Ford Aerospace Limited Respects Your Privacy

This Privacy Policy applies to information about you obtained through www.ford-aersopace.com (the “Website”) by Ford Aerospace Limited (hereon in referred to as “Ford Aerospace Limited”, “we”, “us” or “our”) and our parent company SPIROL International Holdings (“SPIROL”). Ford Aerospace Limited is the controller and responsible for the collection and processing of your personal data through your use of this Website.

The Privacy Policy describes how we may collect, use, and disclose your personal data; the choices you have regarding our use of your personal data; how we safeguard the personal data we collect; and how to contact us regarding our privacy practices.

By accessing or otherwise using the Website, you agree to the collection, use, and disclosure practices and other activities as described in this Privacy Policy.

The types of Personal Data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

If you are a website user or represent a customer or prospective customer of Ford Aerospace Limited, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name;
• Contact Data includes email address and telephone numbers;
• Transaction Data includes details about payments to and from your organisation (our customer) which you represent;
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this Website;
• Profile Data includes job title, relevant place of work, purchases or orders made by your organisation (our customer) which you represent, your interests, preferences, feedback and survey responses;
• Usage Data includes information about how you use our Website, products and services; and
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• If you are a job applicant of Ford Aerospace Limited, please refer to our Job Applicant Privacy Notice which can be found here.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate individuals’ Technical and Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our Website to help improve the Website and our service offering. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with your organisation (our customer) which you represent, and you fail to provide that personal data when requested, we may not be able to perform the contract we have or are trying to enter into with your organisation (for example, to provide your organisation with our products or services). In this case, we may have to cancel a product or service your organisation has with us but we will notify you if this is the case at the time.

How we collect your Personal Data

We collect certain personal data (for example Identity, Contact, Profile and Marketing and Communications Data) about you that you provide to us directly through the Website. For example, you may complete the Request a Quote or Contact Us forms or submit details via contactus@ford-aerospace.com.

As you interact with our Website, we will automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see more information concerning the cookies we use to operate this Website below.

We may collect personal data about you from various third parties and public sources as set out below:

• Technical and Usage Data from the following parties:
  • analytics providers such as Google based outside the UK; and
  • search information providers such as Google based outside the UK; and
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.

How we use your Personal Data

We will only use your personal data when the UK data protection legislation allows us to. Most commonly, we will use your personal data in the following circumstances:

• where we need to perform the contract we are about to enter into or have entered into with your organisation (our customer) which you represent (performance of a contact);
• where it is necessary to conduct our business and pursue our legitimate interest(s) (or those of a third party), for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interest(s). We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law);
• where we need to comply with a legal obligation;
• where we have obtained your active agreement (consent) to use your personal data for a specified purpose, for example if you subscribe to an email newsletter; and
• where it is necessary for us to process your personal data based on a recognised legitimate interest.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the lawful basis or bases we rely on to do so. We have also identified what our Legitimate Interests are where appropriate. Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are processing your personal data. Please contact us if you need details about the specific lawful basis we are relying on to process your personal data where more than one lawful basis has been set out in the table below.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to who the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the lawful basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law. For example, we are not required to inform you where we intend to use your personal data for research, archiving in the public interest or generating statistics if it would involve a disproportionate effort for us to do so. We strongly recommend that you routinely check this Privacy Policy for any changes concerning how we collect and process your personal data.

Retention of Personal Data

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and where we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law, we have to keep basic information about our customers and its representatives (including Identity, Contact, Transaction and Profile Data) for six years after our customer ceases being a customer for tax purposes.

Information Collected Automatically

Cookies

Our Website uses GA4 Cookies. They do not retrieve personal data about you that is stored on your hard drive and do not corrupt or damage your computer or computer files. They help us identify website visitor behaviour and visitors’ particular preferences. As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this Website and on others. The most effective way to do this is to disable cookies in your browser. To learn more please visit [GA4] Cookie usage on websites – Analytics Help

The table below explains the cookies we use and why.

You may exercise choices regarding the use of cookies from Google Analytics by visiting this page or downloading the Google Analytics Opt-out Browser Add-on.

Use and Disclosure of Personal Data

We may share your personal data with the third parties set out below for the purposes set out in the table above:

• internal third parties for example other companies in the SPIROL group of companies acting as separate controllers or processors and who are based outside the UK;
• external third parties for example:
  • service providers acting as processors based in the UK who provide IT and system administration services, including but not limited to, Aspire Technology Solutions;
  • professional advisers acting as separate controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services; and
  • HM Revenue and Customers, regulators and other authorities acting as separate controllers based in the UK who require reporting of processing activities in certain circumstances; and
• third parties to whom we or SPIROL may choose to sell, transfer or merge parts of our business or our assets or where we undertake any internal reorganisation or restricting. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same was as set out in this Privacy Policy.

Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent, or otherwise share for marketing purposes the personal data that we collect through the Website with third parties.

In general, we use your personal data to improve the Website, tailor the features to you, and to offer you additional information, opportunities, promotions, and functionality.

Your personal data may be disclosed to third-party service providers who work with us in order to provide some of the services on the Website and to help us communicate with you. Examples include analysing Technical and Usage Data and providing customer service.

Form submissions (excluding those related to job applications or vacancies) are added to

our global CRM, Salesforce, to enable us to process legitimate business requests.

The online job application is protected with Google’s reCAPTCHA services to prevent automatic submissions. Such protections are subject to Google’s privacy policies.

We require all third parties to respect the security of your personal data and to treat it in accordance with the UK data protection legislation. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International Transfers

We may share your personal data within the SPIROL group of companies. SPIROL is a global company meaning the personal data we collect may be transferred to, processed, and stored on our group servers in the United States, Canada, Mexico, Brazil, United Kingdom, France and China. The data protection laws and regulations applicable to your personal data transferred to these servers may be different from the laws in your country of business.

Some of our external providers are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data outside of the UK to countries which have laws that do not provide the same level of data protection as the UK data protection legislation, we always ensure that a similar degree of protection is afforded to it by ensuring that one of the following safeguards are implemented:

• we will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data; or
• we may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection it has in the UK, namely the International Data Transfer Agreement or the International Data Transfer Addendum to the European Commissioner’s standard contractual clauses for international transfers. Before we do this, we will carry out a Transfer Risk Assessment (also known as the Data Protection Test).

Please contract us if you want further information on the specific mechanism used by us when transferring your personal data outside of the UK.

Links to Third-Party Sites

This Website may contain links to other websites or services that are not controlled by Ford Aerospace Limited or SPIROL; these links are provided for your convenience and information. We are not responsible for any third party’s data collection or privacy practices, and we encourage you to review the privacy policies or notices posted on those third-party websites for further information.

Your Choices

Ability to Unsubscribe

Should you opt-in to receive a promotional email from us, you may opt out of receiving further promotional email communications from us by following the unsubscribe instructions on the email. You may also contact us directly at subscriptions@ford-aerospace.com

Security

We have put in place appropriate technical and organisational measures to protect your personal data from loss, theft, misuse, and unauthorised access, disclosure, alteration, and destruction. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Children’s Privacy

We do not provide services to children. This Website is not intended for, nor targeted to, children and we do not knowingly or intentionally collect information from children. If we learn that we have received information directly from a child, we will delete their personal data in accordance with applicable law.

Revisions

This Privacy Policy is subject to change at our discretion. We will indicate changes to this page by updating the “Last Updated” date at the bottom of the page. We encourage you to review this Privacy Policy frequently to stay informed about our information practices. Your continued use of this Website after any update to this Privacy Policy will constitute your acceptance of the changes.

Company Status

Ford Aerospace Limited is a limited company. Registered number 00384775.

Ford Aerospace Limited is a wholly owned subsidy of SPIROL.

Your rights

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new postal address or phone number.

Under certain circumstances, you have rights under the UK data protection legislation in relation to your personal data. This includes the right to:

• object to processing of your personal data;
• request access to your personal data;
• request correction of your personal data;
• request erasure of your personal data;
• request restriction of processing your personal data;
• request the transfer of your personal data; and
• withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

You have the right to make a complaint to us regarding our processing of your personal data. In the event you are not happy with the outcome of the complaint, you have the right to make a complaint to the Information Commissioner’s Office (or the Information Commission as it will be known from April 2026 following Part 6 of Data (Use and Access) Act 2025 (DUAA)), the UK regulator for data protection issues (www.ico.org.uk).

Contact

If you have any questions about this Privacy Policy, please email us at privacy@ford-aerospace.com