All personal data is obtained, held, and processed by FLYINGGROUP, in compliance with, this Policy, any and all data protection related laws and regulations that are applicable to FLYINGGROUP (including without limitation, Regulation (EU) 2016/679 of the European Parliament and of the Council (“GDPR”), and any and all data protection related terms in any agreement or contract in force between you and FLYINGGROUP in relation to the supply by us to you of services and/or products.
Please note that depending on which FLYINGGROUP entity you contract for the provision of Services, the entities mentioned here-above may also bedeemed “Data controllers” according tothe meaning assigned bythe GDPR.
The Main Establishment of FLYINGGROUP for purposes of the GDPR shall be Belgium (Europe).
When we ask you to provide certain personal data, then you can be assured that it will only be used in accordance with this Policy.
This Policy applies to personal data about you that we collect, use and otherwise process in connection with your relationship with us as a client or potential client, including when you travel with us or use our other services, use our websites or mobile apps, service agents and book to use our services through third parties (such as agents, brokers and other carriers).
This Policy applies to you whether you use our services or products on a casual basis, or have registered to use any of our services or products, or have entered into a contract with us in relation to the supply by us to you of services and/or products. Any products and/or services acquired by you from us will be subject to their own terms and conditions which you must also read and accept. In the event of any conflict between this Policy and the terms and conditions of any such products or services (suchas, without limitation, those terms and conditions in, any FLYINGGROUP CharterAgreement,or any FLYINGGROUP Aircraft Managementor, any FLYINGGROUP Program Partnership Agreement, or, in the FLYINGGROUP General Terms and Conditions of Carriage,) then the terms and conditions of those products or services shall prevail.
This Policy is effective as of the “Effective Date” which appears at the bottom of this Policy. Use the “Last Revised Date” appearing at the bottom of this Policy to determine when this Policy was last updated. This Policy is current as of the “Last Revised Date”. We reserve the right, at our sole and absolute discretion, to change or modify this Policy at any time.Any such changes or modifications will become effective when posted on this page. Please check this page periodically to ensure that you are happy with any such changes or modifications. It is in your own interest to access this page regularly to view the latest version of this Policy. If we make a change or modification to this Policy, we may, where appropriate and where possible in our sole discretion, alert you with a notice on our website or with any other means of notification we deem fit. Your continued access to or use of any of our services or products or your purchase of any of our products or services or your continued provision of personal data to us following any change or modification to this Policy shall be deemed your acceptance to be bound by any such changes or modifications.
Your access to or use of any our services or products and your purchase of any of our products or services is entirely voluntary. Please read this Policy carefully, as your access to or use of any our services or products and your purchase of any of our products or services constitutes your acceptance of all of the terms and practices described in this Policy, including without limitation, the collection, use, processing, and disclosure of your personal data as described in this Policy. Please do not access or use any of our services or products or purchase any of our services or products if you disagree with any part of this Policy.
We may collect personal information from you in the course of our business, including through your use of our Site, when you contact or request information from us, when you engage our Services as a result of your relationship with one or more of our staffor clients.
Our primary goal in collecting personal information from you is to help us:
To undertake these goals,we may process the following personal information:
We collect personal information about you whenever you use our services (whether these services are provided by us or by other companies or agents acting on our behalf), including when you travel with us, when you use our website or mobile applications, or interact with us via email or useour contact center.
In addition, we may receive personal information about you from third parties, such as:
Certain categories of personal information, such as that about race, ethnicity, religion, health, sexuality or biometric information are special categories of data referred to here as “sensitive personal data”. Generally, we try to limit the circumstances where we collect and process sensitive personal data.
Sensitive personal data will only be processed where:
By providing any personal data that is orcould be considered to be “sensitive personal data”, you explicitly agree that we may collect, use, share with third parties and transfer such data, within and outside of the European Economic Area, in accordance with this Policy.
We store, handle, send and generally process personal data where we have a legal basis to do soaccording to the GDPR rules:
We will need to use the personal data to fulfill your requestto use our servicesto it is necessary for us to process your information to perform our obligations in accordance with any contract we may have with you;it is our legitimate interest or a third party’s legitimate interest to use your personal information in such way to ensure that we provide the very best service and in particular for the following reasons:
Please also be aware that in some airportswhere we operate, facial recognition and related biometric technology is used in order to facilitate passenger boarding.
We shall keep your personal data for the above purposes in accordance with those retention periods set by applicable law and our internal policies.We will not retain your data for longer.To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means.
We must also consider periods for whichwe might need to retain personal data in order to meet our legal obligations or to deal with complaints, queries and to protect our legal rights in the event of a claim being made.
When we no longer need your personal data, we will securely delete or destroy it. We will also consider if and how we can minimizeover time the personal data that we use, and if we can anonymize your personal data so that it can no longer be associated with you or identify you, in which case we may use that information withoutfurther notice to you.
We may disclose your personal data (and any third party personal data provided by you to us) to:
FLYINGGROUP and other carriers are required by laws in several countries to give border control agencies and other public authorities’access to booking and travel information and other personal data (including data obtained from official photo identification documents). Therefore, any information we hold about you and your travel arrangements may be disclosed to the customs, immigration and public authorities of any country in your itinerary.
In addition, laws in several countries require FLYINGGROUP and other carriers to collect passport and associated information for all passengers prior to travel to or from those countries. When required, FLYINGGROUP will provide this information to the relevant customs and immigration authorities.
We collect personal data about you when you use our services or products (whether directly provided by us or by another company or agent), when you travel with us, and when you use our website.
The following are examples of when we collect personal data about you:
In addition, we may receive personal data about you from third parties, such as:
Cookies are a small amount of data sent from the server, which is then stored on your computer’s hard disc drive. We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users’ browsing actions and patterns anddoes not identify any individual. For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies help us to improve our services and to deliver a better and more personalizedservice.
You may receive marketing communications from us, or from third parties used by us to send marketing communication on our behalf ifyou have opted in to receive such material. Our marketing communications will always include the option for you to unsubscribe from receiving any further marketing communications.
If you have previously agreed to us using your information for direct marketing purposes, you may change your mind at any time by writing to us at firstname.lastname@example.org
Please note that if you tell us that you do not wish to be sent further marketing communications, you will still receive service communications.
We are committed to ensuring that your personal data is secure at all times. We have in place suitable physical, electronic and managerial procedures to safeguard and secure the personal data we collect online.
All of our employees and suppliers with access to your personal data and/or who are associated with the processing of that data are contractually obliged to respect the confidentiality of your personal data. As an example, if you are a passenger on a flight operated by us you can be assured that none of our crews, will take a photo of you whilst you are on our aircraft and then upload the photo on social media, or disclose to any person the fact that you are flying on our aircraft, or disclose any of your confidential information that they may become privy to during your flight (in each case, unless disclosure is required for any reason set out in this Policy).
Your personal data will be stored on and processed by our systems and may also be stored on and processed by systems of a third-party data processor(s) appointed by us.
The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”).
The nature of our business means it is often necessary for us to send your personal information outside the European Economic Area to fulfil your travel arrangements. This occurs because our business and the third parties identified in ’Who do we share your personal information with?’ have operations in countries across the world. For example, where you are flying outside of the European Economic Area, your personal information will be transferred to border control and immigration outside of this area.
In addition, we may transfer your data to parties in countries outside the country in which you are located to provide services to us.This may involve sending your data to countries where under their local laws you may have fewer legal rights.
Where your personal information is transferred outside the European Economic Area because we are using a service provider in a third country, we will implement safeguards so that your personal information continues to be protected to the standards set out in this privacypolicy.
It may also be processed by employees operating outside the EEA who work for us or for one ofour suppliers. Such employees may be engaged in, amongst other things, the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Policy, the GDPR, and any data protection related laws that are applicable to FLYINGGROUP.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Services; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorizedaccess.
Our websites, online services may, from time to time, contain links to and from websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. You are advised to please check these policies before submitting any personal data to these websites or using these services.
If you are providing personal data to us about someone else you confirm that they have appointed you to act for them, to consent to the processing of their personal data, and that you have informed them of our identity, of this Policy, and of the purposes (as set out in this Policy) for which their personal data will be processed.
You have the following rights in relation to the personal information we hold about you:
Your right of access
If you ask us, we’ll confirm whether we’re processing your personal information and, ifnecessary, provide you with a copy of that personal information (along with certain of thedetails). If you require additional copies, we may need to charge a reasonable fee.
Your right to rectification
If the personal information we hold about you is inaccurate or incomplete, you are entitled to request to have it rectified. If you are entitled to rectification and if we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you whowe’ve shared your personal information with so that you can contact them directly.
Your right to erasure
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to restrict processing
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to us. If you are entitled to restriction and if we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to data portability
You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine-readableformat) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
Your right to object
You can ask us to stop processing your personal information, and we will do so, if we are:
If you wish to receive a copy of your personal informationor exercise one of your Rights as detailed here-above,you can fill a Data Subject Request form that you can find: http://fygpublicwebsitewordpress.azurewebsites.net/wp-content/uploads/2020/08/Data-Subject-Request-Form.pdf
Once completed, this form should be submitted:
Flying Service NVAtt : Privacy team Luchthavenlei 1/8 -2100 Deurne (Antwerp)Belgium
Please note that in order to process your Data Subject request, we are obliged to levy a fee of 100,00 € to cover our administrative costs.
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the relevant Supervisory Authority established within the EEA. List of contact details of supervisory authorities within the EEA is available via this link: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080
Any dispute arising from or related to the acceptance, interpretation or observance of this Policy shall be submitted to the exclusive jurisdiction of the competent Court of Belgium which shall apply the laws of Kingdom of Belgium.
If any portion of this Policy is held to be invalid or unenforceable for any reason by a court or governmental authority of competent jurisdiction or by a supervisory authority, then suchportion will be deemed to be stricken and the remainder of this Policy shall continue in full force and effect.
|4thMay 2018||1||Effective Date|
|25th June 2018||1.1||Last revised Date|
|10thJuly 2018||1.2||Include data subject request formFormatting|