Privacy Policy

Aero Business Solutions. Privacy Practices

 

 

Below you will find Aero Business Solutions’s Privacy Policy and Cookie Policy. These policies apply to Aero Business Solutions and its affiliated companies (collectively “Aero Business Solutions”). PLEASE READ THESE POLICIES CAREFULLY.

PRIVACY POLICY

Effective Date: May 25, 2018.

This policy applies to Aero Business Solutions. and its affiliated companies (collectively “Aero Business Solutions”).

Aero Business Solutions understands that your privacy is important to you and is committed to safeguarding the confidentiality and privacy of personal information entrusted to it.

This Privacy Policy describes how Aero Business Solutions handles and protects your personal information in connection with the hosting of this website, and the provision of its diverse business advisory services in the fields of corporate finance and restructuring, economic and financial consulting, forensic and litigation consulting, health solutions, strategic communications and technology (“Services”), as explained in more detail here: https://www.aerobusinesssolutions.com/services.

Scope of this policy

This policy applies to personal information which is collected and/or used by Aero Business Solutions in its capacity as a controller as that term is defined in the Indian Personal Data Protection Bill, 2018. The contexts in which this might occur are explored under “When do we collect personal information” below.

When we provide Services to clients, we sometimes handle personal information as a processor. This means that we process the information solely on the instructions of our clients, who retain control of the information. Therefore, if our use of your personal information is not covered by this policy, you may need to contact the client (and controller) on whose behalf the processing of your information is carried out.

Quick read

Aero Business Solutions collects personal information from and on behalf of its clients (e.g. about their employees and customers) to provide business advisory and other services to those clients. It also processes client personal information to manage its relationship with those clients. Further, Aero Business Solutions also collects some personal information from visitors to this website, recruitment applicants, and attendees at Aero Business Solutions events.

Aero Business Solutions uses personal information to deliver its Services to clients. For its own purposes, it also uses personal information to analyse and improve how it delivers those services, to contact representatives of its clients or prospective clients and to market to them, and to administer recruitment and events.

If Aero Business Solutions uses your personal information, you may have certain important rights which you can exercise. The rights you will be able to exercise will depend on how and why Aero Business Solutions uses your information.

The primary point of contact at Aero Business Solutions for questions regarding your personal information is privacy@aerobusinesssolutions.com (or support@aerobusinesssolutions.com).

Who is your controller?

The Aero Business Solutions entity responsible for your personal information will be the entity that originally collected information from or about you. If you have a direct interaction with Aero Business Solutions (for example, you attend an Aero Business Solutions hosted event), the identity of your controller may be disclosed to you in connection with that interaction. If we process your personal information in the course of providing our Services to clients, your controller will be the ABS entity providing the Services (assuming those Services are provided as a controller, see above for an explanation). Please note that the contact details for all ABS entities in respect of data protection or privacy issues are the same, and are as set out below.

Your Acceptance

In respect of personal information collected over this and other Aero Business Solutions websites, your continued use of these websites constitutes your understanding of, and agreement to, the practices described in this Privacy Policy and elsewhere on the websites as well as any subsequent updates. Please see the additional information under the heading [Legal] for more information about our online terms of use and policies in general.

When do we collect personal information?

We collect information about you if:

  • you use this (or any other Aero Business Solutions) website;
  • you enquire about, or engage Aero Business Solutions to provide, its Services (either in a personal capacity, or as a representative for your employer or client);
  • the use of your personal information is reasonably necessary to provide our Services (in these circumstances, your personal information may be disclosed to us by our client who may, for example, be your employer or service provider, or we may obtain your personal information from a range of public or subscription sources, directly from you, or from your associates or persons known to you);
  • you apply for a position with Aero Business Solutions;
  • you attend an Aero Business Solutions hosted or sponsored event or webinar;
  • you contact us with any other enquiry, complaint or notice.

What types of personal information are collected and what do we use it for?

The following is a summary of the types of personal information we collect, and the purposes for which that information is used.

Website Users

Aero Business Solutions collects your name, address, e-mail address, telephone number and any other personally-identifiable information which you voluntarily provide as “comments” when you submit an inquiry through the “Contact Us” tool or sign-up forms or other opt-in forms. Aero Business Solutions also collects other background information about you in connection with career-related inquiries that you submit through its website.

Aero Business Solutions may also automatically collect personal information (through the use of Cookies or similar technologies, including your IP address, device identifier, browsing patterns on its websites, clickstream data, and HTP protocol elements) to ensure the effective operation of the website or in order to align the presentation of our Services more closely to your requirements (for example, processing information about your broad geographic location to serve you with a local version of this website). This tracking information is stored in an anonymous, aggregated and non-personal format, and is also used to understand and analyze trends, to administer the websites, and to learn about user behavior on the websites.

Please refer to our Cookie Policy for a more detailed overview on how Aero Business Solutions uses Cookies.

In certain instances, Aero Business Solutions may use IP addresses to help identify you when Aero Business Solutions feels, in its sole discretion, that it is necessary to enforce compliance with this Privacy Policy, to protect its services, websites, systems, information, employees, business partners, subsidiaries, affiliates, users, customers or others, or when required by law or for law enforcement purposes.

Aero Business Solutions’s Former, Current and Prospective Clients

If you submit an enquiry to Aero Business Solutions about our Services (either over the website, or by emailing, telephoning or meeting with one of our colleagues), then we will process information such as your name, job title and contact information in order to respond to your enquiry.

If you attend an Aero Business Solutions event or webinar, or if you associate with an Aero Business Solutions colleague at, for example, an industry event, then Aero Business Solutions may collect basic personal information, such as contact details, which you voluntarily provide (for example, by filling in a form or handing over a business card) in order to facilitate your participation in the event, and for the management of our relationship with you as an actual or prospective client.

If you or the organisation you are associated with becomes an Aero Business Solutions client, then we may process your personal information in order to:

  • carry out “Know Your Client” checks and screening prior to starting a new engagement (as well as basic contact information, this may mean processing compliance related information such as proof of your identity, information about your professional background, history of directorships and, in some circumstance, details of any criminal convictions or adverse media coverage);
  • carry out background checks for the purposes of complying with anti-money laundering and terrorist financing laws;
  • carry out client communication, service, billing and administration;
  • deal with client complaints; and
  • administer claims.

Taking account of applicable marketing laws, we also process personal information about our clients (former, current and prospective) in order to:

  • send our clients newsletters, know-how, promotional material and other marketing communications;
  • invite our clients to events (and arrange and administer those events).

Performing Services for Our Clients

As discussed above, many of our Services involve the processing of personal information. In the majority of cases, personal information is provided to us in strict confidence, subject to restrictive undertakings on its use / disclosure.

Illustrative examples of the use of personal information in connection with our Services, and the legal bases we rely upon for using personal information, are set out in Annex 1 (Use of Personal Information for our Services).

Other Uses

If you apply for a position with Aero Business Solutions, we will need to collect personal information in order to consider your application, and during any interview and assessment phase.

If you enquire about, or decide to purchase stock in Aero Business Solutions, then we will collect (either from you or from your broker / investment manager) basic personal information required to register you as a stockholder.

Finally, if you contact us for any other reason, we will collect basic contact details, as well as any other personal information relevant to the reason for your enquiry, in order to resolve that enquiry.

What is our legal basis for collecting personal information?

All processing (i.e. use) of your personal information is justified by a “lawful basis” for processing. In the majority of cases, processing will be justified on the basis that:

  • the processing is necessary for the performance of a contract to which you are a party, or to take steps (at your request) to enter into a contract (e.g. where you request certain Services as an individual client, or where we help advise your employer or service provider on fulfilling an obligation to you under a contract);
  • the processing is necessary for us to comply with a relevant legal obligation (e.g. where we are required to collect certain information about our clients for tax or accounting purposes, or where we are required to make disclosures to courts or regulators); or
  • the processing is necessary for the performance of a task carried out in the public interest (e.g. background checks for anti-money laundering and terrorist financing purposes); or
  • the processing is in our legitimate interests, subject to due consideration for your interests and fundamental rights (this is the basis we rely upon for the majority of the processing of personal information in connection with the provision of our Services, and also for the purposes of most client on-boarding, administration and relationship management activities).

In limited circumstances, we will use your consent as the basis for processing your personal information, for example, where we are required by applicable law to obtain your prior consent in order to send you marketing communications.

Before collecting and/or using any special categories of data (as that term is defined in the GDPR), or criminal record data, we will establish a lawful exemption which will allow us to use that information. This exemption will typically be:

  • your explicit consent;
  • the establishment, exercise or defence by us or third parties of legal claims; or
  • other uses allowed by applicable law including context specific exemptions provided for under local laws of EU Member States and other countries implementing the GDPR, such as in relation to the processing of special category data for the purposes of preventing or detecting fraud in relation to instructions from potential clients.

Disclosure of Personal Information to Third Parties

Aero Business Solutions will not disclose your personal information to third parties other than as described in this Privacy Policy unless Aero Business Solutions has your permission or is required or permitted by law. Aero Business Solutions may share such information with its affiliates as necessary to carry out the purposes for which the information was supplied or collected. Similarly, third party contractors, consultants and/or vendors engaged by Aero Business Solutions to provide services may have access to your personal information. These third parties will be subject to their own data protection requirements providing the same or greater level of security provided by Aero Business Solutions and in most instances will also have entered into a written agreement with Aero Business Solutions which addresses the protection of your personal information.

Aero Business Solutions may also disclose your personal information for the purposes of:

  • responding to requests from law enforcement agencies, regulators or courts, or to subpoenas, search warrants, or other legal requests;
  • the prevention and/or detection of crime;
  • establishing legal rights or to investigate or pursue legal claims;
  • a merger, acquisition or corporate restructuring to which Aero Business Solutions is subject;
  • preventing risk of harm to an individual.

International Hosting and Transfer of Information

Aero Business Solutions is a global organization and may transfer certain personal information collected on its websites across geographical borders to Aero Business Solutions offices, personnel, or third parties located throughout the world. Aero Business Solutions may also store such information in a jurisdiction other than where you are based.

Aero Business Solutions will take appropriate steps ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights. To this end:

  • Where we transfer your personal information outside Aero Business Solutions to third parties who help provide us with any of the activities described in this policy, we obtain contractual commitments (such as the Standard Contractual Clauses) from them in order to protect your personal information.
  • Where we receive requests for information from law enforcement, courts or regulators (who may be based overseas), we carefully validate these requests before any personal information are disclosed.

You have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information when this is transferred as mentioned above.

Information Security

Aero Business Solutions has reasonable technical safeguards, security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Measures we take include placing confidentiality requirements on our staff members and service providers, limiting access to your personal information on a “need to know” basis, and providing training to appropriate Aero Business Solutions personnel. We also maintain comprehensive policies addressing data incident response protocols.

Despite Aero Business Solutions’s best efforts, however, security cannot be absolutely guaranteed against all threats.

Retention of your personal information

Aero Business Solutions retains your personal information for the period of time required for the purposes for which it was collected, any compatible purposes which we subsequently establish, or any new purposes to which you subsequently consent, or to comply with legal, regulatory and Aero Business Solutions policy requirements. This period of time will usually be the period of your, or the relevant client’s, relationship or contract with Aero Business Solutions plus a period reflecting the length of time for which legal claims may be made following the termination of such relationship or contract. Some information (such as call recordings, tax records and certain information required to demonstrate regulatory compliance) may need to be kept for longer. Personal information will be kept for a shorter or longer period of time if so required by law or an Aero Business Solutions policy, if the information becomes subject to a legal hold (for example, following a communication from our regulator) or if we have identified through a data protection impact assessment that a different retention period is appropriate.

Right to Access

You have the right to access personal information which Aero Business Solutions holds about you, together with certain information about how and why your personal information is processed.

Right to Rectification

You have a right to request us to correct your personal information where it is inaccurate or out of date.

Right to be Forgotten (Right to Erasure)

You have the right under certain circumstances to have your personal information erased. Your information can only be erased if it is no longer necessary for the purpose for which it was collected, and we have no other legal ground for processing the information.

Right to Restrict Processing

You have the right to restrict the processing of your personal information, but only where:

  • its accuracy is contested, to allow us to verify its accuracy; or
  • the processing is unlawful, but you do not want it erased; or
  •     it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
  • you have exercised the right to object, and verification of overriding grounds is pending.

Right to Data Portability

You have the right to data portability, which requires us to provide personal information to you or another controller in a commonly used, machine readable format, but only where the processing of that information is based on (i) consent; or (ii) the performance of a contract to which you are a party. Please note that Aero Business Solutions rarely relies upon consent as a legal basis, and the performance of a contract basis will only be relevant to the extent that you, as an individual, are party to a contract with Aero Business Solutions or a client, and our use of your personal information is necessary for the performance of that contract.

Right to Object to Processing

You have the right to object to the processing of your personal information at any time, but only where that processing is based on our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

Marketing

Aero Business Solutions may send you information related to its services, products and events that we believe are of interest to you. This information may be sent by post or via email. If at any point you no longer prefer to receive marketing communications from Aero Business Solutions you can (i) unsubscribe from Aero Business Solutions communications sent by email using a link provided in marketing emails sent from Aero Business Solutions; or (ii) contact us to exercise your right to prevent all forms of marketing (both post and email).

Children

Aero Business Solutions’s websites are not intentionally designed for or directed at children under the age of 13. It is Aero Business Solutions’s policy never to knowingly collect or maintain information about anyone under the age of 13, except as part of an engagement to provide professional services.

Links

Aero Business Solutions websites may contain links to other sites, including websites maintained by Aero Business Solutions affiliates that are governed by other privacy policies that may differ somewhat from this one. Users should review the privacy policy of each website visited before disclosing any personal information. To the extent that Aero Business Solutions provides links to third party websites, such links do not constitute an endorsement, sponsorship, or recommendation by Aero Business Solutions of the third parties, the third party websites, or the information contained on those websites, and Aero Business Solutions is not responsible or liable for your use of such third party websites. Where appropriate you should review the privacy policies of any websites or applications before submitting personal information.

Changes to this Policy

By using Aero Business Solutions websites you consent to the collection, use and storage of personal information as described in this Privacy Policy and elsewhere on the websites. Aero Business Solutions reserves the right to make changes to this Website Privacy Policy from time to time. Aero Business Solutions will notify you by posting amendments to the Privacy Policy on this website.

Contact Us

If you have questions or concerns regarding this policy or Aero Business Solutions’s personal data processing policies, please contact Aero Business Solutions at: support@aerobusinesssolutions.com.

If you reside in the EEA and have questions or concerns regarding this policy or processing of your personal information by Aero Business Solutions please contact us at support@aerobusinesssolutions.com.

COOKIE POLICY

Effective Date: May 25, 2018.

This policy applies to Aero Business Solutions and its affiliated companies (collectively “Aero Business Solutions”).

Aero Business Solutions is committed to safeguarding the privacy of your personal information and to being transparent about the technologies it uses. This Cookie Policy explains how and why Cookies and similar technologies are used by Aero Business Solutions to improve and enhance your user experience when using our websites. This Cookie Policy should read in conjunction with the Aero Business Solutions Privacy Policy. By continuing to browse or use Aero Business Solutions websites you agree that Aero Business Solutions can store and access Cookies as described in this Policy.

What are Cookies and other Tracking Technologies?

A cookie is a small text file containing small amounts of information that a website puts on a user’s computer (or mobile device) when you visit a website and is used by the website to send information to your browser and for the browser to return information to the website.

You can find more information about cookies at: www.allaboutcookies.org and www.youronlinechoices.eu. For a video about cookies, please visit www.google.com/policies/technologies/cookies.

How do we use Cookies and other Tracking Technologies?

The information your browser sends to one of Aero Business Solutions’s websites is used for authentication and identification of your session and allows Aero Business Solutions to display the correct information on the website. Aero Business Solutions matches the cookie against your details so it can distinguish you from other users as you browse the site, which helps it to provide you with a good user experience. Most web browsers enable you to erase cookies, block cookies, receive a warning before a cookie is stored on your device or disable cookies. If you wish to withdraw consent to use Cookies at any point you will need to delete cookies using your web browsers settings. If you do so, however, this site may not function correctly.

Logging: Aero Business Solutions records and stores details of the pages visited so that it can generate usage statistics. Except as otherwise provided in this Privacy Policy, Aero Business Solutions does not sell or share any information gathered to other companies.

Cookie retention: This website uses cookies which are persistent and non-persistent (session-based). While many of the cookies used on this website only last for the duration of your use of this website (session-based cookies), other cookies are persistent, i.e., stay in one of your browser’s subfolders until you delete them manually or your browser deletes them.

What types of Cookies may be used?

First party cookies – First party cookies are set by the Aero Business Solutions website you are visiting and they can only be read by Aero Business Solutions.

Session cookies – Session cookies are used by the server to store information about user page activities so users can easily pick up where they left off on the server’s pages. These are temporary cookie files, which are erased when you close your browser, and when you restart your browser and go back to the site that created the cookie, the website will not recognize you. You will have to log back in (if login is required) or select your preferences/themes again if the website uses these features. A new session cookie will be generated, which will store your browsing information and will be active until you leave the site and close your browser.

Persistent cookies – Persistent cookies are employed to store user preferences. These files stay in one of your browser’s subfolders until you delete them manually or your browser deletes them based on the duration period contained within the persistent cookie’s file. For Information on session and persistent cookies, see here.

Third party cookies – Third party cookies are set by a different organization to the owner of the website you are visiting. For example, the website might use a third party analytics company that will set its own cookies to perform this service (for example, as described below, this website uses Google Analytics).

Aero Business Solutions websites also uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to help analyze how users use the site, for example which pages are most frequently visited. The information generated by a Google Analytics cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. 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. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

By continuing to use this website you give your consent for Aero Business Solutions to use cookies as detailed above.

If the way Aero Business Solutions uses cookies changes significantly (e.g. a new cookie being added with different functionality), Aero Business Solutions will inform you from the login page. This detail will always be available to you from the navigation links at the bottom of all pages.

What if I don’t want cookies to be used?

By using Aero Business Solutions’s website you agree that Aero Business Solutions can place cookies on your device as explained above. If you want to remove existing cookies from your device you can do this using your browser options. If you want to block future cookies from being placed on your device you can change your browser settings to do this. Please note that if you use your browser settings to block the use of all Cookies it may impact certain functionality on the Aero Business Solutions websites or degrade your browsing experience.

Contact Us

If you have questions or concerns regarding this policy or Aero Business Solutions’s personal data processing policies, please contact Aero Business Solutions at: support@aerobusinesssolutions.com.