MCGEE AIR SERVICES TEAM MEMBER PRIVACY POLICY  

McGee Air Services (“McGee”, “we” or “us”) provides this Team Member Privacy Policy (the “Policy”) to inform you of our practices regarding the collection, use, storage and disclosure of personal and other information we collect from current and former employees, directors, contractors, and officers (collectively “McGee Team Member” or “you”) in connection with your working relationship with McGee. 

Scope of the Policy 

The Policy covers “Personal Information” and other information of McGee Team Member that McGee collects in connection with your employment or working relationship with McGee.  When we refer to “Personal Information,” we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or is otherwise defined or regulated as personal information under applicable laws or regulations. This includes information that directly identifies you (e.g., your name, social security number or other government-issued identifier), but also includes information that we have linked to those identifiers (e.g., your date of birth, telephone number, and information about your performance, all of which are linked to your name). 

Except as may be specifically required by law, this Policy does not apply to information available from a public source (such as a telephone directory) or to aggregated or de-identified information McGee may collect about its workforce, nor to references to McGee Team Member in company work product, such as the names of persons attending a meeting, contributing to a report, or signing a purchase order.  You may also provide information on others, such as a family member you name as a beneficiary.  When you provide such information, you confirm that you are authorized to do.  McGee will process and store such information in accordance with this Policy. 

McGee Company-Wide Procedures 

In addition to this Policy, McGee maintains other policies intended to help protect your Personal Information, such as McGee’s privacy and security procedures documented in the McGee employee handbook. Your careful attention to these and other policies and procedures will help maintain your privacy and respect the privacy of others. Relevant company-wide procedures can be found on the McGee Intranet, at: McGee Handbook.  

Protection of Applicable Laws 

In addition to this Policy, federal, state, local and similar laws may govern our use of your Personal Information (including certain sensitive information, such as medical and financial records, bank account and payment card details, official identifiers such as Social Security and driver’s license numbers, and student records) and your rights with regard to your Personal Information. Our practices reflect those requirements as set forth by applicable law in the jurisdiction in which you work for McGee. Information revealing certain personal or family circumstances, such as age, gender, disability, medical or family leave, physical or mental disabilities, racial or ethnic origin, religious preference, and sexual orientation are also often regulated by anti-discrimination and other laws.  The details of these laws vary among the states, where we operate. Human Resources can direct you to sources for additional information on these topics.  McGee conducts its business and handles the information related to McGee Team Member in compliance with applicable law in the relevant jurisdiction of the applicable individual.  

Personal Information Collected Regarding You 

Throughout your working relationship with us (e.g., through on-boarding, using our systems, and signing up for benefits), we collect types of Personal Information necessary to manage our relationship with you. 

We may collect Personal Information about you directly from you, from publicly available information about you (which may include information you post publicly to social media websites), automatically when you use our systems, and sometimes from third parties. 

The Personal Information that we collect and use about you may include:  

• Application information that becomes part of your file once you become McGee Team Member (e.g., your resume, information you provide on our application form, references supplied by your former employer); 

• Right to work information (e.g., work permit / visa application information, citizenship and/or legal residency information, or any other information required by federal or state law); 

• Basic personal details (e.g., name, date of birth); 

• Contact details (e.g., telephone number, email address, postal address); 

• Information required for payroll purposes (e.g., bank account details, tax information); 

• Information related to benefit entitlements and schemes (e.g., details of participation, contributions made); 

• Information related to gender, race or ethnic origin for purposes of complying with applicable anti-discrimination  legislation (where applicable); 

• Information we are required to collect by government, airport authorities, or other third parties that control the areas where you will work, including restricted areas (e.g. driving records to use airport vehicles);  

• Medical information, if necessary to comply with applicable laws, or in order to provide workplace accessibility, accommodations, or medical care to you (such as through workplace assessments and for the other purposes described below); 

• Performance related data (e.g., information about and assessments of your performance collected as part of the employee review process); 

• Information relating to the results of third party background checks about you (e.g. results of a criminal background check, driving records check, or drug and breath alcohol tests), however we do not receive information beyond pass/fail results in connection with such tests;  

• Location information, including through GPS tracking technology on devices owned by McGee (e.g., use of technology on laptops owned by McGee to locate and/or wipe lost or stolen laptops), however, we do not collect location information from or otherwise track your personal devices; 

• Information in connection with disciplinary action or investigations; 

• Information about your use of our systems or information that you provide to us through our information systems (e.g., information from your company email account, information posted on our website, information you submit through applications or software made available to you); 

• The content of communications by or about you made on McGee corporate communications systems  where McGee is not the intended recipient (such as McGee email, Teams, and other messaging services made available by McGee); 

• Audio-visual information, such as photos, videos and voice recording, for purposes of protecting and securing McGee facilities and property, and other McGee Team Member;  

• Payment information you provide for goods, services, and other transactions authorized by you in your capacity as McGee Team Member, such as travel expenses;  

• Biometric information, such as your fingerprint for purposes as described below, or your face for facial recognition; 

• Any other information that you provide directly to us in connection with your working relationship with McGee or that we receive in the course of your relationship with us. 

You may be granted certain travel privileges as a benefit of your job, and you may be granted the right to extend travel privileges to your relatives, such as your spouse or significant other, parent, sibling, or child. If you choose to do so, we will collect your relative’s Personal Information from you to administer the program. In addition, we will require you to provide us with information that proves your relationship in order to qualify your relative for travel privileges, such as a birth certificate or adoption paperwork. 

To the extent permitted by applicable law, we may collect information about you from your personal social media accounts that is made publicly available.  

You understand that all messages and other information, including Personal Information about you, communicated through McGee systems (such as McGee email, Teams and other messaging services made available by McGee) are considered corporate communications and subject to monitoring, use and disclosure by McGee. You have no expectation of privacy in connection with the communication, transmission, receipt or storage of any information through McGee systems, even when that information is deleted or protected by passwords.  

Purposes for which Your Personal Information is Used  

We use your Personal Information primarily to manage our relationship with you by providing services that facilitate your working relationship with us and providing you benefits and privileges that you earn through working with us. We also use your Personal Information to help us manage our business, including management of resources, and keep our systems secure. 

Where furnishing your Personal Information is optional (such as providing an emergency contact or enrolling in a benefits program), we tell you so.  Where it is not optional, we ask for it because we have a legal obligation to collect it or because we require it for our legitimate interests in managing the business. 

The purposes for which we use Personal Information may include: 

• Running and managing our business; 

• Recruitment; 

• Providing you with equipment, training and support so that you can carry out your role. We do this in order to meet applicable contractual and employment related obligations to you; 

• Providing staff training, feedback, disciplinary procedures and investigations to meet our legitimate interests in ensuring our staff are best able to carry out their roles; 

• Compensation and benefits management, to ensure that you are paid and can take advantage of benefits offered by McGee and its partners;  

• Providing you care and notifying your loved ones in case of an emergency; 

• Organization management and administration, including management of staffing resources, financial planning, corporate compliance, internal audits and other administration to meet our legitimate interests in running our business effectively; 

• Career development, succession planning, and consideration for transfers and promotions; 

• Administration of travel and entertainment reporting and corporate card program; 

• Administration of absences in accordance with company and statutory leave programs; 

• Communications necessary to manage our business (ie SMS text messages)

• Compliance with legal obligations, including health and safety requirements, requests for information from government agencies, and security investigations; 

• Provision of employment references if requested by a potential employer; 

• Administering our applications, software, and systems; 

• Statistical and analytical purposes to understand and improve worker satisfaction and performance; and 

• Such other purposes as we may disclose to you from time to time. 

How We Share Your Personal Information  

We will not disclose, sell or otherwise distribute to any third party any of your Personal Information without your prior permission, except under the following circumstances: 

• At your direction: We may disclose your Personal Information when you direct us to do so, such as when you enroll in health care benefits. 

• Subsidiaries and Affiliates: We may share your Personal Information with our affiliates and subsidiaries for business, analytical, and operational purposes.  

• Text Message Data. Notwithstanding anything else in this policy, we do not share Personal Information we collect specific to our text message programs (such as mobile number and record of consent) with third parties for their own direct marketing purposes without your specific consent.  

• Third-party service providers: We may outsource some or all of the operations of our business to third-party service providers and we may use third parties to act as our agents to provide services to us or to you. Services provided by third parties may include payroll processing, administering and providing you with benefits, accounting, legal, and other professional services. In such cases, it will be necessary for us to disclose your data to those service providers. In some cases, the third parties may collect data directly from you on our behalf. We restrict how such third parties may access, use and disclose your data. 

• Labor unions or works councils, where applicable: We may share relevant records such as those concerning eligibility, ballots, grievances, and payroll deductions with authorized employee representatives, where applicable.  

• Airport and government authorities: We may be required to disclose certain information about you, such as driving records or background check results, to airport authorities, government agencies or other third parties (e.g. USPS when you work at USPS facilities or handle mail) to obtain authorizations for you to work in restricted areas and/or operate equipment on the ramp or elsewhere in the airport. 

• Legal requests and investigations and to comply with law: We may be required to disclose certain information about you to comply with government requirements, laws, or regulations. We may disclose any data about you when, in our opinion, such disclosure is necessary to prevent fraud or to comply with any statute, law, rule or regulation of or any legal process issued by any governmental authority or any order of any court of competent jurisdiction. We may also disclose data about you when necessary for McGee to exercise and defend legal claims and enforce its rights. 

• Business Transfers: As we continue to develop our business, we might sell or buy companies, subsidiaries, or business units. In such transactions, employee data generally is one of the transferred business assets. Any data transferred will, to the extent required by law, remain subject to the promises made in any pre-existing privacy statement unless you consent to the new privacy policy, which may be required as a condition of employment, subject to applicable law in your jurisdiction. 

When you take advantage of our travel privileges program, our travel partners (e.g. Alaska Airlines, ID90 or MyID Travel) may collect your Personal Information directly from you to provide you with flights and other travel privileges offered through the program. Personal Information that you provide directly to our travel partners is not subject to this Policy, and will be governed by the travel partner’s own privacy policy and terms. Note that, as part of the travel privileges program, we may share your Personal Information to confirm your eligibility for offered privileges or as otherwise necessary for our partners to administer travel privileges. Our travel partners may also share information with us, including Personal Information, about your use of travel privileges. 

Sometimes, you may be required to submit your Personal Information to a third-party company that we have engaged to provide you services necessary to perform your job duties, for example a third-party business travel agent. When you interact with such third parties, the collection and use of your Personal Information will be subject to the third party’s own privacy policy and terms of use and is not governed by this Policy.  

Video Recording  

To protect and ensure the safety of you, other persons in the working environment and McGee’s and third parties’ equipment and vehicles, vehicles in the work environment may be equipped with video camera monitors (“Vehicle Cameras”) directed at both the interior and exterior of the vehicle. In addition, the facilities where you work (such as the airport ramp, airline hangars and other facilities where McGee Team Member may be assigned to work) may be equipped with video cameras (“Facility Cameras”) directed at the interior or the exterior of the facility. 

Vehicle Cameras and Facility Cameras may be operated by McGee or other third parties active in the work environment (for example, the airport operator, or airlines operating at the airport). McGee may collect through Vehicle Cameras and Facility Cameras information relating to the vehicle or facility, as applicable, and your use of the vehicle or facility, including video recordings of persons in the vehicle or facility, some of which may constitute Personal Information as described in this Policy. Vehicle Cameras may also collect your geolocation data. McGee may directly collect any such information through Facility Cameras or Vehicle Cameras that it operates or it may receive such data collected through Facility Cameras or Vehicle Cameras operated by third parties. In addition, McGee may share data it directly collects through Facility Cameras or Vehicle Cameras with other third parties that are active in the work environment (for example, the airport operator, airlines operating at the airport, or USPS).  

McGee processes Personal Information collected through the Facility Cameras and Vehicle Cameras, and vehicle-related information collected through the Vehicle Cameras, to protect the safety of you, other persons in the work environment, the facilities and the vehicles, for your training, and to monitor and enforce compliance with all applicable McGee policies and employment terms. Information collected through third party Facility Cameras and Vehicle Cameras may be used for safety, training or other purposes by their respective third party operators and is subject to the applicable third party’s privacy policies. 

Use and Storage of Fingerprinting Data  

McGee may collect your fingerprint data, in connection with providing access to McGee systems and/or devices, in connection with your timekeeping, or in connection with background checking required by government or airport authorities or USPS for you to access their restricted areas when required to do so for your job. Fingerprint data will be collected, used, processed and retained as described in this Policy, and where required by law will be collected only with your consent. We may share fingerprint data we collect from you when required by government or airport authorities or USPS to conduct background checks to obtain authorization for you to work in their restricted areas. Fingerprint data may also be shared with McGee’s service providers solely in connection with the purposes set forth in this paragraph.  

Security of Your Personal Information 

We have adopted commercially reasonable security procedures and practices designed to protect your Personal Information in our possession from loss, misuse and unauthorized access, disclosure, alteration, and destruction. Access to our systems that store your Personal Information is restricted, including by means of a user ID and password that are issued only to authorized team member. You are also responsible for preventing unauthorized access to your Personal Information by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have accessed your account(s). 

Retention of Your Personal Information 

The length of time we retain your Personal Information depends on the status of our relationship with you and applicable legal requirements. We will retain your Personal Information for as long as your working relationship with us lasts, and for a certain period after your working relationship with us has ended. To determine that period, we take into account our legal and regulatory obligations (such as financial reporting obligations and equal opportunity or anti-discrimination reporting obligations) and whether we may need to retain Personal Information to resolve disputes, make and defend legal claims, conduct audits, pursue legitimate business purposes and/or enforce our agreements.  

Changes to this Policy 

We may amend this Policy from time to time. If we make any material changes to the way we use or disclose your Personal Information, we will notify you where required by law. If required by applicable law, we will afford you the opportunity to consent or to opt out of any new use or disclosure. 

Questions about this Policy 

Any questions regarding this Policy may be directed to Human Resources at servicecenter@mcgeeairservices.com. 

Notice to California Residents 

California provides additional privacy rights to residents of the state. If you are a California resident, please see our Notice to McGee’s California Team Members for more information about how to exercise your privacy rights. 

Support contact: servicecenter@mcgeeairservices.com | 1-206-788-8000