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X-1FBO DATA USE AND SHARING POLICY

Last Updated: November 14, 2024

Introduction

This Data Use and Sharing Policy ("the Policy") is a legally binding agreement and forms an integral part of the Terms and Conditions of use for the X-1FBO software, including any associated services and platforms such as the X-1 Data Hub, provided by [Your Company Name] ("the Company"). This Policy governs the collection, use, sharing, and protection of data obtained from Users of the X-1FBO software, X-1 Pilot, and other X-1 products, as well as from Third-Party System Users, such as Jet Insight or Tuvoli.


Definitions

  • "User" refers to any individual or entity registered and using the X-1FBO software or any other X-1 products.

  • "Third-Party System User" refers to individuals or entities using external software systems that integrate with the X-1FBO software.

  • "Personal Data" refers to any information relating to an identified or identifiable natural person.

  • "Proprietary Data" includes any confidential and/or proprietary information, pricing, personal notes, and FBO-specific data.

  • "Shared Data" encompasses non-proprietary, non-sensitive data suitable for sharing within the X-1 Data Hub.

Data Collection and Use

  1. Data Collection: The Company collects various types of data, including but not limited to user-identified data, operational data, and transactional data from its Users and Third-Party System Users.

  2. Use of Data for System Management and Support: Access to User data is essential for managing the X-1FBO system, providing necessary customer support, troubleshooting issues, and ensuring optimal software performance. The Company may access data for these purposes with the strictest confidentiality.

  3. Use of Data for Market Research: The Company may also use aggregated and anonymized data for market research purposes, including but not limited to regional pricing analysis, industry benchmarking, and price reasonableness studies (e.g., for the Defense Logistics Agency (DLA) contract). In all such cases, the Company will ensure that data cannot be linked to any specific User. When necessary, data sets will be adjusted or excluded to prevent identification, such as removing pricing data for a region with few customers to maintain confidentiality.

Data Ownership, Sharing, and Disclosure

  1. Ownership and Control: Users retain ownership and control over their Proprietary Data.

  2. Consensual Sharing of Proprietary Data: Users may opt to share Proprietary Data, including specific pricing information, under specific circumstances or with specific entities, at their discretion.

  3. Aggregated and Anonymized Data: The Company may use aggregated or anonymized data, which does not identify any specific User, for analytics, market research, and product improvement, as permitted by law.

Data Security and Confidentiality

  1. Security Measures: The Company commits to implementing and maintaining robust security measures to protect data against unauthorized access, alteration, disclosure, or destruction.

  2. Confidentiality Obligations: The Company and its Users shall maintain the confidentiality of all Proprietary Data, only using such data for the purposes permitted under this Policy and applicable law.

  3. Non-Disclosure of Identifiable Data: The Company will take all reasonable steps to ensure that any data used for market research, reporting, or benchmarking remains anonymized and aggregated, avoiding any identification of specific Users.

User Rights and Responsibilities

  1. User Consent: By using the X-1FBO software, Users consent to the collection, use, and sharing of data as outlined in this Policy.

  2. Data Accuracy and Updating: Users are responsible for ensuring that their data is accurate, complete, and up-to-date.

Liability, Indemnification, and Compliance

  1. Compliance with Laws: The Company and its Users shall comply with all applicable laws and regulations relating to data protection and privacy.

  2. Limitation of Liability: The Company shall not be liable for any loss or damage arising from unauthorized use or disclosure of Shared or Proprietary Data by Users or Third Parties.

  3. Indemnification: Users agree to indemnify and hold harmless the Company from any claims, damages, or expenses arising from their violation of this Policy.

8. Amendments and Modifications

  1. Policy Changes: The Company reserves the right to modify this Policy at any time. Users will be notified of significant changes through the X-1FBO software interface or via email.

  2. Acceptance of Changes: Continued use of the software after such changes constitutes acceptance of the new terms.

Governing Law and Jurisdiction

This Policy shall be governed by the laws of [Jurisdiction], without regard to its conflict of law provisions.


Contact Information and Inquiries

For questions or concerns regarding this Policy, please contact GMSTEK at:

  • Email: info@gmstek.com

  • Address: 18001 Old Cutler Rd., Suite 472, Palmetto Bay, FL 33157

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