Privacy Policy

Privacy Policy

Effective date: 27th June 2017
Last revised on 16th December 2021

ITC-AeroLeasing, Inc. and our subsidiaries (“we”/”us”/“our”) privacy policies are written to comply with: (a) the Japanese Act on the Protection of Personal Information, as amended (the “Act”), (b) guidelines regarding the Act, and (c) other related laws and regulations regarding the handling and protection of personal information.

1. Definition of personal information
For the purpose of this Privacy Policy, “personal information” refers to the information specified in Article 2, Paragraph 1 of the Act.

2. Measures for the safe management of personal information
We will implement appropriate organizational, personnel, physical, and technical measures to protect and safely manage personal information, to prevent leakage, loss, or damage of personal information handled by us.

3. Compliance with the Act
We will comply with the following items when we obtain, use, and provide personal information.
a. Acquisition of personal information
To the extent necessary in connection with aircraft operating leases, aircraft sales (including import and export), and other services provided by us and related ancillary services (the “Service”), we may acquire personal information from users of the Service (for the purposes of this Privacy Policy, the terms “you”, “your” and “yourself” shall include any prospective user or other person associated with the Service.).
b. Purpose of use of personal information
We will not use personal information obtained by us beyond the scope necessary to achieve the purposes of use specified below, except as provided by law or with your consent.
i. To confirm the identity of the applicant when applying for the Service.
ii. To bill and settle remuneration such as lease payments, aircraft sales (including import and export) and commissions incurred in connection with the use of this service. (including importing and exporting), and for billing and settlement of commissions and other remuneration. To confirm, investigate, or reply to inquiries received regarding the Service.
iii. To provide various reports such as status reports and progress reports to customers who are using the Service.
iv. To make various proposals related to the Service, including announcements, advertisements, promotions, and introductions of information that may be useful to customers.
v. To provide personal information to a third party with the consent of the customer in accordance with section 3(c).
c. Provision of personal information
Except as required by law, we will not provide personal information obtained based on your consent to a third party without your prior consent.
d. Requests for disclosure, correction, addition, or deletion of personal information
We will comply with the laws and regulations and respond appropriately to any requests for the disclosure, correction, addition, deletion, suspension of use of personal information, suspension of provision of personal information to third parties, or notification of the purpose of use of personal information. For specific request procedures, please see section 10 below.

4. Changing the purpose of use of personal information
As a general rule, we will not change the uses specified in section 3(b) above, except in cases where we have obtained your consent. However, this does not apply to cases where we publicly announce the purpose to the extent that we deem that the change is reasonably related to the purpose of use before the change.

5. Provision and outsourcing of personal data to third parties
We may provide or entrust all or part of the handling of personal information to a third party for the purpose of use described in 3. In such cases, the Company will examine the eligibility of the party to which the information is provided or entrusted, and will endeavor to exercise necessary and appropriate supervision over the party to which the information is provided or entrusted in order to ensure the safe management of the personal information.

6. Provision and outsourcing of personal data to foreign third parties
We may provide or entrust all or part of the handling of personal information to a third party for the purpose of use described in 3. In such cases, the Company will examine the eligibility of the party to which the information is provided or entrusted, and will endeavor to exercise necessary and appropriate supervision over the party to which the information is provided or entrusted in order to ensure the safe management of the personal information.

7. About Cookies
A cookie is a function that allows a customer’s website browsing information to be stored on that customer’s computer. Our website uses cookies to obtain browsing information, such as the number of visits and pages visited, for statistical purposes. All of the information obtained is anonymous and cannot be used to identify you personally.

8. Improvement and review of the handling of personal information
We will conduct audits of the handling of personal information, management systems and initiatives, and strive to continuously improve and review them.

9. Deletion of personal information
We will endeavor to delete or dispose of personal information when we determine that it is no longer necessary in light of the purpose for which it is used, and such deletion and disposal will be conducted in a manner that is necessary and appropriate to prevent risks such as leakage to outside parties, and to the extent necessary for the performance of our business.

10. Contact information for inquires, requests, complaints, consultation
ITC-AeroLeasing, Inc.
5F THE WALL, 2-1-5 Shinkawa, Chuo-ku, Tokyo
Tel: 03-3555-3621
Attention: Manager Responsible for the Management of Personal Data
Masafumi Imanishi

11. GDPR Privacy Policy
In addition to the above, we will comply with the EU General Data Protection Regulation (GDPR) and other relevant laws and regulations when handling personal information of individuals located within the European Union (EU), the United Kingdom (UK), Iceland, Liechtenstein, or Norway (the “GDPR Jurisdiction”), and will use such information appropriately in light of our business activities, including the following items, after reading the definition of personal information in this Privacy Policy in accordance with the GDPR and other relevant laws and regulations to the extent that the GDPR is applicable to us. For the purposes of this section 11, “you / your” refers to those natural persons who are subject to the scope of the GDPR by virtue of using our services from within the GDPR Jurisdiction. For all other users our privacy policy is limited to sections 1-10 inclusive, and section 12.
a. Legal basis for processing of personal information
We may handle personal information obtained directly or indirectly from you, or through public information, social media, third parties, if:
i. you consent,
ii. if the disclosure is necessary for the performance of a contract to which you are a party to or for precontractual procedures,
iii. if the disclosure is necessary for us to comply with a legal obligation to which we are subject,
iv. if the disclosure is necessary to protect your vital interests or the vital interests of another natural person,
v. if the disclosure is necessary for the public interest or the exercise of our official authority,
vi. if the disclosure is necessary for customer service, marketing, or our other legitimate interests.
b.Your rights
You have the right to withdraw your consent to the processing of your personal data. You also have the right of access, rectification, erasure, restriction of processing, notification, opposition, data portability and the right not to be subjected to automated processing of your personal information. For the contact information, please section 10 above.
c. Retention period for personal information
At the end of the legal retention period under applicable laws, we will promptly erase the personal information concerned, unless it is necessary in connection with the purpose of processing the personal information.
c. Contact for inquiries
Please see section 10 above.

This Privacy Policy is made in Japanese and English. In the event of conflict between the two versions, the Japanese version will prevail.

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