Privacy Policy

LAST UPDATED: 10/16/2020

Sierra Nevada Corporation, its subsidiaries and its affiliates (collectively, “SNC”), wants you to be familiar with how we collect, use and disclose information.  This Privacy Policy describes our practices in connection with information that we collect through:

• Websites operated by us, including the one from which you are accessing this Privacy Policy (the “SNC Sites”);
• Our social media pages located at the URLs listed below (collectively, our “Social Media Pages”);
  
  • Twitter: http://twitter.com/sierranevcorp
  • Facebook: https://www.facebook.com/SierraNevCorp/
  • Instagram: https://www.instagram.com/sierranevcorp/
  • LinkedIn: https://www.linkedin.com/company/sierra-nevada-corporation/
  • YouTube: https://www.youtube.com/user/sierranevadacorp
• HTML-formatted email messages that we send to you that link to this Privacy Policy or other communications with you; and
• Offline business interactions you have with us.

Collectively, we refer to the SNC Sites, Social Media Pages, emails, and offline business interactions as the “Services.”

Personal Information

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual.  The Services collect Personal Information, including:

• Name
• Postal address (including billing and shipping addresses)
• Telephone number
• Email address
• IP address (we may also derive your approximate location from your IP address)
• Payment card data
• Profile picture
• Social media account ID and profile information
• Name of employer and title
• Information on your resume or CV (if provided)

Collection of Personal Information

We and our service providers collect Personal Information in a variety of ways, including:

• Through the Services. 
  • We collect Personal Information through the Services, for example, when you enter information on our website, place orders through our online store, communicate with us via phone, email or otherwise, when you complete questionnaires, participate in discussion boards or sign up for email alerts.

• From Other Sources. 
  • We receive your Personal Information from other sources, for example:
    • publicly available databases;
    • our third party sellers;
    • joint marketing partners, when they share the information with us.

We need to collect Personal Information to provide the requested Services to you.  If you do not provide the information requested, we may not be able to provide the Services.  If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Use of Personal Information

We and our service providers use Personal Information for the following purposes:

• Providing the functionality of the Services and fulfilling your requests.
  • To provide the Services’ functionality to you including providing you with related customer service.
  • To respond to your inquiries and fulfill your requests, when you contact us, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for or other information about our Services.
  • To complete your transactions, verify your information, and provide you with related customer service.
  • To send administrative information to you, such as changes to our terms, conditions, and policies.
  • To allow you to send messages to another person through the Services if you choose to do so.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

• Providing you with email alerts, marketing materials and facilitating social sharing.
  • To send you marketing related emails, with information about our services, new products and other news about our company that we believe may be of interest to you.
  • To facilitate social sharing functionality that you choose to use.

We will engage in this activity with your consent or where we have a legitimate interest.

• Aggregating and/or anonymizing Personal Information.
  • We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.

• Accomplishing our business purposes.
  • For data analysis, for example, to improve the efficiency of our Services.
  • For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements.
  • For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.
  • For developing new products and services.
  • For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures.
  • For identifying usage trends, for example, understanding which parts of our Services are of most interest to users.
  • For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.
  • For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.
  • For talent management, recruiting, and employment purposes.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.

• Allowing you to participate in promotions.
  • We may offer you the opportunity to participate in a promotion. Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information.  Please read those additional rules before choosing to participate.

We use this information to manage our contractual relationship with you.

Disclosure of Personal Information 

We disclose Personal Information:

• To our affiliates for the purposes described in this Privacy Policy.
  • You can consult the list and location of our affiliates here: https://www.sncorp.com/contact-us/.
• To our third party service providers, to facilitate services they provide to us.
  • These can include providers of services such as information protection, website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.
• To third parties, to permit them to send you marketing communications, consistent with your choices.
• To third party sponsors of sweepstakes, contests and similar promotions.

By using the Services, you may elect to disclose Personal Information.

• On message boards, chat, profile pages, blogs, and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
• Through your social sharing activity. By doing so, you authorize us to facilitate this sharing of information, and you understand that the use of shared information will be governed by the social media provider’s privacy policy.

Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:

• To comply with applicable law and regulations.
  • This may include laws outside your country of residence.
• To cooperate with public and government authorities.
  • To respond to a request or to provide information we believe is necessary or appropriate.
  • These can include authorities outside your country of residence.
• To cooperate with law enforcement.
  • For example, when we respond to law enforcement requests and orders or provide information we believe is important.
• For other legal reasons.
  • To enforce our terms and conditions; and
  • To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
• In connection with a sale or business transaction.
  • We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, 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).

OTHER Information

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:

• Browser and device information
• App usage data
• Information collected through cookies, pixel tags and other technologies
• Demographic information and other information provided by you that does not reveal your specific identity
• Information that has been aggregated in a manner such that it no longer reveals your specific identity

Collection of Other Information

We and our service providers may collect Other Information in a variety of ways, including: 

• Your browser or device.
  • Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly. 
• Cookies and tracers.
  • Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences and other traffic data.  We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience.  We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services.  We may also use cookies or other technologies in online advertising to track responses to our ads. For example, we use tracking scripts or “tracers” that recognize a unique identifier from a cookie placed on your hard drive by another website to determine whether you visit our employment pages after visiting a resume or career site where SNC placed a banner ad. We do not currently respond to browser do not track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website.  You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience reduced website functionality.  You also may not receive advertising or other offers from us that are relevant to your interests and needs.
• Pixel tags and other similar technologies.
  • Pixel tags. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
  • Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends.  This service may also collect information regarding the use of other websites, apps and online resources.  You can learn about Google’s practices by going to google.com/policies/privacy/‌partners/, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law.  If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.  In some instances, we may combine Other Information with Personal Information.  If we do, we will treat the combined information as Personal Information as long as it is combined.

security

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization.  Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

CHOICES AND ACCESS

Your choices regarding our use and disclosure of your Personal Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes.  You may opt out from: 

1. Receiving marketing-related emails from us. If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out through the ‘unsubscribe’ options in each such email or by contacting us directly at opt-out@sncorp.com.

We will try to comply with your request(s) as soon as reasonably practicable.  Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.

How you can access, change, or delete your Personal Information 

If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below.  We will respond to your request consistent with applicable law.  If you are a California resident, please refer to the “Additional Information Regarding California” section at the end of this Policy for more information about the requests you may make under the CCPA.

In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database.  For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.  We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion). 

RETENTION PERIOD

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. 

The criteria used to determine our retention periods include: 

• The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link.  The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with our Social Media Pages.

THIRD PARTY ADVERTISING

We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services.

• You may receive advertisements based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags).  They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.  If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/.

use of Services by MINORS

The Services are not directed to individuals under the age of thirteen (13), and we do not knowingly collect Personal Information from individuals under 13. 

Jurisdiction and CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.  In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

ADDITIONAL INFORMATION REGARDING THE UK AND THE EEA: Some non-EEA countries are recognized by the UK and/or the European Commission as providing an adequate level of data protection (the full list of these countries is available here). For transfers from the UK to countries not considered adequate by the European Commission, we will put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these measures by contacting us in accordance with the “Contacting Us” section below.

SENSITIVE INFORMATION

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.

THIRD PARTY PAYMENT SERVICE

We may use a third party payment service to process payments made through the Services. If you wish to make a payment through the Services, your Personal Information will be collected by such third party and not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy.  We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your Personal Information.

UPDATES TO THIS PRIVACY POLICY

The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised.  Any changes will become effective when we post the revised Privacy Policy on the Services. 

CONTACTING US

Sierra Nevada Corporation located at 444 Salomon Circle Sparks, NV 89434, is the company responsible for collection, use, and disclosure of your Personal Information under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us at http://www.sncorp.com/contact-us/, or

By mail, at:

Sierra Nevada Corporation
Attn:  Legal Department
444 Salomon Circle
Sparks, NV 89434

By phone or fax, at:

(p) (833) 671-0037
(f) (775) 331-0370

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us. 

ADDITIONAL INFORMATION REGARDING THE UK OR THE EEA

You may also:

• Contact our Data Protection Officer (DPO) responsible for your country or region, if applicable.
• Lodge a complaint with the data protection authority for the country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs. Information about the UK Information Commissioner’s Office is available here.

ADDITIONAL INFORMATION REGARDING CALIFORNIA

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following additional details regarding the categories of Personal Information about California residents that we have collected, used and/or disclosed.

CCPA Collection of Personal Information

The following chart details the categories of Personal Information, as listed in the CCPA, we plan to collect, and have collected and disclosed within the preceding 12 months and to which categories of third parties Personal Information was disclosed for our operational business purposes:

Category of Personal Information	Disclosed to which categories of third parties for operational business purposes
A. Identifiers, such as name, contact information, online identifier, Internet Protocol address, and Social Security numbers and other government-issued ID numbers.	Our Affiliates and Service Providers
B. Personal information, as defined in the California customer records law, such as name, contact information, insurance policy number, education, employment, employment history financial information, medical information and health insurance information.	Our Affiliates and Service Providers
C. Characteristics of protected classifications under California or federal law, such as sex, age, race, religion, national origin, disability, medical conditions and information, citizenship, immigration status and marital status.	Our Affiliates and Service Providers
D. Commercial information, such as transaction information, purchase history and financial details.	Our Affiliates and Service Providers
E. Biometric information, such as fingerprints, scans of hand or face geometry, retina or iris scans and voiceprints.	Our Affiliates and Service Providers
F. Internet or network activity information, such as browsing history, online behavior, and interactions with our and other websites, applications, systems and advertisements.	Our Affiliates and Service Providers
G. Geolocation data, such as device location and IP location.	Our Affiliates and Service Providers
H. Audio, electronic, visual and similar information, such as images and audio, video or call recordings created in connection with our business activities.	Our Affiliates and Service Providers
I. Professional or employment-related information, such as work history, prior employer, information relating to references, CV, details of qualifications, skills and experience, human resources data and data necessary for benefits and related administration services.	Our Affiliates and Service Providers

As described above, we collect this Personal Information from you and from other categories of sources: publicly available databases and joint marketing partners, when they share the information with us.  Also as described above, we may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, for example, using Personal Information to: develop, improve, repair, and maintain our products and services; personalize, advertise, and market our products and services; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.

We share Personal Information with our affiliates, service providers, third-party sponsors of sweepstakes, contests, and similar promotions, and our business partners.

We do not “sell” and have not “sold” Personal Information for purposes of the CCPA in the last 12 months. We do not sell the Personal Information of minors under 16 years of age. For purposes of this Privacy Policy, “sold” or “sale” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.

CCPA Requests and Rights

If you are a California resident, you may make the following requests:

1. Request to Know: You may request that we disclose to you the following information covering the 12 months preceding your request:
   • The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
   • The specific pieces of Personal Information we collected about you;
   • The business or commercial purpose for collecting Personal Information about you; and
   • The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).
2. Request to Delete: You may request that we delete Personal Information we collected from you.

To make a request for the disclosures or deletion described above, please contact us in accordance with the “Contacting Us” section above. We will respond to your request consistent with applicable law.   

To make a Request to Know or a Request to Delete, please contact us at opt-out@sncorp.com or (833) 671-0037.  We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request.  We may need to request additional Personal Information from you (such as your email address, order number, or circumstances under which you believe your information was collected) to verify your identity and protect against fraudulent requests.  If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information.  If you make a Request to Delete, we may ask you to confirm your request before we delete your Personal Information.

Authorized Agents

If you want to make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above.  As part of our verification process, we may request that you provide, as applicable:

• Proof of your registration with the California Secretary of State to conduct business in California;
• A power of attorney from the California resident pursuant to Probate Code sections 4121-4130;

If an authorized agent has not provided us with a power of attorney from the California resident pursuant to Probate Code sections 4121-4130, we may also require the resident to:

• Provide us with a written permission signed by the resident to make the Request to Know or Request to Delete on the resident’s behalf;
• Verify the resident’s own identity directly with us;
• Directly confirm with us that the resident provided you permission to submit the Request to Know or Request to Delete.

Right to Non-Discrimination

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

Right to Request Removal of Content

If you are a resident of California, under 18, and a registered user of the Services, you may ask us to remove content or information that you have posted to the Services by writing to opt-out@sncorp.com.  Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.