Privacy Notice for Customers
This Privacy Notice explains how the personal data of Euroflite’s (“we” or “Euroflite”) current, previous and potential customers and their employees, directors and representatives (“you” or “Customer”) may be processed and how the privacy rights of individuals may be exercised. We process your personal data especially to enable cooperation with you and to comply with our contractual obligations, as explained below in more detail. The controller of the personal data is Wihuri Aviation.
In case you have any questions or requests concerning your personal data or data protection, you may always contact us through the following email address:
dataprotection@wihuri.com
We may periodically update this Privacy Notice by posting a new version of the Privacy Notice on Euroflite’s website.
Further Information on the Processing of Your Personal Data
Sources of Your Personal Data
The personal data we process is mainly collected directly from you.
In addition, we may also collect personal data through Euroflite’s own operations and from publicly available sources.
Further, when legally required or permissible, we may receive personal data from third parties relating e.g. to any bans on engaging in commercial activities, authorisations to sign and positions of authority.
What Type of Personal Data Do We Process?
The data we process may include especially the following categories of your personal data:
- Contact information, such as email address and phone number,
- Person identification information, such as date of birth, nationality, gender and social security number,
- Information related to traveling, such as passport and visa information and travel history,
- Information on your position, such as your job title and company name,
- Information on any meetings between us, including time, place and participants,
- Information relating to product and/or service offers and/or orders, such as your food/drink preferences and special needs and requests,
- Health information, such as possible allergies, dietary requirements and medical diagnosis (for ambulance flights),
- Correspondence and other information relating to the maintenance of your customer relationship,
- Financial information, such as your company credit card information,
- Information necessary in order to comply with our statutory obligations relating to financial crime protection and flight safety, such as economic sanctions and passport information,
- Results of customer satisfaction surveys and any other feedback; and
- Security and log data.
The personal data we process depends on your relationship with us and may not include all categories of data listed above.
What Are the Purposes and Legal Basis for Processing of Your Personal Data?
We only process personal data when we have a legal justification to do so especially for one of the following purposes:
- Management, assessment, performance, enforcement and/or compliance with our contractual obligations between you and us, or taking steps prior to entering into such contract, and
- Compliance with our legal or regulatory obligations.
Based on our legitimate interest relating to our relationship between the Customer you represent and us, we may also process your personal data for the following purposes:
- Maintenance and development of our relationship with you or the Customer you represent,
- Maintenance and development of our operations,
- Management of risks relating to our operations,
- Marketing of our products and/or services that you have previously purchased from us (if a separate consent is not required),
- Ensuring the physical and information security when you are present at our premises and/or networks, and
- Prevention and mitigation of misuse of our products and services.
Based on your consent, we may also process your personal data for the following purposes:
- Ensuring your physical safety, and
- Marketing of such Euroflite’s or its affiliates’ products and/or services for which consent is required.
With Whom May We Share Your Personal Data?
Other Wihuri Group companies: We may transfer your personal data to other Wihuri Group companies involved in the same projects as us or if you have consented to receive marketing of their products and/or services. Some of these companies may act as independent data controllers for the personal data we provide them.
Third parties: We may disclose your personal data to government agencies and regulators, courts and other government authorities where there is a legal obligation to do so. We may also disclose your personal data to external advisors (e.g. lawyers, accountants, auditors etc.) and debt collection agencies.
Service providers and other partners: As part of normal operations Euroflite contracts with third party service providers (e.g. IT systems and support providers etc.). These partners process your personal data only at and according to Euroflite’s instructions to provide the services.
May There Be Any International Data Transfers?
Euroflite operates in a global market. Due to this, your data may be transferred to non-EU/EEA countries too. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data when required. Adequate safeguards that Jetflite and our partners may use include standard contractual clauses approved by EU Commission.
How Do We Protect Your Personal Data?
Euroflite complies with all applicable data protection legislation and aims to ensure that your privacy is not infringed in any phase of the processing.
We continuously develop and implement administrative, technical and physical security measures to protect your data from unauthorised access and against loss, misuse or alteration. The rights of access to the data are predefined and limited. We also require our service providers to implement all appropriate security measures to protect your personal data.
For How Long Do We Retain Your Personal Data?
We retain your data only for as long as it is necessary for the processing purposes stated above or as long as we have a legal obligation to do so. Please note that the data retention periods may vary by data category. Inaccurate or outdated data is deleted regularly.
If you ask us to remove your personal data, we may still retain your data if necessary for our legitimate business interest, such as to comply with our legal obligations, resolve disputes or to enforce our agreements.
Your Rights and Options
You have the right to access your personal data and to correct your data. In some circumstances you may also have the right to have your unnecessary or inaccurate data deleted, to object to how we use or share your data, to restrict how we process your data, and to have your data transferred to another data controller. When the processing of your personal data is based on your consent, you can always withdraw your consent.
You can exercise these rights by contacting Wihuri’s data protection expert in data protection matters through the contact details set out above.
Even though Euroflite seeks to resolve any privacy related disagreements in co-operation with you, you also have the right to lodge a complaint to a data protection authority about our processing of your personal data. For more information, please contact your local data protection authority.