The following Privacy Policy is adopted by Panasonic Avionics Corporation ("Panasonic") in connection with the introduction of its aeronautical connectivity service offerings to customer airlines. Consistent with its commitment to protect personal privacy, Panasonic declares that it adheres to the Safe Harbor Principles embodied in the Safe Harbor Agreement concerning the transfer of personal data from the European Union to the United States of America, effective November 1, 2000. Protection of the privacy and Personal Information of airline passengers and other users of the aeronautical connectivity service offerings are the focus of Panasonic's Privacy Policy.

Consistent with its commitment to protect personal privacy, Panasonic declares that it adheres to the Safe Harbor Principles embodied in the Safe Harbor Agreement concerning the transfer of personal data from the European Union (EU) to the United States of America, effective November 1, 2000. The United States Department of Commerce and the European Commission have agreed on the Safe Harbor Principles and related materials to enable U.S. companies to satisfy EU law requirements for adequate protection of Personal Information transferred from the EU to the United States.(www.export.gov/safeharbor/) If there is a conflict between the provisions of Panasonic’s Privacy Policy and the Safe Harbor Principles, the Safe Harbor Principles will govern

The following definitions apply to all statements throughout this Privacy Policy:

"Personal Information" means any information or set of information that is transferred from the EU to the United States, is recorded in any form, pertains to or is about any individual, and can be linked to or used to identify that individual. Personal Information does not include information that is encoded, or publicly available information that has not been combined with non-public Personal Information. Personal Information does not include information that pertains to or is about a specific individual, but from which that individual could not reasonably be identified.

"Sensitive Personal Information" means Personal Information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sexual activity. For purposes of this Privacy Policy, Panasonic will treat any Sensitive Personal Information received from a third party as required by the Safe Harbor Principles.

In order to provide the aeronautical connectivity service offerings, such as Internet access, it is necessary for Panasonic to collect certain Personal Information about users of such service offerings, including, but not limited to, account user name, IP address (local and public), session information and other usage data. Some of this Personal Information may be provided to Panasonic by its service partners for Panasonic’s aeronautical connectivity service offerings. To the extent necessary for management of the aeronautical connectivity service offerings and statistical purposes, Panasonic may retain collected Personal Information for a limited period of time, after which time the information will be discarded or destroyed. Where possible, any such retained Personal Information will be stripped of personal identifiers, if any, and rendered anonymous.

Customer billing and carriage of communications traffic associated with the aeronautical connectivity service offerings is conducted by one or more service partners (e.g., a user’s home Internet service provider or an airline’s wireless Internet service provider). As a result, an end user’s customer relationship is with such service provider. Panasonic does not maintain a direct customer relationship with users of the aeronautical connectivity service, and does not collect, retain or have access to a user’s account information, including personal information such as name and address or credit, payment and other financial information regarding a user.

Panasonic’s operations and processing of Personal Information conform to the following Safe Harbor Privacy Principles as stated below under the heading of each principle.

To the extent permitted by the Safe Harbor Principles, Panasonic reserves the right to process Personal Information in the course of providing aeronautical connectivity to airline customers and users without the knowledge of the entities or individuals involved. If and when Panasonic collects Personal Information directly from individuals in the EU, Panasonic will inform them about the types of Personal Information it collects from them, the purposes for which Panasonic collects and uses it, and the types of non-agent third parties to which Panasonic discloses that information. Panasonic will also inform those individuals about the choices and means, if any, that Panasonic offers to limit the use or disclosure of their information.

Where Panasonic receives Personal Information from its subsidiaries, affiliates or other entities in the EU, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such Personal Information relates.

To the extent permitted by law, Panasonic will offer individuals the opportunity to choose (opt-out) whether their Personal Information is: (a) to be disclosed to a non-agent third party; or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

For Sensitive Personal Information, Panasonic will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

Panasonic will provide individuals with reasonable mechanisms to exercise their choices.

Panasonic has identified a privacy administrator who is responsible for training employees regarding the appropriate use of Personal Information and conducting regular self-assessment reviews to ensure full compliance with the Safe Harbor Principles. Panasonic will not disclose an individual's Personal Information to third parties, except when one or more of the following conditions is true:

• Panasonic has the individual's permission to make the disclosure;
• The disclosure is required by statute, government regulation or case law that creates explicit authorizations, provided that, in exercising any such authorization, Panasonic can demonstrate that its non-compliance with the Principles is limited to the extent necessary to meet the overriding legitimate interests furthered by such authorization;
• The disclosure is required to meet national security, public interest, or law enforcement requirements;
• The disclosure is reasonably related to the sale or disposition of all or part of Panasonic’s aeronautical connectivity business;
• The information in question is publicly available;
• The disclosure is reasonably necessary for the establishment or defense of legal claims; or
• The disclosure is to another Panasonic entity or to persons or entities providing services on Panasonic’s or the individual's behalf (each a "transferee"), consistent with the purpose for which the information was obtained, if the transferee, with respect to the information in question:
  • is subject to laws providing an adequate level of privacy protection;
  • has agreed in writing to provide an adequate level of privacy protection; or
  • subscribes to the Safe Harbor Principles.

Permitted transfers of information, whether to third parties or within Panasonic, include the transfer of data from one jurisdiction to another, including transfers to and from the United States

To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use and confidentiality of information, either for its own purposes or on behalf of its clients, customers and business partners, Panasonic has put in place and rigorously enforces appropriate physical, electronic, and managerial procedures to safeguard and secure the information that Panasonic processes. However, Panasonic cannot guarantee the security of information on, or transmitted via, the Internet.

Panasonic processes Personal Information only in ways compatible with the purpose for which it was collected or subsequently authorized by the individual. To the extent necessary for such purposes, Panasonic takes reasonable steps to make sure that Personal Information is accurate, complete, current and otherwise reliable for its intended use.

Upon request, individuals will be permitted to access any Personal Information received by Panasonic within a reasonable time period except in the circumstances as described below. If an individual becomes aware that Personal Information Panasonic maintains about that individual is inaccurate, or if an individual would like to update or review that individual’s Personal Information, the individual may contact Panasonic using the contact information below. In every case, Panasonic will take reasonable steps to permit individuals to correct, amend, or delete Personal Information that is demonstrated to be inaccurate. The individual seeking to access or amend such Personal Information will need to provide sufficient identifying information, such as name, address, wireless carrier billing statement, account user name, email address or other identifiers. Panasonic may request additional identifying information as a security precaution, including seeking assistance from a partner service provider to confirm an individual’s identity.

Panasonic may limit or deny access to Personal Information where the burden and expense of providing such access would be disproportionate to the risks to the individual’s privacy in the case in question, where the legitimate rights of persons other than the individual would be violated, or as otherwise permitted by the Safe Harbor Agreement. In some circumstances, Panasonic may charge a reasonable fee, where warranted, for access to Personal Information. Any questions regarding a user’s account information should be directed to the user’s service provider.

Panasonic utilizes the self-assessment approach of verification to assure its compliance with this Privacy Policy. Panasonic periodically verifies that this Privacy Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, accessible and in conformity with the Safe Harbor Principles. A signed statement verifying Panasonic’s self-assessment is retained by Panasonic and will be made available upon request by individuals in the context of an investigation or complaint about non-compliance with this Privacy Policy.

Panasonic encourages interested persons to first raise any concerns about Panasonic’s implementation of this Privacy Policy using the contact information below. Panasonic will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Privacy Policy.

Any claim arising out of or relating to Panasonic’s adherence to the Safe Harbor Principles, or the breach thereof, that cannot be resolved through Panasonic’s internal processes, will be settled by arbitration administered by the American Arbitration Association (“AAA”) in accordance with its applicable commercial rules. Any arbitrator will be either an attorney or retired judge having significant and recognized experience with, and knowledge of, privacy issues and information technology. The arbitration panel will apply New York law, without regard to its conflict of laws principles, as well as the Safe Harbor Enforcement Principles issued by the U.S. Department of Commerce. In addition, the exclusive location for such arbitration will be New York, NY. All decisions of the arbitration panel will be final and binding on the parties, which waive any right to appeal the arbitration award further, to the extent an appeal may be lawfully waived. Panasonic is also subject to the jurisdiction of the U.S. Federal Trade Commission and other U.S. government agencies.

Panasonic may change this Privacy Policy from time to time, consistent with the requirements of the Safe Harbor Principles or the United States Department of Commerce. Panasonic will post any revised privacy policy in its work places, train its employees about such changes and how to comply with them, and will publish any amended privacy policy on this Web site or a similar Web site that replaces this Web site.

Panasonic is committed to following the Safe Harbor Principles for all Personal Information within the scope of the Safe Harbor Agreement. Certain Personal Information, however, is subject to policies of Panasonic that may differ in some respects from the provisions of this Privacy Policy. Personal Information subject to such additional policies includes Personal Information obtained from or relating to a customer airline or business partner that is subject to the terms of any privacy notice or agreement with such customer or business partner, as well as any applicable laws.

Questions or comments regarding Panasonic’s Safe Harbor certification and this Privacy Policy should be submitted to Panasonic by mail or e-mail at the addresses provided below. Any complaints regarding Panasonic’s adherence to this Privacy Policy or the requirements of the Safe Harbor Principles should be addressed to Panasonic by mail or email as provided below:

Version 1.0, Effective: January 24, 2011