Privacy Policy

1. Overview

Air Trending is a marketing and sales agency specialized in the aviation industry, operated by Sternac LLC ("Air Trending", "we", "us", "our"). Our European operations are based at Carrer de Catarroja 13, 46940 Manises, Valencia, Spain.

This Privacy Policy ("Policy") describes how we handle personal data when you visit air-trending.com, contact us, request a proposal, or otherwise engage our services. Please read it carefully. If you do not agree with it, please do not use our website or services. By using them, you acknowledge the practices described here.

We may update this Policy from time to time. The version in force is the one published on this page, with its "Last Updated" date. Material changes will be signposted on the website.

2. Our Roles: Controller and Processor

Our role under data protection law depends on the activity:

• Data controller. For personal data collected through our website, our own marketing, and our business operations (for example, enquiries, proposals, newsletters and prospecting), we decide why and how the data is processed. We are the controller.
• Data processor. When we deliver managed services for a client, for example running advertising campaigns, managing a CRM, or building funnels, we process the personal data inside those accounts on the client's documented instructions. The client is the controller and we are the processor. That processing is governed by our Data Processing Agreement and described in Section 12.

3. Information We Collect and How

We collect two kinds of information: Personal Data, which identifies you or can be linked to you (such as name, business email, company, job title and phone number), and Non Personal Data, which does not identify you on its own (such as aggregated usage statistics).

Directly from you

When you complete a form on our website, request a strategy call or proposal, subscribe to a newsletter, book a meeting, or contact us by email, phone or social media, we collect the details you provide. This typically includes your name, business contact details, company, and the content of your message. If you opt in to SMS or messaging, we collect your number and your consent record.

Automatically

When you browse the website, we collect technical data through cookies and similar technologies, such as IP address, device and browser type, pages viewed, referring source, and interaction events. See Section 6.

From third parties

For business to business outreach, we may obtain professional contact details from public sources, professional networks such as LinkedIn, business directories and reputable data providers. We may also receive data from advertising and analytics partners about how our ads and content perform. We take reasonable steps to confirm that data obtained from third parties was collected lawfully.

4. How We Use Personal Data and Legal Bases

If you are in the European Economic Area, the United Kingdom or Switzerland, we rely on one or more of the legal bases below for each purpose.

• To provide and manage our services, respond to your enquiries, prepare proposals and perform our agreement with you. Legal basis: performance of a contract, or steps taken at your request before entering one.
• To run our business, including billing, accounting, security, fraud prevention and record keeping. Legal basis: legitimate interests and compliance with legal obligations.
• For marketing and business development, including newsletters, relevant offers and business to business prospecting. Legal basis: your consent where required, or our legitimate interest in promoting aviation marketing services to relevant businesses, balanced against your rights.
• To measure and improve our website, content and campaigns through analytics. Legal basis: consent for non essential cookies, and otherwise legitimate interests.

Where we ask for personal data to meet a legal requirement or to enter a contract, we will make that clear and explain the consequences of not providing it. Where we rely on legitimate interests, we have assessed that those interests are not overridden by your rights.

5. Marketing and Your Choices

You can opt out of marketing at any time, by using the unsubscribe link in any email, replying STOP to a text message, or contacting us at gdpr@air-trending.com. If you opt out of marketing, we may still send you service messages, for example about an active project or a change to our terms.

We do not sell your personal data, and we do not share your phone number or SMS opt in consent with third parties for their own marketing, except as needed to deliver the messaging you have requested.

6. Cookies and Similar Technologies

Our website uses cookies and similar technologies for strictly necessary functions, analytics and marketing. When you first visit, a consent banner lets you accept, reject or manage non essential categories, and you can change your choice at any time. We operate consent management so that analytics and advertising tags only load where you have given consent. Some browsers offer a "Do Not Track" signal. There is no common industry standard for these signals, so our website does not currently respond to them, but you can control tracking through the cookie banner and your browser settings.

7. When We Share Your Information

We share personal data only as needed, and with appropriate safeguards. We may disclose it:

• With service providers and sub-processors who help us operate, for example hosting, CRM and automation (including the Air Lift platform), email and SMS delivery, analytics and advertising platforms. Our current list is published on our Sub-processors page.
• With advertising and analytics partners to deliver and measure campaigns, in line with your cookie choices.
• With professional advisors such as accountants, auditors and lawyers, under confidentiality.
• For legal reasons, where required by law, regulation or legal process, or to protect our rights, users or the public.
• In a corporate transaction such as a merger, acquisition or sale of assets, subject to this Policy.
• With your consent, when you ask us to.

8. International Data Transfers

Some of our service providers are located outside the EEA, the UK or Switzerland, including in the United States. Where we transfer personal data to such providers, we put in place an appropriate transfer mechanism, in most cases the European Commission's Standard Contractual Clauses, together with the UK Addendum and Swiss adaptations where relevant, and supplementary measures as needed. You can request more information about these safeguards using the contact details below.

9. Retention

We keep personal data only for as long as needed for the purposes set out in this Policy, and to meet legal, tax, accounting and reporting obligations, or to resolve disputes. When data is no longer needed, we delete or anonymize it. Retention periods vary by data type and context, for example enquiry records, client contracts and accounting records each have different legal retention requirements.

10. How We Protect Your Information

We apply appropriate administrative, technical and organizational measures to protect personal data against loss, misuse and unauthorized access, alteration or disclosure. These include encryption in transit, least privilege and role based access, vetted vendors, and a documented incident response process. A summary is available in our Security & Compliance Overview. No method of transmission or storage is completely secure. If you believe your interaction with us is no longer secure, please contact us immediately.

11. Your Rights

Depending on where you live, you may have the right to access your personal data, to correct or delete it, to restrict or object to certain processing, to data portability, and, where processing is based on consent, to withdraw that consent at any time without affecting prior lawful processing.

To exercise any of these rights, contact us at gdpr@air-trending.com. We may need to verify your identity. We aim to respond within the timeframe required by law.

If you are in the EEA, the UK or Switzerland and you believe we have not handled your data properly, you have the right to lodge a complaint with your local supervisory authority. In Spain this is the Agencia Española de Protección de Datos (AEPD), www.aepd.es. We would appreciate the chance to address your concern first.

12. Data We Process for Our Clients

When we deliver managed services, we process personal data inside our clients' accounts as their processor, on their instructions. In that role, the client is the controller and is responsible for the lawfulness of the data, for any required notices and consents, and for responding to data subject requests. If you are an individual whose data we process on behalf of a client, and you wish to exercise your rights, please contact that client directly. We will assist them as required by our Data Processing Agreement. If you contact us and we can identify the relevant client, we will refer your request to them.

13. Information From Children

Our website and services are intended for businesses and professionals, not for children. We do not knowingly collect personal data from children under the age of 16, or under the minimum age set by local law. If you believe a child has provided us with personal data, please contact us and we will delete it.

14. Links to Other Websites

Our website may link to third party sites and services that we do not control. This Policy does not cover their practices. Please review the privacy notices of any third party site you visit.

15. US State Privacy Rights

If you are a resident of a US state with a comprehensive privacy law (such as California, Colorado, Connecticut, Utah or Virginia), you may have rights to access, correct or delete your personal data, to opt out of targeted advertising and any "sale" or "sharing", and to be free from discrimination for exercising these rights. We do not sell personal data for monetary compensation. To exercise these rights, contact us at gdpr@air-trending.com. We will verify your request as required and you may use an authorized agent where permitted.

16. Changes to This Policy

We may revise this Policy to reflect changes in our practices, technology or legal requirements. Updates take effect when posted on this page. Please review it periodically.

17. How to Contact Us

For any question about this Policy or our handling of personal data, or to exercise your rights, contact us at: