Privacy policy

We act as the data controller for Data processed in connection with the collection of Users’ Data. The identity and contact details of the data controller are:

GD Aviation Solutions SAS

French corporation (société par actions simplifiée)

registered under number 913 025 227

registered office at 67 Cours Mirabeau, 13100 Aix En Provence

Email : info@airlineselectionprogramme.com

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

"Account": means collectively the personal data, payment Information and credentials used by Users to access Services and / or any communications System on the Web Site;

"Cookie": means a small text file placed on your computer by Airline Selection Programme when you visit certain parts of this Web Site. This allows us to identify recurring visitors and to analyse their browsing habits within the Web Site. The Cookie Policy is available here https://online.airlineselectionprogramme.com/cookies.

"Data": means collectively all information that you submit to the Web Site. This includes, but is not limited to Account details and information submitted using any of our Services or Systems;

"Airline Selection Programme": means Airline Selection Programme, ADDRESS;

"Service": means collectively any online facilities, tools, services or information that Airline Selection Programme makes available through the Web Site either now or in the future;

"System": means any online communications infrastructure that Airline Selection Programme makes available through the Web Site either now or in the future. This includes, but is not limited to, web-based email, message boards, live chat facilities and email links;

"User" / "Users": means any third party that accesses the Web Site and is not employed by Airline Selection Programme and acting in the course of their employment; and

"Website": means the website that you are currently using (online.airlineselectionprogramme.com) and any sub-domains of this site (e.g. subdomain.yourschool.com) unless expressly excluded by their own terms and conditions.

2. Data Collected

Without limitation, any of the following Data may be collected:

• 2.1 name;

• 2.2 date of birth;

• 2.3 job title & profession;

• 2.4 contact information such as email addresses and telephone numbers;

• 2.5 demographic information such as post code, preferences and interests;

• 2.6 financial information such as credit / debit card numbers;

• 2.7 IP address (automatically collected);

• 2.8 web browser type and version (automatically collected);

• 2.9 operating system (automatically collected);

• 2.10 a list of URLS starting with a referring site, your activity on this Web Site, and the site you exit to (automatically collected); and

• 2.11 Cookie information (see cookie policy).

3. Our Use of Data

• 3.1 Any personal Data you submit will be retained by Airline Selection Programme for as long as you use the Services and Systems provided on the Web Site. Data that you may submit through any communications System that we may provide may be retained for a longer period of up to three years from our last contact.

• 3.2 Unless we are obliged or permitted by law to do so, and subject to Clause 5, your Data will not be disclosed to third parties. This includes our affiliates and / or other companies within our group.

• 3.3 All personal Data is stored securely in accordance with the principles of the Data Protection Act 1998. For more details on security, see Clause 9 below.

• 3.4 Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Web Site. Specifically, Data may be used by us for the following reasons:

• 3.4.1 internal record keeping;

• 3.4.2 improvement of our products / services;

• 3.4.3 transmission by email of promotional materials that may be of interest to you;

• 3.4.4 contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Web Site.

4. Legal Basis

Airline Selection Programme processes Data about Users on the basis of our legitimate interest for purposes of providing our Services and improving our Services and the way we provide them.

Furthermore, we may also process Users’ Data in order to comply with the legal and regulatory requirements bearing on us, for instance to answer requests we may receive from judicial or administrative authorities.

Airline Selection Programme only collects Data that is appropriate, relevant and limited to what is necessary for the purposes for which they are processed.

5. Third Party Web Sites and Services

Airline Selection Programme may, from time to time, employ the services of other parties for dealing with matters that may include, but are not limited to, payment handling, delivery of purchased items, search engine facilities, advertising and marketing. The providers of such services do not have access to certain personal Data provided by Users of this Web Site. Any Data used by such parties is used only to the extent required by them to perform the services that Airline Selection Programme requests. Any use for other purposes is strictly prohibited. Furthermore, any Data that is processed by third parties must be processed within the terms of this Policy and in accordance with the Data Protection Act 1998.

Furthermore, collected and processed DATA may be sent to:

• authorised persons from the relevant departments within Airline Selection Programme,

• in the event of an offence or other breach of our general terms and conditions or the law, Data may be transferred to our insurance company and/or brokerage company, which is required to maintain the confidentiality of the Data sent and, where applicable, to the police and legal services.

• the administrative and judicial authorities, and more generally to public bodies in the context of compliance with our legal obligations or to allow us to defend our rights and interests,

• our legal advisers and lawyers, where necessary,

• if we sell or transfer our business or part thereof and the Data relate to the part sold or transferred, or if we merge with another business, we will share Data with the new business owner or our merger partner, respectively.

6. Your rights

Users are informed that they have, under the conditions of the Data Protection Act 1998 and the laws applicable in France, a right of access, rectification, erasure and portability of their Data, as well as a right of limitation, querying and objection to the processing of these Data.

The User may exercise his/her rights with Airline Selection Programme at no cost using the contact details provided above.

 The User therefore has the following rights:

• Right of access: the User shall have the right to obtain from us confirmation as to whether or not Data concerning him/her are being processed, and, where that is the case, access to the Data and information relating to the purposes of the processing. Manifestly unfounded, excessive or repeated requests may not receive a response,

• Right of rectification: the User shall have the right to obtain from us the rectification of inaccurate Data concerning him/her without undue delay,

• Right to erasure: the User shall have the right to obtain from us the erasure of Data concerning him/her,

• Right to portability: the User shall have the right to receive the Data concerning him/her, which he/she has provided to us, in a structured, commonly used and machine-readable format, and shall have the right to transmit those Data to a third party. This right applies only to Data provided, when the processing is based on consent or a contract and is carried out using automated processes,

• Right to restrict the processing: the User shall have the right to obtain from us a restriction of the processing of his/her Data,

• Right to withdraw consent: Users shall have the right to withdraw their consent to the processing of their Data if this processing is based on consent. The withdrawal of this consent does not affect the lawfulness of the processing based on the consent granted before its withdrawal,

• Right to object: the User shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of Data concerning him or her, which is based on legitimate interest,

• Right to determine the outcome of his/her Data in the event of death: the User shall have the right to define general or specific guidelines relating to the storage, erasure and communication of his/her Data after his/her death,

• Right to lodge a complaint with a supervisory authority: without prejudice to any other administrative or judicial remedy, the User shall have the right to lodge a complaint with a supervisory authority (the CNIL in France) if he/she considers that the processing of Data relating to him/her infringes the regulations applicable to Data.

7. Security

Data security is of great importance to Airline Selection Programme and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected online. Airline Selection Programme limits access thereto solely to those of the company's employees or service providers who need them in connection with the processing. All persons with access to Data are bound by a duty of confidentiality and are subject to sanctions if they do not comply with these obligations. When we use subcontractors, service providers or transfer Data to partners, this communication is covered by a contract to ensure the protection of this information.

8. Changes to this Policy

Airline Selection Programme reserves the right to change this Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Web Site and you are deemed to have accepted the terms of the Policy on your first use of the Web Site following the alterations.

9. Contacting Us

If there are any questions regarding this Policy, you may contact us at info@airlineselectionprogramme.com