BBAM Privacy Notice

This Privacy Notice explains how BBAM US LP and its affiliates (“BBAM”) collects, uses, shares and otherwise processes your Personal Data in connection with our Services. When we use the term, “Services”, we are referring to all the services that we offer on your behalf, including, without limitation, our product and service offerings and the websites and services that link to this Privacy Notice. This Privacy Notice also describes your choices and rights regarding the use, access and correction or deletion of your Personal Data.

BBAM is a leading provider of asset origination and management services in the aircraft leasing industry. BBAM had over $28.7 billion of assets under management as of December 31, 2019. In this Privacy Notice, the use of “we”, “us”, and “our” means BBAM, the controller of your Personal Data.

From time to time, we also receive (submitted through our email address humanresources@bbam.com) unsolicited applications for roles throughout our organization. Personal Data of such applicants is processed in accordance with this Privacy Notice.

This Privacy Notice does not cover or address services that we provide solely on behalf of a third party or Personal Data and privacy practices relating to our employees and other personnel.

Region-Specific Disclosures

We may choose or be required by law to provide different or additional disclosures relating to the processing of Personal Data about residents of certain countries, regions or states. Please refer below for disclosures that may be applicable to you:

• If you are a resident of the State of California in the United States, please click here for additional California-specific privacy disclosures.
• If you are a resident of the State of Nevada in the United States, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at dataprotection@bbam.com. Please note we do not currently sell personal information as defined by Chapter 603A of the Nevada Revised Statutes.
• If you are a resident of the United Kingdom or the European Union, please click here for additional UK and EU-specific privacy disclosures.

Summary

To enhance, personalize, and support your experience on the Site, among other things, we collect, use, and share your Personal Data. As detailed below, your Personal Data may also be used by BBAM to provide social media features (e.g., features that allow you to share content directly to your preferred social media platform), analyze traffic, and provide similar services and content.

As noted above, Personal Data contained in unsolicited applications for roles in BBAM is also processed in accordance with this Privacy Notice.

BBAM will not share any Personal Data with any third party without your consent, except as outlined in this Privacy Notice or as permitted by law. If you have any requests, comments, or questions about this Privacy Notice or your Personal Data, please contact us using the information provided in the Contacting Us section below.

1. WHAT IS PERSONAL DATA?

When we used the term “Personal Data” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to you.

2. WHAT PERSONAL DATA DO WE COLLECT?

We collect your Personal Data when you use the Services. Sometimes you may submit it to us yourself, other times it may be collected automatically or through a third party. You can manage and change your preferences as outlined below.

Personal Data Collected Directly from You

When you use the Services, your Personal Data may be collected, used, and shared in a variety of ways. The type of Personal Data collected may vary based on how it was gathered, but may include, among other things, your name, email address, and other information that you voluntarily submit (e.g., if you contact us by email through our contact page, you may submit your contact information and professional information).

Personal Data Automatically Collected

We may collect certain Personal Data automatically when you visit our Services, including:

• Log File Data, including your internet protocol (IP) address, operating system, browser type, browser id, date/time of visit and pages visited.
• Analytics Data, including the electronic path you take to our Services, through our Services and when exiting our Services, as well as your usage and activity on our Services, such as the links and objects you view, click or otherwise interact with (also known as “Clickstream Data”).
• Location Data, including your general geographic location based on your IP address or more precise location when accessing our online services through a mobile device.
• For information about our and our third-party partners’ use of cookies and related technologies to collect information automatically, and any choices you may have in relation to its collection, please see the How We Use Cookies and Other Tracking Technology to Collection Information section below.

Personal Data From Third Parties

We may also obtain Personal Data from third parties, including but not limited to other brands and affiliates in our family of companies, our service providers and advisors, analytics providers, potential and existing customers, social networks, and publicly available sources; which we often combine with Personal Data we collect either automatically or directly from you.

3. HOW DO WE USE YOUR PERSONAL DATA?

Our primary goal in collecting, using and sharing your Personal Data is to enhance your experience using the Services, support the Services, and improve its features, performance and other elements.

Further, if you submit an application to us for a role with BBAM, your Personal Data may be analyzed by BBAM to determine your suitability for any roles vacant within BBAM at that time.

Your Personal Data may be used for the purposes outlined below. We will not use your Personal Data without a valid legal basis to do so. However, we may rely on a number of separate and overlapping legal bases to lawfully process your Personal Data.

In particular, we use Personal Data for the following purposes to pursue the legitimate interests of BBAM:

• We will use your Personal Data to pursue our legitimate interest of providing our Services to users, and to manage our organization and its day-to-day operations.
• We will use your Personal Data to pursue our legitimate interests of administering, improving and personalizing our website and the Services. We may also use your Personal Data to test, enhance, update and monitor the Services, or diagnose or fix technology problems.
• We may use your Personal Data to conduct research and analytics on our customer base and our Services. We may also use your Personal Data to improve, market, promote and customize our service offerings to address the needs and interests of our customer base and other individuals we interact with.
• We may use your Personal Data to defend, protect or enforce our rights or applicable contracts and agreements.
• Where we receive employment applications, we process the Personal Data in pursuit of our legitimate interests to consider the applications and to respond to individuals.
• We will use your Personal Data when it is in our legitimate interests or necessary to comply with legal obligations, including to preserve or defend our rights in court, to respond to law enforcement requests or discovery procedures, or where required or permitted by applicable laws, court orders, government regulations, or government authorities, which may include lawful access by courts or governmental authorities outside your country of residence.
• We will process your Personal Data for safety and security purposes as is necessary to pursue BBAM’s legitimate interests of protecting against security risks of all types, including to help maintain the safety, security and integrity of our property and Services, technology assets and business. We may also use your Personal Data to prevent, investigate or provide notice of fraud or unlawful or criminal activity. Any such processing in this respect would also be in your legitimate interests.

When an individual chooses to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide additional privacy disclosures where the scope of the inquiry/request and/or Personal Data we require fall outside the scope of this Privacy Notice. In that case, the additional privacy disclosures will govern how we may process the information provided at that time.

4. HOW WE USE COOKIES AND OTHER TRACKING TECHNOLOGY TO COLLECT INFORMATION

We and our third-party partners automatically collect certain types of usage information when you visit our Services, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, file information and similar technology (collectively, “Tracking Technologies”).

We and our third-party partners use Tracking Technologies to automatically collect usage and device information, such as:

• Your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account, and other such information.
• We also collect information about the way you use our Services, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, the links you click, how frequently you access the Services, whether you open emails or click the links contained in emails, whether you access the Services from multiple devices, and other actions you take on our Services.
• When you access our Services from a mobile device, we may collect unique identification numbers associated with your device (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system, brand and model, phone number, and depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address.
• We may collect analytics data, or use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Services and to understand more about our users by monitoring aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Websites. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.
• We may also work with third party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.
• We use or may use the data collected through cookies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit our Services; (b) provide and monitor the effectiveness of our Services; (c) monitor online usage and activities of our Services; (d) diagnose errors and problems with our Services; (e) otherwise plan for and enhance our Services; and (f) facilitate the purposes identified in the How Do We Use Your Personal Data? section of this Privacy Notice.

Please note that we link some of the Personal Data we collect through cookies with the other Personal Data that we collect about you and for the purposes described above.

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies.

5. HOW DO WE SHARE YOUR PERSONAL DATA?

In limited circumstances, we may share your Personal Data with third parties in the following ways:

• With our group companies: In order to respond to enquiries that you may send to us by email through our website, it may be necessary to share your Personal Data with one or more of our group companies in other jurisdictions, including but not limited to BBAM UK Limited, BBAM Aviation Services Switzerland GmbH, SZ Services Puerto Rico LLC, BBAM Singapore Pte. Limited, BBAM Aviation Services Limited or BBAM Japan LLC.
• With our service providers: To a limited extent, we may share Personal Data with our service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, customer service, email delivery services, administrative services, marketing and advertising services, and other similar services.
• For legal and safety reasons: We may provide Personal Data to a third party if we believe in good faith that it is reasonably necessary for legal reasons; in connection with the establishment, exercise, or defense of legal claims; to comply with laws or to respond to lawful requests and legal process; to enforce our terms or agreements; to detect, investigate, prevent, and address fraud and other illegal activity, security or technical issues; to protect the rights, property or safety of BBAM, our employees, users, or others; or as otherwise required by applicable law.
• Otherwise with consent or direction: We may disclose Personal Data about an individual to certain other third parties or publicly with their consent or direction.

6. HOW LONG DO WE KEEP PERSONAL DATA?

We will keep your Personal Data in accordance with applicable legal requirements, and only for as long as necessary for the purposes described above, or as long as required by law or to defend potential legal claims.

7. HOW DO WE KEEP YOUR PERSONAL DATA SECURE?

We treat Personal Data as an asset that must be protected against loss and unauthorized access. We employ many different security techniques to protect such data from unauthorized access by users inside and outside the company. However, “perfect security” does not exist on the Internet. If you are concerned that your privacy may have been breached, please contact us as provided below.

By choosing to access and use the Services, or to submit an unsolicited application to us for a role in BBAM, you understand that your Personal Data will be transferred to and stored in the United States and that the privacy protections and the rights of authorities to access your Personal Data may not be the same as in your home country.

8. PRIVACY OF CHILDREN

The Services are intended for people who are at least 16 years of age. If you are less than 16 years old, please do not send any Personal Data to us – including information such as your name, address, or e-mail address. We do not knowingly collect (nor do we wish to collect) any Personal Data from children under the age of 16. In the event that we learn we have collected any Personal Data from a child under the age of 16, we will delete that information.

9. INTERNATIONAL TRANSFERS

If you are based in the UK or EU, we will transfer your Personal Data outside of the UK or EU including to the United States; these international transfers of your Personal Data will be made pursuant to appropriate safeguards as required under applicable data protection laws, such as the EU Standard Contractual Clauses or UK equivalent international data transfer clauses. You can request a copy of these clauses by contacting us as set forth in the Contacting Us section below.

10. WHAT ARE YOUR RIGHTS?

UK OR EUROPEAN RESIDENTS

If you are resident in the UK or EU, you have certain rights in connection with your Personal Data. These include:

• the right to obtain a copy of your Personal Data in an easily accessible format;
• in certain circumstances, you also have the right to object to the processing of your Personal Data;
• the right to request the amendment or deletion of your Personal Data; and
• the right to withdraw your consent to the processing of your Personal Data (where we are relying on consent as the legal basis for processing your Personal Data).

Without prejudice to any other rights you may have, you may file a complaint with your national data protection authority. For a list of national data protection authorities, see http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080 or if you are a resident in the UK, you may lodge a complaint with the UK Information Commissioner’s Office (contact details for the ICO can be found on its website here https://ico.org.uk/global/contact-us/).

If you would like to exercise any of your rights or you have any questions about your rights, please email us at dataprotection@bbam.com. Alternatively, you can contact us by telephone or post using the contact details available below.

11. CALIFORNIA RESIDENTS

This section applies to you if you are a resident of the state of California. California law requires us to disclose certain information regarding the categories of personal information we collect. For purposes of this ‘California Residents’ section, “Personal Information” has the meaning provided by the California Consumer Privacy Act of 2018 (the “CCPA”) and does not include information that is publicly available, that is deidentified or aggregated such that it is not capable of being associated with us, or that is excluded from the CCPA’s scope. This section does not apply to information relating to our employees, contractors, and other personnel.

Collection and Use of Personal Information. We collect Personal Information from and about you for a variety of purposes, as described in the How Do We Use Your Personal Data? section above. In the last 12 months, we have collected the following categories of Personal Information:

• Identifiers, such as your name, address, phone number, email address, or other similar identifiers;
• Commercial Information, such as records of services purchased, obtained or considered;
• Internet/Network Information, such as IP address, unique device information, logs and analytics data;
• Geolocation Data, such as approximate location data generated based on your IP address or other information;
• Profession / Employment Information, such as your employment history and other information submitted in connection with applying for a job;
• Inferences about your interests and preferences, generated from your use of our Services.
• We collect this information directly from you, from our business partners and affiliates, from your browser or device when you visit our websites, or from third parties that you permit to share information with us.

Disclosure of Personal Information

We may share Personal Information with third parties for business purposes. The categories of third parties to whom we disclose your Personal Information for a business purpose include: (i) other brands and affiliates in our family of companies; (ii) our service providers and advisors; (iii) analytics providers; and (iv) social networks. To learn more about how we disclose data to third parties, please refer to the How Do We Share Your Personal Data? section above.

In the previous 12 months, we have disclosed the following categories of Personal Information to third parties for a business purpose:

All of the categories of Personal Information we collect, explained in the Collection and Use of Personal Information section above.
In the last 12 months, we have not sold Personal Information about you.

Your Rights and Choices

As a California resident, you may be able to request to exercise the following rights:

• The Right to Know any or all of the following information relating to your Personal Information we have collected and disclosed in the last 12 months, upon verification of your identity:
• The specific pieces of Personal Information we have collected about you;
• The categories of Personal Information we have collected about you;
• The categories of sources of the Personal Information;
• The categories of Personal Information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
• The categories of Personal Information we have sold and the categories of third parties to whom the information was sold (if applicable); and
• The business or commercial purposes for collecting or selling the Personal Information.
• The Right to Request Deletion of Personal Information we have collected from you, subject to certain exceptions.
• The Right to Opt Out of Personal Information Sales to third parties now or in the future.
• You also have the right to be free of discrimination for exercising these rights. However, please note that if the exercise of these rights limits our ability to process Personal Information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

How to Exercise Your California Rights

You may submit a request to exercise your right to know and/or right to deletion through one of the mechanisms described below. We will need to verify your identity before processing your request, which may require us to request additional Personal Information from you. In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.

To exercise your California Consumer Rights, please submit a request by:

Emailing dataprotection@bbam.com with the subject line “California Rights Request,” or
Filling out our California Consumer Rights Request Form.
PLEASE NOTE: We do not sell Personal Information.

Authorized Agents. If you are submitting a California Consumer Rights request on behalf of another individual or your minor child, we may require additional documentation to verify that you are properly authorized to request this information and it may take additional time to fulfill your request.

Minors. We do not sell the Personal Information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “Right to Opt In”) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age.

California’s “Shine the Light” Law. California’s “Shine the Light” law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. In the past 12 months, we have not sold personal information to third parties for their direct marketing purposes, as defined by the Shine the Light law.

Do Not Track Signals. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser or mobile application at this time.

12. CONTACTING US

If you have any questions regarding this Privacy Notice or our use of your Personal Data, please contact us using the following information:

Web
https://www.bbam.com

Email
dataprotection@bbam.com

Telephone
(415) 267-1600

Postal address
BBAM US LP
50 California Street, 14th Floor
San Francisco, CA 94111 USA

13. CHANGES TO THIS PRIVACY NOTICE

We keep this Privacy Notice under regular review. If we make any changes to this Privacy Notice, we will change the “Last Updated” date at the end of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify you by means of a notice on this website, or through other appropriate communications channels. We encourage you to periodically review this page for the latest information on our privacy practices.

Last Updated: June 1, 2022