Privacy Policy

ASL Aviation Holdings Designated Activity Company

ASL Aviation Holdings Designated Activity Company, whose registered office is at 3 Malahide Road, Swords, Co. Dublin (referred to as “ASL”), respects your privacy and is committed to protecting your Personal Data.  ASL is classified as a “Controller” under the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and any data protection legislation from time to time in force in Ireland including the Data Protection Act 2018 and/or any successor legislation in respect of Personal Data you may furnish to us.

We will use your Personal Data only for the purposes and in the manner set forth below, which describes the steps we take to ensure our processing of Personal Data is in compliance with the GDPR and implementing legislation.

1. Personal Data

“Personal Data” is any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier such as a user IP addresses or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

2. Personal Data Collected and Processed

We collect information about you from three sources. This includes information we collect directly from you, information we automatically collect when you visit our sites or view our online content and information we collect about you from other sources.

Any Personal Data sent via the website will be treated with the highest standards of security and confidentiality, strictly in accordance with the GDPR.

We collect the following information directly from you when you choose to participate in our marketing campaign programs, to register your interest in our services and products, to subscribe to our emails, to call or email us, or otherwise provide information directly to us.

• Name
• Email address
• Mailing address
• Phone number
• Other information that you voluntarily provide to us when you contact us

We do not collect any Special Categories of Personal Data about you (this includes your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions or offences.

3. Technical Data Collected

We use technologies to automatically collect the following information, including Personal Data, about the services you use and how you use them when you visit our sites or view our online content.

• service usage data;
• login information (account number and password)
• device number;
• the IP address of the visitor’s web server;
• the top-level domain name used (for example .ie, .com, .org, .net);
• the previous website address from which the visitor reached us, including any search term used;
• location based data; and
• Google analytics which shows the traffic or visitors around this website such as pages access and documents downloaded

Further information on the cookies used by our site is available in the Cookie Disclaimer.

4. Information We Collect From Third Parties

We may collect information about you from third parties when you share an article using a link to a third party service (e.g. Facebook, Linkedin Twitter and Instagram). We do not control or supervise how the third parties providing your information process your Personal Data.

The third party service may send us information such as your registration and profile information from that service.

5. How We Use This Information

We may use your information to:

send you communications which you have requested and that may be of interest to you. These may include information about our products and services.

• notify you of changes to our services or policies;
• seek your views or comments on the services we provide;
• ensure that content from our site is presented in the most effective, responsive and compatible manner for you and for your computer or device;
• respond to your requests for information and other communication or correspondence you may submit to us;
• carry out our obligations arising from any contracts entered into between you and us;
• improve our products and services that we provide to you;
• carry out statistical analysis and market research;
• allow you to participate in interactive features of our site, when you choose to do so;
• investigate any improper use of our products, services or the network; and
• carry out activities necessary to the running of our business, including systems testing, network monitoring, staff training and quality control.
• We review our retention periods for personal information on a regular basis. We will hold your personal information on our systems for as long as is necessary for the relevant purpose.

6. Disclosure of Your Personal Data To Third Parties

We consider your Personal Data to be private and confidential. We may sometimes disclose your Personal Data to agents or service providers appointed by us, to regulatory bodies, to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries or to others who work for us in connection with the provision of products and/or services to you.

We may access and/or disclose your Personal Data if required to do so by law or in good faith and belief that such action has an appropriate legal basis under GDPR. 

We may also provide aggregated and/or anonymous information to third parties, where such information is combined with similar information of other users of our site.

For example, we might inform third parties regarding the number of unique users who visit our site, the demographic breakdown of our community users of our site, or the activities that visitors to our site engage in while on our site.

The third parties to whom we may provide this information may include our website design, development and hosting contractors. 

7. Transfers of Your Personal Data Outside of the European Union

We may share your Personal Data within the ASL group, including subsidiaries and affiliates based outside of the European Union such as the United Kingdom, Switzerland, India, the Republic of South Africa and Thailand.  In connection with the above we may transfer and store your Personal Data outside the European Economic Area (“EEA“), including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for Personal Data as is provided for in the European Union. Your Personal Data may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.

If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which include entering into a contract governing the transfer which contains the ‘standard contractual clauses’ approved for this purpose by the European Commission.

8. How We Secure Your Personal Data

Your Personal Data that we capture may be held at our offices and those of our group companies and may also be stored on the document storage platforms of those companies located in Ireland and in the other countries in which we operate. Technical data (which may include Personal Data) will be collected and stored in the site’s database and may be monitored and accessed by our website provider in additional to members of the ASL group.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to this website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

9. Your Rights

You have certain rights in relation to your Personal Data held by us, including in particular the right to object to your Personal Data being processed on the basis of our legitimate interests and / or for direct marketing purposes.  You have the following rights, in certain circumstances and subject to certain restrictions, in relation to your Personal Data:

1. The right to access your Personal Data;
2. The right to request the rectification and/or erasure of your Personal Data;
3. The right to restrict the use of your Personal Data;
4. **The right to object enables you to object to your personal data being processed on the basis of our legitimate interests (or those of a third party). You also have the right to object to us processing your personal data for direct marketing purposes;
5. The right to be forgotten in certain circumstances; and
6. The right to receive your Personal Data, which you have provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller.

Generally, we do not rely on consent as a legal basis for processing your Personal Data, but where you have provided consent for the use of your Personal Data you can withdraw it at any time by writing to us at the details provided in the ‘Contact Us’ section.

10. Contact Us

In order to exercise any of the rights set out above, please contact us at privacy@aslaviationholdings.com.

11. How Long We Retain Your Personal Data

We are required to ensure that your personal data is accurate and maintained in a secure environment for a period of time no longer than necessary for the purposes for which we are processing your personal data. 

We generally retain your personal data for the following periods:

• Where applying for services – a period of at least 7 years after the end of our relationship.
• Where giving us feedback – a period of at least 7 years after the end of our relationship.
• Where you have requested marketing materials to be sent to you – 1 year after sending the most recent marketing message or earlier if you object to receiving direct marketing.

However, in some cases we may need to keep personal data for longer than the above stated periods (e.g., where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or dealing with complaints, legal challenges or prospective litigation).

12. Links To Other Websites

This Privacy Policy applies only to the ASL website. The website may contain links to other web sites not operated or controlled by us (“Third Party Sites”). The policies and procedures we describe here do not apply to Third Party Sites and we are not responsible for Third Party Sites’ content, any use of Third Party Sites, or the privacy practices of Third Party Sites. Any links from this website do not imply that we endorse or have reviewed Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

13. Changes To This Privacy Policy

We reserve the right to make changes to this Privacy Policy at any time without prior consultation. Any changes to this Privacy Policy will be posted on this website so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

If at any time we decide to use your Personal Data in a manner materially or substantively different from that stated in this Privacy Policy, or otherwise disclosed to you at the time it was collected, we will notify you at the last email address that you provided to us, and you will have a choice as to whether or not we use your Personal Data in the new manner.

14. Questions and Complaints

Our Privacy Officer should be able to answer any queries or resolve any concerns you have regarding the use of your Personal Data, and is contactable at privacy@aslaviationholdings.com

You have the right to lodge a complaint with your local supervisory authority, the Office of the Data Protection Commissioner, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland if you consider that the processing of your personal data infringes the GDPR.

The Irish Data Protection Commission can also be contacted at info@dataprotection.ie.

Last Updated: 3 November 2022