Introduction

Propeller Industries, LLC (“Company”) is a Delaware Limited Liability Company with its principal place of business located at 110 William Street, Suite 2200, New York, NY 10038 (United States). This statement (“Privacy Statement”) sets forth the privacy standards that the Company utilizes to collect, retain, and use personal data obtained from individuals located within the European Union and the United Kingdom (together, for purposes of this Privacy Statement, the “EU”), the European Economic Area (“EEA”) and Switzerland, as well as from individuals located in the United States and elsewhere in the world. It is the Company’s policy to respect, and protect, personally identifiable information obtained from individuals as set forth in this Privacy Statement.

There are certain provisions of this Privacy Statement that only apply to individuals from the EU or EEA. Those sections are denoted as “EU/EEA Data Subjects Only.”

There are certain provisions of this Privacy Statement that do NOT apply to individuals from the EU or EEA. Those sections are denoted as “Not Applicable to EU/EEA Data Subjects.”

1. What Is the Scope of this Statement?

This Privacy Statement sets forth the principles under which the Company collects, uses, processes, retains, and discloses personal data and/or sensitive data in the United States from individuals, including by and through our website located at https://www.propellerindustries.com/ (the “website”) and information you provide to us based upon information from our website (i.e., if you send us an e-mail at an e-mail address identified on the website). This statement covers information received in electronic or other formats.

2. Terms

The terms “we”, “us” and “our” refer to the Company, and its officers, directors, owners, employees and agents.

The term “personal data” means any data which relates to a natural person (as opposed to a business or corporate entity) that makes you identifiable. As used herein and in connection with our business, the term personal data may include:

    • Names and contact information, including phone number, physical address, fax and e-mail;
    • Social security number or other national identification number;
    • Gender and nationality;
    • Date of birth;
    • IP address;
    • Title, position, business/company name; and
    • Any other similar information provided to us by you or your company in connection with our services.

The term “data controller” means the person or entity that decides the purposes for which, and the way in which, any personal data is processed.

The term “data processor” means the person or entity which processes personal data on behalf of the data controller.

The term “processing” means any operation or set of operations performed on personal data. Processing includes, but is not limited to, the collection of data, the organizing of data, the recording or saving/storage of data, the altering of data, the using of data, the disclosing or transfer of data, the deleting or destruction of data, or the making available of data.

4. How We Collect Information About You

We collect information about you (including personal data) when:

    • You Give Us Information. You may provide us information when:

– you set up an account with us; you provide it to us by filling out forms;
– you send us e-mail or provide information via phone or in person;
– you provide us with information in writing and send it to us other than via e-mail, phone or in person (i.e., mail, FedEx, etc.);
– you provide us with documentation.
– you provide us with information that may contain personal data;
– you provide it to use through our “Contact” page on the website;
– you provide us with information in connection with seeking employment with the Company.

    • We Collect Information Automatically – We automatically collect certain types of information when you visit our website (as explained below).
    • We Collect Information From Other Sources – We may also obtain information about you from outside sources, for example, commercially available information about you obtained from third-parties. We may also receive information from third-parties who provide services for us through web-beacons and other technologies described in this Privacy Statement.

5. Use Of Cookies

About Cookies

    • A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
    • Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
    • Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

Cookies That We Use

We use cookies for the following purposes related to the services we provide for and to you and our users:

    • authentication – we use cookies to identify users of the website and/or the location of individuals accessing the website;
    • status – we use cookies to help us to determine if you are logged into our website;
    • personalization – we use cookies to store information about your preferences and to personalize the website for you;
    • security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
    • analysis – we use cookies to help us to analyze the use and performance of our website and services; and
    • cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

Cookies Used By Our Service Providers And Vendors

    • Our service providers and vendors may use cookies and those cookies may be stored on your computer when you visit our website. These service providers and vendors may include:

– Google Analytics (google.com/analytics)
– Google Tag Manager (google.com/analytics/tag-manager)
– Google AdWords (https://adwords.google.com)
– Facebook (facebook.com)
– LinkedIn (linkedin.com)
– Instagram
– Godaddy
– Twitter
– Greenhouse (greenhouse.io)
– Wordpress (https://wordpress.com)

    • You should review the privacy and cookie policies of the above websites to learn more about the cookies that are used in connection with the above.

Managing Cookies

    • You can manage cookies on the website by going to the home-screen at https://www.propellerindustries.com/ and clicking on the “Cookies” tab at the bottom;
    • Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

– Chrome: https://support.google.com/chrome/answer/95647?hl=en (Chrome);
– Safari: https://support.apple.com/kb/PH21411
– Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
– Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
– Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
– Opera: http://www.opera.com/help/tutorials/security/cookies/ (Opera);

    • Blocking some or all cookies may have a negative impact upon the usability of many websites, including our website and our services.

6. Server Logs

A web “server log” is a record of activity created by a computer that delivers certain webpages to your browser. Certain activities that you perform on our website may record information in server logs. For example, if you enter a search term into a search box located on the website, the server log may record the search term, the link you clicked on to bring you to our website and/or information about your browser, such as your IP address and the cookies set on your browser.

7. How We Use Your Personal Data

    • We process your personal data identified in this Privacy Statement to perform the Services as defined above. The legal basis for this processing is your consent set forth herein, as well as our contractual obligations.
    • We may process your personal data identified in this Privacy Statement where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings, alternative dispute resolution or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
    • We may process your personal data identified in this Privacy Statement where necessary for the purposes of managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
    • We may process your personal data identified in this Privacy Statement where such processing is necessary or advisable for compliance with a legal obligation to which we are subject (in the United States, the EEA, the EU, Switzerland or otherwise), or in order to protect your vital interests or the vital interests of another natural person.

8. Providing Your Personal Data To Others

    • We may disclose your personal data to our officers, directors, employees, and agents insofar as reasonably necessary for the purposes, and on the legal bases, set out in this Privacy Statement, including to provide or potentially provide Services to you or for your benefit.
    • We may disclose your personal data to our professional advisers insofar as reasonably necessary for the purposes of managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings, ADR or in an administrative or out-of-court procedure.
    • We may disclose certain of your personal data to the suppliers and subcontractors pursuant to separate consent provided by you to us.
    • The foregoing disclosures are made insofar as reasonably necessary, and only to the extent required, for assisting us in providing our Services to you, storing data and in connection with the administration of our business.
    • In addition to the specific disclosures of personal data set out in this Section 9, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings, alternative dispute resolution, or in an administrative or out-of-court procedure.

9. International Transfers Of Your Personal Data – For EU/EEA Data Subjects Only

    • In this Section 9, we provide information about the circumstances in which your personal data may be transferred to countries outside the EEA (Austria, Belgium, Bulgaria, Czech Republic, Cyprus, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, United Kingdom) or Switzerland.
    • Propeller Industries, LLC, is a California Limited Liability Company with its principal place of business located at 110 William Street, Suite 2200, New York, NY 10038 (United States). The European Commission has made an “adequacy decision” with respect to the data protection laws of the United States. In the event the Company transfers any of your personal data to a third party in the United States or elsewhere outside of the EEA, such transfers will be protected by appropriate safeguards through the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
    • By providing your personal data to the Company, you are agreeing to the transfer and processing of your personal data to and in the United States in accordance with this Privacy Statement.
    • By using our Services, you are agreeing to the transfer and processing of your personal data to and in the United States in accordance with this Privacy Statement.

10. Retaining And Deleting Personal Data

    • This Section 10 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
    • Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
    • It is often not possible for us to specify in advance the periods for which your personal data will be retained as the purpose for which it was obtained and the requirements of retention may vary. Therefore, we will determine the period of retention based upon the performance of our Services, and any applicable industry and governmental standards.
    • We may also retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

11. Amendments

    • We may update this Privacy Statement from time to time by publishing a new version on our website.
    • You should check this page occasionally to ensure you are happy with any changes to this Privacy Statement.
    • We may notify you of significant changes to this Privacy Statement by email or through the private messaging system on our website.

12. Your Rights – EU/EEA Data Subjects Only

    • In this Section 12, we have summarized the rights that EU/EEA data subjects have under applicable data protection law, including the GDPR. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
    • Your principal rights under data protection law are:

– the right to access;
– the right to rectification;
– the right to erasure;
– the right to restrict processing;
– the right to object to processing;
– the right to data portability;
– the right to complain to a supervisory authority; and
– the right to withdraw consent under certain circumstances.

    • You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
    • You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
    • In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing where no other legitimate basis for retention exists; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation (including contractual obligations); or for the establishment, exercise or defense of legal claims.
    • In some circumstances you may have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
    • You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
    • You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
    • You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
    • If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
    • To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
    • If you do not wish to receive emails about special offers and other promotions from us, click the unsubscribe link located in our emails.
    • You may exercise the same rights as individuals from California (United States) pursuant to Section 15 below by using the contact information instructions set forth in Section 15, or below in this Section.
    • If you do not wish to receive other marketing materials from us and/or if you do not want us to share your personal information with other entities as stated in this Privacy Notice, please provide us with your exact name and address and advise us that you wish to opt-out for information sharing or receiving information from us or both as the case may be. Please note that de-identified and aggregate data including your personal information may still be shared, but it will not be identified or identifiable to you. Please direct your opt-out request, or your request to exercise any of your rights in relation to your personal data by written notice to us at:

Propeller Industries, LLC
110 William Street, Suite 2200
New York, NY 10038 (United States)
Attention: Privacy Officer (privacy@propellerindustries.com)

With a copy (including the words “Propeller Industries – GDPR” in the subject line) to:
OlenderFeldman LLP
422 Morris Avenue
Summit, NJ 07901 (United States)
Attention: Michael J. Feldman, Esq.
(mfeldman@olenderfeldman.com)

13. Your Choices About Information We Collect – Not Applicable to EU/EEA Data Subjects

    • If you do not consent to the way in which we may use your personal information, please do not submit any personal information to us. Please note that if you do not provide us with certain personal information the Company may be unable to provide you with its services, or those services may not be as good as they otherwise could be.
    • If you do not wish to receive emails about special offers and other promotions from us, click the unsubscribe link located in our emails. If you do not wish to receive other marketing materials from us and/or if you do not want us to share your personal information with other entities as stated in this Privacy Notice, please provide us with your exact name and address and advise us that you wish to opt-out for information sharing or receiving information from us or both as the case may be. Please note that de-identified and aggregate data including your personal information may still be shared, but it will not be identified or identifiable to you. Please direct your opt-out request to the following contacts:

Propeller Industries, LLC
110 William Street, Suite 2200
New York, NY 10038 (United States)
Attention: Privacy Officer (privacy@propellerindustries.com)

With a copy (including the words “Propeller Industries – Privacy” in the subject line) to:
OlenderFeldman LLP
422 Morris Avenue
Summit, NJ 07901 (United States)
Attention: Michael J. Feldman, Esq. (mfeldman@olenderfeldman.com)

14. Privacy of Children Who Visit The Website

We recognize the importance of children’s safety and privacy. The website is not designed to attract children, and is not intended for use by any children under the age of 18. We do not request, or knowingly collect, any personally identifiable information from children under the age of 18. If you are under age 18, you do not have permission to use this website or our Services.

15. Your California Privacy Rights

We collect various types of personal information about you during the course of your relationship with us. Under California law, if you are a resident of California, you have the right to make a written request to us about how we have shared your information with third parties for their direct marketing purposes.  However, we do not share your information with third parties for their direct marketing purposes.