Effective date: October 29, 2025
Last updated: September 27, 2026 Version: 2.0
1. Who we are
Foxtrot LLC is an Arizona limited liability company with its registered office at 12112 N Rancho Vistoso Blvd, STE 100, Oro Valley, AZ 85755, United States. We provide independent aircraft technical and consulting services to airlines, lessors, MROs and operators worldwide, and we own and operate foxtrotllc.com and synops.org.
In this policy, “we”, “our” and “us” mean Foxtrot LLC. For personal information collected through foxtrotllc.com, Foxtrot LLC is the data controller.
2. Scope
This policy covers personal information we collect through foxtrotllc.com and through business communications connected to it, including enquiries, newsletter subscriptions, supplier registrations and job applications.
Our Synops product website has its own Privacy Policy.
Where we carry out a technical services engagement for a client, such as a pre-purchase inspection, lease return, ferry or storage project, any personal information contained in records we handle on that client’s behalf is processed under the engagement contract, and the client is the controller of that information.
3. Information we collect
3.1 Information you give us
- Business contact details. Name, job title, employer, work email address, telephone number and country, submitted through our contact form or direct correspondence.
- Correspondence. The content of emails, form submissions and messages you send us, including attachments.
- Newsletter details. Email address and consent record when you subscribe.
- Supplier and procurement data. Company registration details, tax identifiers, insurance certificates, banking details for payment, and contact details for named representatives, including information exchanged through the SAP Business Network.
- Engagement data. Names, roles, licence and authorisation references, and contact details of client and vendor personnel involved in a project.
3.2 Job applicants
If you apply through our careers page or send us a speculative application, we collect your CV, cover letter, contact details, work history, licences and certifications such as AME, A&P or EASA Part 66, right to work information, references, and interview notes. We use this to assess your suitability, to communicate with you, and to meet legal duties. Our legal basis is steps taken prior to entering a contract, our legitimate interest in recruitment, and compliance with a legal obligation. We keep unsuccessful applications for 12 months to consider you for other roles, unless you ask us to delete them sooner.
3.3 Information collected automatically
- Server log data. IP address, date and time, pages requested, HTTP status, referring URL, user agent.
- Device and browser data. Browser type and version, operating system, language settings.
- Essential cookie data. Session and security identifiers described in our Cookie Policy.
3.4 Information from other sources
Publicly available business contact information, referrals from mutual contacts, and delivery and engagement records from our hosting and email providers.
We do not knowingly collect special category data through this website. Please do not send it to us in free text fields.
4. How we use your information, and our legal basis
| Purpose | Legal basis under UK and EU GDPR |
|---|---|
| Responding to enquiries and proposal requests | Steps taken at your request prior to contract, and legitimate interest |
| Delivering, managing and invoicing consulting engagements | Performance of a contract |
| Supplier onboarding, qualification and payment | Performance of a contract, and legal obligation |
| Recruitment and candidate assessment | Pre-contractual steps, legitimate interest, and legal obligation |
| Newsletters and business updates by email | Consent, or legitimate interest in business to business marketing where local law permits |
| Operating and securing the website | Legitimate interest |
| Accounting, tax and corporate record keeping | Legal obligation |
| Export control screening, sanctions screening and conflict checks | Legal obligation, and legitimate interest |
| Establishing, exercising or defending legal claims | Legitimate interest |
Where we rely on legitimate interests, we have assessed that our interests are not overridden by your rights, and you may request a summary of that assessment.
We do not use your personal information for automated decision making that produces legal or similarly significant effects on you.
5. Marketing communications
If you subscribe to our newsletter, we will send you updates about our services, industry insights and press releases.
You can unsubscribe at any time using the link in any marketing email or by writing to privacy@foxtrotllc.com. We act on unsubscribe requests promptly and within ten business days at the latest.
We keep a record of your consent, including date, form and submission IP address, because we are required to demonstrate consent under Canada’s Anti-Spam Legislation and the GDPR.
Unsubscribing does not stop operational messages relating to an active engagement, a procurement process or a live application.
6. Cookies
foxtrotllc.com uses strictly necessary cookies only. We do not use advertising, profiling or third party analytics cookies. Full detail is in our Cookie Policy.
7. Disclosure of your information
We do not sell your personal information, and we do not share it for cross context behavioural advertising or targeted advertising. We have not sold or shared personal information in the preceding twelve months.
We disclose personal information only in these circumstances:
- Service providers. Website hosting, email delivery, customer relationship management, accounting, document storage, IT support, background screening for recruitment, and professional advisers, each under written contract and acting on our instructions.
- Clients and project counterparties. Where an engagement requires it, for example providing the name and licence reference of an assigned engineer to an operator, lessor, MRO or authority.
- Authorities and regulators. Civil aviation authorities, customs and export control authorities, courts and law enforcement where disclosure is legally required or necessary to establish, exercise or defend a legal claim.
- Corporate transactions. A prospective or actual purchaser in a merger, acquisition, financing or sale of assets, subject to confidentiality.
- With your direction. Where you ask us to share information.
A current list of the categories of service providers we use is available on request.
8. International transfers
We operate from the United States and Canada and serve clients worldwide, so personal information may be transferred internationally. If you are in the European Economic Area, the United Kingdom or Switzerland, your information will be transferred outside your jurisdiction.
For those transfers we rely on the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Addendum, or another lawful transfer mechanism, together with supplementary measures where appropriate. Request a copy of the relevant safeguards at privacy@foxtrotllc.com.
9. Retention
| Category | Retention period |
|---|---|
| Enquiries that do not lead to an engagement | 24 months from last contact |
| Client engagement and project records | Duration of the engagement, then 7 years |
| Technical records connected to an aircraft transaction | As required by the engagement contract and applicable aviation regulation |
| Supplier and procurement records | Duration of the relationship, then 7 years |
| Unsuccessful job applications | 12 months from decision |
| Newsletter subscription and consent records | Until you unsubscribe, then 3 years to evidence consent |
| Server and security logs | 12 months |
| Contracts, invoices and tax records | 7 years, or longer where law requires |
Where information is relevant to an actual or anticipated legal claim, we retain it until the matter is resolved, then delete or anonymise it.
10. Security
We maintain technical and organisational measures appropriate to the risk, including encryption in transit, least privilege access control, multi factor authentication on administrative accounts, patching, logging, and contractual security obligations on our processors.
No method of transmission or storage is completely secure. If a personal data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority and affected individuals as required by applicable law.
11. Your rights
Subject to the law that applies to you, you may have the right to:
- obtain confirmation of whether we process your personal information, and a copy of it;
- have inaccurate information corrected;
- have your information deleted;
- restrict or object to processing, including objecting to direct marketing at any time;
- receive your information in a portable, machine readable format;
- withdraw consent at any time, without affecting the lawfulness of processing before withdrawal;
- be free from discrimination for exercising your privacy rights.
How to exercise them. Write to privacy@foxtrotllc.com with enough detail for us to identify you and understand the request. We respond within 30 days, or within 45 days where US state law allows and the request is complex, in which case we will tell you before the initial period ends. We may ask for information to verify your identity, used only for that purpose. There is no fee unless a request is manifestly unfounded or excessive.
Authorised agents. Where US state law permits, an authorised agent may submit a request with written permission, and we may verify the agent’s authority with you directly.
If you are in the EEA, the UK or Switzerland, you may lodge a complaint with your national supervisory authority, in the UK the Information Commissioner’s Office. We would appreciate the chance to address your concern first.
If you are in Canada, you may complain to the Office of the Privacy Commissioner of Canada or your provincial regulator.
If you are in California, you may exercise the rights to know, delete, correct and limit under the CCPA as amended. We do not sell or share personal information and we do not use or disclose sensitive personal information for purposes that require a limitation right.
12. Children
foxtrotllc.com is a business to business website. It is not intended for anyone under 16, and we do not knowingly collect personal information from children. If you believe a child has provided us with personal information, write to privacy@foxtrotllc.com and we will delete it.
13. Third party links
Our website links to third party services, including SAP Business Network and LinkedIn, and to synops.org. We are not responsible for the content or privacy practices of third party sites. Review their policies before providing personal information.
14. Contact
Privacy enquiries and rights requests privacy@foxtrotllc.com
General enquiries contact@foxtrotllc.com
Postal Foxtrot LLC Attn: Privacy 12112 N Rancho Vistoso Blvd, STE 100 Oro Valley, AZ 85755 United States
15. Changes to this policy
We review this policy at least annually. When we make a material change, we will update the effective date and version at the top of the page and, where the change significantly affects how we use information already collected, give notice by email or a prominent notice on the website at least 14 days before it takes effect. Continued use of the website after a change takes effect indicates acceptance.
Previous versions are available on request.
16. Governing law
This policy and any dispute arising from it are governed by the laws of the State of Arizona, United States, without regard to conflict of law principles. This does not remove any protection you have under mandatory data protection law in your country of residence.