LEADERSHIP IN FLIGHT TRAINING ACADEMY LLC and LIFT MAINTENANCE CALIFORNIA EMPLOYEE PRIVACY NOTICE

Last Updated: August 25, 2025

The California Consumer Privacy Act, as amended, including its implementing regulations (collectively, the “CCPA”) gives California residents certain rights and requires businesses to make certain disclosures regarding their collection, use, and disclosure of personal information. This California Employee Privacy Notice (the “Notice”) provides such notice to Leadership in Flight Training Academy LLC and LIFT Maintenance (“LIFT,” “we,” “us,” “our”) employees and independent contractors who are residents of California (collectively, “Employees”).

Please note that this Notice only addresses LIFT’s collection, use, and disclosure of personal information about Employees and only applies to residents of California. This Notice does not apply to individuals who are residents of other U.S. states and/or who are not Employees. For further details about our privacy practices pertaining to non-Employee personal information, please see our Privacy Policy.

As an Employee, you have the right to know what categories of personal information LIFT collects, uses, discloses, sells, and shares about you. This Notice provides that information and other disclosures required by California law.

A. DEFINITIONS

  • Personal information: As used in this Notice, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information includes sensitive personal information, but does not include protected health information covered by the Health Information Portability and Accountability Act (“HIPAA”), nonpublic personal information under the Gramm-Leach-Bliley Act (“GLBA”), publicly-available information, or any other information that is exempt from the CCPA.
  • Sensitive personal information: As used in this Notice, “sensitive personal information” includes personal information that reveals, among other things, social security number, driver’s license number, state identification card number, passport number, racial or ethnic origin, union membership, or the contents of a Consumer’s mail, email, and text messages, unless LIFT is the intended recipient of the communication. Sensitive personal information also includes information concerning the Employee’s health, or sexual orientation.
  • Other CCPA Definitions: As used in this Notice, the terms “collect,” “processing,” “service provider,” “third party,” “sale,” “share,” “consumer,” and other terms defined in the CCPA and their conjugates, have the meanings afforded to them in the CCPA, whether or not such terms are capitalized herein, unless contrary to the meaning thereof.

A. COLLECTION & PROCESSING OF EMPLOYEE PERSONAL INFORMATION

We, and our service providers, collect the following categories of personal information about Employees. We also have collected and processed the following categories of personal information about Employees in the preceding 12 months:

  1. Identifiers, such as 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, physical characteristics or description, or other similar identifiers;
  2. Contact and financial information, including phone number, address, email address, financial information, medical information, health insurance information, health insurance policy number;
  3. Characteristics of protected classifications under state or federal law, including race, ancestry, national origin, age (40 years or older), marital status, sex, sexual orientation, medical condition, disability, and veteran or military status;
  4. Biometric information
  5. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding an Employee’s interaction with an internet website, application, or advertisement;
  6. Geolocation data, such as device location;
  7. Audio, electronic, visual and similar information, such as call and video recordings;
  8. Professional or employment-related information, such as work history and prior employer;
  9. Education information, as defined in the federal Family Educational Rights and Privacy Act, such as student records and directory information; and
  10. Sensitive personal information, including:
    • Personal information that reveals:
      • Social security, driver’s license, state identification card, or passport number;
      • Account log-in, or financial account number; or
      • Racial or ethnic origin, or union membership;
    • Personal Information collected and analyzed concerning a consumer’s health.

C. CATEGORIES OF EMPLOYEE PERSONAL INFORMATION WE DISCLOSE TO SERVICE PROVIDERS & THIRD PARTIES

In the past twelve months, we have disclosed the following categories of Employee personal information to service providers and third parties for a business purpose:

  1. Identifiers, such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, social security number, driver’s license number, passport number, physical characteristics or description, or other similar identifiers;
  2. Contact and financial information, including phone number, address, email address, financial information, medical information, health insurance information, health insurance policy number;
  3. Characteristics of protected classifications under state or federal law, including race, ancestry, national origin, age (40 years or older), marital status, sex, sexual orientation, medical condition, disability, and veteran or military status;
  4. Biometric information;
  5. Audio, electronic, visual and similar information, such as call and video recordings;
  6. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding an Applicant’s interaction with an internet website, application, or advertisement;
  7. Geolocation data, such as device location;
  8. Professional or employment-related information, such as work history and prior employer;
  9. Education information, as defined in the federal Family Educational Rights and Privacy Act, such as student records and directory information; and
  10. Sensitive personal information, including:
    • Personal information that reveals:
      • Social security, driver’s license, state identification card, or passport number;
      • Account log-in, or financial account number; or
      • Racial or ethnic origin, or union membership;
    • Personal Information collected and analyzed concerning a consumer’s health.

D. PURPOSES FOR PROCESSING & DISCLOSING EMPLOYEE PERSONAL INFORMATION

We, and our service providers, collect, process, and disclose Employee personal information (excluding sensitive personal information) described in this Notice to:

  • Manage your Employee relationship with us;
  • Manage and provide compensation, payroll, tax, and benefits planning, enrollment, and administration;
  • Provide you access to our systems, networks, databases, equipment, and facilities;
  • Manage our workforce and its performance, including personnel planning, productivity monitoring, and evaluation;
  • Manage workforce development, education, training, and certification;
  • Monitor, maintain, and secure our systems, networks, databases, equipment, and facilities;
  • Authenticate your identity and verify your access permissions;
  • Arrange, confirm, and monitor work-related travel, events, meetings, and other activities;
  • Assess your working capacity or the diagnosis, treatment, or care of a condition impacting your fitness for work, and other preventative or occupational medicine purposes (including work-related injury and illness reporting);
  • Contact and communicate with you regarding your employment, job performance, compensation, and benefits, or in the event of a natural disaster or other emergency;
  • Contact and communicate with your designated emergency contact(s) in the event of an emergency, illness, or absence; and
  • Contact and communicate with your dependents and designated beneficiaries in the event of an emergency or in connection with your benefits.

In addition to the purposes identified above, LIFT may use and disclose any and all Employee personal information we collect as necessary or appropriate to:

  • Comply with laws and regulations, including, without limitation, applicable tax, health and safety, anti-discrimination, immigration, labor and employment, and social welfare laws;
  • Monitor, investigate, and enforce compliance with and potential breaches of LIFT policies and procedures and legal and regulatory requirements;
  • Comply with civil, criminal, judicial, or regulatory inquiries, investigations, subpoenas, or summons; and
  • Exercise or defend the legal rights of LIFT and its employees, affiliates, customers, contractors, and agents.

E. PURPOSES FOR PROCESSING & DISCLOSING EMPLOYEE SENSITIVE PERSONAL INFORMATION

We, and our service providers, collect, process, and disclose the sensitive personal information described in this Notice only for the below purposes that are authorized by the CCPA:

  • Performing the services reasonably expected by an average consumer who requests those services;
  • Ensuring security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes;
  • Preventing, detecting, and investigating security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information;
  • Resisting malicious, deceptive, fraudulent, or illegal actions directed at the business and prosecuting those responsible for those actions;
  • Ensuring the physical safety of natural persons;
  • Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a consumer’s current interaction with us; provided that we will not disclose the consumer’s personal information to a third party and/or build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with us;
  • Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf;
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured by, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us; and
  • Collecting or processing sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

F. SALE & SHARING OF EMPLOYEE PERSONAL INFORMATION

We sell and share, and have sold and shared in the past twelve months, personal information we collect on our websites via cookies and other tracking technologies, such as IP addresses and other electronic network activity information. We sell and share this information to marketing and analytics providers to personalize, advertise, and market our products and services. You have the right to opt out of the sale and sharing of your personal information and can do so by clicking the “Your Privacy Choices” link in the footer of our websites and then clicking “Reject All.”

We will not sell or share any of the other categories of Employee personal information we collect, and we have not sold or shared any of the other categories of Employee personal information we have collected in the past twelve months. Relatedly, we do not have actual knowledge that we sell or share personal information of California consumers under 16 years of age. For purposes of the CCPA, a “sale” is the disclosure of personal information to a third party for monetary or other valuable consideration, and a “share” is the disclosure of personal information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

G. RETENTION OF EMPLOYEE PERSONAL INFORMATION

We retain each of the categories of personal information listed in Section B for the duration of your Employee relationship with us, and longer as may be required by applicable laws or necessary for our legitimate business purposes.

H. CATEGORIES OF ENTITIES TO WHOM WE DISCLOSE EMPLOYEE PERSONAL INFORMATION

  • Affiliates & Service Providers. We may disclose Employee personal information to our affiliates and service providers for the purposes described in Sections D and E of this Notice, as applicable. Our service providers provide us with Employee selection and related hiring services, website services, as well as other products and services, such as web hosting, data analysis, customer service, infrastructure services, technology services, email delivery services, legal services, and other similar services. We grant our service providers access to Employee personal information only to the extent needed for them to perform their functions, and require them to protect the confidentiality and security of such information.
  • Third Parties. For each category of Employee personal information identified in Section C, we disclose such personal information to the following categories of third parties:
    • At Your Direction. We may disclose your personal information to any third party with your consent or at your direction.
    • Business Transfers or Assignments. We may disclose your personal information to other entities as reasonably necessary to facilitate a merger, sale, joint venture or collaboration, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
    • Legal and Regulatory. We may disclose your personal information to government authorities, including regulatory agencies and courts, as reasonably necessary for our business operational purposes, to assert and defend legal claims, and otherwise as permitted or required by law.

I. SOURCES FROM WHICH WE COLLECT EMPLOYEE PERSONAL INFORMATION

We collect personal information directly from Employees. We also collect personal information from public databases, providers of demographic data, publications, professional organizations, educational institutions, social media platforms, service providers and third parties that help us screen and onboard individuals for hiring purposes, and service providers and third parties when they disclose information to us.

J. DATA SUBJECT RIGHTS

  • Exercising Your Rights. You may exercise the right to opt-out of sales or sharing of your personal information or processing of your personal information for purposes of targeted advertising by clicking the “Your Privacy Choices” link in the footer of our websites and then clicking “Reject All.” You may exercise the other data subject rights below by email at privacy@flywithlift.com, by phone at 1-844-565-5546 or by clicking here and submitting details regarding your request. You may also authorize an agent to submit data subject requests to us on your behalf. In such instances, authorized agents may use the same methods as you to submit the requests on your behalf. To verify your identity and protect your Personal Information, we may ask the requestor to provide information that will enable us to verify your identity in order to comply with your data subject request, such as asking your agent to provide proof of signed permission from you, or ask you to confirm with us directly that you provided the agent with permission to submit the request. In some instances, we may decline to honor your request if an exception applies under applicable law. We will respond to your request consistent with applicable law.
  • Data Subject Rights Available to You. As an Employee, you have the following rights regarding our collection and use of your personal information, subject to certain exceptions:
    • Right to Know: You have the right to know the following details about our privacy practices at or before the point of collection. We have provided such information in this Notice. You may also request that we provide you with information about the following aspects of how we have handled your personal information:
      • The categories of personal information we have collected about you;
      • The categories of sources from which we collected such personal information;
      • The business or commercial purpose for collecting, selling, or sharing personal information about you;
      • The categories of third parties to whom we disclose personal information; and
      • Specific pieces of personal information we have collected about you.
    • Right to Deletion: You may request that we delete any personal information about you we that we collected from you.
    • Right to Correction: You may request that we correct any inaccurate personal information we maintain about you.
    • Rights to Opt-Out of the Sale and Sharing of Your Personal Information and to Limit the Use of Your Sensitive Personal Information: You have the right to opt-out of the sale and sharing of your personal information. You also have the right to limit the use of your sensitive personal information to the purposes authorized by the CCPA. However, please note that we do not use or disclose Employee sensitive personal information for purposes beyond those authorized by the CCPA.
    • Right to Non-Discrimination: You have the right not to be discriminated against for exercising your data subject rights. We will not discriminate against you for exercising your data subject rights. For example, we will not make hiring, firing, promotion, or disciplinary decisions based on or in consideration of your exercise of your data subject rights.
  • Opt-Out Preference Signals. We recognize opt-out preference signals that we are required to recognize for compliance with applicable law. Where required by law, we treat such opt-out preference signals as a valid request to opt-out of sale and sharing for the browser or device through which the signal is sent and any consumer profile we have associated with that browser or device, including pseudonymous profiles. Further, if we know the identity of the consumer from the opt-out preference signal, we will also treat the opt-out preference signal as a valid request to opt out of sale and sharing for such consumer. Employees may use opt-out preference signals by downloading or otherwise activating them for use on supported browsers and setting them to send opt-out preference signals to websites they visit.

K. OTHER DISCLOSURES

  • Financial Incentives. We do not provide financial incentives to Employees who allow us to collect, retain, sell, or share their personal information. We will describe such programs to you if and when we offer them to you.
  • Changes to this Notice. We reserve the right to amend this Notice at our discretion and at any time. When we make material changes to this Notice, we will notify you by posting an updated Notice on our website and listing the effective date of such updates.
  • Contact Us: More information about our privacy practices can be found in our Privacy Policy. If you have any questions regarding this Notice or LIFT’s collection and use of your personal information, or would like to exercise your data subject rights, please contact us by mail at Chief Information Officer, LIFT, 2753 Cargo Drive, Indianapolis, IN 46241, by email at privacy@flywithlift.com, or by phone at (844) 565-5546. If you are unable to review or access this notice due to a disability, you may contact us via any of the above methods to access this notice in an alternative format.

View the LIFT Privacy Policy

View the Applicant Privacy Notice

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