Privacy policy, Data policy,cookies policy and gdpr

Global Aviation Exchange Limited trades as Global AVX. Global AVX publishes articles, news posts and other such advertisements and publications which may include information and posts of users. Such publications and advertisements issued by Global AVX are for advertising purposes only and information contained within same should not be relied upon. Should such reliance occur and a detriment occur to the user, Global AVX will not be liable for any such loss/damage that has/could occur.

This privacy policy explains how we use any personal information we collect about you when you use this website or dealings directly with staff employed by Global AVX over the phone, email or any other medium, or at events:

This Privacy Policy applies to all users of our platform whether you have registered and created an account or otherwise. If you do not accept this privacy policy, you must not use this site.

WHY DO WE COLLECT DATA?

We collect data to enhance the user experience and to consistently improve our service. We also collect data to connect customers with one another, to connect potentially interested parties with a seller who has what the buyer wants. 

We use it to keep you and ourselves informed about the Aviation market, listings, trends, events and products, and to manage your account, communications, print and digital magazine subscriptions, advertising purchases and to assist in the collation of Transparency Reports™ for users where appropriate.

That includes:

HOW DO WE COLLECT & USE YOUR DATA?

Marketing

1. User account

When you register with Global AVX to advertise aircraft, to purchase aircraft or to receive digital magazine or aircraft alerts, you create an account with a username or email address and password.

We store your email and username but do not store your password. If you forget your password, you will need to reset it via the site, in the ordinary cours

Depending on if you set up a buyer or seller account we will store and require different data.

2. Email Enquiries to Advertisers for Aircraft Sales or Aviation Services:

When you complete an email enquiry, we collect the following data and pass to the relevant advertiser or the Global AVX Admin Team: Your Name, Email Address, Location, Company Name (Optional), Phone Number, Aircraft Type/Model and content of the query.

Whilst we require advertisers not to use your personal information for anything other than addressing your enquiry, we cannot control the conduct of third parties and do not accept any liability in respect of any conduct of such third party.

Enquiries put on a public listing on the platform will not bare any information about the publisher, it will contain a randomised username for the user putting in the enquiry so as to protect anonymity. 

3. Email Aircraft Alerts and Digital Magazines Sign Ups:

When you sign up for Alerts or Digital magazines, we collect the following data: Your Name, Email Address, Location, Aircraft Type/Model that you are interested in

4. Auctions

Global AVX may contact you in relation to auctions that you have been granted access to, bided on, engaged with. This contact may be by way of phone or email, to inform you of upcoming similar auctions, new data/documents uploaded on the specific listing, auction window opening or nearing an end, new bids on the listing and any other such communication that we feel you may be interested in. when a user places a bid on a listing, that user will be given a unique bidder number. This is in the interest of privacy for the user. When a subsequent bid is placed by that user, the same bidder number will be applied to the bids.

We collect information from each individual auction – number of users that visited the listing, bids placed, value of bids, time of visits and bids, timeline of events, auction window, when information was accessed, questions/comments asked on listings, number of verified bidders, attendees to auction room and data room, time spent in the auction room or data room, downloads of information and/or documents, winning bidder and value, requests for further fund verifications, number of refused attendees, and any other such relevant information. We collect this to keep our systems up to date and to deliver each user with the best system we can. We also collect this information to develop our platform, for the collation of Transparency Reports™, for the use in subsequent auctions to assist other users achieve the best possible price for their asset, to contact underbidders for upcoming similar auctions and other such communications with users. We will never provide a third party/other user with your personal data such as name or contact details (save in accordance with a request by you to do so or in the instance of a successful bid/offer being accepted as such details are required for the finalising of contracts/sales sheets).

5. Advertisements and Print Subscriptions:

When you book advertisements online or via our staff, or take out print subscriptions, we collect the following data: Your Name, Company Address, Addresses, Phone Numbers, VAT number, Conversation Notes, Purchase and Payments details. Payment details are not retained or stored in any format by Global AVX.

6. Social Media

We may promote your advertisements via our Social Media channels. Our website includes Social Media links to Facebook, Twitter and Instagram so that you can share and comment on our content on your account. These Social Media companies may collect your IP address, which page you are visiting, and may set a cookie to enable the related feature to function properly. Your interactions with these companies are governed by their privacy policies.

7. Keeping in Touch

We may contact you about the service you have signed up for, e.g. to provide you with password reminders, to notify you that a particular service, activity or online content has been suspended for maintenance, to notify you of updates to our Privacy and Cookies Policy, Data Policy or Terms of Use, to let you know if your account has become dormant and to ask if you would like to use it again before we close it. We may also contact you to clarify verification documents and to keep up to date with fund verification and address/identity verification.

We may from time to time contact you by email or phone in relation to new listings, auctions that you may be interested in given your previous activity and interests whilst on our site. Such contact may be by way of email, e-magazine or otherwise. Should you wish to be contacted in relation to certain changes or new listings please contact our Admin Team at admin@globalavx.com.

Please note that any communications had with us and/or our staff by way of phone, email, in person or any other medium may be recorded and kept on our systems for as long as we deem necessary. Please note that we retain the right to delete or maintain such communications/data.

 8. Google Analytics & Google DFP

Global AVX gathers information via Google Analytics, as is industry-standard practice, including internet protocol (IP) addresses, browser type, internet service provider (ISP), landing pages, referral sources such as Search Engines, Other Websites and Social Media, Device Use, Location, Operating System, Date/Time and more. Google Analytics includes features that can be considered profiling from the perspective of the GDPR. To read more about Google’s privacy policy, you may visit this site:  https://privacy.google.com/. If you wish to block the Google Analytics tool from being used to track your use of the website, you may also use this Google browser add-on to block all Google Analytics code:https://support.google.com/analytics/answer/181881?hl=en 

We use  Google DFP to serve display banner and MPU advertising.

Further, we use data collected by Google Analytics to enhance the user experience and develop our platform and services. Data collected by Google Analytics is also used in the collation of Transparency Reports™.

Google Analytics uses cookies to collect information about users of our site. This information is used by us to improve the user interface and compile reports for internal use and also for Transparency Reports™ for our own records and for users. These cookies are also collected on an anonymous manner and do not include any site that you came from before visiting our site, identity of the user etc. The information generated by the cookies of Google about the user of our site (including your IP Address) will be transmitted to and stored by Google on serves in the United State of America. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of our site, this may also interfere with your ability to use such facilities such as placing bids etc. By using our site, you consent to the processing of data about you by Google in the manner and for the purposes set out above and below. 

As Google Analytics is a third party provide we advise that you satisfy yourself with Google’s Data and Privacy policy as linked above.

9. Cookies

Cookies are text files downloaded to your computer (or mobile device/tablet) when you visit a site or application that collects standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. Most browsers are initially set to accept cookies, but you can change your settings to notify you when a cookie is being updated, or to block cookies altogether. Please note that by blocking any or all of these cookies you may not have access to certain features, content or personalization available through our Site. This information does not identify individual users. 

Cookies are able to record user preferences and behaviours on a particular site and can be used to identify user, market trends for statistical purposes and also to develop and better the user experience on the site. Without the use of cookies, a server would not have a record/note of any previous user visits. Authorising us to use and collect cookies whilst you use our site is essential to the development of the site, ensuring it is user friendly and also giving users feedback on each element of the site/their listings. However, it is important to note that the use of cookies does not grant us access to personal information. By using the site as it is and without amending the cookie usage/authorisations, you agree to our use of cookies, including through Google Analytics.

OPTING OUT OF E-MARKETING?

You may opt out at any time. Please contact our office via the Contact page, requesting to opt out of same. 

CHECKING + CHANGING YOUR DATA

We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.

You can request a copy of the information that we hold about you free of charge. *

We aim to respond to your request within one month of receiving it, if a sufficient response cannot be obtained within that time in our opinion, we will inform you of any delay and a projected time of completion.

You can access and make edits to the personal data we hold about you by logging into the site and accessing your account. Please note any amendment may affect your fund or identity verification; and therefore may result in a delay or inability to use the site/platform in full and/or bid on listings for a period until such is verified by our Admin Team.

If you would like to enquire about any additional data we hold about you, we will need to verify the identity of the person making the request, using ‘reasonable means’. This will include asking for some details to verify your identity. Please include proof of your identity and address (e.g. a copy of your driving licence or passport, and a recent utility or credit card bill) and specify the personal data you want access to.

Once you have received your details you can also request that we correct or delete any inaccuracies in this information free of charge. Clarification/proof may be required prior to any amendment and/or deletion. Global AVX reserves the right in our absolute discretion to amend or delete same were we deem it reasonable to do so.

Please follow the same process as above and specify which information is incorrect and what it should be replaced wi

*However, we may charge a ‘reasonable fee’ when a request is manifestly unfounded or excessive, particularly if it is repetitive. The fee charged will be based on the administrative cost of providing the information. You will be informed of this estimated cost prior to our office commencing any work on same, at which point you may decide to proceed with such a request or not. Payment of this cost will need to be made prior to the release of the report/assessment by our office.

WHO ELSE HAS ACCESS TO MY DATA?

Certain Data may be used in the creation or collation of data for Transparency Reports™ for other uses, this data will not include your personal data if the report is for another user. However, the Transparency Reports™ may contain your data in the form of a statistic or a recognition of a bid, view, offer, query etc on another users Transparency Reports™.

We will never disclose your personal information to anyone outside of Global AVX except where we have your consent or are requested by you to do so; where we are required or permitted to do so by law, such as when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process; where other companies who provide a service to us as part of our order process require that data i.e. delivery companies, payment providers; or companies who send out email communications on our behalf; or where they are successors in title to our business. Personal data may be shared with another user where an agreement is met between the users and the data is required in order to finalise details/terms of agreement/contract or to arrange viewings or the sharing of additional documents/information.

Your information may be used as part of our Transparency Reports™ and for statistical analysis for our own use or for use in publications and advertisements by Global AVX but such information will be anonymous. 

We also may look at data to review market trends and complete company progress reports and Transparency Reports™, and publications on market analysis and other such topics

We may need to use or store some of your information to comply with our legal and regulatory obligations, or for possible legal proceedings. For fund verified bidders we keep all up to date fund verifications and documents provided in relation to same for such period that the verification is valid or until new verification is provided, whichever is the later.

payments – auction deposits and account details

If the user wants to become a verified user and granted access to an Auction Room or Data Room, the user may be required to put a deposit in escrow. Please see the how it works page.

This access deposit is required before access will be granted to the user. The Deposit is to be made to the designated Global AVX Escrow provider. Account details are to be sent electronically and verified over the phone prior to any transfer. This applies to a transfer into and out of the Escrow Account. The Escrow provider may keep your account details on record for as long as they hold funds on your behalf or for any such period to which you authorise them to hold same. You authorise Global AVX to contact the Escrow provider to verify that funds have been received this is in order that the user be granted access to the Auction Room or Data Room. Further, on the completion of a successful action/bid, you authorise Global AVX to contact the Escrow provider to release our fee to our designated company account.

If you decide to send details via e-mail, please remember that any communications via the internet aren’t safe unless they’ve been encrypted.  If someone gets into your emails without your permission or the information is shared publicly, it is out of our control and we cannot accept responsibility. If sent via email we may call to verify the details sent.

THIRD PARTIES & DATA MANAGEMENT 
  1. Please do not submit your personal information to us if you do not wish for us to collect, use and/or transfer your personal information under the terms of this policy.
  2. Except where we specifically ask for information from you, we do not collect your personal data.
  3. This privacy policy only applies to this site. When you visit other websites via links from or on our site, please read their privacy policies.
DATA SECURITY

We follow best practice for data collection and storage and have followed what we feel to be in accordance with GDPR Guidelines.

We have considered the issues around Data Breach and reviewed our policies to protect the personal information that we collect and process about you.

Any client financial data is protected by third party encryption.

The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. 

No data transmission over the internet is completely secure, so we do not guarantee the security or integrity of your personal information and/or use of the site. However, we do follow best practice to protect your personal data by using encryption technology. We will use reasonable efforts to prevent accidental loss, destruction, copying and/or damage. We follow industry accepted standards to protect the personal information submitted to us. In order to access your account, where some of your personal information and data is kept, you will be required to conduct a two-step authentication. This will include having a verified account via email link, providing a telephone number to be linked to your account. Given the sensitivity of the data/personal information on your account and that your account may be verified to place offers/bids, the two-step authentication will be required at each login. This process will be completed by inputting the code that is sent to your linked phone number onto the platform.

Each user will automatically be logged out after a period if there is no activity on their login session. Each session can be extended and the user will be prompted to do so. This is in order to help keep your account and data secure and to restrict unauthorised usage. Further, we may use third party providers such as Cloudfare, a third party provider that is an integrated global cloud platform that is ISO 27001 Certified.

Further, we have incorporated reCaptcha as an addition, albeit minor, level of security against the creation/admission of computer generated accounts

If you feel that your account or data has been accessed by an unauthorised user please contact us immediately as admin@globalavx.com or via your appointed Global AVX liaison. We conduct continuous security assessments of our system and how it can be improved. If there is an area in which we can improve on please do not hesitate in contacting us.

We will keep your information for as long as you actively receive our newsletters or as needed to provide you with our services/use of our platform. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

After an account is cancelled, copies of some information may remain viewable in some circumstances where, for example, you or we have posted items on social media. Global AVX reserves the rights to keep such social media post and other publications/articles/information and data on our system and media platforms. Due to the nature of caching technology, your account may not be instantly inaccessible to others. We may also retain backup information related to your account on our servers for some time after cancellation for fraud detection or to comply with applicable law or our internal security policies. It is not always possible to completely remove or delete all your information due to technical constraints, contractual or legal requirements.

If you disagree or are unhappy with the way we handle your personal data and we are unable to resolve your issue, you have the right to lodge a complaint with the Data Protection Commissioner, contact details can be found at dataprotection.ie.

Should you wish to discuss any of the above or any of the other terms and conditions/terms of use, data policy or otherwise, please do not hesitate to contact us at info@globalavx.com and one of our staff will revert to you at their earliest convenience.

PRIVACY POLICY UPDATED

We review our privacy policy regularly. However, we may change or amend our policies from time to time, as such we require and you are advised to review them on a regular basis. Third party providers that we use may also amend their terms/policies from time to time, we also recommend that you familiarise yourself with such policies at regular intervals.

This privacy policy was last updated on 31st March 2020.