HomePrivacy Policy Privacy Policy Network Aviation Group Privacy Notice Introduction Welcome to the Network Aviation Group Privacy Notice. Network Aviation Group respects your privacy and is committed to protecting your personal data. This Privacy Notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you. This Privacy Notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this Privacy Notice. 1. IMPORTANT INFORMATION AND WHO WE ARE 2. THE DATA WE COLLECT ABOUT YOU 3. HOW IS YOUR PERSONAL DATA COLLECTED 4. HOW WE USE YOUR PERSONAL DATA 5. DISCLOSURES OF YOUR PERSONAL DATA 6. INTERNATIONAL TRANSFERS 7. DATA SECURITY 8. DATA RETENTION 9. YOUR LEGAL RIGHTS 10. GLOSSARY 1. Important information and who we are Purpose of this Privacy Notice This Privacy Notice aims to give you information on how Network Aviation Group collects and processes your personal data, including through your use of this website and also (if you are our customer) where we provide you with a service or (if you are our service provider) where you have provided us with a service. This website is not intended for children and we do not knowingly collect data relating to children. Controller Network Aviation Group is made up of different legal entities, details of which can be found at https://www.network-airline.com/our-companies. This Privacy Notice is issued on behalf of the Network Aviation Group so when we mention Network Aviation Group, “we”, “us” or “our” in this Privacy Notice, we are referring to the relevant company in the Network Aviation Group responsible for processing your personal data. We will let you know which Network Aviation Group entity will be the controller for your data when you purchase a product or service with us. Network Aviation Group is the controller and responsible for this website. If you have any questions about this Privacy Notice or how to exercise your legal rights in relation to our processing of your personal data, please contact us using the details set out below. Contact details Our full details are: Full name of legal entity: Network Aviation Group Company Number: 08339061 Postal address: First Floor, Unit A2, Faraday, Road, Manor Royal, Crawley, RH10 9TF Telephone number: Tel: +44 (0) 1293 547737 You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. Changes to the Privacy Notice and your duty to inform us of changes This version was last updated on 23 May 2018. The data protection law in the European Union will change on 25 May 2018. Although this Privacy Notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 2018 as we are still working towards getting our systems ready for some of these changes. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. Third-party links This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. 2. The data we collect about you Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows: • Identity Data includes first name, last name, title. • Contact Data includes billing address, delivery address, email address and telephone numbers. • Financial Data includes bank account and, for customers, payment card details. • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us if you are our customer or that we have purchased from you if you are our supplier. • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. • Usage Data includes information about how you use our website, products and services. • Marketing and Communications Data where you are our customer includes your preferences in receiving marketing from us and our third parties and your communication preferences. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. If you fail to provide personal data Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. 3. How is your personal data collected? We use different methods to collect data from and about you including through: • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: • order services from us (where you are our customer); • provide goods or services to us (where you are our supplier of goods or services) • request marketing to be sent to you; or • give us some feedback. • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details. • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below: • Technical Data from the following parties: (a) analytics providers such as Google based outside the EU; (b) advertising networks such as LinkedIn based outside the EU; and (c) search information providers such Google & Bing based outside the EU. • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as IATA Cargo Accounting Settlement System (CASS) based inside and outside the EU. • Identity and Contact Data from data brokers or aggregators such as Company Credit Check Agencies based inside and outside the EU. • Identity and Contact Data from publicly availably sources such as Companies House based inside the EU. 4. How we use your personal data We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: • Where we need to perform the contract we are about to enter into or have entered into with you. • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. • Where we need to comply with a legal or regulatory obligation. Please refer to the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data. Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. Purposes for which we will use your personal data We have set out below, in a table format, 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 data. Please contact us 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 in the table accessible through the following link: https://www.network-airline.com/purposes-which-we-will-use-your-personal-… Marketing We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms: Promotional offers from us We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing. Third-party marketing We will get your express opt-in consent before we share your personal data with any company outside the Network Aviation Group of companies for marketing purposes. Opting out You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions. Cookies You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy. Change of purpose We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 5. Disclosures of your personal data We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above. • Internal Third Parties as set out in the Glossary. • External Third Parties as set out in the Glossary. • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 6. International transfers We share your personal data within the Network Aviation Group. This will involve transferring your data outside the European Economic Area (EEA). Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-o…. • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-o…. • Where we use providers based in the US, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-o… or visit https://www.privacyshield.gov/welcome. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA. 7. Data security We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 8. Data retention How long will you use my personal data for? We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax reporting purposes and in case of any dispute. We keep basic information about our suppliers (including Contact, Identity, Financial and Transaction Data) for seven years after we purchase goods or services form them so that we can contact them if. For example, there are any issues with our previous purchase or to order further goods or services from them in the future. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. 9. Your legal rights Under certain circumstances, you have rights under data protection laws in relation to your personal data: • 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. For more information on these rights please see the Glossary. If you wish to exercise any of the rights set out above, please contact us. No fee usually required You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Time limit to respond We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 10. Glossary LAWFUL BASIS Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. THIRD PARTIES Internal Third Parties Other companies in the Network Aviation Group acting as joint controllers or processors and who are based within the EU or outside the EU specifically in Canada, Kenya, UAE and USA and provide IT and system administration services and undertake leadership reporting. External Third Parties • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the EU and outside the EU specifically Canada, Kenya, UAE and USA who provide consultancy, banking, legal, insurance and accounting services. • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances. YOUR LEGAL RIGHTS You have the right to: Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. Network Aviation Group Cookie Policy Information about our use of cookies Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. We use the following cookies: · Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. · Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. · Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). · Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. You can find more information about the individual cookies we use and the purposes for which we use them in the table accessible through the following Link: https://www.network-airline.com/our-individual-cookies Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. Network Aviation Group May 2018 Network Aviation Group About Us Contact Us News Network Airline Services What We Do Our Network Network Airline Management Scheduled Cargo Services Managed Fleet Configurations Worldwide Charters Specialist Services Policies Terms and Conditions Privacy Policy Career Opportunities Code of Ethics Head Office Tel: +44 (0) 1293 547 737 Fax: +44 (0) 1293 539 587 Email: reslgw@network-airline.com A2 Windsor Place, Faraday Road, Crawley, West Sussex, RH10 9TF, United Kingdom © Network Aviation Group 2021. All Rights Reserved.