Last Revised:  July 27, 2026

This California Privacy Notice supplements our Privacy Policy and describes how we collect, use, disclose, and “sell” or “share” the personal information of California residents, as well as the rights available to you under California law. This California Privacy Notice is incorporated into and forms an integral part of our Privacy Policy. If there is any conflict between this California Privacy Notice and our Privacy Policy, this California Privacy Notice will govern for California residents.

Categories of Personal Information We Collect and Use

Category collected

Purposes

Sources

Identifiers

Respond to inquiries; provide products and services; manage customer relationships; communicate with you; send newsletters or updates; maintain records; detect and prevent fraud; comply with law.

Directly from you; automatically from your device or browser; service providers.

Customer Records

Process orders, invoices, payments, and customer communications; maintain transaction records; provide customer support; comply with law.

Directly from you; payment processors; business records.

Commercial Information

Respond to product and order inquiries; understand product interests; provide customer support; maintain customer and transaction records; improve products and services.

Directly from you; transaction records; customer communications.

Internet or Other Electronic Network Activity

Operate, secure, and improve the Site; conduct analytics; diagnose technical issues; understand Site usage; if applicable, support advertising or measurement.

Automatically from your device or browser; cookies and similar technologies; analytics providers.

Approximate Geolocation

Estimate general location from IP address for Site operation, analytics, security, and similar purposes.

Automatically from your device or browser.

Sensitive Personal Information

Identity document information, such as passport and driver’s license numbers; credit card or debit card information

Directly from you

Other Information You Voluntarily Provide

Respond to communications, inquiries, event interactions, or other information you choose to provide.

Directly from you.

Below, we have provided more detail regarding the two ways we disclose your personal information: (a) “sales” and/or “sharing” of personal information and (b) general disclosures of personal information for a business purpose.

“Sales” and “Sharing” of Personal Information

Under California law, a “sale” broadly includes any disclosure of personal information to third parties for valuable consideration, which does not need to be monetary. “Sharing” includes disclosing personal information for cross-context behavioral advertising.

In the past 12 months, we may have “sold” and/or “shared” the following categories of personal information to the following third parties:

Personal Information Category

Third-parties

Internet or Other Electronic Network Activity

Advertising networks, remarketing providers, or analytics providers

We do not sell or share personal information of minors under 16 years of age, or have actual knowledge of any sale or sharing of the personal information of minors under 16 years of age.

Disclosure of Personal Information for a Business Purpose

To manage our business and provide Services to you, we sometimes disclose personal information with service providers or contractors. These service providers or contractors cannot further collect, sell, share, or use the personal information we disclose to them except as necessary to perform the designated purposes or as instructed by us.

In the past 12 months, we may have disclosed the following categories of personal information to the following third parties for our operational business purposes:

Category of Personal Information

Disclosure

Identifiers

  • Service Providers

Customer Records

  • Service Providers

Commercial Information

  • Service Providers

Internet or Other Electronic Network Activity

  • Service Providers

Inferences Drawn From Other Personal Information

  • Service Providers

Sensitive Personal Information

  • Service Providers

 

Sensitive Personal Information

Under CCPA, we do not process sensitive personal information, except for passport/government ID information and (ii) credit card information, but only incidentally where, and to the extent, a customer provides to us credit card information over the phone to purchase Services, and we enter it into a point of sale (POS) terminal or an online payment processing platform. We do not store credit card information. We do not process sensitive personal information except to provide the Services.

Data Retention

In the absence of a verifiable consumer request from you, we will retain your personal information for as long as we reasonably determine is necessary to fulfill the purposes for which it was collected. We may also retain your personal information to the extent permitted by law before deleting it (and directing our service providers to delete it). Retention periods vary by category of personal information. In determining the appropriate retention period, we consider criteria that may include:

  • contract requirements;
  • operational needs;
  • legally mandated retention periods;
  • pending or reasonably anticipated litigation;
  • historical archiving; and
  • intellectual property or ownership rights.

Do-Not-Track Signals

At this time, we do not recognize automated “do-not-track” browser signals.

Your Rights

Under California law, you may have the following rights:

  • Right to Know/Access: You can request information about the personal information we have collected about you, including the categories of information, sources, purposes, and third parties with whom we share it.
  • Right to Delete: You can request that we delete your personal information, subject to certain exceptions.
  • Right to Correct: You can request that we correct inaccurate personal information we maintain about you.
  • Right to Opt-out: You can direct us not to sell or share your personal information.
  • Right to Non-Discrimination: We will not discriminate against you for exercising any of these rights.

Exercising Your Opt-Out Rights

You may exercise your right to opt-out of sales and sharing by clicking this link: Your Privacy Choices. We also recognize the Global Privacy Control (“GPC”) as a valid consumer request to opt out of sales and sharing for the browser you are using.

Exercise Your Rights

California residents can exercise their rights to access, correction, or deletion by submitting a verifiable consumer request to us through any of the following methods:

  • Through this web form
  • By calling us toll-free at: 800-891-3790
  • By email at info@hillsboroaviation.com with the subject line “California Privacy

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Responding to Your Verifiable Consumer Request

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We respond to a verifiable consumer request within 45 days. If we require more time, we will inform you of the reason and extension period in writing. Our disclosures we provide will cover the 12-month period preceding the verifiable consumer request’s receipt, unless you request information beyond this time frame. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. Before we are able to process your request for access or deletion of personal information, we will need to properly verify your identity for security purposes. If we possess appropriate personal information about you (e.g., name, email, address), we will attempt to verify your identity using that information. If it is not reasonably possible to identify you, we may not be able to respond to your request.

For an authorized agent to make a request on your behalf, we may require your authorized agent to provide proof that you gave the authorized agent signed permission to submit the request. We may also require you to verify your identity directly with us.

California’s “Shine the Light” Disclosure

We have not shared any personal information with other companies for their direct marketing use within the immediately preceding calendar year. Accordingly, California’s “Shine the Light” law, Cal. Civil Code § 1798.83 to § 1798.84, does not apply to us and we have not established any mechanism for you to request information on our sharing of information for third parties’ marketing purposes.

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