Starflight Aviation Limited & its affiliates

Privacy Policy

Starflight Aviation Limited & its affiliates(“we", “us”, “our”, “the Group”) is committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, when you engage with our services, visit our website or otherwise contact us, will be processed by us.

It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and notices and is not intended to override them.

For the purposes of the Data Protection Act 1998 and, when it comes into force, the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) and all successor legislation to the Data Protection Act 1998 and the GDPR (the “Data Protection Legislation”),the data controller is Starflight Aviation Limited (company no. 02394668 of Business Aviation Centre, Farnborough Airport, Farnborough, Hampshire, GU14 6XA). We can be contacted by letter to that address or by e-mail to GDPR@flystarflight.com(these contact details being, collectively, the “Contact Details”).

  1. Information we collect from 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 (known as “anonymous data”).

We may collect, use, store and transfer the following data about you:

We may also collect, use and share aggregated datasuch 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. 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 policy.

From time to time we may collect special categories of personal dataabout you directly in relation to your health and might also collect data in the categories identified above from which it is possible to infer information about your race, ethnicity or religious beliefs. We will only process this data as is necessary for reasons of substantial public interest (the collection of identity information in relation to your movement between countries), where necessary in the public interest in connection with public health (identification and prevention of the spread of cross-border health hazards) and/or where you have given your specific consent to the processing. We will not otherwise process any special categories of personal data about you (this includes details about your philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data).

We do not expect to need to collect any information about criminal convictions and offences. If we are obliged to do so at any time, we shall only process such data to the minimum extent and for the minimum duration necessary, and as authorised by law providing such safeguards for your rights and freedoms as may be required.

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 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.

  1. Uses made of your information

We will only use your personal data when the law allows us to. Most commonly, we will use your personal information

Generally we do not rely on consent as a legal basis for processing your personal information other than in relation to sending third party direct marketing communications to you via email.

  1. 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 below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

Identity and contact details

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges;

(b) Collect and recover money owed to us

Identity, contact details and financial and credit card information

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy;

(b) Asking you to leave a review or take a survey

Identity, contact details, and marketing preferences

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

Identity, contact details and marketing preferences

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Identity, contact details and technical data such as IP address

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Identity, contact details, technical data such as IP address, marketing preferences

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Technical data such as IP address

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

Identity, contact details, usage data and marketing preferences

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your identity, contact details, usage data, technical data and marketing preferences 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.

You may receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any company outside the Starflight Aviation Limitedgroup for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will only apply to the processing of your personal datain connection with such communications, and will not impact on the provision of our other services, the performance of our contract with you or for your benefit, or our compliance with any legal obligation to which we are subject.

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.

  1. Disclosure of your information

We may have to share your personal information with the third parties set out below, or any other third parties notified to you, for the purposes set out in paragraph 3 above:

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.

  1. International transfers

Many 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:

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

  1. 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.

However, the transmission of information via the internet is never completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.

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.

  1. Retention

We will only retain your personal information for as long as is necessary to carry out the purpose for which it was collected, 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 have adopted a data handling and retention policy which can be made available to you on request via the Contact Details.

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.

  1. Your rights

Under the Data Protection Legislation you may be entitled to the following rights:

You can exercise any of the above rights at any time by contacting us using the Contact Details.

  1. Links to and from our site

Our site may, from time to time, contain links to and from the websites of our partners 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.

  1. Changes to your personal data

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.

  1. Changes to our privacy policy

Any changes we make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy.

  1. 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. Our cookie policy can be viewed by visiting our website.

  1. Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to us, by post or e-mail, using the Contact Details.

If you have any complaints relating to our privacy policy or our use of your personal data, please contact us at Business Aviation Centre, Farnborough Airport, Farnborough, Hampshire, GU14 6XA or by email to GDPR@flystarflight.com (the “Contact Details”). You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. Further information can be found at www.ico.org.uk.