Air Lease Corporation
Updated May 2020

Website Privacy and Cookies Policy

Introduction

This Privacy and Cookies Policy ("Policy") applies to information that Air Lease Corporation and its subsidiaries and affiliates (collectively referred to in this Policy as "ALC", the "Company" or "we") collects about you on or through the Company's website. This Policy describes how we collect such information, how we use it and to whom and under what circumstances we may disclose it. Appendix A contains important information about how we use cookies. Appendix B contains important information for residents of California about the California Consumer Privacy Act ("CCPA"). Appendix C contains important information for citizens of the European Union regarding the EU's General Data Protection Regulation ("GDPR").

ALC is a leading aircraft leasing company principally engaged in purchasing commercial aircraft and leasing them to our airline customers worldwide. The Company collects personal information on its website to facilitate the use of the website or to send you information you have requested. Personal Data, includes but is not limited to, your name, company affiliation, email address, and for purposes of the EU's General Data Protection Regulation (GDPR) if applicable to you, any information relating to an identified or identifiable natural person ('data subject'); 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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person ("Personal Data").

The Company may store Personal Data on the Company's systems or third-party systems the Company uses.

Policy Overview

The Company seeks to adhere to the following privacy principles:

  • To collect only information that is necessary and relevant
  • To maintain Personal Data in a secure manner
  • To use reasonable practices and technology consistent with the industry standards to safeguard security and privacy of data
  • To limit access to only those persons who have legitimate business need to access the Personal Data
  • To disseminate information only as necessary to conduct the Company's business and pursuant to reasonable written assurances regarding confidentiality.

Processing of Personal Data

The Company will not process or transfer Personal Data or disclose or permit the disclosure of Personal Data to any third party other than (1) as necessary for the provision of the website, 2) disseminating the requested information to the requester or (3) as required to comply with privacy and other applicable laws. The Company may appoint certain third parties to provide services such as web support, cloud storage service, or email distribution, and these third-party service providers are in each case subject to the terms of privacy and confidentiality.

The Company uses Google reCAPTCHA technologies as a method of protection on the subscription system and contact form located on the Contact Us page. Google requires placement of a cookie for this technology to function. Google does not share this information or its use of the information with the Company. Google may use the information gathered by the cookie to deliver content and/or ads to the user. Refer to Google's Privacy Policy (https://policies.google.com/privacy) for information on their data capture and use policies.

Confidentiality and Security

The Company shall keep Personal Data confidential and will instruct its employees and third-party processors to do the same. Personal Data must be treated as confidential on a personal level and secured with suitable organizational and technical measures to prevent unauthorized access, illegal processing or distribution, as well as accidental loss, modification or destruction. The Company has implemented appropriate technical and organizational measures to ensure a level of security appropriate to the risk in its technology infrastructure and systems, IT support functions, and various tools for storing and disseminating Company information, including Personal Data.

Children's Privacy

The Company does not knowingly collect, use or disclose personal information from or about children, as defined by local law. If you believe that we have collected personal information about a child, please contact us so that we can delete the information.

Deletion of Personal Data

The Company will, at the request of the subject of the Personal Data, delete the Personal Data to the extent reasonably possible.

Subject data requests must be submitted in writing via email to [email protected] or by writing to the below address,:

Attention:
Air Lease Corporation,
2000 Avenue of the Stars,
Suite 1000N,
Los Angeles, CA 90067

Such requests must contain information necessary to properly identify your computer and browser. We will reply to each request within 30 days of receipt of the request.

Personal Data Breach

The Company will notify the subject of the Personal Data after becoming aware of any personal data breach and will provide the subject with sufficient information to meet any obligations under applicable privacy laws.

Training

The Company will regularly train its employees, consultants and contractors on all the Company's policies, including this Policy, and will raise and maintain awareness about the importance of security and integrity in the management and processing of Personal Data.

Appendix Index