At hullo Aircrew (“We”) are committed to protecting and respecting your privacy. This policy (together with our Member Terms and Conditions and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. We are committed to protecting your personal information when you use any of our services. Whenever you provide such information we will only use your information in line with all applicable data protection laws, including the General Data Protection Regulation (GDPR). Your information will be kept in a secure environment and access to it will be restricted.
This policy was last updated on 23rd May 2018.
We are the data controller for the purpose of the Data Protection Act 1998 (the “Act”).
What we may collect from you?
We may collect and process the following data about you:
1.1. Information you give us. You may give us information about you by filling in forms on our Website or by corresponding with us by phone, email or otherwise. This includes information you provide when you register to use our Website, search for a flight posting, search for a service or place an order on our Website, and when you report a problem with our Website. The information you give us may include your name, address, e-mail address and phone number, and/or financial and credit card information. The information may also include copies of your passport, flight crew licences and ratings and medical information.
1.2. Information we collect about you. With regard to each of your visits to our Website we may automatically collect the following information:
1.2.1. technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
1.2.2. information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call us.
1.3. Information we receive from other sources. We may receive information about you if you use any other websites we operate. We may also work with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
We will use collected information
3. USES MADE OF THE INFORMATION
We use information held about you in the following ways:
3.1. Information you give to us. We will use this information:
3.1.1. to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and products that you request from us;
3.1.2. to provide you with information about other services or goods we offer that are similar to those that you have already purchased or enquired about;
3.1.3. to provide you with information about services or goods we feel may interest you;
3.1.4. to notify you about changes to our service; and
3.1.5. to ensure that content from our Website is presented in the most effective manner for you and for your computer.
3.2. Information we collect about you. We will use this information:
3.2.1. to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
3.2.2. to improve our Website to ensure that content is presented in the most effective manner for you and for your computer;
3.2.3. to allow you to participate in any interactive features of our Website, when you choose to do so;
3.2.4. as part of our efforts to keep our Website safe and secure;
3.2.5. to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
3.2.6. to make suggestions and recommendations to you and other users of our Website about services or goods that may interest you or them.
3.3. Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
4. DISCLOSURE OF YOUR INFORMATION
4.1. We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
4.2. We may share your information with selected third parties including:
4.2.1. Operator Members;
4.2.2. business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you; and
4.2.3. analytics and search engine providers that assist us in the improvement and optimisation of our Website.
4.3. We will not disclose your information to third parties for advertising purposes unless you give your express consent for us to do so.
4.4. We may disclose your personal information to third parties:
4.4.1. in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
4.4.2. if hullo Air Crew or substantially all of its assets are acquired by a third party, in which case personal data held by it about its members will be one of the transferred assets; and
4.4.3. if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Member Terms and Conditions and other agreements; or to protect the rights, property, or safety of our members, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Where we store your personal data
5. WHERE WE STORE YOUR PERSONAL DATA
5.2. All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
5.3. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
6. YOUR RIGHTS
6.1. You have the right to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. We will provide an option to unsubscribe from any such communications in the body of each such communication.
6.2. Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Your rights to your personal data
7. YOUR RIGHTS TO YOUR PERSONAL DATA
7.1. You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request with respect to these rights, you can email [email protected]. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous, inaccurate or extremely impractical, if it jeopardizes the rights of others or if it is not required by law, but in those circumstances, we will still use best endeavours to respond to notify you of such a decision. In some cases, we may need you to provide us with additional information, which may include Personal Data, as necessary, to verify your identity and the nature of your request.
7.1.1 Where permissible, you can request more information about the Personal Data we hold about you and you can request a copy of your Personal Data. If you have an active account with us, you can also access your Personal Data by visiting your account settings on our website.
7.1.2 If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such Personal Data. You can also correct some of this Personal Data directly by visiting your account settings on our website.
7.1.3 Where permissible, you can request that we erase some or all of your Personal Data from our systems. You can also delete your account with us at any time by emailing us at [email protected].
7.1.3 If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent to this processing at any time, which you can do by emailing us at [email protected]. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data if such use or disclosure is necessary to enable you to utilise some or all of our Services.
7.1.3 Where permissible, you can let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as marketing to you (to name one example), and you can also ask us to restrict further processing of your Personal Data.
7.1.4 Where permissible, you can ask for a copy of your Personal Data in a machine-readable format, and you can also request that we transmit the data to another controller where technically feasible.
7.1.5 You have the right to lodge a complaint about our practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. Please visit http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm for more information.
7.1.6 We retain your Personal Data for as long as you have a working account with us, or as otherwise necessary to provide you with the Services. In some cases, we retain Personal Data for longer, if doing so is necessary to pursue our legitimate business interests (but only if those interests are not overridden by your own interests, rights and freedoms), comply with our legal obligations, resolve disputes or collect fees owed, conduct audits, or if doing so is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we dispose of your Personal Data securely, but may retain some information in a depersonalised or aggregated form but not in a way that would identify you personally.
As stated above, you can request us to erase some or all of your Personal Data from our systems, and you can delete your account with us at any time, by emailing us at [email protected].
We may update this policy from time to time. If we make significant changes we will let you know but please regularly check this policy to ensure you are aware of the most updated version.