Privacy Statement
About this Privacy Statement
Effective May 25, 2021
This privacy statement sets out how JSA International U.S. Holdings, LLC and Jackson Square Aviation Ireland Limited (collectively, “JSA” or “we”) will collect and process personal data about:
- visitors to our website and authorised social media pages (collectively “the Site”)
- individuals who apply for jobs through our website
- individuals who we communicate or interact with, or whose personal data is provided to us, in the course of our business.
This privacy statement also sets out information about data subject rights and our obligations under data protection law. You should read this privacy statement prior to providing any personal data to JSA and refer to it at any time should you have queries regarding the use of your personal data.
This privacy statement does not apply to data collected in the course of our Know Your Customer procedures. KYC data is subject to the privacy noticed provided at the time information is requested.
About Data Protection and Data Privacy
JSA processes personal data in accordance with the requirements of applicable data protection laws. Under data protection law, you are the “data subject” in respect of any personal data relating to you, and “personal data” is any information which relates to an identifiable natural person; it does not include information relating to a company or other legal entity.
JSA International US Holdings, LLC, 909 Montgomery Street, Suite 500, San Francisco, CA 94133 is the “data controller” for personal data collected in connection with the use of the Site. However, it may engage third parties (other than its own employees) to provide services to it. Any of those third parties who process personal data on our behalf is a “data processor”, and “processing” means any action performed on personal data, including collection, storage, copying, consulting, disclosure or destruction. We process personal data inside and outside of the United States. To the extent that it is necessary to transfer personal data outside of the United Kingdom or European Economic Area to the United States, it is transferred on the basis of mechanisms approved under applicable laws, such as the standard contractual clauses.
1. INFORMATION THAT WE COLLECT FROM YOU
There are instances where we may invite or request individuals to provide us with their personal data. In addition, individuals may volunteer their personal data to us such as if you apply for a job with JSA or email us with questions. If you contact us, we may keep a record of that communication. Categories of such personal data may include: name, email and mailing address, resume (including education and professional background), contact information and other information that is relevant to our business.
In the course of our business, we may also receive personal data indirectly, such as from recruiters, or companies with whom we do business. We also use cookies and similar technologies on our Site so that it functions in the correct way, to understand how the Site performs and how you interact with it, to keep our services secure, to provide advertisements that are relevant to you and to enable us to deliver a better user experience. Further details can be found in the Section about Cookies below.
2. HOW WE USE PERSONAL DATA
The purposes for which we use personal data and the legal basis for why that processing is necessary or permitted are:
| Purpose(s) for Processing | Legal Basis |
| Communicating with you, our customers or other persons in the course of our business | To support our legitimate interests in managing our business and providing services to our customers; provided that, such interests are not overridden by the rights and interests of the data subjects concerned |
| Maintaining and operating our website | As above |
| Processing of job applications | (a) To perform or enter into a contract with the data subject; and/or (b) to support our legitimate interests in managing our business and providing services to our customers; provided that, such interests are not overridden by the rights and interests of the data subjects concerned |
| For the prevention and detection of fraud, money laundering and other crimes or for the purpose of responding to a binding request from a public authority or court | To comply with our legal obligations |
| Transferring information to third parties, including to our own service providers | (a) To support our legitimate interests in managing our business and providing services to our customers; provided that, such interests are not overridden by the rights and interests of the data subjects concerned; (b) to comply with our legal obligation; and/or (c) to protect vital interests |
We will retain personal data about job applicant candidates for no more than one year, unless otherwise agreed by you. We will otherwise retain personal data only for as long as necessary for the purposes for which it was collected; as required by law or regulatory guidance to which we are subject; and for the exercise or defense of legal claims that may be brought by or against us.
3. DISCLOSURE OF YOUR PERSONAL DATA TO OTHERS
We may disclose personal data to:
- third parties who provide a service to us, including auditors and outside professional advisers, data security and storage providers, and IT service providers such as website hosting, monitoring and analytics, email / communications vendors, etc.
- a public, legal or regulatory authority in the event that we are required to do so by applicable law, rule or regulation
- a third party where we are under a duty to disclose or share personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements, or to protect the rights, property or safety of JSA, our customers or others
- a prospective seller or buyer of such business or assets in the event that we sell or buy any business or assets
- a third party where it is necessary to protect the vital interests of the data subject or another natural person
In addition, we may disclose your personal data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
4. COOKIES AND SIMILAR TECHNOLOGIES
Cookies are small text files that are used to store small pieces of information. The cookies are stored on your device when the website is loaded on your browser. Cookies help make this Site function properly, make the Site more secure, provide you with a better user experience, and help us to understand how the Site performs and to analyse what works and where it needs improvement.
Our Site may also contain electronic images known as web beacons (also called single-pixel gifs) that we use to help deliver cookies on our websites, count users who have visited those websites, and gather usage and performance data. We also include web beacons in our email messages or newsletters to determine whether you open and act on them.
Our Site includes web beacons and cookies from third-party service providers. In some cases, that is because we have hired the third party to provide services on our behalf, such as website analytics. In other cases, it is because our Site contain third-party content (such as embedded videos, maps, and plug-ins,) that contain web beacons used to determine the effectiveness and track your interaction with that content. When your browser connects to a third party’s web server to retrieve content and/or web beacons, that third party is able to set or read its own cookies on your device and may collect information about your online activities over time and across different websites or online services that also contain that third party’s content or web beacons.
For example, we use Google Analytics and other Google services to support the operation of our Site. To learn about how Google uses and shares data it collects through these services, we encourage you to visit https://www.google.com/privacy.html and https://www.google.com/policies/privacy/partners/.
The cookies used on this Site are grouped into the following categories:
Necessary
Necessary cookies are essential for the Site to function properly. This category only includes cookies that ensures basic functionalities and security features of the website. To the extent personal data is processed via these cookies, the respective legal basis is Article 6(1)(f) GDPR as operating the Site is in our legitimate interest.
Non-Necessary
Any cookies that may not be particularly necessary for the Site to function or that collects data via analytics or other embedded contents are termed as non-necessary cookies. These may include the following:
- Performance / Analytics. These cookies are used to collect information about how our Site is used, including the number of visitors, pages visited, how the user navigated to our Site, your computer or mobile device identifier, IP address, the website you visited before browsing to our Site, general location information such as city, state or geographic area; and information about your use of and activity on our Site.
- Functional. These cookies enhance the functionality, performance, and service of the Site. They remember your region or country, language, accessibility options and your settings.
- Social Media. These cookies are used when you engage with our content on or through a social platform such as LinkedIn or Twitter. The cookies do not directly identify you or store your personal information, however they can uniquely identify your browser and internet device.
- Targeting / Advertising. These cookies help determine which content or advertising may be relevant to a user’s interests. They can also be used to assess the performance of marketing activities.
To the extent personal data is processed via non-necessary cookies, the respective legal basis is your consent in accordance with Article 6(1)(a) GDPR. EU/UK residents may withdraw consent at any time with future effect by adjusting your cookie settings.
The below list details the cookies used on our Site.
| COOKIE | DESCRIPTION |
| Necessary | |
| viewed_cookie_policy | The cookie is set by the Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. |
| cookielawinfo-checkbox-necessary | This cookie is set by Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Necessary”. |
| cookielawinfo-checkbox-non-necessary | This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Non Necessary”. |
| Non Necessary | |
| Performance | |
| GtEglX | This cookie was added by the host server for caching and performance. |
| KUmYMxLh | This cookie was added by the host server for caching and performance. |
| eIvyn_hmq | This cookie was added by the host server for caching and performance. |
| aka_debug | This cookie is installed by Vimeo’s video source files. |
| Analytics | |
| _ga | This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of site usage for the site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to identify unique visitors. |
| _gid | This cookie is installed by Google Analytics. The cookie is used to store information of how visitors use a website and helps in creating an analytics report of how the website is doing. The data collected including the number visitors, the source where they have come from, and the pages visited in an anonymous form. |
| _gat_gtag_UA_151146017_1 | Google uses this cookie to distinguish users. |
If you do not wish to receive cookies, you may configure the settings of your website browser to limit cookies on your computer or device. If you previously accepted all cookies and later wish to remove the cookies, you can delete the cookies on your device at any time through your browser settings. Please note that if you prevent or delete cookies required for the proper function of our Site, it may result in reduced performance and limited access.
To learn more about cookie management and deletion, you can visit www.aboutcookies.org or use your favorite search engine for instructions on “cookie deletion”.
5. LINKS TO OTHER SITES
Our website may, from time to time, contain links to and from other third-party websites or resources. These links are provided for your information only. We have no control over the contents or practices of those websites or resources and accept no responsibility for them. Third parties have their own terms of use and privacy policies. Please check those before you submit any personal data to third parties.
6. DATA SUBJECT RIGHTS
To the extent that we are a controller of your personal data, some jurisdictions (such as the European Union, the United Kingdom, and some states in the United States) provide certain rights to residents under applicable data protection laws. Depending on where you live, these rights may include:
- The right to access and obtain a copy of your personal data;
- The right to correct any inaccurate or incomplete personal data we hold about you;
- The right to ask we erase or delete your personal data in certain circumstances;
- The right to restrict processing of all or some of your personal data in certain circumstances (JSA does not sell personal data and does not perform automated decision-making or profiling on data subject to this privacy statement)
- The right to object to the processing your personal data on the basis of our legitimate interests (or those of a third party), or a violation of applicable law;
- The right to data portability, where applicable; and
- The right to withdraw your consent. (Please note that rescission of consent does not affect the lawfulness of any processing before the withdrawal of such consent.)
If you wish to exercise any of the rights that may be available to you, please contact us. We may ask you to complete a form to help us identify the data you require. We may request that you provide proof of your identity and residence so that we can verify your request. In the case of certain manifestly unfounded or excessive requests, we reserve the right to decline a request or to charge a reasonable administrative fee where permitted by law. We will timely consider your request and act upon it in accordance with applicable data protection laws.
You have the right in certain jurisdictions to lodge a complaint with your local data protection authority. The relevant contact info of supervisory authorities in Europe can be found here: https://edpb.europa.eu/about-edpb/board/members_en
7. SECURITY
JSA maintains reasonable physical, electronic, and procedural safeguards to help guard your information from loss, theft, misuse, and unauthorised access, disclosure, alteration, and destruction. Please be aware, however, that any email or other transmission you send through the Internet cannot be completely protected, and we cannot guarantee the security of your information collected through our Site.
8. CHANGES TO THIS PRIVACY STATEMENT
We reserve the right to change this privacy statement from time to time at our sole discretion.
9. CONTACT US
Questions, comments, requests and complaints regarding this privacy statement and the personal data we hold are welcome and should be addressed to info@jsa.com.
