Welcome to www.metrea.aero (“Website”), which is owned and operated by Metrea Management LLC, a company incorporated under the laws of the United States, having its principal address at 1054 31st Street NW, Suite 215, Washington, DC, 20007, and its affiliates (“Metrea,” “we,” “us,” “our”). We are committed to protecting and respecting your privacy, and we aim to be clear about how we use personal data. When we use the term “personal data,” we mean any information about an individual from which that person can be identified.
This Privacy Policy sets out the types of information Metrea may collect from you when you visit our Website or interact with us, what is done with this information, with whom this information is shared, and your rights. It also explains how we process and protect personal data that we obtain through our dealings with other businesses and corporate entities that we have business or professional dealings with. This includes personal data relating to customers, vendors, job applicants, employees, officers, directors, shareholders, investors, and third-party representatives of those corporate entities or businesses (“you”). This Privacy Policy should be read in conjunction with our Cookie Policy and our Terms of Use, which provide additional details on our data processing and Website practices.
Please review this Policy carefully to understand what we do with your information, and where applicable, the following sections:
- European and UK Users. If you are subject to the EU General Data Protection Regulation (“EU GDPR”), or the EU GDPR as it forms part of the laws of the United Kingdom by virtue of section 3 of the European Union (Withdrawal) Act 2018 and as amended by the Data Protection, Privacy and Electronic Communications (Amendments) (EU Exit) Regulations 2019 (the “UK GDPR”, and, together with the EU GDPR, the “GDPR”), we are the data controller for all personal data we collect. Please review the below section “Additional Information for European and UK Users” for additional disclosures and a description of your rights.
- California Users. If you are a California resident and the California Consumer Privacy Act (with any implementing regulations and as may be amended from time to time, “CCPA”) applies to the processing of your information, please review the below section “Additional Information for California Users” for additional disclosures, our notice at collection, and a description of your rights.
1. Who We Are and How to Get in Touch
If you have any queries in relation to this Privacy Policy or any aspect of our data privacy practices, please feel free to contact us at:
Meta Aerospace Management LLC
d/b/a Metrea Management
1054 31st Street NW, Suite 215
Washington, DC 20007
Email: info@metrea.aero
2. Types of Personal Data We Collect
We may collect personal data and other information from the sources described below. When we use the term “personal data,” we mean information that can help us directly or indirectly identify you, such as your name, address, telephone number, email address, Internet Protocol (“IP”) address, or other online identifiers.
Personal Data You Provide to Us
Depending on how you interact with us, including if you are a job applicant or business contact, we may collect the following categories of personal data directly from you or from the business you represent:
- Contact details such as your name, mailing address, telephone number, email address, online identifiers, or other similar identifiers.
- Additional information protected under certain federal or state laws such as your Social Security Number, passport number, signature, education information, driver’s license number, state identification number, credit card, bank account, or other financial information.
- Characteristics of protected classifications under certain federal or state law such as gender, national origin, citizenship status, marital status, criminal conviction, or health data.
- Professional or employment-related information such as employer names and professional titles.
- Education information, including information that is not publicly available, personally identifiable information as defined in the Family Educational Rights and Privacy Act.
- Inferences drawn from other information to create a profile reflecting your preferences or characteristics.
- Audio, electronic, or visual information such as call recordings and passport photos.
- Geolocation data such as information about your location or the location of your device.
- Correspondence and communications with you or the business you represent including records of information provided by you when you contact us with feedback, comments, questions, or for any other reason.
Please note that if you do not provide us with your personal data, we may not be able to comply with our legal obligations or manage our business.
Information Collected Automatically
When you visit our Website and interact with us through online media and advertisements, we may collect certain information, which may include personal data, about your visit or interaction that is automatically logged through the use of cookies and similar tools. Cookies are text files containing small amounts of information that are stored on your browser or your device when you visit our Website, online media, and advertisements.
We may automatically collect the following information, which may include personal data, through our Website and these tools:
- Log Files. Records of a range of variables about your visit to our Website, including: your browser type and language, app version, access times, pages viewed, IP address, approximate geographic location, and the webpage or online service you visited before navigating to our Website.
- Website Browsing Data. Information gathered while you browse our Website, including technical, usage, and navigational data that shows what pages you have visited and how long various features are used.
- Device Information. Information about the device you use to access our Website, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
For additional information on the various tools we use, the purposes for which we use them, and your ability to control them, please read our Cookie Policy.
3. Why We Process Your Data
We may collect, hold, and process your personal data for the following business or commercial purposes:
- Business Contact. To interact with you as part of professional dealings with the businesses and corporate entities you represent.
- Legal. To comply with legal oblations, protect our interests, conduct sanctions checks, prevent and detect fraud, money laundering, or other crimes, or for the purpose of responding to a binding request from a public authority or court.
- Job Applications. To assess your application and contact you about employment opportunities.
- Communicate and Respond to Your Questions. To respond to any queries you send to us or where a problem with the website is reported.
- Managing and Operating our Website. To keep our Website updated and relevant, to develop our business, and to inform our marketing strategy.
- Advertising. To provide you with information, products, or services we feel may interest you.
4. How We Share Your Information
We may share your personal data and other information with entities for our business or commercial purposes, including:
- Any member within our group of related companies, including subsidiaries, our parent companies, and their subsidiaries. These companies include, but are not limited to: Metrea Aerospace Management; Metrea Special Aerospace; Metrea Special Aerospace, Air Operations; Metrea Special Aerospace, Technical Services; Metrea Special Aerospace, Signal Applications; Metrea Special Aerospace, Advanced Payloads and Deliverables; Metrea Special Aerospace, Intelligence, Surveillance, & Reconnaissance; Metrea Special Aerospace, Vertical Applications; Metrea Special Aerospace, Special Mobility; Metrea Advanced Signals; Metrea Mission Data; Metrea Immersive Synthetics; Metrea Simulations; Metrea Strategic Mobility; Metrea Orbital Effects; Metrea Aviation Services, Metrea Spectrum Operations; Metrea Vertical Applications, Metrea Strategic Mobility; Metrea Algorithmic Technologies; Metrea Strategic Insights; Metrea Vantage Labs; and Metrea Discovery Partners.
- Service providers, including, without limitation, providers that provide sanction checks in connection with the Office of Foreign Control (“OFAC”), our Internet Service Provider, and website analytics companies, such as Google Analytics.
- A third party where we are under a duty to disclose or share your personal data in order to comply with any legal obligation.
- A third party where it is necessary to protect the vital interests of the data subject or another natural person.
- A third party where it is necessary for our legitimate business interests to protect the rights, property, or safety of Metrea, our clients, customers, or others.
- Other support service providers necessary to support Metrea in its services, including external legal counsel.
- A prospective seller or buyer of any of our business or assets in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).
We may also share your personal data where you have specifically authorized or consented to the disclosure.
5. International Transfers of Your Personal Data
Metrea is a U.S.-based company, and as such, your personal data may be transferred, stored, or otherwise processed in the United States. When you or the business you represent provide personal data to us from outside of the U.S., please be aware that we will receive and process it in the U.S. and that U.S. data protection laws may be different from those of your country of residence. We may transfer the personal data we collect to other countries where we do business, which may not have the same data protection laws as the country in which you originally provided the data.
We comply with applicable legal requirements providing adequate safeguards for the transfer of personal data to countries other than the country where you are located. In particular, we may transfer personal data to countries for which adequacy decisions have been issued by the European Commission, the Secretary of State in the U.K. or other relevant bodies in other jurisdictions, or use contractual protections for the transfer of personal data to third parties, such as the European Commission’s Standard Contractual Clauses, as supplemented where and if required.
If you have additional questions related to the safeguards we use to transfer your personal data internationally, please contact us at the information provided in Who We Are and How to Get in Touch.
6. Retention of Personal Data
We will store your personal data for as long as required to satisfy the purpose for which the data was collected and used, unless a longer period is necessary to fulfill our legal obligations, or for the exercise or defense of legal claims.
Where we process your personal data for the purpose of corresponding with you for our legitimate interests in managing our business, we will retain personal data for as long as it is necessary for the purposes for which it was collected. Retention periods can vary based on the type of information and how it is used. We have established retention periods based on several criteria, including the type of data collected, our purposes for collecting it, applicable laws, pending or potential litigation, intellectual or property rights, contract requirements, and historical archiving.
Typically, this will require that we hold such data for a period of seven years from the date on which the relationship is terminated. If you have any further queries in relation to our data retention procedures, please contact us at the address provided in Who We Are and How to Get in Touch.
7. Links to Other Websites
Our Website may contain links to third-party websites. Any access to and use of such third-party websites is not governed by this Privacy Policy, but, instead, is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.
8. Automated Decision-making/Profiling
We will not process your data in such a way as to make solely automated decisions about you that will have a legal or similarly significant effect.
It may be necessary for us to provide your information to third-party processors who will engage in an automated process of sanctions checks in connection with OFAC. The results of this automated process will be reviewed before a decision is made. We undertake these checks to protect our business against fraud and to ensure that we do not engage in any activity that would infringe upon our legal and regulatory obligations.
Where we engage in profiling of this nature, you have a right to object, and can raise such an objection by contacting us as the address provided in Who We Are and How to Get in Touch. We note that, as set out in Types of Personal Data We Collect, if you refuse to allow certain types of data processing, we may not be able to comply with our legal obligations or manage our business, and accordingly may not be able to engage with the business you represent.
9. Your Rights
We take reasonable steps to keep your personal data accurate and complete. Under applicable law, you have certain rights relating to our collection and use of your personal data:
- Access and Correct Your Information. You may contact us using the information provided in Who We Are and How to Get in Touch above with “Rights Request” in the subject line to request access to, modification, or deletion of personal data you have provided to us. Please note that we will maintain personal data in our database whenever we are required to do so by law, for necessary operational reasons, or to maintain uniform business practices.
- European Privacy Rights. If you are located in the European Economic Area (“EEA”), Switzerland, or the U.K., please review Additional Information For European and UK Users below for a description of your rights.
- California Privacy Rights. If you are a California resident, please review Additional Information for California Residents below for information regarding rights of California residents.
10. Additional Information for European and UK Users
The GDPR imposes certain obligations on us, as a data controller, and grants certain rights to individuals located in the EEA or U.K. “Personal data” and other terms as used in this section have the same meaning provided in the GDPR.
Legal Basis
If the processing of your personal data is subject to the GDPR, we ensure that we have identified a legal basis for doing so, including:
- Contract. Depending on the circumstances, we may need to process your personal data for the performance of a contract to which you are a party.
- Legitimate Interest. This processing of personal data is necessary for our legitimate business interest in managing and promoting our business, provided that our interest is not overridden by your interest. In identifying this basis, we have weighed our legitimate interest as a business against your rights and freedoms and have determined that it will not unfairly impact your rights. You have the right to object to our processing of your personal data where it is done on this basis. If you would like further information on how we balanced these interests, you can contact us using the details provided in Who We Are and How to Get in Touch.
- Legal Requirements. We may need to process your personal data in order to comply with certain legal and regulatory requirements. In certain circumstances, we may also process some personal data for carrying out our or your obligations and exercising specific rights in the field of employment and social security and social protection law authorized by certain countries’ laws.
- Consent. We may also process your personal data with your consent, as required, and, where applicable, your explicit consent. You have the right to withdraw this consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent.
Individual Rights
If the processing of your personal data is subject to the GDPR, you have the right to request access to, rectification of, or erasure of your personal data, or restriction of processing or object to processing of your personal data, as well as the right to data portability. In each case, these rights are subject to restrictions as laid down by law. The following is a summary of your rights:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data in certain circumstances, for example, where we no longer need it or you have withdrawn your consent. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below). Please note that, upon receiving a request from you to erase your personal data for any of the above reasons, we will endeavor to remove as much data as is legally allowable. If we are unable to comply with your request to erase personal data, we shall tell you in writing what personal data we have continued to retain, the reasons for retaining it, and how long we expect to retain it for.
- Object to processing of your personal data. This enables you to object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation that makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in certain circumstances, for example, if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to another party. This enables you to request that we transmit your personal data to another party without hindrance, or to give you a copy of it so that you can transmit it to a third party, where technically feasible.
- Withdraw consent. Where you have provided your consent to our processing, you have the right to withdraw it at any time.
- Lodge a Complaint with a Data Protection Authority. You also have the right to lodge a complaint with the relevant Data Protection Authority in the country of your residence, your place of work, or place of an alleged infringement, if you believe that the processing of your personal data infringes upon the GDPR.
How to Exercise Your GDPR Rights
If you wish to exercise your rights under the GDPR, you may submit a request by emailing us at info@metrea.aero with “GDPR Request” in the subject line or using the other contact information provided in Who We Are and How to Get in Touch.
11. Additional Information for California Residents
The CCPA imposes certain obligations on us and grants certain rights to California residents (“California Resident,” “you” or “your”) with regard to “personal information.” If you are a California Resident, please review the following information about our collection, use, disclosure, and sale of your personal information and your potential rights with regard to your personal information under the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law.
Terms used in this section have the meaning ascribed to them in the CCPA. Meta Aerospace Management LLC is a “business.”
Notice at Collection and Use of Personal Information
Information We Collect
Depending on how you interact with us, we may collect the categories of personal information listed above in “Types of Personal Data We Collect.”
How We Use Collected Information
We may use your personal information for the purposes listed in “Why We Process Your Data.”
Our Collection, Use, Disclosure, and Sharing of Personal Information
Information We Have Collected
In the preceding 12 months, and depending on how you interact with us, we may have collected the categories of personal information listed in “Types of Personal Data We Collect.”
Sources of Personal Information
We may collect personal information about you directly from you through sources such as: (i) job applications and other forms or related documentation; (ii) written, electronic, or verbal correspondence with us or our service providers; and/or (iii) from information captured on applicable websites. In addition, we may collect personal information from different sources, such as: (i) our affiliates, our service providers, or our affiliates’ service providers; (ii) public websites or other publicly accessible directories and sources, including governmental agencies and departments, and regulatory authorities; and/or (iii) from credit reporting agencies, sanctions screening databases, or from sources designed to detect and prevent fraud.
Purposes for Collecting Personal Information
We may use your personal information for the purposes listed in “Why We Process Your Data.”
Our Disclosure, Sharing, of Personal Information
We do not sell your personal information. In the preceding 12 months, we may have disclosed for a business purpose the following categories of personal information to the following categories of third parties:
| Category of Personal Information | Category of Third Party Information Disclosed to for a Business Purpose |
|---|---|
| Identifiers and Similar Information (such as name, email, or IP address) |
|
| Additional Information Protected by Certain Federal or State Laws (for example, financial information) |
|
| Characteristics Information (such as age or gender) |
|
In addition, in the preceding 12 months, we may have disclosed for a business purpose all of the categories of personal information identified above in the section, “Types of Personal Data That We Collect,” to the following categories of third parties: (i) judicial courts, regulators, or other government agents purporting to have jurisdiction over us, our subsidiaries or our affiliates, or opposing counsel and parties to litigation; and (ii) other third parties as may otherwise be permitted by law.
We may also share your personal information with our service providers such as our IT providers, email providers, or CRM provider, other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in or as otherwise permitted by the CCPA. We also may disclose personal information about you or your accounts to a third party at your request or direction or with your consent.
Individual Rights Under the CCPA
- Request to Delete. Request that we delete any personal information about you that we have collected or maintained, subject to certain exceptions.
- Request to Know. Request that we provide you with: (i) the categories of personal information we have collected about you; (ii) the categories of sources from which we collected the personal information; (iii) the business or commercial purpose for collecting or selling the personal information; (iv) the categories of third parties with whom we share personal information; (v) the specific pieces of personal information we have collected about you; and (vi) the categories of personal information about you we have sold or disclosed for a business purpose.
- Not to Be Discriminated Against. Not be discriminated against because you exercised any of your rights under the CCPA.
- Opt-Out of Sale. Request that we not sell your personal information.
The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. We also reserve the right to retain, and not to delete, certain personal information after receipt of a Request to Delete from you where permitted by the CCPA or another law or regulation.
How to Exercise Your Rights
You may submit a Request to Know, as described above, through the following telephone number 877-851-4107, or through our Website at our Contact Us page or via email at info@metrea.aero with “CCPA Request” in the subject line. You may submit a Request to Delete, as described above, through the same two methods.
We are required to provide certain information or to delete personal information only in response to verifiable requests made by you or your authorized agent. When you submit a Request to Know or Request to Delete, we may ask that you provide clarifying or identifying information to verify your request. Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name and email address. Any information gathered as part of the verification process will be used for verification purposes only.
If you would like to use an authorized agent to submit a request, we may request proof that that they are authorized to act on your behalf, or have a power of attorney. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.
12. Additional California Privacy Rights
You have the right to ask us one time each year if we have shared personal data with third parties for their direct marketing purposes. Please note, however, that we do not currently disclose any of your personal data to third parties for their direct marketing purposes.
Internet browsers can be configured to send “Do Not Track” signals (“DNT”) to the online services that you visit. California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how we respond to “Do Not Track” browser settings. Our Website supports Do Not Track settings that you can set in your browser.
13. Security
We are committed to protecting the security of your personal data. We use reasonable security technologies and procedures to help protect your personal data from unauthorized access and use. As effective as modern security practices are, no physical or electronic security system is entirely secure. We cannot guarantee the complete security of our database, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. Any transmission of personal data is at your own risk.
14. Changes to our Privacy Policy
We reserve the right to change this Privacy Policy from time to time at our sole discretion. If we make any changes, we will post those changes here and update the “Last Updated” date at the top of this Privacy Policy. However, if we make material changes to this Privacy Policy, we will notify you by means of a prominent notice on the Website prior to the change becoming effective. Please review this Privacy Policy periodically for updates.
