Willis Lease Finance Corporation
Privacy Policy

Last Updated: April 02, 2026

This Privacy Policy describes how Willis Lease Finance Corporation and our subsidiaries and affiliated companies [ED1] [TL2] (collectively, “Willis,” “we,” or “us”) collect, use, disclose, and otherwise process information about you. This Privacy Policy applies to information we collect when you access or use our websites and other online products and services that link to this Privacy Policy (collectively, our “Services”) and when you otherwise interact with us, such as through our customer support channels or on social media. We may provide different or additional notices of our privacy practices for certain offerings, in which case those notices will supplement or replace the disclosures in this Privacy Policy.

This Privacy Policy is effective as of the “Last Updated” date above. We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the “Last Updated” date at the top of this policy. If we make material changes, we will provide you with additional notice (such as by adding a statement to the Services or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

COLLECTION OF INFORMATION

The information we collect about you depends on how you interact with us. In this section, we describe the categories of information we collect and the sources of this information.

Information You Provide to Us

We collect information you provide directly to us. For example, we collect information directly from you when you visit our website, apply for a job, complete a “Connect with Us” form, communicate with us via third-party platforms, request customer support, or otherwise communicate with us. The types of information that we collect directly from website visitors and customers/potential customers include your name, email address, job title, company name, phone number, and any other information you choose to provide.

Information We Collect Automatically

We automatically collect information about your interactions with us or our Services, including:

• Device, Usage, and Activity Information: We collect information about how you access our Services, including data about the device and network you use (such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version). We also collect information about your activity on our Services, including the route by which you access our Services, access dates and times, browsing behavior (such as pages viewed and links clicked), and information about your activity on specific pages (such as mouse movements and keystrokes).
• Audio Recordings: If you call Willis, we may monitor and retain those conversations, including for training purposes.
• Information Collected by Cookies and Similar Tracking Technologies: We use tracking technologies, such as cookies, pixels, and session replay, to collect information about your interactions with the Services and our marketing communications. These technologies help us improve our Services and marketing communications, personalize your experience, and analyze your interactions with us, including to see which areas and features of our Services are popular and count visits. For more information about the choices available to you, see the Your Choices sections below.

Information We Collect from Other Sources

We obtain information from other sources. For example, we may collect Device, Usage, and Activity Information from data analytics providers.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address.

USE OF INFORMATION

We use the information we collect to provide, maintain, and improve our Services.

We also use the information we collect to:

• Provide, maintain, and improve our products and services;
• Develop new products and services;
• Personalize your experience with us;
• Send you technical notices, security alerts, support messages, and other transactional or relationship messages;
• Send marketing communications (see the Your Choices section below for information about how to opt out of these communications at any time);
• Monitor and analyze trends, usage, and activities in connection with our products and services and
• We use information to generate de-identified data that we (i) maintain and use only in a de-identified fashion and (ii) will not attempt to re-identify, except as permitted by law;
• Detect, investigate, respond to, prosecute, and help protect against security incidents and other malicious, deceptive, fraudulent, or illegal activity, and help protect the rights and property of Willis and others; and
• Comply with our legal and financial obligations.

DISCLOSURE OF INFORMATION

We disclose information about you as follows:

• Vendors and Service Providers: We make personal information available to our vendors, service providers, contractors and consultants who perform services on our behalf, such as companies that assist us with web hosting, customer service, analytics, and marketing.
• Law Enforcement & Legal Requests: where required by law or to respond to legal process.
• Law Enforcement Authorities and Individuals Involved in Legal Proceedings. We disclose personal information in response to a request for information if we believe that disclosure is in accordance with, or required by, any applicable law, regulation, or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
• To Protect the Rights of Willis and Others. We may disclose personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Willis, our users, the public, or others.
• Professional Advisors. We disclose personal information to our legal, financial, insurance, and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
• Corporate Transactions. We disclose personal information in connection with, or during negotiations of, certain corporate transactions, including a merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
• Corporate Affiliates. Personal information is disclosed between and among Willis and our parents, affiliates, subsidiaries, and other companies under common control and ownership.
• With Your Consent or at Your Direction. We make personal information available to third parties when we have your consent or you intentionally direct us to do so.

We also disclose aggregated or de-identified information that cannot reasonably be used to identify you.

APPLICANT INFORMATION

When you apply for a position with Willis Lease, we collect the information that you provide in connection with your application. This includes name, contact information, professional credentials and skills, educational and work history, and other information that may be included in a resume or provided during interviews (which may be recorded). This may also include demographic information. We may also conduct background checks and receive related information.

We use applicants’ information to facilitate our recruitment activities and process applications, including evaluating candidates and monitoring recruitment and hiring statistics. We use successful candidates’ information to administer the employment or independent contractor relationship. We may also use and disclose applicants’ information (a) to improve our Services, (b) as otherwise necessary to comply with applicable laws, (c) to respond to subpoenas or warrants served on Willis Lease, and (d) to protect and defend the rights or property of Willis Lease or others.

DATA RETENTION

We store personal information for as long as necessary to carry out the purposes for which we originally collected it and for other business purposes explained in this Privacy Policy.

YOUR CHOICES

Cookies and Similar Tracking Technologies

Willis uses cookies and similar tracking technologies, as described above. You can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect some of the functionality of our Services.

Communications Preferences

You may opt out of receiving promotional emails from Willis by following the instructions in those communications. If you opt out, we may still send you non-promotional emails.

ADDITIONAL INFORMATION FOR SPECIFIC JURISDICTIONS

California Residents

If you reside in California, this section applies to you and serves as our California notice at collection.

As required by certain California law, we use the table below to explain our collection and disclosure of information.

Disclosure of Personal Information for Business Purposes

We generally do not collect information that is considered “sensitive” under California law nor do we use or disclose sensitive personal information for the purpose of inferring characteristics about you.

As described in the Collection of Information section above, we collect personal information from various sources, including directly from you, automatically when you access or use our Services, and from third-party sources.

We retain personal information as described in the “Data Retention” section above.

Sales and Sharing
We do not “sell” or “share” personal information as defined by California law.

Access, Correction, and Deletion
You have the right to (1) request to know more about and access your personal information, including in a portable format, (2) request deletion of your personal information, and (3) request correction of inaccurate personal information.

To request access, correction, or deletion of your personal information, email dataprotection@willislease.com or call 800-935-0897. To authenticate your request, we may ask you to verify your email address and/or provide information related to your recent interactions with us.

Nondiscrimination
You have the right not to be discriminated against for exercising any of your privacy rights.

Authorized Agents
You may also designate an authorized agent to submit an access, deletion, or correction request on your behalf. We may ask authorized agents to submit proof of their authority to make a request, such as a valid power of attorney or proof that they have signed permission from the consumer who is the subject of the request. In some cases, we may contact the individual who is the subject of the request to verify their own identity or confirm the authorized agent has permission to submit the request. If you are an authorized agent seeking to make an access, correction, or deletion request on behalf of a California resident, please contact us at dataprotection@willislease.com.

Individuals in Europe or the United Kingdom

If you are located in Europe or the United Kingdom, this section applies to you.

Legal Basis for Processing

When we process your personal data as described in this Privacy Policy, we do so in reliance on the following lawful bases:

• To perform our responsibilities under our contract with you (e.g., processing payments for and providing the products and services you requested);
• When we have a legitimate interest in processing your personal information to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you);
• To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications); or
• When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing of your personal information, you may withdraw such consent at any time.

Data Subject Requests

You have the right to (1) access your personal data, including in a portable format, (2) request erasure of your personal data, and (3) request correction of inaccurate personal data. In addition, you may have the right to object to certain processing or request we restrict certain processing. To exercise any of these rights, please email dataprotection@willislease.com.

If you have a concern about our processing of personal data, we encourage you to contact us in the first instance. However, if we are not able to resolve it, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

For individuals in the European Union: https://edpb.europa.eu/about-edpb/board/members_en

For individuals in the UK: https://ico.org.uk/global/contact-us/

For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

You can also adjust certain cookie settings by clicking here.

International Transfers

Willis is based in the United States, and we and our service providers process and store personal information on servers located in the United States and other countries. Whenever we make restricted international transfers of personal information, we take steps to ensure that your personal information receives an adequate level of protection (by putting in place appropriate safeguards, such as contractual clauses) or ensure that we can rely on an appropriate derogation under data protection laws. Where relevant, you may request access to any safeguard which we use to transfer your personal information outside of the European Economic Area, the United Kingdom, or Switzerland (although we may need to redact data transfer agreements for confidentiality reasons).

CONTACT US

If you have questions about this Privacy Policy, please contact us at dataprotection@willislease.com.