Privacy and cookie policy

Your rights to privacy and the protection of your personal data are very important to us.

This Privacy Policy only applies to Leading Edge Aviation and not to the websites of our business partners or to any other third parties, even if their websites are linked to our website. We recommend you review the privacy policies/statements of any other parties you interact with.This Privacy Policy applies to the way we collect, store and process personal data about our customers, suppliers, online users and other third parties (“you”). This policy sets out how we handle personal data that we collect from you, or that you give to us. Please read the policy carefully to understand our views and practices regarding your personal data and how we will treat it.

Data protection principles

When we process your information, we make sure we follow six principles of good practice, which say that your personal data must be:

processed lawfully, fairly, and in a transparent manner
processed for specified, explicit, and legitimate purposes
adequate, relevant, and limited to what is necessary
accurate and kept up to date
kept for no longer than is necessary, and
processed securely.

Information about you that we collect and process

We may collect and process personal data about you (such as your name, address, email address, phone number, etc., plus information such as username, IP address and similar fields recorded in security and access logs when accessing our websites) when you:

fill in forms or use the functions and services on our websites
enter into a contract with us (e.g. by means of our sales representatives, through service agreements, as a supplier, or a business partner, etc.)
access our premises
use our IT resources and communication systems (e.g., email, network, Wi-Fi, etc.)
correspond with us by phone, email, letters or otherwise
apply to work for us
buy products from us
subscribe to any of our services, or communication channels.

We may use the information you give to us for a number of different purposes. For each purpose, we’re required to confirm the ‘lawful basis’ that allows us to use your information, as follows:

Purposes for which we will use the information about you	Lawful basis
To store your personal data in our Enterprise Resource Planning systems, for warehouse, accounting, sales, service, and purchase management purposes	It will be necessary for the performance of the contract between you and us.
To store your personal data in databases linked to public-facing websites, for customer service, online ordering of products, and customer relationship management	It will be necessary for the performance of the contract between you and us, and for our legitimate business interests, namely the correct management of the business relationship with our customers, as well as internal administrative purposes.
To store your personal data in our systems (including emails) and file shares for customer relationship, business contact, or supplier relationship management	It will be necessary for the performance of the contract between you and us, and for our legitimate business interests, namely the correct management of the business relationship with our customers and suppliers, as well as internal administrative purposes.
To collect, store and use shipping information (including their communication to shippers and freight forwarders)	It will be necessary for the performance of the contract between you and us, and for our legitimate business interests, namely internal administrative purposes.
To screen your personal data against denied parties’ lists/systems for controlling the access to our premises	It will be necessary for our legitimate business interests, namely the interest of preventing fraud and/or illicit behaviors and/or unlawful accesses as well as protecting our assets and premises.
To screen your personal and shipping data against denied parties’ lists/systems for carrying out import/export controls	It will be necessary for our legitimate business interests, namely the interest of preventing fraud, crimes and/or unlawful behaviors, and for complying with a legal obligation to which we are subject under UK law.
To screen your personal data against denied parties’ lists/systems for processing employment applications, or in the context of acting as a sales consultant, distributor or other representative or of Leading Edge Aviation.	It will be necessary for our legitimate business interests, namely the interest of preventing fraud, crimes and/or unlawful behaviors, and for complying with a legal obligation to which we are subject under UK law.
To screen your personal data against denied parties’ lists/systems for onboarding you as a customer or supplier to Leading Edge Aviation.	It will be necessary for our legitimate business interests, namely the interest of preventing fraud, crimes and/or unlawful behaviors, and for complying with a legal obligation to which we are subject under UK law.
To store your personal data in our Active Directory systems for server, user, domain, or access management	It will be necessary for our legitimate business interests, namely for the purposes of ensuring network and information security.

As the table above shows, in most cases we’re legally obliged to collect and process your data. It’s sometimes also necessary for us to collect and process your data so that we can perform the obligations we have as part of our contract with you. We may also collect and process information about you to protect our legitimate business interests, which are listed above.

None of this overrides your interests or fundamental rights and freedoms. But it’s important to note that, if you don’t want us to collect or process information about you, we won’t be able to enter into a contract with you, or let you access our premises and/or use our IT resources and communication systems.

Information we collect about you from other sources

When you visit our websites, we may collect information about you such as the Internet Protocol (IP) address used to connect your computer to the Internet, your username, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. We may use tracking cookies to ask if it’s okay to collect additional information in order to enhance your experience of our website.

We may use the information we collect about you for a number of different purposes. For each purpose, we are required to confirm the ‘lawful basis’ that allows us to use your information, as follows:

Purposes for which we will use the information about you	Lawful basis
To administer our websites and for internal operations, including troubleshooting, data analysis, testing, research, and statistical purposes	It will be necessary for providing you with the services expressly requested (e.g., browse the sites and use their functions) and for our legitimate business interests, namely for the purposes of statistics and for ensuring network and information security.
To make sure you receive the best experience possible when accessing and using our websites, measure or understand the effectiveness of advertising we serve to you, and to deliver relevant advertising to you via third-party analytics and/or profiling cookies	We will only do this if you give us your consent by some specific, informed, and unambiguous method (e.g., when you click on the “OK” or “Accept” button on a displayed cookie consent banner/pop-up).
We also collect information through the use of cookies including Google Analytics to understand general traffic patterns	We will only use this information stored for statistical tracking purposes and not for individual identification. In no way does Leading Edge Aviation relate personal information to these traffic pattern statistics.

You can change the settings on your internet browser to restrict the amount of information that we can collect when you visit our website. But this may mean you don’t get the best user experience possible when accessing and using our website.

Disclosure of your information

You acknowledge that we have the right to share your personal information with:

Competent authorities and regulatory bodies to which we are, or may be, subject
our auditors and quality assurance assessors
online cloud providers
selected third parties, including:
- suppliers and subcontractors to the extent we reasonably consider that it is in your best interests for us to do so, or it is necessary for our legitimate business interests, and
- analytics and search engine providers that assist us in the improvement and optimisation of our sites.

We’ll disclose your personal information to third parties:

if we enter into negotiations to sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets
if Leading Edge Aviation or a substantial number of its assets are acquired by a third party, in which case any personal data we hold about you will be one of the assets transferred to the third party
if we’re under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any contract between you or us, or our website terms of use, or to protect the rights, property, or safety of Leading Edge Aviation, our customers, or others.

Identifying you as a customer

If you’re a business client, we may identify you as a client of Leading Edge Aviation in our marketing material or in legal directories, although we’ll never publicly disclose any confidential information about you without your consent. If you don’t agree to us identifying you as a customer of Leading Edge Aviation, please let us know by writing to our address (see Contact us section on our website).

Where we store your personal data

All the information we collect and process about you is stored on our servers in our various business units, or hosted in secure cloud-based environments. We’ll take all steps reasonably necessary to make sure your data is treated securely, including putting the following safeguards in place:

Entry controls. This includes physical controls in relation to entering our premises as well as computer security controls related to accessing our data and information systems infrastructure.
Secure lockable desks and cupboards. Desks and cupboards are kept locked when not in use if they hold confidential information of any kind.
Methods of disposal. Paper documents are disposed of by shredding in a manner that ensures confidentiality.
Equipment. Our internal policies require that individual computer monitors showing confidential information can’t be seen by passers by, and that users lock or log off from their computer when they’re not using it.
Information security. Leading Edge Aviation employs a number of industry-recognised best practices to make sure our systems meet or exceed internationally-recognised information security standards.

Some of the data that we collect may be processed by external personnel who work for us, our group companies, or one of our suppliers. This includes staff engaged in, among other things, the fulfillment of your orders, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. If you’re concerned about the levels of data security for any of those suppliers, please let us know and we’ll let you know what steps will be taken to protect your data.

Although we’ll use significant measures to protect your personal data, we can’t guarantee its security. Any transmission is at your own risk. Once we’ve received your information, we’ll use strict procedures and security features to try to prevent unauthorised access.

How long we’ll store your personal data

The length of time we’ll store your data will depend on the ‘lawful basis’ for us using that data, as follows:

Lawful basis	Length of time
Where we use/store your data because it is necessary for the performance of the contract between you and us	We will use/store your data for as long as it is necessary for the performance of the contract between you and us.
Where we use/store your data because it is necessary for us to comply with a legal obligation to which we are subject	We will use/store your data for as long as it is necessary for us to comply with our legal obligations.
Where we use/store your data because it is necessary for our legitimate business interests	We will use/store your data until you ask us to stop. However, if we can demonstrate the reason why we are using/storing your data overrides your interests, rights and freedoms, then we will continue to use and store your data for as long as it is necessary for the performance of the contract between you and us (or, if earlier, we no longer have a legitimate interest in using/storing your data).
Where we use/store your data because you have given us your specific, informed and unambiguous consent	We will use/store your data until you ask us to stop.

Your rights

You have various legal rights in relation to the information you give us, or which we collect about you, which are:

You have a right to access the information we hold about you free of charge, together with various information about why and how we’re using your information, to whom we may have disclosed that information, where we originally got the information and how long we’ll use your information.
You have the right to ask us to rectify any information we hold about you that is inaccurate or incomplete.
You have the right to ask us to erase the information we hold about you (the ‘right to be forgotten’). Please note that this right can only be exercised in certain circumstances and, if you ask us to erase your information and we’re not able to do so, we’ll explain why not.
You have the right to ask us to stop using your information where:
- the information we hold about you is inaccurate
- we’re using your information unlawfully
- we no longer need to use the information
- we don’t have a legitimate reason to use the information.

Please note that we may continue to store your information, or use your information for the purpose of legal proceedings or for protecting the rights of any other person.

You have the right to ask us to transmit the information we hold about you to another person or company in a structured, commonly used and machine-readable format. Please note that this right can only be exercised in certain circumstances and, if you ask us to transmit your information and we’re not able to do so, we’ll explain why not.
Where we use/store your information because it’s necessary for our legitimate business interests, you have the right to object to us using/storing your information. We’ll stop using/storing your information unless we can demonstrate why we believe we have a legitimate business interest which overrides your interests, rights and freedoms.
Where we use/store your data because you’ve given us your specific, informed and unambiguous consent, you have the right to withdraw your consent at any time.
You have the right to object to us using/storing your information for direct marketing purposes.

If you wish to exercise any of your legal rights in respect of the personal data which we hold about you, please contact Leading Edge Aviation by writing to our address (see Contact us section on our website).

You also have the right, at any time, to lodge a complaint with the competent Information Commissioner’s Office if you believe we’re not complying with the laws and regulations relating to the use/storage of the information we collect about you.

Automated decision-making

We may use automated decision-making processes during selection (employee and cadet candidates) where specific prerequisites, like rights to work or education qualifications, apply to the role or campaign for which you are applying.

Changes to our policy

Any changes we make to our policy in the future will be posted on our website and, where appropriate, we’ll let you know either by post or email. Please check our website often to see if there have been any updates or changes to our policy.

Contacting us

Questions, comments and requests regarding this policy are welcomed and should be addressed to:

Leading Edge Aviation
Airspeed House
London Oxford Airport
OX5 1RA
United Kingdom

You may also email us via the Contact us section on our website.

Data Protection Officer: Katie Broadhurst
katie.broadhurst@leadingedgeaviation.com