ELMS Aviation Limited Privacy Policy

Introduction: This policy is designed to provide you with certain details about how We use your information when you visit the website www.elmsaviation.co.uk (the “Website”) or otherwise provide Us with (or We are provided with) information about you. If you are a user of the ELMS Solution, then please also read the ELMS Solution Data Use Statement found on the Website to understand how We use data on the ELMS Solution. Your continued use of the Website shall constitute acceptance of this policy.

Who we are: ELMS Aviation Limited (registered in England with company number 09436348 with its registered office at c/o Francis Clark LLP, North Quay House, Sutton Harbour, Plymouth, PL4 0RA) trading as ELMS Aviation (“We”, “Our”, “Us”). We have appointed a data protection officer who can be contacted in writing at ELMS Aviation Limited, Unit 1 Exeter International Office Park, Clyst Honiton, Devon, EX5 2HL or via email: dpo@elmsaviation.co.uk.

Information We may collect from you: We may collect and process the following data about you:

Information you give us. You may give us information about you by filling in forms on the Website or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to and/or use our services (including the ELMS Solution), search for a product, place an order on our site, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site. The information you give us may include (but shall not be limited to) your name, address, e-mail address and phone number, financial and credit card information, personal description, qualifications, career and work history and related documentation and photographs.

  • Information we collect about you. With regard to each of your visits to our site We may automatically collect the following information:
    • technical information, including the Internet protocol (“IP”) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
    • information about your visit, including the full Uniform Resource Locators (“URL”) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
  • Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or any of the services (including the ELMS Solution) we provide. We may also work closely with third parties (including, for example, regulatory bodies, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

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 the Website and also allows Us to improve the Website. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

How We use your personal data and the lawful bases for processing the same: We are obliged by data protection legislation to tell you how We use any personal data about you (including any special categories of personal data) that you give Us or We receive from others (the “Data”) and the lawful bases upon which We process such Data:
We use the Data as follows:

  • to carry out our obligations arising from any contracts entered into between you and Us and to provide you with the information, products and services that you request from us;
  • to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about and/or to provide you with information about goods or services we feel may interest you. We will ask before providing such information whether or not you are happy to consent to receiving such information and if you have consented, we shall contact you by email with information about such goods or services. If you do not want us to use your data in this way, then you do not need to tick the relevant box. If you do consent, but change your mind at a later date, then please contact us at info@elmsaviation.co.uk or follow the “unsubscribe” link on any email from us containing information about such goods or services;
  • to notify you about changes to our services;
  • to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to ensure that content from our site is presented in the most effective manner for you and for your computer;
  • to allow you to participate in interactive features of our service, when you choose to do so;
    as part of our efforts to keep our site safe and secure;
    to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
    if required by law.

Where Data is not categorised as special categories of personal data and/or data relating to criminal convictions or offences, We may rely on the following lawful bases to process your Data (and if one of these lawful bases ceases to exist, then We may seek to rely upon another):

  • you have given your consent to the processing; and/or
  • processing is necessary for compliance with a legal obligation; and/or
  • processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to you entering into a contract; and/or
  • We have a legitimate interest (which is not overridden by your fundamental rights and freedoms) in undertaking the processing which may include the administration and delivery of the Website, a contractual obligation to honour, the operation of the ELMS Solution and/or providing other services; and/or
  • We are processing in connection with the establishment, defence or exercise of legal claim (or taking advice on the same).

Where Data is categorised as special categories of personal data and/or data relating to criminal convictions or offences, We may rely on the following lawful bases to process your Data (and if one of these lawful bases ceases to exist, then We shall seek to rely upon another):

  • you have given your explicit consent to the processing; and/or
  • the processing is necessary in field of employment, social security or social protection law (and the appropriate safeguards are in place); and/or
  • processing relates to data manifestly made by public by you; and/or
  • processing is necessary in the substantial public interest (and the appropriate safeguards are in place); and/or
  • processing is necessary for the establishment, exercise or defence of legal claims (or taking advice on the same).

Who We may share your Data with: We may share your Data with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. We may share your information with selected third parties including:

  • If you are a user of the ELMS Solution: as set out in the Data Use Statement but also industry regulators (including the Civil Aviation Authority) or as required by law;
  • Analytics and search engine providers that assist us in the improvement and optimisation of our site;
  • Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you;
  • In order to enter into a contract or arrangement;
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or in order to enforce or any contract or agreement to which we are a party; or to protect the rights, property, or safety of ELMS Aviation Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Transferring Data outside of the EEA: Users of the ELMS Solution should refer to the Data Use Statement in connection with their data on the ELMS Solution and worldwide transfers. It is not envisaged that We shall process Data outside of the EEA, were We to do so, We would communicate this to you.

Your rights: please see Appendix A for details of the rights you have in connection with your Data.
Data Retention:
– Users of the ELMS Solution should refer to the Data Use Statement in connection with their data on the ELMS Solution and retention periods.
– Where we have a contract with you We will generally keep Data for 7 years after that contract concluded (unless we need to keep it longer, for example where there is a claim).
– Certain technical information will only be retained for as long as you permit it, and this can be deleted by clearing your browsing history.
– Otherwise We will generally only keep Data for as long as it is relevant for Us to keep it.
Notwithstanding any of the above, where We believe there is a good reason (for example in connection with a legal claim, investigation or dispute) for Us to keep any Data and/or data on the ELMS Solution for any longer than specified, We shall do so and the period that We retain this shall be determined by the nature of the reason We are keeping it.

Automated Decision Making: this is not envisaged.

Other websites: The Website may, from time to time, contain links to and from the websites of our partner networks, advertisers 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.

Changes: Any changes we may 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. This is Version May.18.
Appendix A
Please contact the data protection officer if you wish to exercise any of these rights (dpo@elmsaviation.co.uk) Some rights are only exercisable in certain circumstances and for some rights processing may be necessary for a particular reason (meaning the right cannot be exercised).

  • The right of access.
    • The right to obtain confirmation from the controller of whether or not Data is being processed and, where Data is being processed, the following information: the purpose of the processing; the categories of Data concerned; the recipients to whom the Data has been or will be disclosed (in particular recipients in third countries or international organisations); where possible the envisaged period for which the Data will be stored, or, if not possible, the criteria used to determine that period; the existence of the right to request from the controller rectification or erasure of Data or restriction of processing of Data or to object to such processing; the right to lodge a complaint with the supervisory authority; where Data is not collected from you, any available information about the source; and the existence (if any) of automated decision making, including profiling and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.
    • Where Data are transferred to a third country or international organisation, you have the right to be informed of the appropriate safeguards (if any) pursuant to Article 46 of the GDPR relating to the transfer.
    • The right if requested to be provided with a copy of the Data being processed by the controller (for any further copies, a reasonable fee based on administrative costs may be requested). Where the request is made by electronic means, the Data shall unless otherwise requested be provided to by electronic means.
  • The right to rectification.
    • The right to obtain from the controller without undue delay, the rectification of inaccurate Data, which may include (depending on the purposes of the processing) the right to have incomplete Data completed (including by means of a supplementary statement).
  • The right to erasure.
    • Where any of the following apply, you have the right to obtain from the controller the right to erasure of Data without undue delay and the controller shall have the obligation to erase Data without undue delay where:
      • the Data are no longer necessary for the purposes for which they are collected or otherwise processed (please refer to the earlier sections for details of the purposes for which Data is collected and the duration it is retained);
      • you withdraw consent where this has been given as a ground for processing and no other legal ground for processing exists;
      • you object to processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing under Article 21(2) of the GDPR;
      • The Data have been unlawfully processed;
      • The Data have to be erased for compliance with a legal obligation to which the controller is subject;
      • The Data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
  • The right to erasure shall not apply to the extent that any processing is necessary:
    • For the exercising of freedom of expression and information;
    • For compliance with a legal obligation which requires us to process the Data or there is task that we need to carry out in the public interest or in the exercise of official authority;
    • The Data requires processing in the area of public health for reasons of public interest;
    • For archiving reasons in the public interest, scientific or historical research purposes or for statistical purposes in accordance with Article 89(1) in so far as the exercise of the right to erasure will render impossible or seriously impair the achievement of the objectives of that processing; or
    • For the establishment, exercise or defence of legal claims.
  • The right to restriction of processing.
    • You may request the restriction of processing by the controller when one of the following applies:
      • The accuracy of the Data is contested by you, so processing is restricted for a period to enable the controller to verify the accuracy of the Data;
      • The processing is unlawful and you oppose the erasure of the Data and instead request restricted use;
      • The controller no longer require the Data for its purposes, but they are required by you for the establishment, exercise or defence of a legal claim;
      • You have objected to processing pursuant to Article 21(1) pending the verification of whether the legitimate grounds of the controller override those of you.
  • The right to data portability.
    • You have the right to receive your Data in a structured and commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance where:
      • The processing is based on point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR or in a contract pursuant to point (b) of Article 6(1) of the GDPR; and
      • The processing is carried out by automated means.
    • If technically feasible You shall have the right to have this Data transmitted from one controller to another controller.
  • The right to object.
    • You have the right to object, on grounds relating to your situation, at any time to the processing of your Data which is based on point (e) or point (f) of Article 6 (1) of the GDPR, including profiling based on these provisions.
    • Where Your Data is used for direct marketing purposes, you have the right to object to any processing of your Data for such marketing, which includes profiling to the extent its related to such direct marketing.
  • The right not to be subject to a decision based solely on automated processing.
    • You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
    • If the decision is necessary for the entering into a contract between you and the controller, is authorised in law, or is based on your explicit consent then this right shall not apply.
  • The right to withdraw consent.
    • Where any processing is based on point (a) of Article 6 of the GDPR or point (a) of Article 9(2) of the GDPR, then you may withdraw consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal.
    • The right to lodge a complaint to a supervisory authority (this should lodged with the supervisory authority, the Information Commissioner’s Office). Contact details for the Information Commissioner’s Office can be found at https://ico.org.uk/concerns/.

 

ELMS/GDPR/DOC2
(Version May.18)

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