1. About Us
1.1 In this Privacy Policy, references to “we” or “us” mean NEWACC (2018) Limited and its subsidiaries and branches.
ACC is a company incorporated in England and Wales, with its head office at Priory Gate, 18 Castlefield Road, Reigate, Surrey RH2 0AP, United Kingdom. ACC will be the controller of any personal data processed as described in this Privacy Policy.
1.2 If you have any questions about your personal information, please contact us using the details on our website or email us directly at DC@accaviation.com.
2. Who This Privacy Policy Applies To
This Privacy Policy applies to the personal data of our website users, visitors to our blog or branded pages on social media services, survey participants, existing clients, suppliers, prospective employees and any other individuals whom we may contact in order to provide the services we offer in the United Kingdom, the European Union, the United States or any other country or territory worldwide.
3. Collection of Information
3.1 When and How We Collect Data: When you access the website by any means, register or submit a request, respond to or participate in a survey or questionnaire sent to you by us, provide comments, purchase our services or contact us from anywhere in the world through any form of media, we may collect, store, use and share certain personally identifiable information in accordance with this Privacy Policy.
3.2 Information You Provide to Us: To register or make an enquiry through the website or by any other means, we will ask for your name and email address.
As part of your profile, you may also provide your location and other information that will help us tailor our services to you. We may also ask you about your gender, employment history or qualifications to help us understand more about you. Responding to these questions will always be optional.
When you make a purchase by credit card, we and/or our payment services provider will collect and process your credit card or other payment details and any necessary proof of identity.
If you contact us, we may retain a record of that correspondence.
3.3 Log Data: We may also collect data relating to your visits to the website that cannot directly identify you but records your use of our platform. This may include, for example, details of how long you have used the website.
3.4 Device Identifiers: We may collect your computer’s Internet Protocol address, commonly referred to as an IP address, to help us verify your region and tailor our services to your location.
3.5 Identity Verification: If you choose to verify your identity through our website, we will receive, process and store your personal information and identity documentation strictly for this purpose.
3.6 Third-Party Sources: We may receive information about you from third parties, such as credit reference agencies, that are legally entitled to disclose that information to us.
4. Use of your information
4.1 By accessing our website by any means, registering or submitting a request, providing comments or purchasing a service, you agree that your personal information may be collected, stored, used and shared by us and our partners or third parties with whom we work for the following purposes:
- To fulfil any contractual agreements between you and us;
- To provide, maintain, protect and improve the quality of the website, including by conducting anonymised market research, and to protect us and our users;
- To provide you with a personalised browsing experience when using the website;
- To send you details of other products and services that we believe may interest you, unless you opt out as described in Section 9 below;
- To tailor our advertising on social media based on your use of the website;
- To allow you to use the full range of features available on or through our website;
- To comply with legal and regulatory requirements;
- To contact you occasionally and invite you to share your opinions and experiences of ACC; and
- To provide third-party goods or services available through our website.
You can manage your email preferences through the settings page accessible from any email we have sent you.
4.2 We may use your email address to send you updates about our services. You can manage your email preferences through the settings page accessible from any email we have sent you.
5. Storage of Information and Data Security
5.1 We take appropriate technical and organisational measures to secure your information and protect it against unauthorised or unlawful use, accidental loss and destruction.
We use secure hosting at Tier 1 data centres with high levels of digital and physical security. We also deploy leading EU-based cloud Software as a Service solutions to support our Enterprise Resource Planning systems.
We keep our servers, applications and security packages up to date to provide our clients with the best possible security and performance.
We place appropriate restrictions on access to personal data.
5.2 As a multinational organisation, the information we collect may be stored, transferred to and processed in various countries across our global network and by our third-party service providers. This may include transferring data across international borders.
Regardless of where your data is processed, we enforce strict technical, organisational and contractual safeguards, including approved international data transfer mechanisms, to ensure your information remains protected in accordance with applicable regulatory standards.
Although we use robust commercial measures to protect your data, no transmission of information over the internet can be guaranteed to be completely secure.
6. Legal Basis for Processing Your Information
6.1 Our legal basis for collecting and using the personal information described above will include our legitimate interests.
Article 6(1)(f) of the GDPR permits us to process your data where processing is necessary for the purposes of the legitimate interests pursued by us or a third party, except where those interests are overridden by your interests, fundamental rights or freedoms requiring the protection of personal data.
6.2 We will normally collect personal information from you only:
- Where processing is in our legitimate interests and those interests are not overridden by your rights;
- Where we need the personal information to perform a contract with you; or
- Where we have your consent to do so.
In some circumstances, we may also have a legal obligation to collect personal information from you.
6.3 Where we ask you to provide personal information to comply with a legal requirement or perform a contract with you, we will make this clear at the relevant time.
We will advise you whether providing your personal information is mandatory and explain the possible consequences if you do not provide it.
This may include providing airline travel services to you when you are travelling or working as a passenger or crew member on chartered or leased flights. This may require us to transfer personal information overseas to countries and territories around the world.
Where such transfers are necessary, ACC is required to ensure that they comply with applicable data protection legislation.
6.4 In certain jurisdictions in which we operate, consent may be used as the legal basis for processing personal information.
Where we collect and use special category personal data, such as medical or dietary information, your specific consent will always be requested at the relevant time.
We do not believe that our activities prejudice individuals. Instead, they help us provide a more tailored and efficient service. However, you have the right to object to us processing your personal data on this basis.
7. Disclosure of Your Information
We may disclose your personal information to third parties where permitted by law, including:
a. With Your Consent: We may disclose your personal information where you have given us permission to do so.
b. To Our Suppliers: We may disclose your information to suppliers that help us provide our services to you, including:
- ACC and its subsidiaries and branches;
- ACC’s contracted airline operators and their subsidiaries, branches and agents;
- Our customer relationship management service providers, which allow us to send personalised email communications to you;
- Our file storage and management service providers where you email us directly;
- Our payment services provider, as discussed in Paragraph 3.2 above, when you make a purchase;
- Our identity verification partner, as discussed in Paragraph 3.5 above, where you choose to use this option; and
- Our customer service software provider if you contact our support team.
c. Business or Asset Sales: If we sell or purchase a business or assets, we may disclose your information to the prospective seller or purchaser of that business or those assets, provided that they continue to use your information substantially in accordance with this Privacy Policy.
d. Acquisition of ACC’s Assets: If all, or substantially all, of our assets are acquired by a third party, information held by us may be included among the transferred assets, provided that the acquiring party continues to use your information substantially in accordance with this Privacy Policy.
e. Legal Obligations and Protection: We may disclose or share your information where we are required to do so to comply with a legal obligation, enforce or apply our Data Protection Agreements and other service contracts, or protect our rights, property or safety, as well as those of our users or others.
This includes exchanging information with other companies and organisations for fraud prevention and credit risk reduction purposes.
8. Data Retention
8.1 We retain personal information collected from you for as long as we have an ongoing legitimate business need to do so. This may include providing a service you have requested or complying with applicable legal, tax or accounting requirements.
8.2 When we no longer have an ongoing legitimate business need to process your personal information, we will delete or anonymise it.
Where this is not immediately possible, such as when personal information has been stored in backup archives, we will securely store the information and isolate it from further processing until deletion becomes possible.
9. Your Rights
9.1 You have the following data protection rights:
- You can request a copy of your personal data from us in a commonly used and machine-readable format.
- You can ask us to correct or update your personal information by contacting us using the details provided in Section 12 below.
- You can object to the processing of your personal information.
- You can ask us to restrict the processing of your personal information.
- You can request the portability of your personal information.
- You can request the erasure of personal information we hold about you where there is no valid reason for us to continue processing it.
- You can object to our processing of your personal data where we rely on a legitimate interest, including the legitimate interests of a third party, and your particular circumstances mean that you believe the processing affects your fundamental rights and freedoms.
- You can object to the processing of your personal data for direct marketing purposes.
- You may unsubscribe from certain email communications by following the unsubscribe link included in the relevant email.
- Where we collect and process your personal information based on your consent, you may withdraw that consent at any time.
Withdrawing your consent will not affect the lawfulness of any processing conducted before your withdrawal. It will also not affect processing carried out under lawful grounds other than consent.
We maintain procedures to help you confirm that your personal information remains accurate and up to date and to manage whether you wish to receive communications from us. We will respond to every email as promptly as reasonably possible.
If you have privacy-related questions or unresolved concerns, you may contact us using the information provided in Section 12 below.
You also have the right to complain to a data protection authority about our collection and use of your personal information. For further information, please contact your local data protection authority. Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries, including the United States and Canada, are available online.
The website may occasionally contain links to and from third-party websites. If you follow a link to one of these websites, please note that it will have its own privacy policy. Please review the relevant policy before submitting personal information through a third-party website.
10. Children
We strongly believe in protecting children’s privacy.
We do not knowingly collect or retain personal information from anyone under 13 years of age, and no part of the website is directed towards anyone under 13.
If you are under 13, please do not use or access the website at any time or in any manner. We will take appropriate steps to delete any personal information collected from anyone under 13.
11. Updating This Privacy Policy
We may update or amend this Privacy Policy from time to time to comply with the law or reflect changing business requirements.
When we update this Privacy Policy, we will take appropriate measures to inform you in a manner consistent with the significance of the changes.
Any updates or amendments will be posted on the website. By continuing to access the website, you acknowledge that your access to and use of the website will be subject to the updated Privacy Policy.
12. Contacting ACC
If you have questions, comments or formal privacy requests relating to this Privacy Policy or how we handle your data, please contact our Data Protection Team at: DC@accaviation.com
Alternatively, you may contact our regional corporate offices by post at the following addresses:
United Kingdom and Europe, Head Office
ACC Aviation
Priory Gate
18 Castlefield Road
Reigate
Surrey RH2 0AP
United Kingdom
Americas
ACC Aviation
1100 Lee Wagener Blvd
Suite 327
Fort Lauderdale, FL 33315
United States
Middle East and Africa
ACC Aviation
Office 247, Building 5E-B
Dubai Airport Freezone
Dubai
United Arab Emirates