SES Privacy Notice

This Privacy Notice was last reviewed and updated in May 2025.

  • OUR COMMITMENT
    • Shannon Engine Support Limited (“SES”, “we”, “us”, or “our”) is a provider of aircraft engine support services to the international civil aviation industry. We are committed to the privacy of those that we engage with, and this statement details our approach. While providing personal data to us during business or using our website, we will manage your data in accordance with this privacy notice (the “Notice”).
    • The purpose of this Notice is to explain how we collect, use, store and transfer your personal data and how you may exercise your rights, including the right to object to certain types of processing we carry out.
    • SES is the “data controller” responsible for the personal data collected and processed as described in this Notice.
  • WHO THIS NOTICE APPLIES TO
    • This Notice applies to all customers, prospective customers, and users of our website https://ses.aero (“Website”) and airline engine related products and services located in the European Economic Area, Switzerland, and the United Kingdom.
  • WHAT INFORMATION WE COLLECT
    • We process your personal data the following types of personal data:
      • Personal Details

Contact details including name, physical address, e-mail address, and phone number. Personal details collected for KYC purposes including individual names, addresses, date of birth, passport details, position in company, phone numbers and individual shareholding percentages.

  • Transaction Information

Enquiry details, proof of identity, credit history/rating, connected party status, details of a guarantor to a lease application, records of communication relating to a lease, financial information relating to payment for our products and services.

  • Voice Messages

Voice messages collected when you choose to leave a voice message.

  • Legal/Regulatory Information

Data required to comply with legal obligations including the Criminal Justice (money laundering and terrorist financing) Act and Amendments.

  • Log Data and Device Information

This includes information such as details about how you have used the Website such as your IP address, access dates and times, hardware and software information, device information, cookie data, location data and page/product views or clicks. Please see our Cookie Policy for further information

  • Where we require your personal data in accordance with a statutory or contractual requirement, we will inform you that you are obliged to provide the personal data in question, or else it may impact our ability to provide you with products and services.
  • We collect your personal data directly from you.
  • HOW WE USE YOUR PERSONAL DATA
    • We only use your personal data when we have a legal basis to do so. The specific legal basis depends on why we use your personal data. You also have rights available to you in respect of our use of your personal data. These rights may vary based on the legal basis we use. For details on exercising your rights, see the “Your Rights” section in the Policy.

Purpose

Information Collected

Lawful Basis For Processing

Engine purchase, supply, and related services: To initiate and manage our relationships with our suppliers, customers, prospective customers and to handle enquiries or communications received.

Personal Details

Transaction Information

 

Performance of a contract.

Lease agreements with customers: To manage the lease process and agreement including assessing creditworthiness, validating information provided during the application process and risk analysis.

Personal Details

Transaction Information

 

Performance of a contract.

Credit control of leases:  To manage the payment of lease including credit searches and engaging with the credit agencies, the transfer of debt and the enforcement of security or guarantee against a lease agreement.

Personal Details

Transaction Information

 

Performance of a contract.

Providing the website: To provide our website to you.

Log Data and Device Information

Performance of a contract.

Direct marketing: To inform prospective customers of services provided by SES. In certain countries (such as those in the European Union), we generally need your consent to send you email marketing messages. You will be given the opportunity to opt out of each marketing communication that we send.

Personal Details

Log Data and Device Information

 

Legitimate interests- It is in our legitimate interests to send marketing materials to prospective customers.

Analytics Information: We use data analytics to ensure website functionality and improve our services. Please see our Cookie Policy for further information.

Log Data and Device Information

 

Legitimate interests- It is in our legitimate interests to understand how you are using our website.

Voice: to maintain a record of communications from customers or potential customers for training and quality purposes.

Voice Messages

Legitimate interests- We retain voice messages to protect our legitimate business interests, including quality assurance, training, and dispute resolution.

Legal Obligations: We process information when required by legal obligations, including responding to valid requests from regulators or law enforcement authorities and implementing mandatory security measures. This may include obligations to access, preserve or disclose specific information.

Examples of Irish and EU laws that could give rise to an obligation requiring us to process information we hold about you include:

●      Civil and commercial matters: where we are in receipt of a court order to disclose information for the purposes of court proceedings, such as under Regulation (EU) No 1215/2012 on jurisdiction and the recognition and enforcement of judgments in civil and commercial matters.

●      Criminal matters: to comply with requests from Irish law enforcement to provide data in relation to an investigation, such as under the Criminal Justice (money laundering and terrorist financing) Act and Amendments or to take steps to report information to law enforcement where required.

●      Corporate and taxation matters: to comply with our obligations under companies legislation and tax law such as the Companies Act 2014 such as where the Irish Revenue requests information.

Personal Details

Transaction Information

Voice Messages

Legal/Regulatory Information

Log Data and Device Information

 

 

Compliance with a legal obligation.

 

  • HOW WE SHARE YOUR PERSONAL DATA
    • Where necessary in order for us to perform our obligations to you or for purposes set forth in this Notice, your data will be shared with affiliates, public authorities and/or other third parties, for example:
      • Affiliate companies that are members of the SES group of companies. The SES group of companies refers to Shannon Engine Support Ltd (Shannon), Beijing Shannon Engine Support Consulting Co., Ltd. (Beijing & Shanghai), Shannon Engine Support Hungary Kft (Budapest), Shannon Engine Support SG PTE LTD (Singapore), Shannon Engine Support LLC (US), Tianjin Shannon Engine Support Leasing No. 1 Company Limited, Tianjin Shannon Engine Support Leasing No. 2 Company Limited, Tianjin Shannon Engine Support Leasing No. 3 Company Limited and SES Secured Funding 1 Limited. Shannon Engine Support Limited is the representative of these organisations in the EU.
      • For engine purchase, supply and servicing personal data may be transferred to suppliers that help us deliver our products to you, such as logistics professionals, and delivery and freight companies.
      • Professional service providers who help us run our business, such as accountants, lawyers, consultants, and advisors representing the leasing or aviation industry.
      • Third party service providers who process information on SES’s behalf, including providers of information technology, website hosting and management, data analysis, anti-spam services, data back-up, security, e-mail, Voice Messages, and storage services.
      • Guarantors, debt collection agencies or others legitimately involved in the process of ensuring payment, a solicitor to affect a legal charge over an asset or a third party who has purchased debt or a lease agreement.
      • Government and law enforcement agencies or public authorities to: (i) comply with a legal process, subpoena, order or other legal or regulatory requirement, or if we believe that it is necessary to comply with our legal obligations; (ii) enforce our Terms and Conditions or other policies; or (iii) pursue available legal remedies or defend legal claims, or protect and defend our rights or property, or the rights or property of a third party, including our customers and employees.
      • If we sell or transfer all or part of our business to someone, in some cases we may give the new owner your personal data as part of that transaction if it’s allowed under the law.
    • SES has taken measures to ensure that contracts with all third parties that provide technical, and processing services include terms that specify appropriate technical and organisational security measures to prevent accidental, unauthorised, or unlawful disclosure or processing of personal data.
    • As we continue to develop our business, we may buy or sell assets. In such transactions, personal data is generally one of the transferred business assets. Accordingly, your personal data may also be disclosed, where permitted by applicable law, in connection with a corporate restructuring, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of SES.
  • DATA TRANSFERS
    • We need to transfer your personal data to recipients outside the European Economic Area (“EEA”) as part of our global operations as a business, for the purposes described in this Notice, including to other members of the SES group of companies in the US, Singapore, and China.
    • Where we transfer your personal data, we do so in accordance with EU data protection law. If you are based in the EEA, when your data is moved from your home country to a third country outside the EEA some of these countries may not have the same data protection safeguards as your home country. If you are located in the EEA or the United Kingdom, we employ one of the following data transfer mechanisms to ensure the transfer is lawful:
      • Transfers to countries deemed as having an “adequate” level of protection by the European Commission (see full list here);
      • EU Standard Contractual Clauses (“SCCs”) approved by the European Commission and the UK International Data Transfer Addendum issued by the UK Secretary of State.

 

  • While transfers to countries that do not have an adequacy decision typically take place on the basis of SCCs, in certain circumstances, transfers can also take place on the basis of exemptions provided under data protection law. For example, sharing with law enforcement or in emergency situations where we learn that a person’s life is at risk.
  • For a copy of the SCCs, please contact us via the details provided in the “How to Contact Us” section.
  • DATA RETENTION
    • SES will retain your personal data only for as long as is necessary for the purposes set out in this Notice. We may also keep some of your personal data as required to meet legal or regulatory requirements, resolve disputes, prevent fraud or abuse, enforce our Terms and Conditions, or for other legitimate business purposes (so long as keeping it for such purposes does not infringe upon your privacy rights).
    • When we no longer have a need to keep your personal data for these purposes, we will either delete your personal data from our systems or anonymise it so that it no longer identifies you. If there is any personal data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the personal data.
  • YOUR RIGHTS
    • Depending on the jurisdiction in which you are located, you have the following rights, in certain circumstances and subject to certain restrictions, in relation to your personal data:
      • access a copy of your personal data held by us;
      • request rectification of your personal data if it is inaccurate or incomplete;
      • request erasure of your personal data in certain circumstances;
      • request to restrict our use of your personal data in certain circumstances;
      • move (or port) personal data which you have given us to process. You can choose to receive your personal data in a usable electronic format or request direct transmission to a third party, subject to that third party’s cooperation;
      • withdraw your consent at any time (to the extent that we rely on consent as a lawful basis for processing of your personal data; and
      • object to the processing of your data where our legal basis for processing your data is our legitimate interests.
    • 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.
    • You may unsubscribe from our mailing lists at any time by using the ‘unsubscribe’ button on marketing communications, or by contacting us at info@ses.aero
    • If you are not satisfied with our use of your personal data or our response to any request by you to exercise any of your rights, you have the right to lodge a complaint with your country’s supervisory authority. If you are based in Ireland the Irish Data Protection Commission is your supervisory authority and its contact details are below:

Data Protection Commission

  • Address: 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland
  • Phone +353 (0)1 7650100 / 1800 437 737
  • You can contact the Data Protection Commission via the webforms on its website, https://dataprotection.ie.
  • THIRD PARTY LINKS
    • We may provide links to third-party web sites that we do not own or control. We are not responsible for the information collection practices of these third-party websites and do not endorse such practices. We encourage you to review and understand the privacy practices of third-party websites before providing any information to or through them.
  • SECURITY
    • We are committed to the security of personal data. We take appropriate security measures to limit abuse of and unauthorized access to personal data. This ensures that only the necessary persons have access to your data, that access to the data is protected, and that our security measures are regularly reviewed.
    • The security measures we use consist of:
  • Login Security
  • DKIM, SPF, DMARC and other specific DNS settings
  • (START)TLS / SSL / DANE Encryption
  • Website Hardening/Security Features
  • Security measures of hardware that contain, or process personal data.
  • ISO27001/27002 Certification
  • HTTP Strict Transport Security and related Security Headers and Browser Policies
  • CHILDREN’S PRIVACY
    • You must be at least 16 years old to use the website. If you believe that there is a user who is below this minimum age, please contact us as described in the “How to Contact Us” section below. If you are under the age of 16, you are not permitted to create an account.
  • CHANGES TO THE NOTICE
    • We may change this Notice from time-to-time to reflect new ways that we process your personal data. If we make material changes that affect your personal data, we will provide you notice of such changes through the website, by email, or other means of contact, as necessary. This notice will give you an opportunity to review the changes made in advance of them taking effect.
  • HOW TO CONTACT US
    • If you have any questions about this Notice, or if you require further information about our use of your personal data or you wish to avail of any of your rights set out herein, please contact SES at info@ses.aero or write to us at our below address:

Shannon Engine Support Ltd.

4000 Atlantic Avenue

Westpark

Shannon

Co. Clare

V14 YX01

Ireland