INFORMATION NOTE ON THE PROTECTION OF PERSONAL DATA
Version updated on 27.06.2022
DELAY AVIATION CONSULT LTD, as a personal data operator, in accordance with the provisions of Law no.190/2018 on measures implementing Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation), processes personal data provided to it on a voluntary basis or in the possession of which it comes into indirectly. Regulation (EU) 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data was adopted by the European Parliament and the Council on 27 April 2016, published in the Official Journal of the Union L119 of 4 May 2016, and its provisions are applicable from 25 May 2018.
Processing’ means any operation or set of operations which is performed upon personal data or upon sets of personal data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Personal data’ means information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity. A “data subject” means any person whose data is collected, retained or processed.
PURPOSE OF COLLECTING AND PROCESSING PERSONAL DATA
The purpose of this data collection and processing is to ensure the provision of seamless handling of complaints about delayed, cancelled or overbooked flights, denied boarding, missed connecting flights or downgrades, and delayed, damaged or lost baggage in accordance with the General Terms and Conditions, published on the website www.DELAY.AERO.
DELAY AVIATION CONSULT LTD keeps personal data only for the period necessary to fulfil the purposes for which they were collected, and thereafter for as long as necessary in accordance with the legal provisions in force on archiving. DELAY AVIATION CONSULT LTD processes the personal data of the following categories of natural persons:
1. Customers of DELAY AVIATION CONSULT LTD
2. Employees of DELAY AVIATION CONSULT LTD
3. Employees/former employees of DELAY AVIATION CONSULT LTD
4. Any natural or legal person (with representatives individuals) who has contractual relations with DELAY AVIATION CONSULT LTD
5. Any person who enters the space equipped with video surveillance system.
Individuals provide a series of data (information about the identity of the person, as well as parents or representatives, acceptance of video monitoring for increased security in the electronic system, etc.). Therefore, the provision of personal data is a legal and contractual obligation, which is necessary for the purpose of initiating/continuing legal relations with DELAY AVIATION CONSULT LTD. Some information is not mandatory (e.g. e-mail address, telephone number), but is necessary to improve the communication process.
Personal data is stored for the duration of the contracts, the duration of the projects or for the period necessary to fulfil the purposes for which the data was collected, taking into account applicable limitation periods and compliance with archiving obligations imposed by applicable law. Once the processing period expires and DELAY AVIATION CONSULT LTD no longer has legal grounds or a legitimate interest in processing your personal data, they will be deleted in accordance with the legal provisions.
TRANSFER OF PERSONAL DATA
Your data will not be transferred to countries within/outside the European Union unless this is strictly necessary from the point of view of the purpose of the collection and only in compliance with the legal provisions in force, applying appropriate protection measures and notifying you when necessary.
ACCESS TO PERSONAL DATA AND THE DESTINATION OF SUCH DATA
Access to personal data is carried out only by DELAY AVIATION CONSULT LTD staff dedicated to the activities requiring such data. Personal data may be disclosed to persons outside the company when this is necessary to achieve the purpose of the processing (for example: airlines, travel/ticketing agencies, state institutions, DELAY.AERO partners, etc.) and/or in cases provided for by law. If some of the data about you is incorrect, please inform us as soon as possible.
CONSEQUENCES OF NOT PROVIDING PERSONAL DATA
You are obliged to provide the data, which is necessary to ensure access to the website or the premises where DELAY AVIATION CONSULT LTD operates. If you do not wish to provide the requested information, DELAY AVIATION CONSULT LTD reserves the right to refuse any kind of collaboration.
DELAY AVIATION CONSULT LTD ensures adequate protection and security regarding the protection of personal data in order to avoid accidental or intentional destruction, loss, modification, disclosure or unauthorized access to them.
THE RIGHTS OF THE DATA SUBJECT
According to Regulation (EU) No 679 of 27 April 2016, the data subject has the following rights:
1. Right to information art.13
2. Right of access of the data subject Art.15
3. Right of rectification Art.16
4. Right to erasure of data Art.17
5. Right to restriction of processing Art.18
6. Right to data portability Art.20
7. Right to object art.21
8. Right not to be subject to a decision based solely on automatic processing art.22
9. The right to lodge a complaint with a supervisory authority.
At the request of data subjects, DELAY AVIATION CONSULT LTD confirms whether or not it processes personal data.
EXERCISE OF RIGHTS
For questions or queries regarding the processing of personal data, or in order to exercise their legal rights, data subjects may contact the Data Protection Officer (DPO) – of DELAY AVIATION CONSULT LTD, at email@example.com or firstname.lastname@example.org .
The present information may be subject to further amendments. All updates and amendments to this notice shall be effective from the date of their notification and publication on the website of DELAY AVIATION CONSULT LTD, owned by DELAY AVIATION CONSULT LTD.
– Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation);
– Regulation (EU) of the European Parliament and of the Council of 23 October 2018 on the protection of individuals with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of such data, and repealing Regulation (EC) No 45/2001 and Decision No 1247/2002/EC
Version updated on 04.07.2022
We aim to provide aviation consultancy services to the highest professional standards, but also to implement the highest standards of confidentiality and transparency with regard to the personal data we process in our current work.
Our core values are defined by full protection and transparency in the processing of your personal data in the provision of our services.
Our privacy statement and practices focus on the fair and lawful processing of personal data while ensuring confidentiality, integrity and availability.
This Privacy Statement applies to the website www.DELAY.AERO owned and operated by the primary operating entity of DELAY.AERO, namely DELAY AVIATION CONSULT LTD (hereinafter referred to as “DELAY.AERO”). For the purposes of this Privacy Statement, the terms “DELAY.AERO”, “DELAY AVIATION CONSULT LTD”, “we”, “us”, “our”, “ours”, “our”, “ours” refer to the entire group of companies or to each of the companies, as the case may be.
We primarily process personal data within the EU. Our activities are regulated under the General Data Protection Regulation (EU) 2016/679 (GDPR), which is a directly binding piece of legislation. The GDPR protects the fundamental rights and freedoms of individuals, in particular their right to the protection of personal data.
DELAY.AERO is considered the data controller and will determine the purposes and means of processing personal data. DELAY.AERO is a data controller registered with the National Supervisory Authority for Personal Data Processing as a central autonomous public authority with general competence in the field of personal data protection. It is the guarantor of respect for the fundamental rights to privacy and protection of personal data, as laid down in particular in Articles 7 and 8 of the Charter of Fundamental Rights of the European Union, Article 16 of the Treaty on the Functioning of the European Union and Article 8 of the European Convention for the Protection of Human Rights and Fundamental Freedoms.
In this Privacy Statement, unless otherwise stated herein, capitalized terms below shall have the same meaning as in the General Terms and Conditions and the Contract Terms.
Personal data means any information relating to an identified or identifiable natural person. Personal data includes all types of information that directly or indirectly identify a person, such as names, dates of birth, home addresses, e-mail addresses, telephone numbers, etc.
Our privacy statement is based on the following data protection principles:
– The processing of personal data takes place in a lawful, fair and transparent manner;
– Personal data is collected only for specified, explicit and legitimate purposes, and the data is not further processed in a way incompatible with those purposes;
– The collection of personal data must be adequate, relevant and limited to what is necessary in relation to the purpose for which it is processed;
– Personal data must be accurate and, where necessary, kept up to date;
– Every reasonable step must be taken to ensure that personal data which are inaccurate in relation to the purposes for which they are processed are erased or rectified without delay;
– Personal data must be kept in a form which permits identification for no longer than is necessary for the purposes for which it is processed;
– All personal data must be kept confidential and stored in a way that ensures adequate security;
– Personal data will not be disclosed to third parties unless the transfer is necessary for DELAY.AERO to provide the services under the contract concluded with the Beneficiary;
– You have the right to request access and rectification or erasure of personal data or restriction of processing or to object to processing, as well as the right to data portability.
Collection and use of personal data
If you wish to take advantage of our services and send us information, you may be asked to provide personal data so that we can operate and improve our business activities and services. Personal data may be submitted via our website, mobile applications, email, other electronic or software solutions supported by us, postal services or telephone. All personal data is collected in accordance with the GDPR. We will only process personal data to the extent necessary for a specific, explicit and legitimate purpose or for a purpose required by law where we operate.
DELAY.AERO collects personal data through the website www.DELAY.AERO , DELAY.AERO agencies at home and abroad, as well as through partner travel agencies that market airline tickets and other services provided by DELAY.AERO. DELAY.AERO may also collect personal data at each interaction with its passengers or any other data subjects interested in DELAY.AERO services, both via call-center and by e-mail or written mail.
We mainly collect personal data such as names, dates of birth, home addresses, e-mail addresses, telephone numbers, passport/ID card numbers and numeric identification codes. We collect this personal data for the purpose of providing DELAY.AERO services, including Information Service, Eligibility Service, Airline Communication Support Service. This is the core business activity of DELAY.AERO.
In addition, we collect personal data for other purposes such as statistics, administration and communication, IT administration and security, physical security, authentication and authorization systems, support systems, collaboration in internal projects and organizational teams and activities.
Where we acquire flight data from third parties, e.g. information on flights delayed or cancelled at a particular time etc, this information is not personal data, but we subsequently combine it with personal data. This Eligibility Service is only used to inform about the likelihood of an eligible claim. The Support Service for communication with the air carrier is provided under contract with the Beneficiary.
Use of personal data
We will use personal data for the purpose for which it was collected and keep it for no longer than is necessary for that purpose. We may retain information for as long as the account is active or as necessary to provide services, comply with legal obligations or for any of the purposes listed above. Access to personal data is strictly limited to DELAY.AERO staff and its controlled subsidiaries and affiliates who have appropriate authorization and a clear business need to use the data. DELAY.AERO may disclose passengers’ personal data to third parties for the fulfilment of a legal obligation, for the performance of the service contract as well as for the provision of the purchased services or in cases where such actions are necessary to protect and defend DELAY.AERO’s property rights or act in emergency situations to protect the Beneficiary’s safety. These data recipients may include: air carriers, travel/ticketing agencies and other suppliers from whom you have purchased services (such as travel insurance, airport transfer services, etc.) through DELAY.AERO; DELAY.AERO partners in whose loyalty programs you have enrolled; banks and other payment service providers to process payments initiated to the Beneficiary; handling and catering service providers; external DELAY.AERO call-center and customer service providers. RO; market research companies, customer satisfaction surveys and marketing and advertising services; DELAY.AERO’s contractual partners, in order to promote the products and services marketed by them; public authorities, according to the legal obligations established for DELAY.AERO; international bodies (EUROPOL, INTERPOL, IATA); courts or arbitration courts, as well as authorities competent to investigate the commission of criminal offences; other subcontractors of DELAY.AERO.
Data retention period
Personal Data collected by DELAY.AERO may not be kept longer than necessary for the purposes for which they are processed, in compliance with the applicable legislation in force. After this period has elapsed, your Personal Data will be completely deleted from the systems or rendered anonymous, in accordance with the company’s procedures. Personal data collected for the purpose of sending commercial communications will be processed until the date of withdrawal of the consent expressed by the data subject.
Sharing of personal data
We will only transfer personal data to third parties under the conditions listed below:
– you have given your consent;
– it is for a purpose directly related to the original purpose for which the personal data was collected;
– it is necessary for the preparation, negotiation and execution of the User Agreement;
– is necessary because of legal obligation, administrative order or court decision;
– it is necessary for the establishment or protection of rights or for defences in court;
– it is necessary in order to respond to lawful requests from public authorities, for example to comply with the requirements of national security and police bodies
– serves to prevent misuse or other illegal activities, such as deliberate attacks, to ensure data security.
Occasionally, we contract with other companies and business partners in and outside the European Economic Area to work on our behalf, such as legal representatives/attorneys, to determine court actions upon request or IT companies to process and deliver systems and technologies to improve our products and services; we will disclose necessary information to these partners in these cases.
Service providers will be permitted to obtain the personal data they need to provide their service. We will not disclose personal data to third parties to enable them to market their products or services. If you do not want us to disclose your personal data to these companies, please contact the Data Protection Officer (DPO) , email@example.com or firstname.lastname@example.org.
Personal data may be transferred outside of European Union only pursuant to legal or contractual obligations.
Recipient companies that process DELAY.AERO passengers’ personal data within the European Union/European Economic Area are subject to the same legal provisions and offer the same level of protection as DELAY.AERO. However, if in order to fulfil the purposes of DELAY.AERO it is necessary to transfer passengers’ personal data to recipients outside the European Union/EEA or countries that do not offer an adequate level of protection, DELAY.AERO will require those recipients to protect the personal data in accordance with the requirements of the Regulation.
The security of your personal data is very important to us. We will process personal data securely, and we will apply and maintain appropriate technical and organizational measures and at generally accepted standards to protect personal data against accidental or unlawful destruction or loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, against all other unlawful forms of processing. Questions about the security of personal data can be addressed to the Data Protection Officer (DPO), email@example.com or firstname.lastname@example.org .
Your personal data protection rights
You have the right at any time to request access to and rectification or erasure of personal data or restriction of processing or to object to processing, as well as the right to data portability. To help us update your personal data, we advise you to inform us of any changes or discrepancies. To view and/or edit personal data or to receive information about how long we intend to keep personal data or other questions about access to personal data, or if you would like us to provide you with information about the holding or processing of any of your personal data on behalf of a third party, please contact the Data Protection Officer (DPO), email@example.com or firstname.lastname@example.org. We will respond to your request within a reasonable time.
Email marketing and advertising preferences
Upon consent, we are authorized to send marketing emails. This specific form of consent must be freely given, informed and unambiguous. These requirements are met when you opt-in to receive (actively agreed) marketing emails.
You will always have the right to object, on request and free of charge, to the processing of your personal data in connection with direct marketing activities without the need for specific justification. You can do this by using the “Unsubscribe” link in emails you receive from us or by contacting us at contact@DELAY.AERO . If you object, your personal data will no longer be processed for direct marketing purposes.
Marketing emails contain information that we think may be of interest, such as the latest news about our products and services.
This privacy statement is the responsibility of our legal team, which has overall responsibility for ensuring compliance. The Data Protection Officer (DPO) ensures day-to-day compliance with the Privacy Statement and is involved in all aspects of personal data protection.
We are accountable and at all times can demonstrate compliance with the GDPR (Data Protection Regulation) as well as our principles set out in this Privacy Statement. We will keep records of the processing activities under our responsibility containing the information required by the GDPR and, where appropriate, make them available to the supervisory authority upon request.
Any questions regarding this Privacy Statement may be directed to the Data Protection Officer (DPO) contact@DELAY.AERO or or alex@DELAY.AERO .
You have the right to lodge a complaint about the processing of your personal data. All requests and complaints will be handled in a timely manner by the Data Protection Officer (DPO) in accordance with internal procedures. Complaints can be sent to the Data Protection Officer (DPO) email@example.com or firstname.lastname@example.org .
If you have a privacy or data use concern that we have not satisfactorily addressed, please contact the (free) US impartial dispute resolution arbiter at https://feedback-form.truste.com/watchdog/request.
If you believe that the processing of your personal data violates the GDPR (General Data Protection Regulation), you may also file a complaint with a supervisory authority.
Changes to this Privacy Statement
This Privacy Statement may be updated from time to time, for example as a result of changes in relevant legislation or changes in corporate structure. If significant changes are made, you will be notified by email or by means of a notice on the website before the change comes into effect.
We encourage you to periodically check the DELAY.AERO page for the latest information about our data use and protection practices.
DELAY AVIATION CONSULT LTD
Registration No. 46349751
Tel: +……………., E-mail: email@example.com