Privacy & Cookies Policy

1. INTRODUCTION

We are Affinity Aviation Group Ltd company number 09300323 and whose registered office is at 2nd Floor, Berkeley Square House, Berkeley Square, London, W1J 6BD and Fly Affinity Ltd company number 13874011 and whose registered office is at 85 Great Portland Street, London, W1W 7LT (“Company”) and these terms apply to both our company and Website “Affinity-Aviation.com”.

1.1 In this policy, “Company”,”We", "Us" and "Our'' refers to Affinity Aviation Group Ltd and Fly Affinity Ltd Our Website Visitors and Members - “Members”, “You”,”Your” and “Yours”

1.2 As a Company We are committed to safeguarding the privacy of Our Website Visitors, and Members Users.

1.3 This policy applies where We are acting as a data controller with respect to the personal data of such persons; (which includes any natural persons, companies, sole traders partnerships and the like) in other words, where We determine the purposes and means of the processing of that personal data.

1.4 Our Website Services incorporates privacy controls which affect how We will process Your personal data. This document highlights how to use Our privacy controls, so that You are able to specify whether You would like to receive direct marketing communications, learn how to modify cookies and clear Your data.

1.5 We use cookies on our Website. Insofar as those cookies are not strictly necessary for the provision of Our Website and data platform, We will ask you to consent to our use of cookies when You first visit our Website.

1.6 We capitalise certain words to indicate their importance, definition and standing.

2. THE PERSONAL DATA THAT WE COLLECT

2.1 In this Section 2 We have set out the general categories of personal data that We process and in the case of personal data that We did not obtain directly from You, information about the source and specific categories of that data.

2.2 We may process data enabling Us to get in touch with You ("contact data"). The contact data may include Your name, email address, telephone number and postal address. The source of the contact data is obtained through You, if You log into our Website and You make a request for Our   Services as a Member or You contact Us directly with travel instructions. You will be asked for this personal information, this information will be necessary for Us to carry out Our services.

2.3 We may process data to manage Your Membership account with Us ("account data"). The account data may include Your account identifier, name, email address, name, account creation, website settings, marketing preferences, payment, travel documents and any other options. The primary source of the account data is You, although some elements of the account data may be generated by Our Website.

2.4 We may process the information You provide in Your personal account profile on Our Website or through your Membership application ("profile data"). The profile data may include Your name, location, telephone number, email address, company name and/or logo, gender, age, details and other such relevant details as travel documents and preferences.

2.5 We may process information relating to Our relationships (“relationship management data"). The relationship data may include Your name, the name of Your company Your contact details, within Our website and in-house relationship management system information contained in or relating to communications between Us and You.

2.6 We may process Your personal data that is provided in the course of the use of Our Services and generated by Our Services in the course of such (service data). The service data may include information about Your profile data, account data, relationship data, information about the interaction with Our Membership Services and Website features.

2.7 We may process information relating to transactions, including purchases through Our Membership Services, that You enter with Us and/or through directly or through Our Website ("transaction data"). The transaction data may include Your name, Your contact details, Your payment card details or other payment details and the transaction details. The source of the transaction data is You and/or Our payment services provider.

2.8 We may process information contained in or relating to any communication that You send to Us or that We send to You ("communication data"). The communication data may include the communication content and metadata associated with the communication.  Our Website will generate the metadata associated with communications made using the Website contact forms or any chat service.

2.9 We may process data about Your use of Our Website and Membership Services supplied ("usage data"). The usage data may include Your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of Your Service use. The source of the usage data is Google Analytics.

2.10 If any of Your data is considered Special Category Data, You expressly give Your permission for its collection and use as agreed under these terms.

2.11 We may share your Personal Data and any Special Category Data with third parties to allow them to provide the agreed Membership services, You expressly give you permission for this.

2.12 Please do not supply any other person's personal data to Us, the data You supply must only be your own.

3. PURPOSES OF PROCESSING AND LEGAL BASIS

3.1 In this Section 3, We have set out the purposes for which We may process personal data and the legal bases of the processing.

3.2 Operations - We may process Your personal data for the purposes of operating Our Website, the processing and fulfilment of Membership Services, providing additional Services, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is the performance of a contract between You and Us and/or taking steps, at Your request, to enter into such a contract.

3.3 Relationships and communications - We may process contact data, account data, relationship data, transaction data and/or communication data for the purposes of managing Our relationships, communicating with You (excluding communicating for the purposes of direct marketing from Us only) by email, SMS, web chat and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with Our Website visitors and Membership Service Users and the maintenance of Our relationships, enabling the use of Our Membership Services, and the proper administration of Our Website, membership Services and business.

3.4 Personalisation - We may process account data, service data and/or usage data for the purposes of personalising the content that You see on Our Website and through Our Membership Services to ensure that You only see material that is relevant to You. The legal basis for this processing is the performance of a contract between You and Us and/or taking steps, at Your request, to enter into such a contract.

3.5 Direct marketing - We may process contact data, account data, profile data, customer relationship data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS and/or web chat and making contact by telephone for marketing-related purposes. The legal basis for this processing is promoting Our business and communicating marketing messages and offers to Our Website visitors, and Membership users You may opt out of this service at any time by contacting Us at sales@affinity-aviation.com.

3.6 Research and analysis - We may process usage data, service data and/or transaction data for the purposes of researching and analysing the use of Our Website and Membership Services, as well as researching and analysing other interactions with Our business. The legal basis for this processing is Our legitimate interests, namely monitoring, supporting, improving and securing Our Website, Membership Services and business generally. This data is anonymised.

3.7 Record keeping - We may process Your personal data for the purposes of creating and maintaining Our databases, back-up copies of Our databases and Our business records generally. The legal basis for this processing is Our legitimate interests, namely ensuring that We have access to all the information We need to properly and efficiently run Our business in accordance with this policy.

3.8 Security - We may process Your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of Our Website, Membership Services and business, and the protection of others.

3.9 Insurance and risk management - We may process Your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is Our legitimate interests, namely the proper protection of Our business against risks.

3.10 Legal claims - We may process Your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is Our legitimate interests, namely the protection and assertion of Our legal rights, Your legal rights and the legal rights of others.

3.11 Legal compliance and vital interests - We may also process Your personal data where such processing is necessary for compliance with a legal obligation to which We are subject or in order to protect Your vital interests or the vital interests of another natural person.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register You as a new Membership user,

(a) Identity
(b) Contact
Performance of a contract with You
To process Your account details including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to Us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(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 and agree to our modes of communication with You
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(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 and complete a survey (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(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  Membership Services and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical
(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 other information to You and measure or understand the effectiveness of the content We serve to You (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for Our legitimate interests (to study how customer, buyers and/or vendors 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 and membership Services, marketing, customer relationships and experiences (a) Technical
(b) Usage
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  You of Our marketing strategy)
To make suggestions and recommendations to You about Membership services that may be of interest to You (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for Our legitimate interests (to develop our Products/Services and grow Our business)

4. AUTOMATED DECISION MAKING

4.1 We may use Your personal data for the purposes of automated decision-making in relation to sending You follow-up correspondence, creating new services and providing you with content that You may find interesting, in line with Our Membership Service.

4.2 This automated decision-making will involve automated process flows that trigger interactions following engagement with Our Website, Web Chat, articles, social media or Membership Services.

4.3 The significance and possible consequences of this automated decision-making are that You may from time to time receive information that You do not find useful or relevant to You. If this is the case you can either immediately delete, close or opt out of further messages by using Our opt out steps as mentioned in section 1.3.

5. PROVIDING YOUR PERSONAL DATA TO OTHERS

5.1 We may disclose Your personal data to Our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.

5.2 Your personal data held in Our database or platform will be stored on the servers of our hosting services.

5.3 Financial transactions relating to Our Website and Membership Services are handled by Our payment services providers. We will share transaction data with Our payment services providers and retain credit card information, only to the extent necessary for the purposes of processing Your payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at www.gocardless.com

5.4 We may disclose contact data along with any other personal data contained in enquiries made through Our Website or Membership services to one or more of those selected third party suppliers of Products and/or Membership Services identified on Our Website for the purpose of enabling them to contact You so that they can offer, market and sell to You relevant Products and/or Services. Each such third party will act as a data controller in relation to the personal data that We supply to it; and upon contacting You, each such third party will supply to You a copy of its own privacy policy, which will govern that third party's use of Your personal data. You can opt out of this service at any time by contacting Us on sales@affinity-aviation.com.

5.5 In addition to the specific disclosures of personal data set out in this Section 5, We may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which We are subject, or in order to protect Your vital interests or the vital interests of another natural person. We may also disclose Your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

6. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

6.1 In this Section 6, We provide information about the circumstances in which Your personal data may be transferred to a third country under UK and/or EU data protection law.

6.2 We may transfer Your personal data to the European Economic Area (EEA) from the UK and process that personal data in the EU for the purposes set out in this policy, and may permit Our suppliers and subcontractors to do so, during any period with respect to which the EU is not treated as a third country under UK data protection law or benefits from an adequacy decision under UK data protection law; and We may transfer Your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this Policy, and may permit Our suppliers and subcontractors to do so, during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.

6.3 The hosting facilities for Our website are situated in the UK only and our website hosting facilities are situated in UK. The competent data protection authorities have made an adequacy determination with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities.

7. RETAINING AND DELETING PERSONAL DATA

7.1 This Section 7 sets out Our data retention policies and procedures, which are designed to help ensure that We comply with our legal obligations in relation to the retention and deletion of personal data.

7.2 Personal data that We process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

7.3 Notwithstanding the other provisions of this Section 7, We may retain Your personal data where such retention is necessary for compliance with a legal obligation to which We are subject, or in order to protect Your vital interests or the vital interests of another natural person. This may entail Your data being retained for longer period.

8. SECURITY OF PERSONAL DATA

8.1 We will take appropriate technical and organisational precautions to secure Your personal data and to prevent the loss, misuse, or alteration of Your personal data.

8.2 We will store Your personal data on secure servers, personal computers, mobile devices, and in secure manual record-keeping systems.

8.3 Data relating to Your enquiries and financial transactions that is sent from Your web browser to Our web server, or from Our web server to Your web browser, will be protected using encryption technology.

8.4 You acknowledge that the transmission of unencrypted or inadequately encrypted data over the internet is inherently insecure, and We cannot guarantee the security of data sent over the internet.

8.5 You should ensure that Your password and any login and/or Membership details is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password You use for accessing Our website and/or your membership Account confidential and We will not ask you for Your password (except when you log in to Our Website or your Membership Account).

9. YOUR RIGHTS

9.1 In this Section 9, We have summarised the rights that You have under data protection law. Further information can be found at https://ico.org.uk/.

9.2 Your principal rights under data protection law are:
(a) the right to access - You can ask for copies of Your personal data;
(b) the right to rectification - You can ask Us to rectify inaccurate personal data and to complete or incomplete personal data;
(c) the right to erasure - You can ask Us to erase Your personal data;
(d) the right to restrict processing - You can ask uU to restrict the processing of Your personal data;
(e) the right to object to processing - You can object to the processing of Your personal data;
(f) the right to data portability - You can ask that We transfer Your personal data to another organisation or to You;
(g) the right to complain to a supervisory authority - You can complain about Our processing of Your personal data; and
(h) the right to withdraw consent - to the extent that the legal basis of Our processing of Your personal data is consent, You can withdraw that consent.

9.3 You have the right to confirm as to whether or not We process Your personal data and, where We do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, We will supply to You with a copy of Your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access Your personal data by logging in to Your account.

9.4 You have the right to have any inaccurate personal data about You rectified and, considering the purposes of the processing, to have any incomplete personal data about You completed.

9.5 In some circumstances You have the right to the erasure of Your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; You withdraw consent to consent-based processing; You object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

9.6 In some circumstances You have the right to restrict the processing of Your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but You oppose erasure; We no longer need the personal data for the purposes of Our processing, but You require personal data for the establishment, exercise or defence of legal claims; and You have objected to processing, pending the verification of Your objection. Where processing has been restricted on this basis, We may continue to store Your personal data. However, We will only otherwise process it: with Your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

9.7 You have the right to object to Our processing of Your personal data on grounds relating to Your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in Us; or the purposes of the legitimate interests pursued by Us or by a third party. If You make such an objection, We will cease to process the personal data unless We can demonstrate compelling legitimate grounds for the processing which override Your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

9.8 You have the right to object to Our processing of Your personal data for direct marketing purposes (including profiling for direct marketing purposes). If You make such an objection, We will cease to process Your personal data for this purpose.

9.9 You have the right to object to Our processing of Your personal data for scientific or historical research purposes or statistical purposes on grounds relating to Your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

9.10 To the extent that the legal basis for Our processing of Your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which You are party or in order to take steps at Your request prior to entering into a contract, and such processing is carried out by automated means, You have the right to receive Your personal data from Us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

9.11 If you consider that Our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. In relation to complaints under EU data protection law, you may do so in the EU member state of your habitual residence, Your place of work or the place of the alleged infringement; in relation to complaints under UK data protection law, You should do so in the UK.

9.12 To the extent that the legal basis for Our processing of Your personal data is consent, You have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

9.13 You may exercise any of Your rights in relation to Your personal data by emailing sales@affinity-aviation.com in addition to the other methods specified in this Section 9.

10. THIRD PARTY WEBSITES

10.1 Our Website may include links too and details of third party websites such as payment providers.

10.2 We are not liable and are not responsible for, the privacy policies and practices of third parties. You should ensure You read these for Yourself.

11. PERSONAL DATA OF CHILDREN

11.1 Our Website and Membership Services are targeted at persons over the age of 18.

11.2 If We have reason to believe that We hold personal data of a person under that age in our databases, We will delete that personal data.

12. UPDATING INFORMATION

12.1 Please let Us know if the personal information that We hold about You needs to be corrected or updated.

13. ABOUT OUR COOKIES

13.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

13.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

13.3 Cookies may not contain any information that personally identifies a user, but personal data that We store about You may be linked to the information stored in and obtained from cookies.

14. COOKIES THAT WE AND OUR SERVICES PROVIDER USE

14.1 We and Our service providers use cookies and those cookies may be stored on Your computer when You visit our website.

14.2 We use Google Analytics. Google Analytics gathers information about the use of Our Website by means of cookies. The information gathered is used to create reports about the use of Our website. You can find out more about Google's use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google's privacy policy at https://policies.google.com/privacy.

15. MANAGING COOKIES

15.1 Most browsers allow You to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647 (Chrome);

(b) https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox);

(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and

(f) https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy (Edge).

15.2 Blocking all cookies will have a negative impact upon the usability of many websites.

15.3 If You block cookies, You will not be able to use all the features or some membership services on Our website.

16. AMENDMENTS

16.1 We may update this policy from time to time by publishing a new version on Our Website. Or when you contact us you may ask for a copy.

16.2 You should check this page occasionally to ensure You are happy with any changes to this policy.

16.3 We may notify You of any significant changes to this policy by email.

17. OUR DETAILS

17.1 This website is owned and operated by Affinity Aviation Group Ltd.

17.2 We are a company registered in the United Kingdom Company number 09300323 and whose registered office is at 2nd Floor, Berkeley Square House, Berkeley Square, London, W1J 6BD.

18.You can contact Us:

(a) using Our Website contact form
(b) using Our website live chat, if available;
(c) by telephone if this has been provided
(d) by email, using the email address published on Our Website on in this document.

last updated 20-04-2022