- How and why Flightworx collect information from you.
- Who we share your information with, why and on what basis.
- What your rights are.
If we make changes to this notice we will notify you by updating it on our website and or by email. Flightworx will be what is known as the ‘Data Controller’ of the personal data you provide to us, and we will sometimes refer to ourselves in this notice as “we” or “us”. By Data Controller, this means Flightworx determines the purposes and way in which any personal data are, or will be, processed. Should you need to contact us please write to: Data Protection Officer, Flightworx Aviation Ltd, 4-8 Cambridge Road, Stansted, Essex, UK, CM24 8BZ or via email@example.com – mark as “Security and Privacy Enquiry”. This privacy notice was last updated on 10th May 2018. What information we collect when you register and why? When you buy services from us, you are entering into a contract with us. You will need to set up a Flightworx Account before ordering from us, so we can set this up we will ask you to provide some personal information such as;
- Full operator information including personal name(s) associated with the Company
- Company name(s)
- Address(es) for billing and postal
- Full owner information and associated details
- Contact number(s), email address(es).
- Contract – your Company, Owner and personal information is processed in order to fulfil a contractual arrangement e.g. in order to send you flight briefs, handling arrangements etc.
- Consent – where you agree to us using your information in this way e.g. for storing your payment card details.
- Legitimate Interests – this means the interests of Flightworx in managing our business to allow us to provide you with the best products and service in the most secure and appropriate way e.g. to transfer your data to certain Third Party’s such as fuel companies, handling agents etc.
- Legal Obligation – where there is statutory or other legal requirement to share the information e.g. when we have to share your information for law enforcement purposes, Govt entities.
Here is a list of the ways that we may use your company, client or personal information, and which of the reasons described above we rely on to do so. Where we list legitimate interests as a reason, we also describe below what we believe these legitimate interests are.
|We Use Your Owner, Company or Personal Information For||Our Reasons (Legal Basis)||Our Explanation Of Flightworx Legitimate Interests|
|Setting up your Flightworx account(s)||Legitimate interest||Process efficiency in dealing with such activity.|
|Storing payment cards||Consent||N/A|
|Processing your orders and requests||Fulfilling a contract||N/A|
|Notify you of your order and request status.||Legitimate interests||Process efficiency in dealing with such activity, and to make improvements to our services.|
|Managing securely your account/ providing customer services to you. This may include: transfers to Third Countries who undertake customer services/communications activities, call recording data verification customer complaints/queries||Legal obligation/ Legitimate interests (depending on nature of services)||Keeping our records up to date, handling our customer contact efficiently and effectively, working out which of our products and services may interest you and telling you about them.|
|To detect, investigate and report financial crime (e.g. Fraud)||Legal Obligation / legitimate interests||Developing and improving how we deal with financial crime. Complying with any legal obligation placed on us by regulators such as the FCA. Complying with any regulations that apply to us. Process efficiency in dealing with such activity, and to make service and process improvements.|
|Undertake website personalisation and administration.||Legitimate interests||Developing products, services, applications and designs that attract and retain customers. Improving customer interaction with our sites. Defining types of customers for new products or services|
|Marketing communications to inform you of special offers, promotions, new lines and Sales. Invitations to key events.||Legitimate interests||Developing products, services, applications and designs that attract and retain customers. Improving customer interaction with our sites.|
|Notifying you about enhancements to our services, such as changes to the website and new services that may be of interest to you.||Legitimate interests||Developing products, services, applications and designs that attract and retain customers. Improving customer interaction with our sites.|
|Contact you to undertake customer satisfaction surveys, invite you to provide product reviews or for market research.||Legitimate interests||Developing products, services, applications and designs that attract and retain customers. Improving customer interaction with our sites.|
|Maintaining network and data security||Legitimate interests||To maintain the security of our network this in turns helps us to maintain the safety and confidentiality of your information.|
|Logistics planning, demand forecasting, management information and research||Legitimate interests||We use information about service habits, products used and volumes, to help us to respond to demand, ensure the right products get to the right areas and to help us plan our ranges.|
Who we share your information with and why Flightworx works with a number of trusted suppliers, agencies and businesses in order to provide you the high quality products, goods and services you expect from us such as fuel companies, ground handling agents, Govt bodies, credit reference agencies, fraud prevention agencies, product technicians and research companies amongst others. Some examples of the categories of third parties with whom we share your data are: Supplier sources Flightworx works with a number of trusted partners who supply products and services on our behalf. All suppliers are subject to thorough feedback checks, and will only hold the minimum amount of personal information needed in order to fulfil the tasks you place or provide a service on our behalf. Delivery of services In order for you to receive your services back to you, Flightworx works to quality control the Suppliers’ return information. Again, we only pass limited information back/forth from them in order to ensure delivery of your service. IT Companies Flightworx works with businesses who support our website and other business systems and who maintain their own GDPR standard. Marketing Companies We work with marketing companies who help us manage our electronic communications with you or carry out surveys and product reviews on our behalf. Payment processing Flightworx works with trusted third party payment processing providers in order to securely take and manage payments. Credit Reference Agencies When you apply for credit with us we will make searches about you with credit reference agencies. We do this to make sure customers who apply for credit accounts are able to manage the level of credit offered and not committing fraud by providing false or inaccurate information. In order to process your application we will supply your company information to a credit reference agency (CRA) and they will give us information about you, such as your financial history. We do this to assess your creditworthiness and product suitability, check your identity, manage your account, trace, recover debts, and prevent criminal activity. The identity of the CRA, and the ways in which they use and share personal information, are explained in more detail at: Creditsafe https://www.creditsafe.com/gb/en/more/about/gdpr.html We will use automated credit-scoring methods to assess your application and to confirm your identity. We will automatically check your credit history against our lending criteria and if you don’t meet our requirements you will be declined for credit. Should you wish to object to the use of automated credit scoring, please contact the Data Protection Officer. Debt recovery and fraud prevention services Before we provide services, goods or financing to you, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you. The company, owner and personal data you have provided, we have collected from you, or we have received from third parties will be used to prevent fraud and money laundering, and to verify identity. Details of the company, owner or personal information that will be processed include, for example: name, address, date of birth, contact details, financial information, employment details, device identifiers including IP address. We and fraud prevention agencies may also enable law enforcement agencies to access and use your company, owner or personal data to detect, investigate and prevent crime. We process your company, owner and personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested. We process your company, owner or personal data on the basis that it is necessary in the public interest or in exercising official authority for us to prevent fraud and money laundering, and to verify identity, in order to protect ourselves and to comply with laws that apply to us. Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years. Automated Decisions As part of the processing of your company, owner or personal data, decisions may be made by automated means. This means we may automatically decide that you pose a fraud or money laundering risk if our processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct, or is inconsistent with your previous submissions, or you appear to have deliberately hidden your true identity. You have rights in relation to automated decision-making: if you want to know more please contact us using the details above. Consequences of Processing If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services or financing you have requested, or to employ you, or we may stop providing existing services to you. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details above. Data Transfers Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing. Your Rights Your personal data is protected by legal rights, which include your rights to object to our processing of your personal data; request that your personal data is erased or corrected; request access to your personal data. For more information or to exercise your data protection rights, please contact us using the contact details above. You also have a right to complain to the Information Commissioner’s Office, which regulates the processing of personal data. Transfers to third countries Some of the information you provide to us may be transferred outside the European Economic Area to countries such as India and the US. This is a transfer to a “third country”. For example Flightworx has a business relationship with Flightworx (Guernsey) Ltd who provide us with further operational support together with customer and supplier account administration services. Although the data is held in UK data centres colleagues in Guernsey may access it to undertake the activities described above. If you place a service order with us and you are outside of the UK we will always transfer the data that we hold on you to Flightworx Aviation Limited in the UK. Flightworx also works with suppliers and partners who may make use of cloud and/or hosted technologies. We undertake data security due diligence on our partners and ensure that that these partners conform to appropriate accreditations. Wherever transfers of data to third counties occurs Flightworx will put in place any appropriate contractual provisions to ensure that there are strict rules regarding both the confidentiality and security of your information. To find out more please contact us at firstname.lastname@example.org. Keeping in touch with you We want to keep you up to date with information about our new services, updates to services that may affect you, special offers and improvements to our website. When you set your account up, we will ask you if you want to receive this type of marketing information. Flightworx will not share your information with companies outside of Flightworx Aviation Ltd for their marketing purposes. Flightworx Aviation Ltd includes Flightworx Fuel Services Ltd, Travelworx and Flightworx (Guernsey) Ltd. If you decide you do not want to receive this marketing information you can request that we stop by writing to the Data Protection Officer at mailto:the postal address provided above, emailing email@example.com the Contact Centre on 01279 668005, via My Account online or the unsubscribe link within the email sent. You may continue to receive mailings for a short period while your request is dealt with, these will not be sent intentionally. How long we keep your information If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We may need your company, owner or personal information to establish, bring or defend legal claims. For this purpose, we will always retain your company, owner and personal information for 7 years after the date it is no longer needed by us for any of the purposes listed under How we use your information above. The only exceptions to this are where:
- the law requires us to hold your information for a longer period, or delete it sooner;
- you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law;
- we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible; or
- in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.
What are your rights You are entitled to request the following from Flightworx, these are called your Data Subject Rights and there is more information on these on the Information Commissioners website www.ico.org.uk
- Right of access – to request access to your personal information and information about how we process it
- Right to rectification – to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
- Right to erasure (also known as the Right to be Forgotten) – to have your personal information erased. Contact Call Centre 01279 668005
- Right to restriction of processing – to restrict processing of your personal information
- Right to data portability – to electronically move, copy or transfer your personal information in a standard form
- Right to object – to object to processing of your personal information
- Rights with regards to automated individual decision making, including profiling – rights relating to automated decision making, including profiling
- They enable you to transact, whilst other non-essential cookies enable us to give you an enhanced, personalised web experience and determine relevant products to show you.
- To personalise and improve your customer experience.
- To recognise the device that you are using.
- To record the areas of the Site that you have visited, products you have viewed and time spent browsing, as well as the products you may be considering. Flightworx uses this information to help make the website more user friendly, develop our Site design and to continuously improve the quality of the service we provide.
- To distribute visitors to our Site evenly across platforms to ensure the content is served at the fastest possible speed.
- For re-marketing purposes to determine relevant related products to show you when you’re browsing on other selected websites. These cookies can be associated with services provided by a third party such as an advertising network.
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Opting Out Website visitors who don’t want their data used by Google Analytics can install the Google Analytics opt-out browser add-on. To opt-out of Analytics for the web, visit the Google Analytics opt-out page and install the add-on for your browser. Learn more about the opt-out and how to properly install the browser add-on here. Visitors can also opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Settings This Cookie Notice was last updated on 10th May 2018, and further changes will be communicated by updating this notice. Contact Should you need to contact us please write to: Data Protection Officer, Flightworx Aviation Ltd, 4-8 Cambridge Road, Stansted, Essex, UK, CM24 8BZ or via firstname.lastname@example.org quoting Security and Privacy Enquiry.