Effective from: June 2018
Next review due: June 2019
2. Identity of the Data Controller
3. Information we collect, use, disclose and why
4. Website Visitors
4.1 Cookies 4.2 Links to other websites
5. Duration of information held
6. Security of information
6.1 Disclosing information to other parties
6.2 Transfers to third countries and the safeguards in place
7. Your rights and how to exercise them
7.1 Access to personal data
7.2 Amendment of personal data
7.3 Withdrawal of consent 7.4 Right to object
9. Changes to this Privacy Notice
9.1 Revision History
1. Scope This policy applies to:
❖ The head office of Air Link Systems Ltd.
❖ All clients, customers and suppliers of ALS.
ALS is committed to safeguarding the privacy of your information in accordance with the principles below.
❖ We will only collect and use your information where we have lawful grounds and legitimate business reasons to do so.
❖ We will be transparent in our dealings with you and will tell you about how we will collect and use your information.
❖ If we have collected your information for a particular purpose, we will not use it for anything else unless you have been informed and where relevant your permission obtained.
❖ We will not ask for more information than we need for the purposes for which we are collecting it.
❖ We will update our records when you inform us that your details have changed.
❖ We will implement and adhere to information retention policies relating to your information and will ensure that your information is securely disposed of at the end of the appropriate retention period.
❖ We will observe the rights granted to you under applicable privacy and data protection laws and will ensure that queries relating to privacy issues are promptly and transparently dealt with.
❖ We will train our staff on their privacy obligations.
❖ We will ensure we have appropriate physical and technological security measures to protect your information regardless of where it is held.
❖ We will ensure that when we outsource any processes we ensure the supplier has appropriate security measures in place.
❖ We will ensure that suitable safeguards are in place before personal information is transferred to other countries.
2. Identity of the Data Controller Air Link Systems Ltd (ALS) is the Data Controller and is committed to protecting the rights of individuals in line with the new General Data Protection Regulation (GDPR). 3. What information do we collect, use, disclose and why We collect only the personal information we need. This may include: ❖ Your address, phone number, email address or any other contact information ❖ Any relevant information related to feedback you have provided ❖ Any other information related to our business practices. We will always inform you, before or at the time of collecting personal information, of the purposes for which we are collecting the information. The information that we collect and store relating to you is primarily used to enable us to provide our services to you, and to meet our contractual commitments to you. In addition, we may use the information for the following purposes: • To notify you about any changes to our website, such as improvements or service/product changes, that may affect our service;
• If you are an existing customer, we may contact you with information about goods and services similar to those that were the subject of a previous sale or service to you. If you do not want your personal information collected, please let us know. If you have submitted personal information and wish to withdraw your consent to its retention, use or disclosure, please contact us (email@example.com). 4. Website Visitors If you are a visitor to our website only, and do not work on behalf of ALS, then this section is relevant for you. By visiting our website, you consent to the collection and use of your personal data as described herein. If you do not agree with the terms set out herein, please do not visit our website.
4.1 Cookies A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website. 4.2 Links to other websites Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy notice. You should exercise caution and look at the privacy notice applicable to the website in question.
5. How long will your information be held? ALS will keep your personal data only as long as is necessary for the purpose(s) We will retain your information for a maximum time period of 10 years.
6. Security of your information We have security policies and procedures in place to protect information. We make every reasonable effort to prevent any loss, misuse or disclosure or modification of personal information as well as any un-authorised access to personal information. Only authorised ALS employees, and authorized employees of our third-party service providers’ processing data on our behalf, have access to your personal data. All ALS employees who have access to your personal data are required to adhere to the ALS Privacy Notice and all third-party service providers are requested by ALS to ensure that any of their employees who have access to your personal data have signed non-disclosure agreements. In addition, contracts are in place with such third-party service providers acting as data processors for ALS that have access to your personal data, to ensure that the level of security required in your jurisdiction is in place, and that your personal data is processed only as instructed by ALS. 6.1 Disclosing information to other parties We will not disclose personal information unnecessarily to employees or any third party without your consent. 6.2 Transfers to third countries and the safeguards in place Your personal information will only be transferred to countries, outside of the EU, whose data protection laws have been assessed as adequate by the European Commission, or where adequate safeguards, such as EU-US Privacy Shield, are in place. 7. Your rights and how to exercise them Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights. Where we decide how and why personal data is processed, we are a data controller and include further information about the rights that individuals have and how to exercise them below. 7.1 Access to personal data You have the right to access information held about you by us. Please write to us or contact us by email if you wish to request confirmation of what personal information we hold relating to you. You can email us at firstname.lastname@example.org. There is no charge for requesting that we provide you with details of the personal data that we hold. We will provide this information within one month of your requesting the data. In addition to the care that ALS takes directly, we also work with all of our partner organisations that may at some point handle any personal information we have gathered. Every third-party partner and distributor has agreed to meet our standards or privacy, confidentiality and security. All employees and third-party staff who in any way handle or manage personal information have acknowledged and adhere to our privacy code and the procedures that support it. 7.2 Amendment of personal data We rely on you to let us know if there is a change to your personal information that may affect your relationship with us. If you believe that any information we are holding on you is incorrect or incomplete, please email us as soon as possible (email@example.com) and we will promptly correct any information found to be incorrect. 7.3 Withdrawal of consent Where you have given your consent for us to use your personal data, you may withdraw your consent at any time. To withdraw consent to our processing of your personal data please email us at firstname.lastname@example.org.
ALS Privacy Notice for Clients, Customers and Suppliers – June 2018
Uncontrolled if printed
Effective from: June 2018, Next review due: June 2019, Version: 1.0