How Spirit processes your Personal Data

Privacy Statement

15th May 2026

Welcome to IMG GlobalSecur, a web-based tool for monitoring your travel itineraries in order to notify you of situations that could threaten your safety and to provide you with recommendations of steps to take in the event of such a situation and FoneTrac, a mobile phone app which allows you to check-in regularly, so Spirit and IMG know you are safe. FoneTrac helps travelers protect themselves, offering regular check-ins to update a traveler’s location and notify the GlobalSecur Command Center and Spirit that the traveler is safe.  By accessing this tool, you agree to provide your personal data to Spirit (as defined below) and that your personal data may be used, accessed, stored, and processed according to this Privacy Statement.

Our commitment

Spirit and all its business segments, divisions, and subsidiaries (collectively “Spirit”, “we” or “our”) are committed to conducting business in a way that complies with applicable data protection laws and regulations in every country in which Spirit operates. These laws govern the collection, storage, processing, and use of Personal Data.

What is Personal Data?

For the purposes of this Privacy Statement, Personal Data means any information about an identifiable individual (“Personal Data”).

Personal Data we collect and obtain

To monitor your travel itineraries, the following personal data will be preloaded in GlobalSecur for you from the travel agencies with whom Spirit partners or you can add it manually:-

• Name
• Email address
• Phone number
• Destination country
• Travel dates

When you register on GlobalSecur, you will be asked to provide the following:-

• Name
• Mobile phone number
• Email address

As a business traveller, you can also provide the following information:-

• Spirit ID
• Division
• Position
• City
• State/Province
• Country
• Work phone number
• Fax number
• Passport number
• Passport country

As an expatriate and long-term relocation employee business traveller working outside your Home Country, you can also provide the following information on your Host Country:-

• City
• State/Province
• Country

You can also provide this information on any dependents including your spouse who are living with you in your Host Country

• Name
• Relationship
• Home phone number
• Mobile phone number
• Work phone number

The Personal Data mentioned above will be saved on your GlobalSecur account.

When you install the FoneTrac app on your mobile phone, your mobile phone number will be added to your GlobalSecur account.  FoneTrac will only track your location when you check-in or send a panic from the app. 

Why we collect Personal Data

We collect and use Personal Data in GlobalSecur and FoneTrac to support travellers or assignees in the event of an emergency in their country of travel or host country.

Legal basis for the use of your Personal Data

We process your Personal Data in GlobalSecur based on a contractual obligation to ensure the safety of our employees.

We process your Personal Data in FoneTrac based on your consent.  Your consent is given through your installation and use of the app.

With whom we share Personal Data

Your Personal Data will be shared internally with the following: -

• Industrial Security
• Travel
• Global Mobility

Your Personal Data may also be shared externally with the following: -

• IMG GlobalSecur and its third sub-processors including United Healthcare (IMG GlobalSecur’s travel consolidation partner)
• Contractors who support our internal staff e.g., staff augmentation for a role that requires access to GlobalSecur data or IT support that we outsource to 3^rd parties
• Government agencies or third parties if relevant to an investigation or litigation

How we protect Personal Data within Spirit

Only Spirit employees or external contractors hired by Spirit, who are bound by confidentiality obligations, will be able to access your Personal Data.

Spirit has internal policies and controls in place to prevent your Personal Data from being lost, accidentally destroyed, misused, or unintentionally disclosed, and accessed except by its employees or external parties hired by Spirit as needed to perform their duties. Spirit employees are requested to comply with data protection laws and familiarize themselves with IT policies around security and acceptable use of IT systems and equipment.

International Transfers of Personal Data

We operate in the United States and in other countries in which the privacy laws may not be as comprehensive as those in your country of residence or citizenship. We transfer Personal Data of individuals located in the UK and the European Economic Area to the United States for storage and processing.

Please take note that your Personal Data will be stored in the US by GlobalSecur.

Automated Decision-Making

Decisions in GlobalSecur are not based solely on automated decision-making.

How long is Personal Data retained

We are committed to ensuring that Personal Data is only retained for the length of time necessary to fulfil the purpose(s) for which it was collected or the minimum retention requirement as prescribed by applicable laws, whichever is greater.

Your location data from FoneTrac is retained for 24 hours

Your travel data is retained for 10 days.

Your rights over your Personal Data

You have certain rights regarding your Personal Data, subject to local laws. These include the following rights to:

• access your personal information
• rectify the information we hold about you
• erase your personal information
• restrict our use of your personal information
• object to our use of your personal information
• receive your personal information in a usable electronic format and transmit it to a third party (right to data portability)
• lodge a complaint with your local data protection authority

If you would like to exercise any of these rights, please notify Spirit by sending us an email at: CorporatePrivacy@spiritaero.com. Following receipt of your request, a representative of Spirit will follow-up with you in a timely manner.

How to contact us

If you have any questions or suggestions about this Privacy Statement or about how we use your Personal Data, please contact our privacy team at CorporatePrivacy@spiritaero.com.

Please let us know if you are unhappy with how we use your Personal Data. Our privacy team will respond to your complaint within thirty (30) days.

Changes to this Privacy Statement

You can view this Privacy Statement at any time via the link in GlobalSecur.

Should we elect to change this Privacy Statement, we will post the changes here, so please check this page from time to time to ensure that you are informed of any changes.