Privacy Notice summary of key changes
We have expanded and clarified which ACS legal entity is responsible for your personal data as ACS is part of a large international group.
In light of additional health & safety measures which have been implemented due to covid-19, we have included information regarding ACS’s processing of special category data (e.g. health data) and what grounds are relied upon in doing so.
We have included further information regarding ACS’s transfer of personal data internationally due to the global nature of its business.
We have expanded the information regarding the rights you have in relation to your personal data.
Updated 7 July 2020
Air Charter Service’s data protection and privacy measures are governed by the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time.
Who are we?
Air Charter Service is made up of different legal entities and this Privacy Notice is issued on behalf of the Air Charter Service group so when we mention “Air Charter Service”, “we”, “us” or “our” in this Privacy Notice, we are referring to the relevant company in the Air Charter Service group responsible for processing your data.
Air Charter Service Group Limited (company registration number: 04028491)of Millbank House, 171-185 Ewell Road, Surbiton, Surrey, KT6 6AP, United Kingdom and its affiliates are all deemed data controllers. However, where Air Charter Service is provided with information from a third party or a customer relating to a passenger that we are arranging a charter for we are data processors and will only process such data in accordance with the third party’s or the customer’s instructions.
How do I contact Air Charter Service?
For any queries or comments about this Privacy Notice or updates, amendments and corrections to your records, or for personal data requests, please contact email@example.com or by post to: Data Protection Team, Air Charter Service, Millbank House, 171-185 Ewell Road, Surbiton, Surrey, KT6 6AP, United Kingdom.
If you wish to make a complaint about how we use your information, please contact our Data Protection team. You can also contact the local data protection authority.
What is the purpose of this Privacy Notice?
Air Charter Service respects your privacy and is committed to protecting your personal data. This Privacy Notice describes how Air Charter Service collects and processes your personal data when you access or use our Website or services. It will also provide information on how we look after your personal data and tell you about your privacy rights and how the law protects you.
What is personal data and do I need to provide it?
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).
You are not required to provide the personal data that we have requested, but, if you choose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have.
What personal data will Air Charter Service collect about me?
When you use Air Charter Service to purchase a service, purchase a product, contact us or complete an online form, we may collect a variety of information, including, but not limited to; your name, job title, mailing address, telephone number, email address, passport details, credit/debit card and bank details. We also collect personal data such as contact details for the purpose of sending marketing communications.
When and why do we collect sensitive personal data?
Special category data is a category of personal data which requires more protection because it is sensitive in terms of applicable law, such as data concerning health.
Health data will only be processed for the purposes of ensuring your safety prior, during and after a flight, and where we have received your consent. By providing this sensitive personal data to us, you explicitly agree that we may collect, use, share with third parties (such as airlines) and transfer such data, within and outside the European Economic Area (EEA) in accordance with this Privacy Notice.
How is my personal data collected?
You may directly provide your personal data to us, for example, by filling in forms or corresponding with us by post, phone, email or otherwise, or we may collect your personal data from third parties, such as customers providing your passenger details for the purpose of arranging a charter. We may also collect information from publicly available sources.
What is Air Charter Service’s basis for processing my personal data?
Air Charter Service collects and processes your personal data on the basis of different legal grounds, depending on the nature of the personal data being provided and the type of processing involved.
Performance of a Contract
Some of the personal data is processed on the basis that it is necessary for the performance of our agreement with you, or in order to take steps at the request of the user prior to entering such an agreement, or to register you as a new customer and verify your identity.
A ground relied upon for processing your personal data is legitimate interests, where we believe you have a reasonable expectation that we will perform a particular type of processing on your behalf, or where such processing is strictly necessary for fraud detection and prevention. An example would be where we respond to your queries and enquiries.
A ground relied upon in order to collect and process certain types of personal or sensitive information, or where appropriate to keep you informed by telephone, SMS or email, about us and our business partners content, products and services, events and special offers. You can withdraw your consent, as detailed in this Privacy Notice where applicable, or by sending an email to firstname.lastname@example.org.
Compliance with a Legal Obligation
A ground relied upon for certain types of processing is that it is necessary in order to allow compliance with a legal obligation. An example of this would be to retain business records for fixed periods of time in order to comply with local legal requirements.
When will Air Charter Service contact me?
- In relation to any service, activity or online content you have signed up for in order to ensure that Air Charter Service can deliver, e.g. to ensure payment of your charter, offer other charter related services or upgrades, or to enquire whether you are in need of our services.
- In relation to any correspondence we receive from you or any comment or complaint you make about Air Charter Service.
- To invite you to participate in voluntary surveys about the Air Charter Service.
- To update you on any material changes to Air Charter Service’s policies and practices.
- To keep you informed periodically on relevant products and services that we think may be of interest to you. Types of communication include quarterly newsletter updates, Cloud magazine, Air Charter Service Flyer or emails such as empty legs and passenger/cargo charter availabilities.
If you wish to adjust what information we use or choose to opt out, you can do so at any time by contacting us to update your preferences.
How long will Air Charter Service keep my personal data?
We retain your personal data as long as it is necessary and relevant for our operations. Generally, we keep personal data in accordance with our internal retention procedures, which are determined in accordance with our regulatory obligations and good practice. In addition, we may retain personal data relating to previous booking activity to comply with national laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, and take other actions permitted or required by applicable national laws. After it is no longer necessary for us to retain your personal data, we anonymise part of the data for analytical purposes and dispose of the rest in a secure manner. If you have any questions in relation to our retention periods, please contact us at email@example.com.
Who will Air Charter Service share my personal data with?
Our service providers
This includes external third-party service providers, such as an airline for when you book a flight; accountants, auditors, experts, lawyers and other outside professional advisors; IT systems, support and hosting service providers; printing, advertising, marketing and market research and analysis service providers; document and records management providers; technical engineers; data storage and cloud providers and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.
Governmental authorities and third parties involved in fraud prevention and law enforcement
Air Charter Service may share personal information with governmental or other public authorities (including, but not limited to, courts, law enforcement, tax authorities and criminal investigations agencies); and third-party civil legal process participants and their accountants, auditors, lawyers and other advisors and representatives as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our group companies; (f) to protect our rights, privacy, safety or property, and that of our group companies, you or others; and (g) to allow us to pursue available remedies or limit our damages.
Our group companies
We may share your personal data with certain members of our group companies. Where they have access to your personal data they will use it only for the purposes set out in this Privacy Notice. Air Charter Service will remain responsible for the management and security of jointly used personal information. Access to personal information within Air Charter Service, and our group of companies, is restricted to those individuals who have a need to access the information for our business purposes.
As we share your personal data within the Air Charter Service group, this will involve transferring your data outside the EEA. Many of our external third parties are based outside the EEA so their processing of your personal data will also involve a transfer of data outside the EEA.
Is my personal data secure?
Air Charter Service is committed to keeping your personal data safe and secure from unauthorised access or unauthorised alterations, disclosure or destruction of information that we hold. Our security measures include:
- Encryption of our services and data;
- Review of our information collection, storage and processing practices, including physical security measures;
- Access control restrictions for personal information;
- Contractual confidentiality and processing agreements for employees and/or third parties who may require access to personal data; and
- Internal policies setting out our data security procedures and training for employees.
What rights do I have in relation to my personal data?
Under certain circumstances, you have rights under data protection Legislation in relation to your personal data. These include the right to:
- 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.
You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive.
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).
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests.
Can I delete my data?
Yes, in some cases you will be able to. To make a deletion request please contact our Data Protection team at firstname.lastname@example.org
Changes to this Privacy Notice
We will occasionally update this Privacy Notice in accordance with business and legal requirements. We will post a notice of any material changes on our Website, and where appropriate, notify you using the contact details we hold for you for this purpose. We encourage you to periodically review this Privacy Notice to be informed of how we use your information.