California Privacy Notice

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS ONLY supplements the information contained in the Privacy Notice of AAR (collectively, “AAR,” “we,” “us,” or “our”), and applies solely to any natural person who is a California resident or domiciled in California (“Consumers” or “You”). We publish this notice to comply with the California Consumer Privacy Act of 2018 as amended (“CCPA”) and other California privacy laws.

Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or household (“personal information”). In particular, we have collected the following categories of personal information from Consumers within the last twelve (12) months:

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

Information Collected – YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Information Collected – YES

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Information Collected – NO

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Information Collected – YES

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Information Collected – NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website including through use of cookies, application, or advertisement.

Information Collected – YES

G. Geolocation data.

Physical location or movements.

Information Collected – NO

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

Information Collected – NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

Information Collected – YES

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Information Collected – NO

K. Inferences drawn from other personal information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Information Collected – NO

Although AAR may collect the following additional categories of personal information, this information is not protected under CCPA:

• Publicly available information from federal, state or local government records.
• De-identified or aggregated consumer information.
• Information specifically excluded from the CCPA’s scope such as:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
  • personal information that AAR collects in the course of the California Consumer acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of AAR.
  • Emergency contact information collected to the extent an emergency contact is on file with AAR.
  • Written or verbal communications between a California Consumer and AAR when the California Consumer is acting as an employee, owner, director, officer, or contractor of an organization when the communications or transactions with AAR occur solely within the context of the business conducting due diligence regarding, or providing or receiving, an AAR product or service.
  • personal information necessary to administer AAR employee benefits.

Sources

We obtain the personal information described above from the following sources:

• Directly and indirectly from activity on our websites (www.aar.org or https://my.aar.org). For example, from submissions through our website portal or website usage details collected automatically through the use of cookies.
• Directly from our members or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
• Indirectly from our members or their agents. For example, through information we collect from our clients in the course of providing services to them.
• From third-parties that interact with us in connection with the services we perform.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided.
• To provide You with information, products or services that You request from us.
• To provide You with email alerts, event registrations and other notices concerning AAR products or services, or events or news, that may be of interest to You.
• To carry out our obligations and enforce our rights arising from any contracts entered into between You and us.
• To improve our website and present its contents to You.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or safety of us, our members or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.As described to You when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing You with notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category I: Professional or employment-related information.

We disclose your personal information for a business purpose to the following categories of third parties:

• Our subsidiaries and/or affiliates.
• Service providers.
• Third parties to whom You or your agents authorize us to disclose your personal information in connection with products or services we provide to You.

Your Rights & Choices

The CCPA provides Consumers (California residents) with specific rights regarding their personal information, including:

• The right to request individual disclosures including the right to request a copy of the specific personal information AAR collected about You during the 12 months before the request;
• The right to have such information deleted (subject to exceptions);
• The right to request that your personal information not be sold to third parties, if applicable;
• The right not to be discriminated against because You exercised any of the above-described rights; and
• The right to sue if AAR’s failure to implement and maintain reasonable safeguards results in the unauthorized access and exfiltration, theft, or disclosure of non-redacted or non-encrypted Personal Information as defined in the Act.

This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to You about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable Consumer request, we will disclose to You:

• The categories of personal information we collected about You.
• The categories of sources for the personal information we collected about You.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about You (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from You and retained, subject to certain exceptions. Once we receive and confirm your verifiable Consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 ).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if You previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which You provided it.

Exercising Access, Data Portability & Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable Consumer request to us by either:

• Calling us at (202-639-2100)
• privacy@aar.org
• Visiting aar.org or https://my.aar.org (login required)

Only You or a person registered with the California Secretary of State that You authorize to act on your behalf, may make a verifiable Consumer request related to your personal information. You may also make a verifiable Consumer request on behalf of your minor child.

You may only make a verifiable Consumer request for access or data portability twice within a 12-month period. The verifiable Consumer request must:

• Provide sufficient information that allows us to reasonably verify You are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide You with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to You. Making a verifiable Consumer request does not require You to create an account with us. We will only use personal information provided in a verifiable Consumer request to verify the requestor’s identity or authority to make the request.

Response Timing & Format

We endeavor to respond to a verifiable Consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform You of the reason and extension period in writing. If You have an account with us, we will deliver our written response to that account. If You do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable Consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable Consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell You why we made that decision and provide You with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against You for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny You goods or services.
• Charge You different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide You a different level or quality of goods or services.
• Suggest that You may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify You by email or through a notice on our website homepage.

Contact Information