Introduction

We want you to know that when you use the Air Elite website (www.airelitenetwork.com), or the website of World Fuel Services Corporation, its subsidiaries and affiliates (collectively, the "Company", "we" or "us"),  the privacy of your personally identifiable information will be respected and protected, subject to this Privacy Notice and related Company privacy policies and procedures detailed in the WFS Privacy Center

We are committed to safeguarding the privacy and personal information of our customers and business partners. This Privacy Notice explains how we may collect, use, process, share, and store personal information about you, including through designated third-party service providers, and the choices that are available to you regarding this information. Please read this Privacy Notice carefully to understand our views and practices regarding your personal information and how we will treat it.

In addition to information kept in hardcopy, this Privacy Notice also applies to Company-related websites, online applications that run on smart phones, tablets, mobile devices (“apps”), and other online services that we offer which link to this Privacy Notice. Please note also that our websites may contain links to other websites. If you follow a link to any of these websites, you should read their own privacy notices. 

 

What information do we collect about you?

Information you give us

We collect information about you in various ways, such as, but not limited to, when you open an account with us, sign up for a promotion, complete an online survey, request further contact during a trade show, purchase our products and services, and/or remit payment for services. We also collect information about you using cookies, and if you interact with us via phone, social media, websites, or apps.

The types of information that you may give us vary depending on the specific entity with which you are doing business and/or the particular services requested.  For example, you may be purchasing aviation, land or marine fuel products and/or related services, engaging with us to provide energy management services, using our trip planning services and/or related products, utilizing our software offerings, or using our payment solutions technology.  

The information you may give us could include categories such as, but not limited to, your name, work or personal address, e-mail address, phone number, date of birth, gender, financial and/or credit card information, passport or driving license information, Social Security Number, national ID number, personal description and/or photograph, as well as customer data, payment data, employee data and/or website user data. 

We will only collect sensitive information about you with your consent and/or where necessary to comply with applicable laws.  Depending on the country, sensitive information could include, but is not limited to, racial or ethnic origin, political persuasion, membership in a trade union, sexual preference, biometric data, and/or health data.

 

Cookies and website usage

Our websites may use cookies to distinguish you from other users of our websites. This helps us to improve the functionality and content of the websites, including keeping our websites and records safe and secure, and to facilitate usage by you. For more information regarding our use of cookies, please review the World Fuel Services Cookie Policy, as well as the information contained in the banners of our various websites.

Please note that our websites are not intended for children under 13 years of age, and we do not knowingly solicit data online from, or market online to, children under 13 years of age.  

Where we have given you (or where you have chosen) a password to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to/from our websites -- any transmission is at your own risk. 

 

Information we receive from other sources

We may receive information about you if you use any of the other websites we operate or the other services we provide. We also work closely with third parties (including, for example, business partners, sub-contractors, payment and delivery services, advertising networks, analytics providers, search information providers, and credit reference agencies) and may receive information about you from them. 

 

How do we use the information about you?

We use your information to provide you with information, process orders for products and services that you request from us, and administer or otherwise carry out our obligations in relation to any agreement you have with us. 

We may use your information to provide you with information about goods or services we feel may interest you.  As part of a promotion, we may, for example, use your information to keep you informed on the status of the promotion and/or follow up with additional relevant product information.

We also value the opinions of our customers and want to improve your experience and our service offerings.  Therefore, from time to time, we may conduct research surveys (e.g. customer satisfaction surveys, service offering benchmark surveys), either directly or through third parties that would be subject to confidentiality and data protection requirements as described below.

If at any time you wish us to stop using your information for any the above purposes, please contact us using the methods detailed below and/or visiting the WFS Subscription Center We will stop the use of your information for such purposes as soon as it is reasonably possible to do so. 

 

How do we share your information?

We may share your personal information with other members of our group of companies and with selected third parties for the performance of any contract we enter into with them or you. These third parties will not use your personal information for any other purposes than what we have agreed to with them, and we request those third parties to implement adequate levels of protection in order to safeguard your personal information.

Since the Company operates globally, the data that we collect from you may be transferred to, and stored at, a destination outside of the country in which you reside (e.g. outside the European Economic Area ("EEA"), Australia, etc.). For example, it may be processed by staff operating outside your country or region who work for us, our subsidiaries, or for one of our suppliers in relation to the fulfillment of your order (e.g. in the US, Costa Rica, etc.). While the information is under our control, we seek to ensure that your personal information receives the same level of protection as it would had it stayed within your home country, including seeking to ensure that it is kept secure and used only in accordance with our instructions and for legitimate purposes.

In the event we go through a business transition, such as a merger, acquisition of another company, or sale of part or all of our assets, we may disclose your personal information to third parties and your personal data held may be among one of the assets transferred.

We may also automatically collect non-personal information about you such as the type of internet browsers you use or the website from which you linked to our website. We may also aggregate details which you have submitted to us. You cannot be identified from this information and it is only used to assist us in providing effective services, including in connection with this website.

Finally, we may be under a duty to disclose or share your personal information for various other reasons, such as to comply with a legal obligation; to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of the Company, our customers, or others. This could include, for example, exchanging information with a law enforcement agency or regulator; or with companies and organizations for the purposes of fraud protection and credit risk reduction.

 

How do we store your information?

We will store your information for the period necessary required to serve the legitimate purpose or as required by law.  We will take a range of reasonable measures to protect your personal information and to store it in a secure environment, whether that is in paper and/or electronic form. We will also take reasonable steps to protect any personal information from misuse, loss and/or unauthorized access, modification, or disclosure.

 

Potential rights under country-specific data privacy laws

Multiple countries have instituted their own data privacy laws that mandate certain rights.  

For example, under the EU General Data Protection Regulation (“GDPR”), if you are a citizen or resident of an EEA country or Switzerland, you may have certain rights regarding your personal information:

Right to access information maintained about you;

Right to ensure your data is accurate and complete;

Right to erasure, or the right to be forgotten;

Right to restriction or suppression of personal data;

Right to data portability;  

Right to withdraw consent if consent was previously provided; and

Right to raise a complaint to the Information Commissioner’s Office.

Similarly, rights available under Australian Privacy Laws may include, for example, the right to access and correct the information that we hold about you, and a general requirement to ensure the quality and accuracy of the personal information collected.  Based on location and/or operation, some of our entities will be subject to the Australian Privacy Act 1988 (Cth).

If you are eligible to invoke one of the rights listed above and wish to do so, you may contact us as part of a subject access request using the details found below.  Please note that we may not always be able to fulfill your request as there may be legitimate purposes, such as certain legal or statutory obligations, that require us to retain your information as stored or if we believe the change would cause the information to be incorrect.

 

Updates to our Privacy Notice

As appropriate, we may make changes to this Privacy Notice that will be posted online and, where appropriate, be sent to you by e-mail. Please check back frequently to remain aware of any updates or changes to this Privacy Notice.

 

How to contact us

We encourage you to first visit the WFS Privacy Center, which contains additional information regarding our policies and procedures.  You can also manage your contact preferences directly via the WFS Subscription Center.

If you have additional questions, or believe you are eligible to submit a subject access request, you can do so using our web form, by email at GDPRInfoRe[email protected] or by post at:

 

World Fuel Services Corporation

Attn: Privacy Administrator, Legal Department

9800 NW 41st Street

Miami, Florida 33178

U.S.A.

Please be aware that when we receive a formal written complaint regarding the processing of personal data, we try to resolve it directly with the person who has made the complaint. However, as necessary, we will work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding our processing of personal data that we cannot resolve with a complainant directly.

If you are dissatisfied with how we have dealt with your personal information, or you have an issue with our compliance with applicable privacy laws, you may contact us using the contact details above.  We will acknowledge your complaint and aim to resolve it as quickly as possible and within applicable statutory deadlines.

You may ultimately choose to raise your concern with the applicable data privacy regulator.  For EEA countries and Switzerland, Data Protection Authority (DPA) contact details are found here. For Australia, the Privacy Commissioner may be contacted either via www.oaic.gov.au or by phone at 1300 363 992.

Version Effective March 2019