365 Aviation Privacy Notice as of 21st May 2018
365 Aviation’s data protection and privacy measures are governed by the (i) the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the GDPR or the Data Protection Act 1998 (“Data Protection Legislation").
For the purposes of Data Protection Legislation, we 365 Aviation collects personal data for customers such as contact details for providing services or sending marketing communications, 365 Aviation will be data controller. Where 365 Aviation are provided with information from a third party or a customer relating to a passenger that we are arranging a charter for we are data processors and will only process such data in accordance with the customer’s instructions.
What personal data will 365 Aviation collect about me? When you use 365 Aviation to purchase a service, purchase a product, contact us or complete an online form, we may collect a variety of information, including, but not limited to; your name, job title, mailing address, telephone number, email address, passport details, credit/debit card or bank details. Where you use the website www. 365Aviation.com (“Website”), we may collect technical data such as IP addresses and cookie ID.
How is my personal data collected? You may directly provide your personal data to us, or we may collect your personal data from third parties, such as customers providing your passenger details for arranging a charter. We may also collect information from publicly available sources.
How data used and what is 365 Aviation basis for processing? We have set out below, 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 personal data. Please contact 365 Aviation 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 below.
1. To register you as a new customer and verify your identity we require your Identiy and Contact information to perform a contract as required by law.
2. To process and deliver the services, including the below we require your Identity, Contact Information, Financial Information and releated Transactional Information.
- Manage payments, fees and charges
- Collect and recover money owed to us
- contacting you and corresponding about the services we provide to you
This is for the Performance of a contract and Necessary for our legitimate interests, should we need to recover debts due to us.
3. To create, develop, offer, operate, deliver, and improve our products, services, content and personalised marketing we require Identity, Contact Information, and releated Transactional Information for our legitimate interests.
4. For loss prevention and anti-fraud purposes, or national security matters we requre Identity, Contact Information, Financial Information and releated Transactional Information as required by law.
5. To respond to queries and enquiries, we require Identity, Contact Information for our legitimate interests.
6. To keep you informed and may include communication by post, telephone, SMS or email, about us and our business partners’ content, products and services, events and special offers, we require you Indentity and Contact Information, for reasons of Consent (where you are considered a consumer)
Legitimate Interests (where you are a business customer).
When will 365 Aviation contact me? In relation to any service, activity or online content you have signed up for to ensure that 365 Aviation can deliver, e.g. to ensure payment of your charter, offer other charter related services or upgrades, or to enquire whether you’re in need of our services.In relation to any correspondence we receive from you or any comment or complaint you make about 365 Aviation.
- To invite you to participate in voluntary surveys about the 365 Aviation.
- To update you on any material changes to the 365 Aviation policies and practices.
- To keep you informed periodically on relevant products and services that we think may be of interest to you. Types of communication include monthly newsletter updates, invites to leading events, Flyer or emails such as empty legs.
If you wish to adjust what information we use or choose to opt out, you can do so at any time by contacting us to update your preferences.
How long will 365 Aviation keep my personal data? We retain your personal data as long as it is necessary and relevant for our operations. Generally, we keep personal data in accordance with our internal retention procedures, which are determined in accordance with our regulatory obligations and good practice. In addition, we may retain personal data relating to previous booking activity to comply with national laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, and take other actions permitted or required by applicable national laws. After it is no longer necessary for us to retain your personal data, we anonymise part of the data for analytical purposes and dispose of the rest in a secure manner. If you have any questions in relation to our retention periods, please contact us at firstname.lastname@example.org
Will 365 Aviation share my personal data with anyone else? At times 365 Aviation may make certain personal data available to:
- strategic partners that work with 365 Aviation to provide products and services, such as when we share your personal data with an airline to book your flight.
- with third party consultants selected by 365 Aviation.
- to protect the rights, property or safety of 365 Aviation customers of for fraud prevention, law enforcement or national security.
365 Aviation will never sell your personal data and it will only be shared by 365 Aviation to provide or improve our products, services and advertising; it will not be shared with third parties for their marketing purposes.
What rights do I have in relation to my personal data? Under certain circumstances, you have rights under Data Protection Legislation in relation to your personal data. These include the right to:
- 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.
Can I delete my data? Yes in some cases you will be able to. To make a deletion request please contact us over the phone on 0203 365 15 665 email email@example.com
Will 365 Aviation employees have access to my personal data? To make sure your personal data is secure we communicate our privacy and security guidelines to all 365 Aviation employees and strictly enforce privacy safeguards within the company.