Privacy Policy
This privacy policy (“Policy”) describes how Aviation Capital Group LLC, ACG Aircraft Leasing Ireland Limited, and our subsidiaries and affiliates (collectively “ACG”) collect, use, and share personal information, whether received directly from you, through our website or our other digital properties, or from third parties (collectively, the “Site”). It also describes your rights and choices regarding our use and sharing of your information, including how you can access and update such information. The Policy applies to all users of the Site.
Please note that this Privacy Policy does not apply to data collected in the course of our Know Your Customer procedures. KYC data is subject to the privacy notice provided at the time information is requested.
INFORMATION WE COLLECT
ACG collects the information that you provide to us, information that is automatically collected while you use the Site, and, in some cases, information from other sources, such as ACG service providers and third parties, as described below.
Information You Provide
ACG collects the information that you provide directly to us. The categories of information we collect may include the following:
- Contact Information including your name, email address, and telephone number, for example when you attend an event, sign up for our updates or contact us via email;
- Communications including the content of messages you send to us; and
- Applicant Data to consider any application for employment you may submit to us, including your employment and education history, resume and references.
Information that is Automatically Collected
When you visit the Site, we automatically collect information about your device and how your device interacts with the Site. The categories of information we have collected about visitors include the following:
- IP Addresses and Other Unique Identifiers; Logs. Either directly, or through our third-party service provider, we may automatically receive and record information from your internet browser, including your IP address (the internet address of your PC), your computer’s name, the type and version of your web browser, referrer addresses, where the computer is routing from and other generally-accepted log information. We may also record page views (hit counts) and other general statistical and tracking information that will be aggregated with information about other users in order to understand how our Site is being used, and for security and monitoring purposes. We may be able to collect or infer your approximate location through certain information we collect, such as your IP address. We may also collect information from emails you receive from us that can help us track which emails are opened and which links are clicked by recipients.
As described further below, we use cookies and similar technologies to collect this information.
Information from Other Sources
In some cases, we may receive professional-related contact information about you from your employer or other third parties. For example, if you attend an event that we sponsor, we may receive your name and work email.
HOW WE USE INFORMATION
ACG collects and uses information for business purposes in accordance with the practices described in this Policy. Our purposes for collecting and using information include the following:
- operating and managing the Site;
- performing services requested by you, such as responding to your inquiries and requests, sending related communications, and considering job applications;
- maintaining the security and integrity of our Site and systems, and preventing and addressing fraud, unlawful access, and breach of our policies and terms;
- sending you technical notices, updates, security alerts, important information about ACG or the Site, and administrative messages;
- analyzing Site trends and usage;
- improving the Site, our services, and communications;
- sending you our newsletters and other communications about ACG; and
- fulfilling any other business or commercial purposes at your direction or with your consent.
Notwithstanding the above, we may use information that does not identify you (including aggregate information or information that has been de-identified) as permitted by law.
DISCLOSURE OF INFORMATION
Your information may be shared with third parties for the following business purposes or under the following circumstances:
- Vendors. We employ other companies to perform functions both on our and your behalf, such as maintaining, monitoring and securing the Site, website analytics, customer service, IT services, marketing, electronic mail, and other functions necessary to support ACG, the Site, and the services that we provide.
- Questions of Harm. We may disclose personal information to law enforcement agencies or other third parties if we believe that you are: (i) at risk of harm from another; (ii) harming or interfering (or will harm or interfere) with others; or (iii) violating (either intentionally or unintentionally) our Terms of Use or other laws, regulations or legal obligations.
- Legal. We may reveal personal information to the extent we reasonably believe we are required to do so by law. In addition, we may share your personal information with third parties as otherwise permitted by law in order, for example, to protect against fraud, the confidentiality or security of our business records or to comply with applicable legal requirements.
- Transfer of Ownership. We may share personal information with a third party in the event of any actual or prospective reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
COOKIES AND SIMILAR TECHNOLOGIES
We and our third-party vendors may provide cookies, pixel tags, web beacons, clear GIFs or other similar technologies for use on our Site and email communications.
- Cookies. A cookie is a small amount of data that is sent to your browser from a website’s computers and stored on your computer’s hard drive. Cookies are used to provide a tailored user experience and to make it easier to use a website upon a future visit. We may include cookies on our Site and use them to recognize you when you return to our Site.
- Tags. We may use “pixel tags,” (also known as “web beacons”, “single-pixel GIFS”, or “web bugs”) to tell us what parts of Site you visited, to measure the effectiveness of searches users perform on our Site and for other purposes. Pixel tags also inform us whether emails have been opened, to help ensure that our messages are of interest to recipients.
- Click-Throughs. We may send emails that use a “click-through URL” linked to content on our Site or third-party sites. When you click one of these URLs, you pass through our web server before arriving at the destination web page. We track this click-through data to help determine interest in particular topics and measure the effectiveness of our communications. If you prefer not to be tracked simply do not click text or graphic links in the email.
Our Cookies
Host | Cookie Name | Description | Expiry |
|---|---|---|---|
Necessary | |||
aviationcapitalgroup.com | PHPSESSID | PHP session cookie associated with
embedded content from this domain. | 0 |
Functional / Analytics | |||
aviationcapitalgroup.com | _ga | This cookie is associated with Google
Universal Analytics – which is an update to Google’s more commonly used analytics service. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the site’s analytics reports. | 730 |
aviationcapitalgroup.com | _gid | This cookie is associated with Google
Universal Analytics. The cookie is used to
store information of how visitors use a
website and helps in creating an analytics
report of how the website is doing. The data
collected including the number visitors, the
source where they have come from, and the
pages visited in an anonymous form. ACG
has implemented Google Analytics so as to
anonymize visitor IP address collected on
the Site. | 1 |
aviationcapitalgroup.com | _gat_gtag_xxx | Google uses this cookie to distinguish
users. | 0 |
Your Choices Regarding Cookies
You can accept or decline non-necessary cookies via the cookie banner on the Site. You can also instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
You may also exercise choices regarding the use of cookies for analytics services. Click here to view the Google Analytics opt-out choice.
THIRD-PARTY LINKS
The Site and certain communications we send to you might contain links to third-party websites or platforms. These links are provided for your convenience only, and your use of third-party sites is subject to the privacy and other policies of those sites.
PRIVACY OF CHILDREN
The Site is intended for persons age 16 and older. We do not knowingly collect personal information from minors under 16 and we will delete any personal information later determined to be collected from such individuals.
DATA SECURITY
ACG maintains reasonable physical, electronic, and procedural safeguards to help guard your information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware, however, that any email or other transmission you send through the internet cannot be completely protected, and we cannot guarantee the security of your information collected through our Site.
DATA CONTROLLER AND INTERNATIONAL TRANSFERS
If you live outside of the United States, ACG Aircraft Leasing Ireland Limited, Lumen Building, 23/25 Baggot Street Upper, Dublin 4, D04Y7T1 Ireland, +353 1 2642200 is the data controller for the personal data collected in connection with your use of the Site. ACG processes personal data inside and outside of the United States. The personal data of users outside the United States is transferred on the basis of mechanisms approved under applicable laws, such as the Standard Contractual Clauses.
DO NOT TRACK
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online websites you visit. There is no industry consensus as to what site and app operators should do with regard to these signals, however, and for that reason, ACG does not respond to “Do Not Track” signals or other mechanisms.
LAWFUL BASIS FOR PROCESSING
Data protection laws in some jurisdictions require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to ACG or to our service providers or partners; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation, or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests.
YOUR RIGHTS AND CHOICES
Communications
You may opt-out of receiving certain marketing communications from or on behalf of ACG by clicking “unsubscribe” at the bottom of any email. We will continue to send you certain emails relating to your use of the Site, and similar administrative or transactional messages.
Data Subject Rights Requests
Certain jurisdictions (such as the European Union, the United Kingdom, and some states in the United States) provide certain rights to residents under applicable data protection laws. Depending on where you live, these rights may include:
- Right to access and obtain a copy of your personal information;
- Right to request your personal information be corrected, amended, rectified, or erased;
- Right to object to the processing of your personal information based on violation of applicable law;
- Right to restrict processing of all or some of your personal information;
- Right to data portability, where applicable; and
- Right to withdraw your consent. (Please note that rescission of consent does not affect the lawfulness of any processing before the withdrawal of such consent.)
To exercise any of the rights listed above, please contact privacy@aviationcapital.com for further instructions on how to process your request. We will timely consider your request and act upon it in accordance with applicable data protection laws. You have the right in certain jurisdictions to lodge a complaint with your local data protection authority. The relevant contact info of supervisory authorities in Europe can be found here: https://edpb.europa.eu/about-edpb/board/members_en
MODIFICATIONS TO THIS POLICY
We reserve the right to change this Privacy Policy, and changes will be effective when we post the revised Policy. To the extent permitted under applicable law, use of the Site will be understood as consent to the updated Policy
CONTACT
Please contact privacy@aviationcapital.com with any questions about this Policy or our
privacy practices.
Updated February 1, 2022
