Privacy Policy

Effective February 1, 2019

The Rotabull Platform is an online site that facilitates the buying and selling of airplane parts. This Privacy Policy explains how Rotabull (“Rotabull”, or “we”, “us” or “our”) collects, uses and shares your personal information when you, whether a buyer or seller, accesses the Rotabull Platform at or subdomains of (the “Platform”) or contact us via the Platform.

Rotabull respects your privacy rights and is committed to transparency in how we collect, use and share your personal information. If you have any questions or concerns about your personal information or this Privacy Policy, email us at In order to access and use the Platform, it is necessary that we collect certain, limited personal information, which will only be used in accordance with this Privacy Policy. You must be at least 18 years old to access and use the Platform. If you have any questions or concerns about your personal information or this Privacy Policy, email us at

This Privacy Policy applies to personal information and other information we collect:

  • On the Platform.
  • In emails, text, and other electronic messages between you and us.
  • Other services offered via the Platform, if any.

However, this Privacy Policy does not apply to information collected by us offline or through any other means, including on any other website operated by us (including any affiliates or subsidiaries) or any third party, including through any third-party application or content that may linked to or be accessible from the Platform. Please read this Privacy Policy carefully to understand our policies and practices regarding your personal information. If you do not agree with these terms and conditions, your choice is not to use the Platform and the associated services. However, by accessing or using this Platform, you agree to the terms and conditions described in the Privacy Policy. Please also refer to our Terms of Use regarding the terms and conditions for access to and use of the Platform.

What Personal Information We Collect

We collect only the minimum necessary personal information in order to enable users’ activities and transactions on the platform. Customers who register on the Rotabull platform will identify those employees or agents who are authorized to access the Platform on the customer’s behalf. These employees or agents will need to provide to us their name, company affiliation, work email and work phone number to access the Platform. We also collect the names, company affiliation, work emails and work phone numbers of our customers’ counterparts, such as buyers of customers selling parts, to complete a transaction on the platform, although these companies or individuals may not be registered on the Platform. Your personal information will also be associated with the details of transactions that are conducted on the Platform. We do not obtain personal information about our customers or their employees or agents from other sources.

Information We Automatically Collect About You

Our servers may automatically record certain information about you when you access the Platform, such as your Internet Protocol (IP) address, device and browser type, operating system, the pages or features of the Platform that you viewed and the time spent on those pages or features, the frequency with which you use access the Platform, search terms, any links that you click on or use, and other statistics. We collect this information in server logs and by using cookies to analyze trends, administer the Platform, track users’ movements around the Platform, or gather statistical information about our user base as a whole. However, there is no targeted advertising on the Platform.

A cookie is a text file that is placed on your hard disk by a web page server. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you. Certain cookies are essential for the operation of a website, such as to enable transactions. Other cookies are used to compile aggregate and statistical data about site traffic and site interaction so that we can offer a better website experience and tools in the future. Typically, these “analytics” cookies do not need access to personal information for their operations. We may contract with third-party service providers to provide these analytics services. They are contractually prohibited from using personal information collected on our behalf except to help us conduct and improve our business.

We use the following cookies on the Platform:

  • Limited “essential” cookies
  • Heap Analytics ( to analyze usage patterns and for debugging, designing new features, etc.

You have the ability to accept or decline most cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. However, if you choose to decline cookies, you may not be able to fully experience the interactive features of the Platform. If you wish to find out more about cookies, or how to refuse cookies for your browser, please visit the Interactive Advertising Bureau's web site at Note, however, “essential” cookies cannot be disabled.

What We Do with Your Information

All personal information we collect is used only for the purpose of connecting buyers and sellers to facilitate transactions on the Rotabull platform. Our processing of your personal information is strictly necessary and proportionate for the purposes of enabling your use of the platform. We do not use your personal information for our own marketing purposes, nor do we disclose, sell, rent or otherwise make available your personal information to third parties for their marketing purposes. We also do not conduct any automatic processing using any personal information.

Payment transactions will be encrypted using current SSL technology and are managed by a third-party payment processor. We do not have access to any payment or other financial information that you provide to a payment processor.

In addition, we may disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Rotabull, our customers, or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We reserve the right to disclose aggregated or anonymous information (i.e., information that does not identify you) about our users without restriction.

Access to and Correction of Your Personal Information

We retain your personal information for as long as the relevant customer account is active or you remain an authorized user on behalf of a customer, as needed to provide you the requested services or information, to protect our legitimate business interests, comply with our legal obligations, resolve disputes and enforce our agreements. You may send us an email at to request access to, correct or delete any personal information that you have provided to us. We can only process requests associated with the particular email address that you use to send us your request, and we will verify your identity before implementing your request. We reserve the right not to accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Data Security

We maintain appropriate physical, technical and administrative safeguards to protect your personal information, including safeguards consistent with Article 32 of the General Data Protection Regulation (GDPR). We routinely update and test these implemented safeguards. Vendors and service providers are contractually required to implement robust data security for any personal information they may process on our behalf.

In addition, we restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.

To register on the Platform, you will be asked to provide an email and unique password. You are responsible for maintaining the strict confidentiality of your login information, especially your password.

Be advised that the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform and associated services.

Links to Other Websites

The Platform may contain links to other web sites and services. We do not control such third-party web sites and services and are not responsible for their actions or privacy practices. The existence of a link on our web site does not mean that we endorse or have vetted such third-party web site or service. You are encouraged to carefully review the policies and practices of every web site and service that you visit or use.

Located in the United States

We are located in the United States and our Platform and servers are maintained in the United States. If you are located outside the United States, your personal information will be transferred to and processed in the United States, which has data protection laws that may be different than those in your country and may not be as protective. The United States has not sought or received a finding of “adequacy” from the European Union under Article 45 of the GDPR.

Legal Basis

Our legal basis for collecting and using your personal information is (i) to do so with your consent; (ii) where we need the personal information for performance of a contract or requested service, or (iii) where the collection and use is in our or another’s legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the personal information in question. If we collect your personal information with your consent, you may withdraw your consent at any time. You understand and agree that we may collect, use, disclose, and otherwise process the personal information you provide even if you are located outside the United States.

EEA, UK and Swiss Residents

If you are a resident of the EEA, United Kingdom and Switzerland (a “Data Subject”), the GDPR provides you with the following data protection rights:

  • Access your personal information
  • Delete, or request deletion of, your personal information
  • Object to or restrict processing of your personal information
  • Request portability of your personal information to a third party
  • Complain to your local data protection authority at any time
  • Object to automated decision making
  • Update your personal information

To exercise any of these rights, please contact us as provided below. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken. You can also help us maintain the accuracy of your information by notifying us of any changes to your information.


We currently honor browser-based Do-Not-Track signals.

Children’s Privacy

The Platform and associated services are intended to be accessed and used by persons at least 18 years or older. We do not collect or maintain information on the Site or services from persons we know to be under age 13, and no part of our Site is designed to attract anyone under age 13. If a child under the age of 13 has provided us with their personal information, we ask that their parent or guardian contact us as provided below to inform us of that fact. We will use reasonable efforts to delete such information from our systems and servers.

Changes to this Privacy Policy

The Effective Date of the current version of the Privacy Policy is provided above. From time to time we may modify this Privacy Policy. We will notify you of any material change by sending a notice to the e-mail address you provided to us or by placing a prominent notice on the Platform. You can view the most recent version of the Privacy Policy at any time by clicking the “Privacy Policy” link at the bottom of each page on the Platform. Your continued use of the Platform after any modification indicates your agreement to the new terms and conditions.

Comments and Questions

If you have comments or questions about our Privacy Policy or your personal information, you may email us at

Rotabull, Inc.
250 Lafayette, 3A
New York, NY 10012 USA
Phone: +1 (347) 871-7163