Privacy Policy

1. Information We Collect

We may collect the following categories of personal information when you interact with our website or services:

Personal Identification Information

This includes your full name, email address, telephone number, postal address, company name, job title, and professional credentials. We collect this information when you submit inquiry forms, request proposals, or communicate with us directly.

Business and Financial Information

For aircraft leasing transactions, we may collect business registration details, financial statements, proof of funds, credit references, insurance certificates, and other documentation necessary for lease qualification and compliance purposes.

Technical Information

When you visit our website, we automatically collect certain technical data including your IP address, browser type and version, operating system, referring URLs, pages viewed, and the dates and times of your visits. This information helps us improve our website and services.

Communication Records

We may record and retain correspondence including emails, phone conversations, and written communications related to your inquiries, lease negotiations, and ongoing account management.

2. How We Collect Your Information

We collect personal information through the following channels:

• Direct Interactions: When you fill out forms on our website, send us emails, call our office, or correspond with us through any communication channel.
• Business Transactions: Throughout the aircraft leasing process including initial inquiry, due diligence, documentation, and ongoing lease administration.
• Automated Technologies: Through cookies, server logs, and similar tracking technologies when you browse our website.
• Third-Party Sources: From credit reporting agencies, business registries, regulatory databases, and references provided during the lease qualification process.

3. How We Use Your Information

We use the personal information we collect for the following purposes:

• To process and respond to your inquiries and service requests
• To evaluate lease applications and conduct due diligence assessments
• To negotiate, document, and administer aircraft lease agreements
• To provide ongoing lease management, billing, and customer support services
• To comply with legal and regulatory obligations including anti-money laundering requirements and aviation safety regulations
• To communicate important updates, service changes, and policy modifications
• To improve our website functionality, user experience, and service offerings
• To detect, prevent, and address fraud, security incidents, and other harmful activities
• To enforce our terms of service and other contractual agreements

4. Legal Basis for Processing

We process your personal information based on the following legal grounds:

• Contractual Necessity: Processing necessary to fulfill our obligations under lease agreements and service contracts.
• Legitimate Interests: Processing for our legitimate business interests including client communication, service improvement, fraud prevention, and network security, provided your rights do not override these interests.
• Legal Compliance: Processing required to comply with applicable laws, regulations, court orders, or government requests.
• Consent: Where we rely on your consent for specific processing activities, you have the right to withdraw your consent at any time.

5. Information Sharing and Disclosure

We may share your personal information with the following categories of third parties:

• Service Providers: Trusted third-party vendors who assist us with website hosting, payment processing, email delivery, data analytics, and customer relationship management.
• Aviation Authorities: Regulatory bodies such as the Federal Aviation Administration (FAA), European Union Aviation Safety Agency (EASA), and other civil aviation authorities as required for aircraft registration and compliance.
• Financial Institutions: Banks, insurance companies, and financial advisors involved in lease financing and insurance arrangements.
• Professional Advisors: Legal counsel, auditors, and consultants who provide professional services to our organization.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.
• Legal Requirements: Law enforcement agencies, courts, or regulatory authorities when required by applicable law or legal process.

We do not sell your personal information to third parties for their own marketing purposes. All third-party disclosures are governed by strict confidentiality agreements and data protection obligations.

6. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, or as required by applicable law. Specifically:

• Inquiry and correspondence records are retained for three years following the conclusion of the inquiry
• Lease transaction records are retained for the duration of the lease term plus seven years thereafter
• Financial and compliance documentation is retained in accordance with applicable recordkeeping requirements
• Website analytics data is retained for a period not exceeding 24 months

When personal information is no longer required, we securely delete or anonymize it in accordance with our data retention and destruction policies.

7. Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit using TLS protocols and at rest using industry-standard encryption algorithms
• Secure server infrastructure with firewall protection and intrusion detection systems
• Access controls and authentication requirements for all personnel handling personal data
• Regular security assessments, vulnerability scanning, and penetration testing
• Employee training on data protection practices and confidentiality obligations
• Incident response procedures to address any potential data breaches promptly

While we strive to protect your personal information, no method of transmission or storage is completely secure. We cannot guarantee absolute security but will promptly notify you of any confirmed data breach affecting your information as required by applicable law.

8. Your Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Right to Access: Request a copy of the personal information we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete personal information.
• Right to Erasure: Request deletion of your personal information subject to certain legal exceptions.
• Right to Restrict Processing: Request limitation of how we process your personal information.
• Right to Data Portability: Request transfer of your personal information to another service provider.
• Right to Object: Object to processing of your personal information for direct marketing or legitimate interests.
• Right to Withdraw Consent: Withdraw your consent at any time where processing is based on consent.

To exercise any of these rights, please contact us using the information provided in Section 12. We will respond to your request within 30 days or as otherwise required by applicable law.

9. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyze site traffic, and understand where our visitors come from. Cookies are small text files stored on your device by your web browser.

We use the following types of cookies:

• Essential Cookies: Required for the basic functionality of our website, including session management and security features.
• Analytics Cookies: Help us understand how visitors interact with our website, which pages are most frequently visited, and how users navigate through our site.
• Preference Cookies: Remember your settings and preferences for future visits to improve your user experience.

You can control cookie settings through your browser preferences. Please note that disabling certain cookies may affect the functionality and performance of our website.

10. Third-Party Links

Our website may contain links to third-party websites, services, or resources that are not owned or controlled by GEW AIRCRAFT LEASING LLC. We are not responsible for the privacy practices or content of these third-party sites. We encourage you to review the privacy policies of any third-party websites you visit.

11. Children Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that a child has provided us with personal information without parental consent, we will take steps to delete such information promptly. If you believe a child has provided us with personal information, please contact us immediately.

12. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or industry standards. When we make material changes, we will update the effective date at the top of this policy and notify you through our website or other appropriate communication channels. We encourage you to review this policy periodically for any updates.

14. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the State of Florida and applicable United States federal law, without regard to its conflict of law provisions. Any disputes arising under this policy shall be resolved in the courts of Collier County, Florida.