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 such 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’s service providers or 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, which may be obtained 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 URL, 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 work for a company that provides services to ACG, or attend an event that we sponsor, we may receive your name, title and/or work email.  

HOW WE USE INFORMATION

ACG collects and uses information for its 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 and analyzing Site trends and usage;
• Improving the Site, our services, and communications;
• 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, investigating, and addressing potential fraud, unlawful access, and/or violations of our policies and terms;
• Sending you technical notices, updates, security alerts, important information about ACG or the Site, and/or administrative messages;
• 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 

We may share your information 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, facilities operations and maintenance 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 may harm or interfere) with others; or (iii) violating (either intentionally or unintentionally) our Terms of Use or applicable 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.