Introduction

As an international Business-to-Business Flight Support Company, data and information are important in the ASM activity.

We take the privacy and protection of data and information seriously and are committed to handling the personal information of all those we engage with, whether customers, suppliers, colleagues or any other community, responsibly and in a way that meets the legal requirements of the countries in which we operate.

As part of using the ASM’s services, browsing our website and contacting the business, data and information is collected. This privacy policy (the “Privacy Policy”) sets out ASM’s approach to safeguarding and maintaining the privacy of that personal information and explains what data is collected, how it is used, the legal basis for its use, and the rights individuals have over that data.
About ASM

ASM provides comprehensive, A to Z aviation support, products and services for commercial and general aviation fleets. ASM takes care of all trip details, planning your flight with expert advice 24/7 state-of-the-art flight control centre with skilled experts in aero operations ensures every detail of your trip is executed efficiently. Upon landing, ASM takes care of your aircraft, assisting with fuelling and ground handling solutions ASM’s Concierge (hotel and transport) services will complement the flight service provided in the skies with the best offers on the ground.

This Privacy Policy explains how ASM collects, uses and protects your personal information to provide you access to our content, and information services.

What we collect

This section explains the personal information that may be collected when using our products and services, and the other personal data we may receive from other sources.

In this Privacy Policy, the term “personal information” refers to the types of information we may collect and use, which include:

  • Contact details, such as your full name, e-mail address, postal address and telephone number;
  • Educational, nationality and professional background information;
  • Usernames and passwords;
  • Payment information, such as a credit or debit card number;
  • Comments, feedback, posts and other content submitted;
  • Interests and communication preferences including marketing permissions where appropriate; and
  • Location information (e.g. through mobile apps).
    We collect and use your personal information in the following main categories:
  • As customer/consumer data, related to transactions, prospective sales or analytics;
  • As contact data, which includes academic and corporate customer contact data such as details of account manager / key contact at corporate customers, and subscriber/user data;
  • In connection to an event, for instance, exhibition or conference visitors, exhibitors, speakers, and attendee data;
  • Product/intelligence data, collected through customer and market research surveys;

Sensitive personal data

If collecting or storing sensitive personal data such as information relating to health, beliefs or political affiliation, we typically ask for your explicit consent. However, there are some situations, of an accidental nature, where it will not be possible to request consent. If this does occur, we will ensure your privacy rights are protected.

Children’s personal data

Our services and products are directed to academics and business professionals. They are not intended for children under the age of 13 and we do not knowingly collect personal data from this age group. If any information is collected from a child under the age of 13 without verification of parental consent, it will be deleted.

How and why personal information is used.
This section explains in detail how and why we use personal information.

LAWFUL PROCESSING IN EUROPE

ASM collects and uses personal information. The lawful bases we use for this activity in Europe, as required under European data protection laws, are:

  • Where it is necessary to enter into or perform a contract with you
  • Where we have a legitimate interest to do so, provided your rights do not override these interests
  • Where you have consented to its use
  • Where our colleagues believe it is in your vital interests to share your details, for example with emergency services
  • Where required to comply with our legal obligation

PRODUCT ENQUIRIES, SALES AND ADMINISTRATION

As part of a purchase, product enquiry, request for information and for account administration, we collect information such as your name, country, job title, company information or academic affiliation, postal address, e-mail address and telephone number.

If you have enquired about us or our products or services, either online or over the phone, we will use your personal information to respond to the enquiry or to take other steps at your request, before you enter into a contract. For example, we collect the e-mail addresses and additional contact details of those who send e-mails to request information. Where a sales representative speaks to you over the phone or live chat, the calls and chats are recorded for training and monitoring purposes only.

If you have registered for or purchased a product or service, including on a trial basis, your personal information will be used to provide that product or service, communicate about it and handle payments, as is necessary for the performance of the contract entered into with us.
For purchases, payment information, including credit/debit card numbers/bank details and billing addresses are also collected. Where payment card processors are used to facilitate payment card transactions on our websites, your data will be collected and used according to that data processor’s privacy policy.

If your personal information is relevant to certain products and is freely available through public sources, such as on a website related to your work or profession, we may use this personal information for providing customers with our products, as is necessary for our legitimate interests as a commercial organisation.

MARKETING

We will use your personal information to send you newsletters, offers or other marketing emails that keep you up to date with news, events, products and research opportunities, from ASM that may be of interest. Depending on the nature of your interaction with us and the laws of the country where you live, you may have actively given us your consent for this, by opting in, or we may be entitled to rely on your implied consent or our legitimate interests. The opportunity to opt out of future marketing emails will always be provided, and information on how to do this is given when your personal information is collected and on every marketing email sent.

CUSTOMER AND PROSPECTS MANAGEMENT INCLUDING ANALYTICS

We may use your personal information, combined with publicly available data and demographic data, to maintain our customer database and carry out internal analysis of the usage of our products and services. This is done to improve those services, develop new products and predict future customer behaviour, as part of our legitimate interests as a commercial organisation. This may include automated profiling and campaign management techniques.

MOBILE APPLICATIONS AND WEBSITES ANALYTICS INCLUDING LOCATION DATA

We may combine visitor session information, or other information collected through tracking technologies, with personally identifiable information to understand and measure your online experience and determine what products, promotions and services are likely to be of interest.

Technical methods are also used in HTML e-mails sent to visitors, for purposes including: (i) to determine whether visitors have opened or forwarded e-mails and/or clicked on links in those e-mails, (ii) to customise the display of banner advertisements and other messages after closing an e-mail, and (iii) to determine whether a visitor has made an enquiry or a purchase in response to a particular e-mail.
In compliance with the California Online Privacy Protection Act (CalOPPA) (e.g.: Browsers Do Not Track Signals) while we strive to offer you choice when using our website and mobile applications, we do not promise that we will be able to receive or honour web browser Do Not Track signals.

AUTOMATED DECISION-MAKING, INCLUDING PROFILING

We use algorithm-based technologies to personalise dynamic web content based on your explicit and/or implicit interests. We carry out general profiling such as segmentation, and non-automated and automated decision-making based on profiling to provide you with a more relevant experience and for our legitimate interests as a commercial organisation. Automated decision-making is never used in any way that produces a legal or similarly significant effect.

Depending on the laws of the country where you live, you may have rights related to our decision. For example, if you live in the European Union, you may have the right not to be subject to our decision, or you may have the right to insist on human intervention in the process, express your point of view or contest the decision. To exercise any such right, please contact us via one of the methods set out in the “Contact Us” section below. In some cases, we may have the right to continue with our decision, following applicable laws. This will be explained if this is the case. Otherwise, we will respond to your request as promptly as reasonably possible.

To ensure compliance with international trade sanction laws and regulations, we screen customers, vendors and suppliers against US, OFAC, BIS, UN, EU and UK sanctions lists. Should any screening check flag an issue where we cannot continue in a contract with a customer or supplier, they will always be informed.

How we protect personal information.

Any personal information given to us will be treated with the utmost care and security. This section sets out some of the security measures in place.

A variety of physical and technical measures is used to keep data safe and prevent unauthorised access to, or use or disclosure of personal information.

Electronic data and databases are stored on secure computer systems and we control who has access to information, using both physical and electronic means. Our colleagues receive data protection training, and we have detailed security and data protection policies that colleagues are required to follow when handling personal data.

All reasonable steps are taken to ensure that your personal information is kept secure from unauthorised access, but we cannot guarantee it will be secure during the transmission process to this website because this transmission is not controlled by us. We make use of HTTPS (HTTP Secure) whereby the communication protocol is encrypted via Transport Layer Security for secure communication over a computer network. The website is loaded via HTTPS, represented by the lock icon in your web browser, which ensures the transmission is secure and is demonstrated by a certificate issued by an official security certificate authority to us.

INTERNATIONAL TRANSFER OF PERSONAL INFORMATION (?)

As an international business and because of the technologies we use, personal information may be accessed by our colleagues and third-party service providers from locations outside of the European Economic Area, whose data protection laws may not be as extensive as those in Europe.
To ensure the same level of protection is in place when processing is conducted outside the European Economic Area, we use appropriate safeguards approved by the European Commission.
We apply appropriate protection to make sure your data remains adequately protected and is treated in line with this Policy. ASM has put in place international data transfer agreements between its companies and relevant third-party service providers based on standard contractual clauses approved by the European Commission.

COOKIES

A cookie is a small text file containing a user ID that is automatically placed on a user’s computer or other device when visiting a website. Cookies record the pages visited and the actions taken on a website, but do not contain any personal information. From time to time, we may use cookies for purposes including administering the Website; tracking your activity on the Website; gathering broad demographic information for aggregate use to improve the Website; and offering time-saving or personalized features on the Website. For more information, please visit the Cookie Policy for the site you are using, which can be found in the website footer.

This website contains links to websites of other businesses, including potential websites of other businesses or public partners of ASM. These businesses will have their privacy policies, tailored to their particular business practices and the sectors in which they operate, and if following those links, we recommend reviewing the privacy policy of each website to understand how personal data is used in that instance. The inclusion of links to these websites does not imply an endorsement or validation of their content, and we are not responsible for their privacy practices, nor do we accept any liability in connection with the content on such websites.
These third-party product providers may share your information with us, which we will use by this policy. In some cases, they will be acting as a controller of your information and therefore we advise you to read their privacy policy.

Who we share personal information with.

As an international company, to provide you with services and products we may share your information for specific reasons. This section explains how and why we share personal data with other companies, our suppliers, and other third parties.

Sharing with ASM partner companies
We may share your personal information with certain other companies within ASM partner network for specific purposes. For example, other companies may assist us in providing products and services to you, in carrying out internal analysis of the usage of products and services, or in offering products and services which may be of interest.

Sharing with Service Providers

We may share your personal information with the following types of third parties, to assist us in providing products and services to you:

  • Fuel providers
  • Ground Handling providers
  • Overflying and landing permit providers
  • Airport Authorities globally
  • Hotels and Ground transportation providers
  • Private Jet services and FBO providers
  • Flight Crew management associations
  • Food & beverage catering providers
    We only share your personal information with such third parties, if and to the extent necessary for them to provide such assistance.

Sharing with other Organisations

We may share your personal information with trusted partner organisations for their marketing purposes, by local data laws and where appropriate your consent. If your personal information is subject to European data protection laws, we will not share it with third parties for their marketing purposes, unless you have actively given us your consent to do this.

We may also share your personal information with third parties in the event of a sale, merger, acquisition, partnership, joint venture, or negotiations related to the same concerning all or part of our business.

In some circumstances, we may be legally required to disclose your personal information, because a court, the police, another judicial or law enforcement body, or a government entity has asked us for it.

How long information is kept

We will only retain your personal information for as long as is necessary and as permitted by applicable laws.

We will retain your personal information while we are using it, as described in the section above, and may continue to retain it after these uses have ended when we have a legitimate business purpose. For example, if you have opted out of marketing communications from us, we will retain limited details about you to ensure we can honour your opt-out request. We may also continue to retain your personal information to meet our legal requirements or to defend or exercise our legal rights.
Personal information will only be retained for as long as is necessary and as permitted by applicable laws. The length of time for which we will retain your personal information will depend on the purposes for which we need to retain it. After we no longer need to retain your personal information, it will be deleted or securely destroyed.

How to update your information and marketing preferences

We want to ensure you remain in control of your personal information. We try to ensure that the personal information held about you is accurate and up-to-date, and will always give the opportunity to opt out of future marketing communications.

We will process your data to send marketing information that we believe is targeted and of interest to you. If you are a registered user, you can access your account information and make corrections or updates upon log-in. The accuracy of such information is solely your responsibility.

Information on how to opt out will be given when your personal information is collected and specified in every marketing email sent. You may opt out of our email marketing lists by following the directions at the bottom of our emails. Please note that ASM has several services and we allow you to opt out selectively. To remove a specific email address from all of ASM marketing communications, send a request to pr@asm.aero. If you wish to remove your email address only from a specific brand, please use the opt-out mechanism provided in emails you receive from such brand, or contact the brand directly.

You may receive email marketing messages from us about the company’s offerings as part of a business partner marketing program. To opt out of a business partner marketing email program, follow the instructions at the bottom of any email sent as part of the program. Please note that opting out of promotional mailings will not affect the delivery of your subscription-based products.
Your rights

ASM operates in countries with data protection laws that may provide individuals the right to be able to access and control their information. We always will enable you to be able to exercise the rights provided by data protection laws.

EU data protection laws give individuals several rights, where their data and information are collected and used by companies that are active and operating in Europe. Under the General Data Protection Regulation, these are:

  • The right to confirm whether or not we have your data and, if we do, to obtain a copy of the personal information we hold. This is known as a subject access request;
  • The right to have inaccurate data rectified;
  • The right to have your data erased. This does not however apply where we must continue to use the data for a lawful reason;
  • The right to request the restriction or suppression of their data, such as we will stop using the data but we may continue storing it)
  • The right to obtain the personal data that you have provided to us, based on consent or performance of a contract, and where technically feasible, transmitted in a common electronic format to you or directly to another company.
  • The right to object to the use of your data. Specifically, you have the right to object to our use for marketing and automated decision-making, including profiling where there may be legal or similarly significant effects.

There are exceptions to the rights above. Where you request us as part of these rights, we will always try to respond to your satisfaction, although there may be situations where we are unable to do so.

Depending on the laws of the country where you live, you may have other rights in respect of your personal information. If you wish to exercise any legal right in respect of your personal information, please contact us via one of the methods set out in the Contact Us section below.
In some cases, we may be entitled to decline a request you have made regarding your personal information, by application laws. We will explain if that is the case. Otherwise, we will meet your request as promptly as we reasonably can. If you have requested that we stop sending you marketing messages, please note that you may still receive them for a short period while the request is processed.

CONTACT US

If you have any questions about this Privacy Policy, contact us at pr@asm.aero

Changes to Privacy Policy
To keep up with changing legislation, best practices and changes in how we process personal data, we may revise this Privacy Policy at any time and without notice by posting a revised version on this website. Checking back periodically will mean you are aware of any changes. This Privacy Policy should be read in conjunction with the website’s Terms and is also subject to these Terms.

This Privacy Policy was last updated on August 8, 2024.