Privacy Policy
July 3, 2025
Introduction
Welcome to ACOM Aviation Ltd’s privacy policy. This privacy policy relates to our online platform Mach2.aero (our Platform).
ACOM Aviation Ltd respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit this website (regardless of where you visit it from) or use our Platform and tell you about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
Important Information and Who We Are
The Data We Collect About You
How Is Your Personal Data Collected
How We Use Your Personal Data
Disclosures of Your Personal Data
International Transfers
Data Security
Data Retention
Your Legal Rights
Glossary
1. Important Information and Who We Are
Purpose of This Privacy Policy
This privacy policy aims to give you information on how ACOM Aviation Ltd collects and processes your personal data through your use of our Platform, including any data you may provide through our Platform when you sign up to our subscription service, provide details of your End User’s requirements through our Platform ,or make a bid via our Platform (if you are or represent an operator).
Our Platform is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.
Controller
ACOM Aviation Ltd is the controller and responsible for your personal data (collectively referred to as ACOM, we, us or our in this privacy policy).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise Your Legal Rights please contact the data privacy manager using the details set out below.
Contact Details
Our full details are:
Full name of legal entity: ACOM Aviation Ltd. We are registered in England and Wales under number 13120644 and we have our registered office at 4 Witan house, Witan Way, Witney, Oxon, England, OX28 6FF.
Name or title of data privacy manager: Andrey K.
Email address: Support@mach2.aero
Postal address:4 Witan house, Witan Way, Witney, Oxon, England, OX28 6FF.
Telephone number: +441865 819991
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Data protection law requires ACOM, as controller for your data:
to process your data in a lawful, fair and transparent way;
to only collect your data for explicit and legitimate purposes;
to only collect data that is relevant, and limited to the purpose(s) we have told you about;
to ensure that your data is accurate and up to date;
to ensure that your data is only kept as long as necessary for the purpose(s) we have told you about;
to ensure that appropriate security measures are used to protect your data.
Changes to the Privacy Policy and Your Duty to Inform Us of Changes
We keep our privacy policy under regular review. This version was last updated on the date at the top of this document. Historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. We may ask you to confirm updates to your personal data from time to time but please keep us informed if your personal data changes during your relationship with us in the meantime. Please inform the data privacy manager of any changes in your data at the following email address: privacy@mach2.aero.
Third-Party Links
Our Platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.
We and organisations connected with us have a social media presence for the purpose of engaging with you.
If you enable such connections or choose to communicate your personal data to us via third-party websites or social media, please remember that we do not control these third-party websites and are not responsible for their privacy statements. When you leave our website or interact with us on social media, we encourage you to read the privacy policy of every website or forum that you visit or use.
2. the 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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes first name, last name, username or similar identifier.
Contact Data includes address, email address and telephone numbers.
Transaction Data includes details about payments to and from you and other details of services you have subscribed to, including details of alerts you have activated.
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 and other technology on the devices you use to access this website and use our Platform.
Profile Data includes your username, your account preferences and settings.
Messaging Data includes information relating to your usage of our Messaging function, including details of messages you share using this function within our Platform.
Information relating to your usage of our Invite function, including details of messages you share using this function within our Platform's mailer capacity, as well as any responses received to these emails.
Directory Data includes information that we publish in our operator directories (including contact information).
Usage Data includes information about how you use our Platform and subscription services.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
Where you use our Platform on behalf of a business (e.g. an operator), we anticipate that most of the data we collect in connection with your use of the Platform will be business information rather than personal data. This privacy policy applies to the extent that you provide us with any personal data ancillary to your use of the Platform for and on behalf of the business that you represent. Where you use our Platform on behalf of a business, you must not upload or otherwise transmit personal data relating to passengers, crew members or any other individuals via our Platform (including via our Messaging & invite functions). If you are, have been previously, or will in future be a passenger or crew member on any flight facilitated via our Platform, we do not process your personal data.
Handling of Inadvertently Received Personal Data:While we prohibit the sharing of personal data within our Messaging and Invite functions, we recognize that personal data, including special category data (such as information 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), may be inadvertently shared. In such cases, the following steps will be taken:
Identification: Any personal data received will be identified and flagged by our system or staff.
Secure Handling: The data will be securely handled, and access will be restricted to authorised personnel only.
Anonymization or Deletion: The personal data will be anonymized or deleted as soon as possible to prevent further use or disclosure.
Notification: We will notify the individual whose data was inadvertently shared and inform the relevant authorities if necessary.
Documentation: All incidents of inadvertent data sharing will be documented and reviewed to improve our data protection measures.
We refer to the above categories of data in the Purposes for which we will use your personal data tables.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Platform feature. 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 any 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.
If You Fail to Provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to enable you to use our subscription services). In this case, we may have to cancel your subscription service but we will notify you if this is the case at the time.
3. How Is Your Personal Data Collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
subscribe to our subscription services;
create an account on our Platform;
request marketing to be sent to you;
enter a competition, promotion or survey;
upload content to our Platform;
give us some feedback or contact us.
Automated technologies or interactions. As you interact with our website and use our Platform, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy (https://mach2.aero/cookies) for further details.
Through our Messaging and/or Invite function, the sharing of personal data within this functions is prohibited, though business contact information such as names, roles, and professional email addresses may be shared as part of standard business communications. This data is encrypted and may be reviewed by designated employees of our data controller to ensure service quality and compliance. Additionally, this data may be anonymized for statistical analysis of performance. By using the Invite function, you consent to this processing of your business contact information.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
Technical Data from the following parties:
analytics providers such as Google Analytics based outside the UK;
application monitoring and error tracking platforms which may be based outside the UK;
cloud computing providers such as Amazon Web Services based outside the UK.
Transaction Data from providers of technical and payment services who may be based inside or outside the UK.
4. How We Use Your Personal Data
We will only use your personal data when the law 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 you (or the business you represent).
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to marketing in certain circumstances. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for Which We Will Use Your Personal Data
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 legal 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 ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
Third party information processing and international transfers
To register you as a new user of our Platform and to enable you to use our Platform, including: by uploading details of your requirements (if you are a End User) and place bids (if you are an operator); by uploading details of flights that may be of interest to End User (if you are an operator); by using our chat and/or Invite functions to contact operators if you are a End User) or End Users (if you are an operator); to set up alerts relating to End Users requirements or flights that are registered on our Platform; to register your details (If you are an operator) on our online directory this information is published for our Users.
Identity
Contact
Transaction
Transaction
Messaging
Invite
Directory
Performance of a contract with you or the business that you represent
To provide you (or the business you represent) with subscription services including to manage payments, fees and charges
Identity
Contact
Transaction
Messaging
Directory
Marketing and Communications
Performance of a contract with you or the business that you represent
To manage our relationship with you which will include:
Notifying you about changes to our terms or privacy policy
Asking you to leave a review or take a survey
Identity
Contact
Profile
Marketing and Communications
Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how Users use our services)
To administer and protect our business and our Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Identity
Contact
Technical
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Necessary to comply with a legal obligation
Functional Software, Inc. dba Sentry (US)
To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Identity
Contact
Profile
Usage
Marketing and Communications
Technical
Necessary for our legitimate interests (to study how Users use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Platform, services, marketing, User relationships and experiences
Technical
Usage
Message, Invite
Necessary for our legitimate interests (to define types of Users for our services, to keep our Platform updated and relevant, to develop our business and to inform our marketing strategy)
Functional Software, Inc. dba Sentry (US)
To make suggestions and recommendations to you about services that may be of interest to you or the business you represent
Identity
Contact
Technical
Usage
Profile
Necessary for our legitimate interests (to develop our services and grow our business)
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can manage your marketing preferences or opt out of marketing at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Promotional Offers from Us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you (or the business that you represent) may want or need, or what may be of interest to you (or the business that you represent). This is how we decide which products, services and offers may be relevant for you or your business (we call this marketing).
You will receive marketing communications from us if you have requested information from us or subscribed to our services and, in each case, you have not opted out of receiving that marketing.
Third-Party Marketing
We will get your express opt-in consent before we share your personal data with any company outside ACOM for marketing purposes.
Opting Out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a subscription to our service.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website or our Platform may become inaccessible or not function properly. For more information about the cookies we use, please visit https://mach2.aero/cookies
Change of Purpose
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 how 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 legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of Your Personal Data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. 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 way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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.
6. International Transfers
Some of our external third parties 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 out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data Retention
How Long Will You Use My Personal Data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available on request by contacting us.
In some circumstances you can ask us to delete your data: see 'Request erasure' below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
No Fee Usually Required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What We May Need from You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Glossary
Lawful Basis
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Third Parties
Service providers acting as processors based both inside and outside the UK who provide IT and system administration services (including cloud computing services, analytics services, application monitoring and error tracking) and payment processing services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
Your Legal Rights
You have the right to:
Request Access to Your Personal Data:
Also commonly known as a "data subject access request", this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request Correction of Your Personal Data:
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request Erasure of Your Personal Data:
This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to Processing of Your Personal Data:
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request Restriction of Processing of Your Personal Data:
This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the Transfer of Your Personal Data:
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw Consent at Any Time:
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.