Welcome to the Hunt & Palmer Plc privacy notice for Aircraft Chartering Services.
We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data which you may share with us in order to use or goods and services or which we may collect through other legitimate means, such as your use of our websites (regardless of where you may visit from) or by making an enquiry of us. We will also tell you about your privacy rights in this respect and how the law protects you.
1.IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how we collect and process your personal data which we collect through your contact with us, including any data you may provide during the course of our relationship with you as a client or potential client. The data may be collected by your use of our website(s), through direct contact with our employees or authorised agents through telephone, email or social media or through any other legitimate means not specifically identified here.
This notice applies to you whether you use our services on a regular or ad hoc basis and should be read in conjunction with our Terms and Conditions, regardless of whether you book with us directly or through a third party (such as through an agent, an event organiser or someone acting on your behalf).
Our website(s) are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice 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 notice supplements the other notices and is not intended to override them.
Hunt & Palmer Plc is the controller and responsible for your personal data (collectively referred to as” Hunt & Palmer”, “we”, “us” or “our” in this privacy notice).
Hunt & Palmer Plc is the parent company of the Hunt & Palmer Group of companies, which is made up of different legal entities, details of which are available upon request. This privacy notice is issued on behalf of the Group so when we mention” Hunt & Palmer”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Hunt & Palmer Group responsible for processing your data.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Company Secretary using the details set out below.
For any questions or concerns you may have about this Privacy Statement or any issue regarding our use of your personal data, please do contact us.
Our full details are:
Full name of legal entity: Hunt & Palmer Plc
Name or title of data contact: The Company Secretary
Email address: [email protected]
Postal address: The Tower, Goffs Park Road, Crawley, West Sussex RH11 8XX
Telephone number: 01293 558000
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
YOUR DUTY TO INFORM US OF CHANGES
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.
Our website(s) may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. THE DATA WE COLLECT ABOUT 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 (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, passport photo and number, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Travel Data includes information about your travel arrangements including your itinerary, any special assistance you may require, or others travelling with you may require, any hotel information in connection with your travel itinerary, details of any visa(s) granted for entry/travel to a give country or countries as required
Medical Data includes details about any medical conditions that may be relevant to your proposed journey, and/or your ability to travel between countries.
Financial Data includes bank account and payment card details.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website(s).
Usage Data includes information about how you use our website(s), products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such 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. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 notice.
We may collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). For example, we may need to collect the Medical Data as set out above. By providing us with such Medical Data you specifically consent to us collecting, using and passing such data on to third parties to allow us to provide our services to you.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you or a third party 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 goods or 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. If we have to do this, you may be liable for any cancellation fees and/or administration charges that may be levied as a result.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, Travel, Medical or Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
ask for a quote for our services;
place an order for our services directly or through a third party;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you;
provide us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
Third parties sources. We may receive personal data about you from various third parties.
Biometric data. You should be aware that in some airports facial recognition and biometric technology is used to facilitate passenger boarding.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
In our industry, we anticipate that there are numerous circumstances where we will process your personal data. These include:
Arranging and fulfilling the flight(s) or other travel services that we are providing for you.
Passing your personal data to relevant authorities (e.g. immigration control and border and customs authorities) to allow us to assist you with your travel itinerary.
Carrying out due diligence by us on you so as to protect our rights, interests and safety, and the interests, rights and safety of our other customers or suppliers.
Checking that you or any passenger flying with you is not the subject of any economic or trade sanction or travel ban.
For internal administration and our record keeping so we are able to track and monitor your use of our services.
Using your personal data to contact you about our services, including requesting feedback, so as to help us to make any necessary improvements to our customer experience.
Your personal data will be stored and processed by us on our systems and may also be processed by a third party processor appointed by us.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
You will receive marketing communications from us if you have requested information from us or obtained services from us and, in each case, you have not opted out of receiving that marketing.
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.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below.
Internal Third Parties including other companies in the Hunt & Palmer Group.
External Third Parties which might include:
Air operators or carriers used to help us to fulfil our contract with you.
Customs and immigration authorities.
Agents or brokers involved in helping us to fulfil your travel arrangements.
Third parties that provide travel assistance such as companies providing taxi or transportation services, ground handling, catering, fuel.
Professional advisers used by us.
HMRC, regulators and other authorities.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy
6. INTERNATIONAL TRANSFERS
By virtue of the nature of our business, and the global nature of our Group structure, we may transfer data to Internal and External Third Parties both within and outside the European Economic Area (EEA). Your data may also be processed by employees based within or outside the EEA who work for us or one of our suppliers or data processors. If we transfer your data outside the EEA we aim to ensure your personal data is processed securely in accordance with the relevant legislation in the country in question.
7. DATA SECURITY
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, 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.
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.
8. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to the processing of your personal data. where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.