ESP USA, Inc.

Effective Date: January 1, 2026

At ESP USA, Inc. ("ESP USA," "we," "our," or "us"), we are committed to protecting your privacy and handling your personal information with care and respect. This Privacy Policy explains what information we collect, how we use it, how we protect it, and your rights regarding your personal data.

By using our services or providing us with your information, you consent to the practices described in this Privacy Policy.

We collect only information essential to service delivery, safety compliance, and legal obligation. By engaging our services, you consent to the collection of:

Mandatory Service Data: Full legal name, date of birth, government-issued ID verification, accurate body weight (aviation), emergency contacts, medical conditions affecting participation, and accommodation details.

Transactional Data: Payment information processed exclusively through PCI-DSS compliant third-party processors; we do not store complete credit card data.

Operational Data: Device identifiers and usage analytics to maintain service quality and prevent fraud.

Exclusion: We do not collect information from minors under 18 without verifiable parental consent.

Your information serves strictly defined operational purposes:

• Service Fulfillment: Coordinating aviation, maritime, and ground transportation logistics; verifying safety compliance; communicating itineraries.
• Safety & Regulatory Compliance: Satisfying FAA passenger manifest requirements, USCG maritime regulations, and firearms range safety protocols.
• Legal & Financial Obligations: Tax reporting, accounting records, dispute resolution, and fraud prevention.
• Internal Analytics: Aggregated trend analysis to optimize service delivery (de-identified where feasible).

Marketing: Promotional communications occur only with affirmative consent; you may opt out via any marketing communication or by contacting operations.

We disclose information only to the extent operationally necessary:

Verified Service Partners: Helicopter operators, yacht charter companies, firearms ranges, and catering services receive only mission-critical data (manifest details, dietary restrictions, safety waivers) under strict confidentiality agreements.

Payment Processors: Secure transaction processing only; no storage of financial data on Company servers.

Legal Compliance: Disclosure pursuant to valid court orders, regulatory investigations, or to protect imminent safety threats.

Explicit Commitment: We do not sell, rent, or trade personal information for commercial marketing purposes.

Security Measures: Industry-standard encryption in transit and at rest; restricted access controls; regular security audits; third-party compliance verification.

Retention Schedule:

• Financial records: 7 years (tax/regulatory compliance)
• Safety manifests: 5 years (aviation/maritime regulatory requirements)
• Marketing data: Until opt-out or 3 years of inactivity
• General correspondence: 3 years

Post-retention, data is securely purged or irreversibly anonymized.

Limitation: While we implement rigorous safeguards, absolute security cannot be guaranteed. You acknowledge inherent risks in electronic data transmission.

We employ essential cookies for site functionality and analytics cookies to improve user experience. Marketing cookies deploy only with consent. Browser settings may disable cookies; however, functionality degradation may occur.

Access & Correction: You may request access to or correction of your personal data, subject to operational and legal constraints.

Deletion: Requests for deletion will be honored within regulatory retention requirements; certain data must be preserved for safety, legal, or financial compliance.

Marketing Opt-Out: Immediate processing upon request; transactional communications (booking confirmations, safety updates) continue regardless of marketing preferences.

Portability: Data export available in standard format where technically feasible.

Jurisdictional Provisions:

• California Residents: CCPA rights honored; we do not "sell" personal information.
• EEA Residents: GDPR protections apply; lawful basis for processing includes contractual necessity and legal obligation. Data transfers to the U.S. are secured via Standard Contractual Clauses.

Third-Party Links: We are not responsible for privacy practices of external sites linked through our platforms.

International Transfers: Data is processed in the United States; by using our services, you consent to transfer and processing under U.S. law, which may differ from your jurisdiction's protections.

Breach Notification: We will notify affected parties of unauthorized data access as required by applicable law, but assume no liability for consequential damages arising from security incidents.

We reserve the right to modify this policy without individual notice. Material changes will be posted with updated effective dates. Continued use constitutes acceptance of revised terms.

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

ESP USA, Inc.

Email: AmazingFCT@proton.me
Phone: (424) 440-4649
Hours: 7:00 AM - 9:00 PM Daily (24/7 for helicopter charter inquiries)

Response Time: Inquiries addressed within 30 business days.

Acknowledgment: By remitting payment or utilizing our services, you confirm understanding of this Privacy Policy and consent to our data practices as described herein.

ESP USA, Inc. – Operational Excellence, Confidentiality Assured.

Last Updated: January 1, 2026