This Privacy Policy (“Policy”) describes the privacy practices of GMSTEK, LLC and its affiliates (“GMSTEK”). The Policy explains how personal information is collected, used, and disclosed with respect to your use of GMSTEK’s products, services, and website located at www.x1fbo.com (collectively, the "GMSTEK Platform"), including but not limited to the X-1FBO software, X-1 Data Hub, X-1 Pilot, and any other services provided by GMSTEK ("we" or "us"). Please read this Policy carefully to understand our practices regarding your information. By using any part of the GMSTEK Platform, you represent that you are 18 years old or older.

We reserve the right to change the provisions of this Policy at any time. We will indicate the date of the latest update at the top of this page. For material changes, we will notify you by email or by a notice on the GMSTEK Platform’s home page. You are responsible for ensuring we have an up-to-date and deliverable email address for you, and for periodically visiting our GMSTEK Platform and this Policy to check for any changes.

Your continued use of the GMSTEK Platform following the posting of changes constitutes acceptance of any changes in our privacy practices, and you expressly waive any right to receive notice of such changes except where your affirmative consent is required. We encourage you to periodically review this Policy to understand how any personal information you provide will be used.

A. What Information Does This Policy Apply To?

This Policy applies to personal data we process in connection with the Site and the GMSTEK Service. Personal data means information that can be directly or indirectly associated with you by reference to an identifier, such as a name, an email address, an identification number, or other information by which you can be identified using reasonable means.

Personal data includes information we receive:

• From you when you create a user account for the GMSTEK Service;

• Through your use of the GMSTEK Service and through contributions by the community of users;

• In email, text, and other electronic messages between you and GMSTEK or the Site;

• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy; and

• Through any other site or application operated by GMSTEK or one of its affiliates that contains a link to this Policy.

B. Data Privacy Rights

General Data Protection Regulation (GDPR):
If you are a resident of the European Economic Area, you have the following rights with respect to your personal data:

• Right of Access – Understand the nature and extent of how your data is processed;

• Right to Rectification – Request correction of inaccurate data;

• Right to Erasure – Request erasure of personal data in some circumstances;

• Right to Restriction of Processing – Limit how your personal data is processed;

• Right to Data Portability – Receive personal data and transfer information to another controller;

• Right to Object – Object to processing of your personal data based on your circumstances, including for direct marketing;

• Right to Freedom from Automated Decision-making – Avoid being subject to decisions based solely on automated processing, including profiling.

California Consumer Privacy Act of 2018:
If you are a California resident, you may have additional rights, including:

• The right to request disclosure of the categories of information collected and the purposes for which that information is collected;

• The right to request deletion of your data and information about sharing with third parties; and

• Assurance of equal service and price regardless of exercising your privacy rights under the CCPA.

GMSTEK does not sell the personal data of its users. Contact us regarding these rights here.

C. How Do We Use the Information That You Provide to Us?

We use personal and operational information to manage and support our software, enhance our business activities, provide customer service, and improve the experience for all users of the GMSTEK Service. We may also use anonymized and aggregated data for market research, pricing analysis, and other industry benchmarking activities. Specifically, we process your personal data for the following purposes:

• System Management and Support: To operate, monitor, and support the GMSTEK Service, we may access your data as needed to troubleshoot issues, perform system updates, and ensure optimal service functionality. This access is conducted securely and only for necessary technical and support purposes.

• Market Research and Analysis: We may use aggregated and anonymized data for market research, regional pricing analysis, and industry benchmarking. For example, we may generate region-specific pricing data or provide insights to fulfill certain contractual obligations, such as for our Defense Logistics Agency (DLA) contract. In all such cases, the Company ensures that data cannot be linked to any specific customer, and we may exclude limited data sets to preserve confidentiality.

• User Accounts: Your information allows us to create and maintain user accounts to access GMSTEK resources and customize your experience.

• Service Content: Any content you share, such as comments, may be further processed and anonymized for the protection of our users’ privacy.

• Service Usage Statistics: We use tools like Google Analytics to understand how users engage with the GMSTEK Service.

• Direct Marketing: Occasionally, we may use your information to notify you about new services and special offers.

• Profiling for Relevant Content: We may analyze collected information to present content that we believe will be of interest to you based on your use of the GMSTEK Service.

• Detecting and Preventing Fraud: We use your information to monitor for fraudulent activities.

• Legal Claims: Disclosure of your data may occur if necessary for legal claims, legal obligations, or compliance with law enforcement requests.

D. Aggregated and Anonymized Data Use

We may use aggregated and anonymized data to improve our services and offer insights to the aviation industry, including:

• Industry Benchmarking and Analysis: Aggregated data (e.g., average pricing and operational statistics) may be used for industry benchmarking, allowing FBOs and operators to make informed decisions based on regional trends.

• Pricing Reasonableness and Contractual Obligations: Anonymized pricing data may be used to provide market-based insights for certain contracts, like our DLA contract. All such analyses are conducted with confidentiality protections, ensuring data is non-identifiable.

E. How Do We Protect Your Information?

We implement security measures to protect against unauthorized access to personal and operational data, including data used for technical support and market research. Internal processes limit data access for support purposes to authorized personnel only, conducted securely.

When performing benchmarking or market research, we ensure data sets are sufficiently anonymized to prevent re-identification. If a data segment is too limited to achieve full anonymity, it is excluded from analysis.

F. How Can You Access and Correct Your Information?

We strive to provide you with access to your data and will correct or delete it at your request (subject to legal or business requirements). Contact us at privacy@gmstek.com for access, correction, or removal requests.

G. Data Retention

We retain your personal information while your account is active or as needed to provide services. Personal data may also be retained as required by legal obligations, regulatory compliance, or for fraud prevention.

H. Children Under the Age of 18

The GMSTEK Service is not intended for children under 18, and we do not knowingly collect information from individuals under this age.

I. Data Controller

GMSTEK, LLC is the data controller for the GMSTEK Service. Our office is located in the United States at 18001 Old Cutler Road; Suite 472; Palmetto Bay, FL 33157.

J. Disclosure of Personal Data

We may disclose personal information:

• To subsidiaries, affiliates, and contractors supporting our business;

• As part of business mergers, divestitures, or similar corporate transactions;

• To fulfill the purpose for which you provide it; and

• As required by legal obligations or with your consent.

K. Transfers of Data

Personal data is processed on dedicated servers in the United States. Transfers are subject to contractual safeguards, and our server provider is Microsoft Azure, certified under the EU-US Privacy Shield.

L. Contact Information and Inquiries

For questions or concerns regarding this Policy, please contact GMSTEK at:

• Email: privacy@gmstek.com

• Address: 18001 Old Cutler Rd., Suite 472; Palmetto Bay, FL 33157