COOKIE STATEMENT
At SMBC Aviation Capital ("we", "us" or "our"), we want to ensure that your visit to our website (the "Website") is smooth, reliable and as useful to you as possible. Subject to your consent where required by applicable law, we use cookies and similar technologies ("cookies") to help us improve the use and functionality of the Website and to better understand how visitors use the Website and the tools and services offered on it.
This Cookie Statement should be read in conjunction with our Website Terms of Use for further information about accessing and using our Website and our Privacy Statement for further details about the ways in which we collect and use your personal data).
1. WHAT ARE COOKIES?
Cookies are small data files that are stored in your web browser on your computer, tablet or smartphone (each a "Device") when you visit a website. Cookies serve a number of purposes like letting you navigate between pages efficiently, remembering your preferences, interests or log in details, and generally improving your experience.
You can use our cookie preference centre to control what cookies are set by the Website. This is available by clicking on "Privacy Settings" in the bottom left corner of the Website.
Most web browsers automatically accept cookies, but if you do not want to allow cookies or only allow the use of certain types of cookies, please refer to your browser settings which should allow you to accept or deny cookies (please read section 12 below for more details about how to do this). You can also use the browser settings to withdraw your consent to the use of cookies at any time or delete cookies that have already been set on your Device. Keep in mind that by disabling certain categories of cookies, you may be prevented from accessing some features of the Website. You should be able to find more in depth information about opting out of cookies on your browser settings menu.
2. DO WE USE COOKIES?
Yes, we use cookies to enhance the visitor experience on our Website.
3. WHY DO WE USE COOKIES?
We use cookies for the following purposes:
- Enable core functionality such as page navigation, security and logged-in status (strictly necessary)
- Understand how visitors interact with the content (analytics)
- Improve the Website by ensuring the Website is performing properly (performance cookies)
- Capture the preferences of visitors to the Website and allow you to watch a video (functional cookies)
- Track how you use social media embedded on the Website (tracking cookies).
4. WHICH COOKIES DO WE USE?
General Information
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Source (Where cookies come from) |
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First Party Cookies |
These cookies are provided by us and used by various features on our Website. Examples may include customising a visitor’s visit, providing statistical information, and verifying a visitor’s identity for security purposes. |
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Third Party Cookies |
These cookies are provided by "Third Party" vendors who provide products and features we have integrated into our Website. Examples include social media sites, ad networks, and security systems. |
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Expiration (How long cookies last) |
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Session Cookies |
These cookies are added when a visitor starts to browse our Website or interacts with a specific feature and are deleted when the browser is closed |
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Persistent Cookies |
These cookies are added when a visitor starts to browse our Website or interacts with a specific feature, but may remain stored on your Device until a certain termination date is reached (in terms of minutes, days or years from the creation/update of the cookie). |
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Type (How do we categorise the cookies) |
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Strictly Necessary cookies |
We set certain cookies which are strictly necessary to allow you to access the Website, to move between pages and to receive services which you have requested. |
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Analytics |
We set analytics cookies to collect information about how visitors use the Website, for instance which pages visitors go to most often. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. |
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Performance cookies |
We set performance cookies to improve our Website and ensure that it is performing correctly |
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Functional cookies |
We set functional cookies to allow the Website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features, such as playing a video. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. We have set Youtube videos to play without setting cookies where possible that track you. |
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Tracking cookies |
Third parties use their own cookies to track performance, identify fraudulent and non-human traffic. |
Website Cookies and other tracking technologies
Further details on our specific use of cookies are contained in the following table:
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Cookie Type |
Name |
Purpose |
Expiration |
Who Provides the Cookie? |
Opt Out Link |
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Necessary |
Cookie-agreed |
Used to determine if a user has consented to the cookie statement |
100 days |
Smbc.aero |
n/a |
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Necessary |
Cookie-agreed-categories |
Used to determine if a user has consented to the cookie categories |
100 days |
Smbc.aero |
n/a |
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Necessary |
SSESS# |
Preserves user state across pages requests |
Session |
Investors.smbc.aero |
n/a |
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Functional |
lang |
Used by Twitter to set the language for our Twitter feed at the bottom of front page
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Session |
Cdn.syndication.twing.com |
n/a |
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Analytics |
_ga |
Registers a unique ID that is used to generate statistical data on how the visitor uses the Website |
0 seconds |
Google Analytics |
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Analytics |
_gat |
Used to throttle request rate. |
0 seconds |
Google Analytics |
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Analytics |
_gid |
Registers a unique ID that is used to generate statistical data on how the visitor uses the Website |
0 seconds |
Google Analytics |
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Tracking |
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Tracking |
GPS PREF Visitor_unfo1-live YSC Yt-remote-cast-installed Yt-remote-connected-devices Yt-remote-device-id Yt-remote-fast-check-period Yt-remote-session-app Yt-remote-session-name |
Enables Youtube videos embedded on the site and collects data about user interaction for Google and SMBC AC |
1 day 8 months 179 days Session Session
Persistent
Persistent Session
Session
Session |
Youtube |
5. WHAT ARE SCRIPTS AND THIRD PARTY REQUESTS?
Scripts are small pieces of computer code that can be used to track users and their behaviour on websites. The Website uses fonts that are provided by Adobe (TypeKit). For more information about the information processed by Adobe please read the Adobe Fonts Privacy Information Page.
6. WHAT ARE SOCIAL MEDIA BUTTONS?
We have included social media buttons on the Website. These provide links to our LinkedIn account and to our Twitter account. We do not place any cookies or other trackers when you use these links from the Website. However, if you are logged into your own LinkedIn or Twitter account, then either of these parties may use their own scripts and trackers to record that you have visited our social media account and use it for their own purposes.
For more information about how these Third Parties process your information, please read the links provided below.
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Social Media Channel |
Policies |
Opt-out |
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YouTube |
7. WHAT TYPE OF INFORMATION DO YOUR COOKIES COLLECT?
We receive the following types of information about you through the cookies we use:-
- Cookie browser data: cookie identifiers, time/date, pages viewed and to which cookies you have consented;
- Device data: device type, screen resolution, operating system version, browser information, such as, its version and basic settings ;
- Log data: Time and duration of usage of the Website and search data;
- Location data: Data in relation to your country & county of access in accordance with your device;
- Analytical data: Data tin relation to your usage of the Website
- IP addresses: In server log files for website security purposes
We anonymise and aggregate the data that we collect. Where you give us permission to collect additional information then we can do this on the basis of your consent. There are a small number of situations where we collect the information in our legitimate interests, for instance IP address data in weblogs to help us keep the Website secure.
8. HOW LONG DOES MY CONSENT LAST FOR?
Your consent will last for 6 months from the date you last provided it to us using the cookie tool on the Website. After this period, the cookie tool will automatically treat your consent as withdrawn. You can change your cookie settings by clicking on "Privacy Settings" at the bottom left of each page of the Website.
9. HOW LONG WILL YOU RETAIN THE INFORMATION?
We do not process or retain personal information in an identifiable format for longer than is necessary.
We process and retain your personal information for the following durations:
- With respect to strictly necessary cookies, the processing of your personal information ends with your browsing session after which your personal information is deleted (except in relation to cookies used to remember your consent preferences, which we retain and process for 6 months from the date you provide your consent).
- All other cookie-related personal information is processed until the consent which permits such processing is withdrawn or expires (i.e. after 6 months in most cases), at which point it is deleted.
The only exceptions to the periods mentioned above are where:
- the law, court or supervisory authority requires us to hold your personal information for a longer period, or delete it sooner;
- you have raised a legal claim, complaint or concern regarding the processing activities described in this statement, in which case we will retain your information for a period of 6 years following the date of that claim, complaint or concern; or
- you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law.
10. WHO WILL HAVE ACCESS TO MY PERSONAL DATA?
We disclose your personal information to third parties or permit them to access that information in connection with the purposes mentioned above.
Our third-party service providers, agents and subcontractors ("suppliers"), commercial partners, group companies and other third parties may receive cookie-related personal information either directly from you, us or from one of our suppliers.
Our suppliers can be categorised as follows:
- Social media platforms
- Website and data analytics/modelling platform providers
- Website and app developers
- Website hosting services providers
The majority of suppliers we use are processors with whom we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions. We only disclose to them or allow them to access personal information that is necessary for them to provide their services.
11. WILL MY PERSONAL DATA BE TRANSFERRED OUTSIDE OF THE EUROPEAN ECONOMIC AREA (EEA)?
The transmission of information via the Internet is not completely secure and may involve the transfer of personal data to a third party outside of the European Economic Area (EEA). To the limited extent that it is necessary to transfer your personal data outside of the EEA, we will ensure appropriate safeguards are in place to protect the privacy and integrity of such personal data, including Standard Contractual Clauses under Article 46.2 of the GDPR, adequacy decision under Article 45, and the Privacy Shield mechanism. Please contact us if you wish to obtain information concerning such safeguards . See Section 17 for contact details.
We use Google Analytics to collect information about your use of the Website. Google does transfer data to the United States of America (USA). However, we have anonymised IP addresses for the Website which means that no individual can be identified by their IP address.
Twitter and Youtube also transfer data collected by the cookies to the USA. We are working to understand how the data transfers to the USA can continue to be conducted lawfully and may take additional safeguarding actions to protect any data collected and transferred.
12. HOW CAN I MANAGE COOKIES?
You can control the cookies placed and retained on your Device. The Privacy Statement and this Cookie Statement are provided to be transparent about our practices regarding the use of cookies and to allow you the opportunity to make an informed choice. You can change your cookie setting by clicking here or by using the "Cookie Preferences" on the bottom of each page of the Website.
Where applicable, we will obtain your prior informed consent to use cookies and other tracking technologies which store or access information on your Device. Most browsers accept cookies automatically but they can be set up to ask for your prior consent before an individual cookie is set on your Device. This will give you control over your cookies, however, it may interfere with your browsing experience as some websites may not function properly and you may not be able to take advantage of all the features offered by the Website.
For instructions on blocking and deleting cookies, see the privacy and help documentation for your specific browser’s website. If you use more Devices and/or browsers you will need to disable cookies on each Device and on each browser separately. Here are the locations of the cookie settings for all major web browsers:
- Internet Explorer - Tools > Internet Options > Privacy tab.
- Mozilla Firefox - Tools > Options > Privacy menu.
- Safari - Edit > Preferences > Privacy menu.
- Chrome - Settings > Content Settings > Privacy > Cookies.
To opt out of being tracked by Google Analytics across all websites, visit https://tools.google.com/dlpage/gaoptout.
If you limit the ability of the Website to set cookies, this may prevent you from using certain features of the Website properly and your user experience, which will no longer be personalised for you, may deteriorate. You may also be able to opt-out from certain cookies through third-party cookie management sites. Disabling cookies may prevent you from using certain parts of the Website. If you delete your cookies from the browser, you may need to remember to re-install opt-out cookies.
13. WHERE CAN I GET MORE INFORMATION ABOUT COOKIES?
You can find more information about cookies by visiting the following information websites:
14. WHO IS THE DATA CONTROLLER?
SMBC Aviation Capital is the data controller for any personal data processed by the Website. Please see the contact us section for more details.
A data controller is the legal entity that decides why and how your personal information is processed. In relation to cookies set by third parties through the website, if any, those parties are also a controller of your personal information, which means they will also have a legal responsibility to you in respect of the personal information they receive. Please see the section "Who will my cookie data be shared with" for further details.
15. WHAT ARE MY DATA RIGHTS?
Under certain circumstances, by law, you have a number of rights, such as:
ePrivacy rights – the right to withdraw your consent to non-necessary cookies – you can change your cookie settings by clicking "Privacy Settings" from the bottom left of each page on the Website.
Data Protection Rights - you have several rights in relation to your personal data processed by cookies on the Website. You have a right to:
- access a copy of your personal data held by SMBC AC;
- request rectification of your personal data if it is inaccurate or incomplete;
- request erasure of your personal data in certain circumstances;
- restrict our use of your personal data in certain circumstances;
- move (or port) personal data which is automated in certain circumstances;
- object to the processing of your data where our lawful basis for processing your data is our legitimate interests;
- withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal;
- not to be subject to automated decision-making which produces legal effects without suitable safeguards and
- lodge a complaint with the Data Protection Commission (if you are unhappy with how your personal data is being handled).
However, these rights may not be exercised in certain circumstances, such as when the processing of your data is necessary to comply with a legal obligation or for the exercise or defence of legal claims. If you wish to exercise any of your rights in this regard, please contact dataprotection@smbc.aero. We will respond to your request within one month. That period may be extended by two further months where necessary, taking into extent the complexity and number of requests. We may request proof of identification to verify your request.
16. CHANGES TO THIS STATEMENT
We reserve the right to change this Cookie Statement from time to time at our sole discretion. If we make any changes, we will post those changes here and updated the "Last Updated" date at the bottom of this Cookie Statement. However, if we make material changes to this Cookie Statement, we will notify you by means of a prominent notice on the Website prior to the change becoming effective.
17. CONTACT US
Questions, comments, requests and complaints regarding this Cookie Statement are welcome and should be addressed to dataprotection@smbc.aero or sent in writing to Legal & Compliance Team, SMBC Aviation Capital, IFSC House, IFSC, Dublin 1, Ireland, D01 R2P9. We will endeavour to deal with all requests promptly and efficiently.
Last Updated: 2 October 2020