Privacy Policy

Date of enactment: December 16th, 2021
Date of revision: March 31st, 2024

ITC-AeroLeasing, Inc. and our subsidiaries (“we”/”us”/“our”) privacy policies are written to comply with (a) the Japanese Act on the Protection of Personal Information, as amended (the “Act”), (b) guidelines regarding the Act, and (c) other related laws and regulations regarding the handling and protection of personal information.

1. Definition of personal information
The meaning of terms used in this Privacy Policy shall be in accordance with the Act and related government ordinances and guidelines issued by the Personal Information Protection Commission.

2. Measures for the safe management of personal information
We will take necessary and appropriate organizational, personnel, physical, and technical measures to protect personal information in accordance with laws and regulations to prevent leakage, loss, or damage of personal information. When handling personal information in foreign countries, we would protect and to safely manage the personal information based on our understanding of the systems for the protection of personal information in those countries.

3. Compliance with the Act
We will comply with the following items when we obtain, use, and provide personal information.
a. Acquisition of Personal Information
To the extent necessary in connection with aircraft operating leases, aircraft sales (including import and export), and other services provided by us and related ancillary services (the “Service”), we may appropriately acquire personal information from users of the Service (for the purposes of this Privacy Policy, the terms “you”, “your” and “yourself” shall include any prospective user or other person associated with the Service.).
b. Purpose of use of personal information
We will not use personal information appropriately obtained by us beyond the scope necessary to achieve the purposes of use specified below, except as provided by law or with your consent.
i. To confirm the identity of the applicant when applying for the Service.
ii. To bill and settle remuneration such as lease payments, aircraft sales (including import and export) and commissions incurred in connection with the use of this service and to exercise rights and fulfill obligations under contracts with you and laws.
iii. To confirm, investigate, and reply to inquiries received regarding the Service.
iv. To provide various reports such as status reports and progress reports to you when using the Service.
v. To make various proposals related to the Service, including announcements, advertisements, promotions, and introductions of information that may be useful to you.
vi. To provide or entrust the handling of personal information to a third party in accordance with iii of this section or Clause 5 of this policy below.
vii. To properly perform the entrusted work when all or part of the processing of personal information is entrusted by other business operators, etc.
c. Provision of personal information
Except as required by law, we will not provide personal information we obtained to a third party without your prior consent.
d. Requests for disclosure, correction, addition, or deletion of personal information
We will comply with the laws and regulations and respond appropriately to any requests from you for the disclosure, correction, addition, deletion, suspension of use of personal information, suspension of provision of personal information to third parties, or notification of the purpose of use of personal information. For specific request procedures, please see Clause 9 below.

4. Changing the purpose of use of personal information
As a general rule, we will not change the uses specified in Clause 3(b) above, except in cases where we have obtained your consent. However, this does not apply to cases where we publicly announce the purpose to the extent that we deem that the change is reasonably related to the purpose of use before the change.

5. Outsourcing of personal information to third parties
We may entrust all or part of the handling of personal information to a third party for the purpose of use described in Clause 3 (b). In such cases, the Company will adhere to the relevant laws and will exercise necessary and appropriate supervision over the party to which the information is provided or entrusted in order to ensure the safe management of the personal information.

6. About Cookies
A cookie is a function that allows a customer’s website browsing information to be stored on that customer’s computer. Our website uses cookies to obtain browsing information, such as the number of visits and pages visited, for statistical purposes. All of the information obtained is anonymous and cannot be used to identify you personally. It is possible to delete cookies already recorded on your device or refuse the use of cookies in the future through your browser’s settings. Please refer to your browser’s operating help manual for details on how to do this.

7. Improvement and review of the handling of personal information
We will conduct audits of the handling of personal information, management systems and initiatives, and strive to continuously improve and review them.

8. Deletion of personal information
We will endeavor to delete or dispose of personal information when we determine that it is no longer necessary in light of the purpose for which it is used, and such deletion and disposal will be conducted in a manner that is necessary and appropriate to prevent risks such as leakage to outside parties.

9. Contact information for inquiries, requests, complaints, consultation
ITC-AeroLeasing, Inc.
President and CEO Mirika Nakayama
5F THE WALL, 2-1-5 Shinkawa, Chuo-ku, Tokyo
Tel: 03-3555-3621
Attention: Responsible Officer for the Management of Personal Data
Masafumi Imanishi

10. GDPR Privacy Policy
In addition to the above, we will comply with the EU General Data Protection Regulation (“GDPR”) and other relevant laws and regulations when handling personal information of individuals located within the European Union (“EU”), the United Kingdom (“UK”), Iceland, Liechtenstein, or Norway (the “GDPR Jurisdiction”), and will use such information appropriately in light of our business activities, including the following items, after reading the definition of personal information in this Privacy Policy in accordance with the GDPR and other relevant laws and regulations to the extent that the GDPR is applicable to us.
a. Legal basis for processing of personal information
We may handle personal information obtained directly or indirectly from you, or through public information, social media, third parties, if:
i. you consent,
ii. if the disclosure is necessary for the performance of a contract to which you are a party to or for precontractual procedures,
iii. if the disclosure is necessary for us to comply with a legal obligation to which we are subject,
iv. if the disclosure is necessary to protect your vital interests or the vital interests of another natural person,
v. if the disclosure is necessary for the public interest or the exercise of our official authority,
vi. if the disclosure is necessary for customer service, marketing, or our other legitimate interests.
b. Your rights
You have the right to withdraw your consent to the processing of your personal data. You also have the right of access, rectification, erasure, restriction of processing, notification, opposition, data portability and the right not to be subjected to automated processing of your personal information. For the contact information, please refer to Clause 9 above.
c. Retention period for personal information
At the end of the legal retention period under applicable laws, we will promptly erase the personal information concerned, unless it is necessary in connection with the purpose of processing the personal information.
d. Contact for inquiries
Please see Clause 9 above.

This Privacy Policy is made in Japanese and English. In the event of conflict between the two versions, the Japanese version will prevail.