This Privacy Policy sets out details of the information that we may collect from you and how we may use that information. This Privacy Policy should be read alongside, and in addition to, ACC’s Cookie Policy. Please read this Privacy Policy carefully.
1. About Us
1.1 In this Privacy Policy, references to “we” or “us” are NEWACC (2018) Limited and its subsidiaries and branches. ACC is a company incorporated in England and Wales (whose Head Office is at Priory Gate 18 Castlefield Road, Reigate, Surrey RH2 0AP, United Kingdom) who 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. This privacy policy applies to
This Privacy Policy applies to the personal data of our website users, visitors to our blog or our 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 via any means, register or send a request, respond to or participate in any survey or questionnaire sent to you by us, provide comments, purchase our services, or contact us from anywhere worldwide using any media, we may collect, store, use, and share certain personally identifiable information in line with this policy.
3.2 Information You Provide to Us: To register or make an enquiry on the website or by any other media, 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 in order to 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 necessary proof of identity. If you contact us, we may keep 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—for example, details of how long you have used the website.
3.4 Device Identifiers: We may collect your computer’s IP address in order to help us verify your region and tailor our services to your location.
3.5 Identity Verification: If you elect 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: Finally, we may receive information about you from third parties (such as credit reference agencies) who are legally entitled to disclose that information to us.
4. Use of your information
4.1 by accessing our website via any means, registering or send 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 we work with, for any of 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 our other products and services which we think may interest you, unless you opt out as described at section 9 below. You can control your email preferences on the settings page accessed through any email which we have sent you;
to tailor our advertising on social media to your use of the website;
to allow you to use the full range of features on or via our website;
to comply with legal and regulatory requirements;
to contact you occasionally in order to invite you to share your opinions and experiences of acc;
and in order to provide third-party goods or services available through our website
4.2 we may use your email address to send you updates about our services. You can control your email preferences on the settings page accessed through any email that we have sent you.
5. Storage of information/data security
5.1 We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction.
We use secure hosting at tier 1 data centres, with high levels of both digital and physical security and deploy leading EU-based Cloud Software as a Service (SaaS) to support our Enterprise Resource Planning (ERP) systems.
We keep our servers and their applications and security packages, up to date, to provide the best possible security and performance to our clients.
We place appropriate restriction on access to personal data.
5.2 As a multi-national organization, 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 includes data transfers across international borders.
Regardless of where your data is processed, we enforce strict technical, organizational, and contractual safeguards (including approved international data transfer mechanisms) to ensure your information remains protected to the highest regulatory standards. However, while we use robust commercial efforts to safeguard your data, please be aware that no transmission of information over the internet can be guaranteed as completely secure.
6. Legal basis for processing your information
6.1 our legal basis for collecting and using the personal information described above will be legitimate interests. Article 6(1)(f) of the gdpr is the one that is relevant here – it says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of you which require protection of personal data.”
6.2 however, we will normally collect personal information from you only (i) where the processing is in our legitimate interests and not overridden by your rights, (ii) where we need the personal information to perform a contract with you, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you.
6.3 if we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as the possible consequences if you do not provide your information); this will include providing airline travel services to you when travelling on or working as passengers or crew members on chartered or leased flights; this may necessitate transferring personal information overseas. This may necessarily be to counties and territories around the world and acc are required to ensure that when we need to do this we comply with the dpa.
6.4 in certain of the jurisdictions in which we operate, a different legal basis for data processing, consent, will be applied and if we collect and use your sensitive personal data, such as medical and dietary information your specific consent will always be requested at the relevant time.
We don’t think that any of our activities prejudice individuals in any way – in fact, they help us to offer you a more tailored, efficient service. However, you do 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 when permitted by law including:
- a. With your consent
- b. To our suppliers in order for them to help us provide our services to you, this includes:
- acc and its subsidiaries and branches;
- acc’s contracted airline operators and their subsidiaries, branches and agents;
- our customer relationship management services (which allows us, for example, to send personalised email communications to you);
- our provider of file storage and management services if you email us directly;
- our payment services provider (as discussed at paragraph 3.2 above) when you make a purchase to process your payment;
- our identity verification partner (as discussed at paragraph 3.5 above) to verify your identity where you choose to select this option; and
- our customer service software if you contact our support team.
- c. If we sell or buy any business or assets, in which case we may disclose your information to the prospective seller or buyer of such business or assets, provided that they continue to use your information substantially in accordance with the terms of this privacy policy;
- d. If all, or substantially all of our assets, are acquired by a third party provided that they continue to use your information substantially in accordance with the terms of this privacy policy, in which case information held by us will be one of the transferred assets; and
- e. If we are under a duty to disclose or share your information in order to comply with any legal obligation,or in order to enforce or apply our Data Protection Agreements and other service contracts; or to protect our rights, property, or safety, our users, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
8. Data retention
8.1 We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
8.2 When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is 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 edit your personal details by contacting us using the contact details provided in paragraph 12 below whenever you wish. We maintain a procedure in order to help you confirm that your personal information remains correct and up-to-date or choose whether or not you wish to receive material from us. We will answer every email as promptly as possible.
In addition, you can object to the processing of your personal information, ask us to restrict the processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided at paragraph 12 below.
You can request the erasure of personal information that we hold about you where there is no good reason for us to continue processing it, where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
You can object to our processing of your personal data where we are relying on a legitimate interest (or that of a third party), and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object to where we are processing your personal data for direct marketing purposes.
You may unsubscribe from certain email communications by following the unsubscribe link in the email communication itself.
Similarly, if we have collected and processed your personal information on the basis of your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
If you have any privacy-related questions or unresolved problems, you may contact us using the information provided in paragraph 12 below.
You have the right to complain to a data protection authority about our collection and use of your personal information. For more 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 us and canada) are available online.)
The website may, from time to time, contain links to and from third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies. Please check these policies before you submit any personal information to these websites.
10. Children
We strongly believe in protecting the privacy of children. In line with this belief, we do not knowingly collect or maintain personal information from persons under 13 years of age, and no part of the website is directed to persons under 13 years of age. If you are under 13 years of age, then 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 of persons less than 13 years of age.
11. Updating this privacy policy
We may update or amend this privacy policy from time to time to comply with the law or to meet our changing business requirements. When we update our privacy notice, we will take appropriate measures to inform you, consistent with the significance of the changes. Any updates or amendments will be posted on the website. By continuing to access the website, you agree that your access and use will be subject to these updates and amendments.
12. Contacting ACC
If you have any questions, comments, or formal privacy requests regarding 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 physical mail at the locations below:
- United Kingdom & 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
- Middle East & Africa: ACC Aviation, Office 247, Building 5E-B, Dubai Airport Freezone, Dubai, United Arab Emirates