Introduction

This is the Privacy Notice of China Aircraft Leasing Limited (CALC). This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.

The General Data Protection Regulation (GDPR) seeks to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain.

CALC has identified its data subjects as being:

1. Employees
2. Contractors/CALC representatives
3. Client and client related contacts
4. Third party suppliers

CALC is pleased to provide the following Privacy Notice:

 

PERSONAL DATA

China Aircraft Leasing Group Holdings Limited ("CALC") is a full value chain aircraft solutions provider for the global aviation industry. The Group and its member companies offer services at every stage of an aircraft life cycle, from new aircraft, used aircraft, to aircraft coming to the end of their life, capturing the asset value of an aircraft fleet by proactive asset management. The Group’s scope of business includes regular operations such as aircraft operating leasing, purchase and leaseback, and structured financing, as well as value-added services such as fleet planning, fleet upgrade, aircraft disassembling and recycling, as well as component sales.

 

Established in 2006 and headquartered in Hong Kong, CALC is China’s first aircraft operating lessor. It is currently the largest independent lessor in China and one of the top 10 global aircraft lessors, based on the combined asset value of its fleet and order book, according to renowned aviation consulting firm ICF International. As of 30 June 2018, CALC’s fleet totalled 115 aircraft, with a strong order book backlog for new aircraft of 189 aircraft. Its clientele is widely spread across 14 countries and regions in Asia Pacific, the Middle East, Europe, North America and Latin America.

CALC does not operate a service to the public. Our clients are corporate bodies and not individuals, however, we collect the personal data of individuals in the context of our dealings with those corporate bodies.
PERSONAL DATA is collected about our data subjects from correspondence and phone calls and agreements entered into, or else in the form of employee details. We collect details of visits to our website, including but not limited to personally identifying information like Internet Protocol (IP) addresses. CALC may from time to time use such information to identify its visitors. CALC may also collect statistics about the behaviour of visitors to its website.

 

CALC website uses cookies, which is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. WordPress.org uses cookies to help CALC identify and track visitors and their website access preferences. CALC website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using CALC website.

 

Any information CALC holds about you and your business encompasses all the details we hold about you.

CALC will only collect the information needed so that it can provide you with our verification and consulting services. We do not buy data, neither do we sell or broker your data.

 

LEGAL BASIS FOR PROCESSING ANY PERSONAL DATA:

CONTRACT:
CALC will process data during the process of providing services to our clients and while carrying out employee contracts. Throughout our business transactions, all data is by default crossing borders as all data is backed up and shared with our parent company in Hong Kong. We notify the data subject in all correspondence by displaying on every email correspondence this fact.

 

LEGAL OBLIGATION:
CALC will process data to meet the CALC’s legal obligations in respect of Company Law, Security, Revenue and Employment Law obligations.

CONSENT
In general CALC will not rely on consent as a lawful basis of processing. Given the business to business element and contractual requirement of all of our dealings consent is not an appropriate lawful basis for processing as withdrawal of consent will have a consequence that will render the contract inoperable.

However, consent will be required where an employee application is being made and the awareness that the cross border element of processing is likely will be brought to the attention of the applicant at the point of data collection.

 

LEGITIMATE INTERESTS PURSUED BY CALC
In general CALC will not rely on legitimate interests, however, should such a lawful basis arise CALC are committed to balancing the data subject data protection rights against this legitimate interest of CALC, we have considered:
a. The frequency of notifications to you in order to ensure that no nuisance is caused to you;
b. The security and integrity of the data you have provided to us;
c. Your rights and entitlements to stop the processing of your data with ease and to this end we have an unsubscribe option within all correspondence of this nature

 

DISCLOSURE AND DATA TRANSFER

CALC do not broker or pass on information gained from your engagement with us.
By operation of our company, which is an international company, data is shared within the CALC group of entities across the group.

The group is bound by Binding Company Rules in the administration and processing of all personal data.

However, CALC may disclose Personal Information to meet legal obligations, regulations or valid governmental request. We may also enforce our Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of CALC its clients and/or the wider community.

 

RETENTION POLICY

CALC will process personal data during the duration of any contract and will continue to store data in accordance within legal obligations, and in accordance with their statutory retention requirements. Otherwise data will be deleted within one year of expiry of its purpose.

DATA STORAGE

Data is held in Hong Kong using cloud based servers. CALC stores personal data outside the EEA.

 

YOUR RIGHTS AS A DATA SUBJECT

At any point whilst CALC is in possession of or processing your personal data, all data subjects have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you, this is qualified by the requirement to retain any confidentially provided information.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records, this is qualified by any statutory obligation of data retention
• Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.

In the event that CALC refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.

CALC at your request can confirm what information it holds about you and how it is processed.

 

YOU CAN REQUEST THE FOLLOWING INFORMATION:

• Identity and the contact details of the person or organisation (CALC) that has determined how and why to process your data.
• Contact details of the Data Protection Officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of CALC or a third party such as one of its clients, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority (Data Protection Regulator).
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

 

TO ACCESS WHAT PERSONAL DATA IS HELD, IDENTIFICATION WILL BE REQUIRED

CALC will accept the following forms of ID when information on your personal data is requested: a copy of your National ID Card, driving license, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If CALC is dissatisfied with the quality, further information may be sought before personal data can be released.

All requests should be made to dpo@CALC.aero or by phoning or writing to us at the address further below.

 

COMPLAINTS

In the event that you wish to make a compliant about how your personal data is being processed by CALC or its partners, you have the right to complain to the Data Protection Commission at www.dataprotection.ie