposes. 
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

You expressly consent to VSAH using your User Data, including without limitation your name, phone number, address and email address, to contact you regarding your activities on the Site, including without limitation regarding any transaction or review on the Site. We may also use your User Data to contact you about Company news and updates and about our own and third parties’ goods and services that may be of interest to you. We may also use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Storage and Retention of User Data

Protecting the security of your User Data is important to VSAH. We follow generally accepted administrative, technical, and physical industry standards to protect personal information submitted to us, both during transmission and once we receive it. However, we cannot and do not guarantee the security of any User Data,. Unfortunately, the transmission of information via the Internet is not completely secure. You must protect the privacy of your own information. You are solely responsible for the security of all such information at all times. You must take precautions to protect the security of all User Data that you may transmit to, from or through the Site over any home networks, routers, private wireless (WiFi) networks, public WiFi networks, and all other communication technologies. We are not responsible for circumvention of any privacy settings or security measures contained on the Site, for the unauthorized acts of others, or for acts or omissions beyond our reasonable control.

Your personal information and all User Data are stored by VSAH on its servers, and on the servers of the cloud-based database management services VSAH engages, located in the United States. We will retain your User Data for as long as you remain a customer, for which we need to hold your User Data to deliver our products and services to you, and for a period of time thereafter as long as necessary for legal reasons or to protect our interests. For more information about how long your User Data is stored, and for more information on your rights for erasure or portability, please contact us at info@victor-sierra.com.

Third Parties and Information We Disclose 

Other than as set forth above and discussed in this section, we will not collect or use your User Data when you use our Site, unless you choose to provide such information to us, nor will such information be sold or otherwise transferred to unaffiliated third parties without your approval at the time of collection. 

We may disclose any information about our users, including without limitation any User Data, in aggregated, anonymized and/or non-personally identifiable form, without restriction (except to the extent prohibited by applicable law).

We may disclose information that we collect about you or that you provide to us as described in this Policy, including without limitation any User Data:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep the information that we disclose about you confidential and use it only for the purposes for which we disclose it to them.
  • To a subsidiary, affiliate, buyer, or other successor in the event of a merger, divestiture, restructuring, consolidation, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, insolvency, liquidation, or similar proceeding, in which information held by the Company about you is among the assets transferred.
  • To third parties to market their products or services to you if you have not opted out of these disclosures.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • Otherwise with your consent.

Your Choices About How We Use and Disclose Your Information

To process your User Data, we rely upon your consent, contract performance, our legitimate business interest, or compliance with law. You may object or restrict our processing of your User Data. You may withdraw any prior consent you may have given to process your User Data at any time. It is also within your rights to refuse to provide any User Data we request. However, refusal to provide certain User Data may limit your access to information or use of the Sites. 

Should you wish to access or amend any User Data you may have provided to us or if you wish to request deletion, please contact us at info@victor-sierra.com.

You may also exercise the following controls over your User Data:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website located at: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html. If you disable or refuse cookies, please note that some parts of the Sites may then be inaccessible or not function properly.
  • Promotional Offers from the Company. If you do not wish to have your email address used by us to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to info@victor-sierra.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt-out does not apply to information provided to the Company as a result of a product purchase or other related transactions.

In any such case of your withdrawal of consent, you acknowledge that there may be a delay before we fully implement your request and you may therefore still be contacted by us for a period of time thereafter. Notwithstanding your withdrawal of consent, VSAH may subsequently contact you for other purposes that are unrelated to marketing and/or selling, including without limitation legal or regulatory purposes. Please be aware that applicable laws, statues, rules and/or regulations may require or permit the collection, processing, retention, use and disclosure of your User Data without your consent. Notwithstanding the foregoing, pursuant to applicable laws, statues, rules and/or regulations or other reasons, there may be circumstances in which you may not withdraw your consent to the collection, processing, use, retention and disclosure of your User Data.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (”NAI”) on the NAI’s website located at http://optout.networkadvertising.org/?c=1.

Most Internet browsers can be set to transmit digital “Do Not Track” requests to websites. Such sites may but are not required to comply with “Do Not Track” requests. At this time, the Site does not respond to any digital “Do Not Track” requests.

VSAH’s Social Media Sites

The Company maintains accounts and sites on third party social media websites, platforms and applications. Your use of the Company’s Social Media Sites shall be subject to all of the following: this Policy; the Terms of Use; and the terms of use, privacy policy, and all other applicable terms and conditions for each social media website, platform and application on which the Company’s Social Media Sites reside, as in effect at such time.

In addition, when you register to use social media websites and platforms in general, you are generally required to furnish profile and other information to such websites and platforms in accordance with their own internal policies. Therefore, by using the Company’s Social Media Sites, you authorize the Company to collect and retain information about you, including your profile and other information you disclosed to such social media websites, platforms and applications and other information arising from your access and use of the Company’s Social Media Sites. You expressly consent to the Company’s collection, processing, retention, use and disclosure of such information in accordance with this Policy and the Terms of Use.

Children 

The Site is not marketed to or intended for users under the age of eighteen (18).  No one under the age of eighteen (18) may provide any personal information, or User Data, to or on the Site. VSAH is committed to the safety of children and to protecting the online privacy of children. We do not request or knowingly collect any User Data from children under the age of eighteen. If you believe we might have any information from or about a child under the age of eighteen, please contact us at info@victor-sierra.com.

Rights of Certain Types of Users

Subject to applicable law, you may have certain rights with regard to your User Data. These rights may include the following rights to (1) access or correct your User Data, (2) request the deletion of your User Data, (3) request to opt out of certain processing or another restriction on the processing of your User Data, (4) request a portable form of your User Data, (5) object to the processing of your User Data, or (6) exercise other rights with respect to your User Data. To learn more about the User Data we collect about you or the rights you may have, please contact us at info@victor-sierra.com. 

  1. International Users 

Under the EU General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”), if you are a user residing in the European Economic Area (EEA) and the United Kingdom (UK), you have certain rights to your User Data, including the rights of access, correction, erasure, restriction, objection, and data portability, as well as the right to withdraw consent to certain processing of your User Data.     

The Company’s (1) legitimate interests and legal basis for processing your User Data; (2) categories of personal data we collect; and (3) storage and retention period of your User Data are set forth above. If the Company engages in any transfer of your User Data outside of the jurisdiction of collection or your residence, we will seek your consent as discussed above and/or transfer such User Data in accordance with the GDPR. 

While we strongly encourage you to first raise any questions or concerns about your User Data directly with us, you may have a right to lodge a complaint with the relevant supervisory authority. To exercise any of the rights listed in this section, or to contact the Company’s data protection officer , please contact us at info@victor-sierra.com.  

For users residing in other international countries, if you provide us with User Data, you understand that your User Data will be transferred to and processed in the United States of America and any other country or jurisdiction at our sole discretion. The laws that apply to the use and protection of User Data in the United States or other countries or jurisdictions in which we transfer or process your User Data may be different from the laws and protections in your country. Please contact us at info@victor-sierra.com. if you have any questions concerning your User Data.

California Users

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. 

For business purposes for the last twelve (12) months, the Company may have collected, used, and shared User Data about you as described in this Policy. The categories of User Data that the Company may have collected and used are set forth above. California residents have the right to request a copy of, access to, make revisions, or seek deletion of their User Data. California residents may also opt out of the sale of their User Data. 

California residents can also designate an authorized agent to submit requests on their behalf. We will take reasonable steps to verify your identity and the identity and authority of your authorized agent prior to complying with any request. The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights. Please note that certain information may be exempt from such requests under California law.

If you are a California resident and would like to exercise any of legal rights under the CCPA, please contact us at info@victor-sierra.com.  

Annually, California residents may request and obtain information about the User Data that the Company has shared with third parties for such third parties’ direct marketing purposes within the prior calendar year (as defined by California Civil Code § 1798.83, commonly known as California’s “Shine the Light Law”). If applicable, this information would include a list of the categories of User Data that was shared and the names and addresses of all third parties with which the Company shared this information in the immediately preceding calendar year. To obtain this information, please send an email message to info@victor-sierra.com with the words “California Shine the Light Privacy Request” in the subject line as well as in the body of your message. The Company shall then furnish any applicable requested information to your email address.

Other United States Users

For users residing in Colorado, Connecticut, Montana, Virginia, Tennessee, Texas, or Utah, and in other such states not explicitly listed, state law grants you additional rights with regard to your User Data under applicable law. You or your legally designated representative may submit a request to exercise your User Data rights by contacting us at info@victor-sierra.com. 

General Terms

This Policy, the Terms of Use, and any other terms or conditions posted by VSAH on any part of the Site, constitute the entire agreement between you and VSAH with respect to the matters herein and therein and supersede all prior and contemporaneous understandings, agreements, representations, and warranties, written and oral, between VSAH and you. No action or inaction by VSAH shall be construed as a waiver of this Policy, the Terms of Use, or any other terms or conditions posted on any part of the Site. No waiver by VSAH of any term or condition in this Policy, the Terms of Use, or any other terms or conditions posted on any part of the Site shall be deemed a further or continuing waiver of such term or condition or a waiver of any other term or condition. If any of the provisions of this Policy, the Terms of Use, or any other terms or conditions posted on any part of the Site are held to be invalid, unenforceable or illegal, such provision shall be eliminated or limited to the minimum extent such that the validity and enforceability of the remaining provisions of this Policy, the Terms of Use, and any other terms or conditions posted on any part of the Site shall not be effected thereby and shall continue in full force and effect.

Contact Information

To ask questions or comment about this Policy and our privacy practices, contact us at:

Victor Sierra Aviation Holdings LLC

1000 N. West Street

Wilmington, DE  19801

(800) 544-8594

 Or you may email us at: info@victor-sierra.com.