PRIVACY AND INFORMATION POLICY FOR THE PROCESSING OF PERSONAL DATA OF WEBSITE VISITORS
1. About us
The société anonyme under the corporate name “JETSTREAM AVIATION TRAINING AND SERVICES SOCIETE ANONYME” and with the distinctive title “JETSTREAM”, with registered seat in Spata, Attica, 198, Vasileos Pavlou Str., VAT registration number: 998102260 (Athens Tax Office for Commercial Companies), and contact number: 2106025700, has been successfully active in pilot and cabin crew trainingfor many years as an approved training organization by the Hellenic Civil Aviation Authority. In the framework of the provision of its services, our company comes in direct contact with a large number of trainees as well as airlines from all over the world that wish to train their staff, focusing on each customer’s satisfaction and offering the greatest possible contribution to the completion of training and success in examinations. With the same commitment and a particularly high sense of responsibility, JETSTREAM wishes to provide you with all the necessary information in accordance with the General Data Protection Regulation (EU) 2016/679 and urges you to dedicate some of your time to read the following information regarding the processing your personal data when navigating the company’s site (www.jetstream.gr).
2. Definition of personal data and processing
‘Personal data’ means any information that can, directly or indirectly, identify an alive natural person, in particular by reference to an identifier such as name-surname, mail address, contact information (telephone, mobile phone), email etc.
‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of personal data that are known or will become known to the Company, either directly by you through the website or within the context of your business relationships with the company.
3. What personal data do we collect from our website and how do we use it?
JETSTREAM informs the website visitors who wish to navigate, learners or interested parties who fill out form to contact us, the Company's associates who use the website, and any other visitor, that, through its website www.jetstream.gr, collects information about all of you, if and only you provide it, which are necessary for the fulfillment of your requests and website navigation. In more detail, the Company collects and processes the following minimum personal data for the following purposes:
- gender (Mr. / Mrs.), name, surname, address, postal code, city, country, telephone, fax, mobile phone, email, message, when you enter and provide them through a contact form and more specifically in the “Contact Us” field in order to contact us for a request / complaint / question / other issue.
- Your IP addresswhenever and wherever you browse our website, for protection against online fraud and other illegal activities.
- JETSTREAM also uses "cookies"in its website to improve your online experience.
In particular, we collect the following “cookies” categories for the following purposes:
- Basic-Functional: Cookies that are absolutely necessary for the website's operation. These cookies do not collect information about you that could be used for marketing purposes or to remember the parts of the internet you have visited. This category of cookies cannot be disabled.
- Statistic: Cookies that are used for statistical purposes, concerning the way the user handles the website and the user's behavior as well as the user's identification through multiple devices.
- Marketing: Cookies for promotional purposes are used to show ads related to specific users and tailored to their interests. They are also used to limit the display frequency of an ad and to measure the effectiveness of advertising campaigns. They register whether you have visited a website or not.
You can control and/or delete cookies according to your wishes. Details can be found here: aboutcookies.org. You can delete all cookies that are already on your computer, as well as to set most browsers in a way that does not allow the installation of cookies. However, in this case, you may have to adjust yourself some preferences each time you visit a website, and also some services may not work properly.
4.Processing of special category personal data ("sensitive personal data")
JETSTREAM essentially does not process sensitive personal data (special category data) through its website, such as data relating to your racial or ethnic origin, religious or philosophical beliefs, health data or data relating to your sexual life or sexual orientation, since the abovementioned data are not necessary for the fulfillment of the above objectives, by applying the principle of minimization, necessity and proportionality as provided for in GDPR.
5. What is the legal basis for the processing of your data by JETSTREAM?
Regarding the legal basis for any processing of your personal data, JETSTREAM shall lawfully process your personal data, which are deemed necessary for specific purposes and, in particular, with the following legal bases:
1. when their processing is necessary for the conclusion, regulation, service, support and monitoring of our contractual relationship (e.g. information about training programs and opportunities) and the proper performance of our contractual obligations or upon a specific request of yours within the context of our contractual relationship,
2. when required so that the Company complies with its legal obligations
3. when required for the pursuit of the legitimate interests of JETSTREAM
4. in accordance with your prior consent, provided that the processing is not based on any of the abovementioned lawful bases of processing.
6. Who are the recipients of your data?
Access to your personal data within the framework of our relationship is given to the trained and authorized personnel for each specific personal purpose of our Company, bound by absolute discretion and confidentiality.
JETSTREAM respecting the privacy of its website visitors, does not further transmit to third parties the personal data it collects from its website, if it is not necessary. It may transmit/disclose some of these to third legal persons, to whom it has partially or totally assigned the processing of your personal data (Processors) on its behalf for specific purposes, such as the support of the website, with whom it has ensured that the processing for the protection of your data shall be in accordance with the Regulation (GDPR), by signing contracts and undertaking to implement adequate measures, pursuant to the relevant provisions of GDPR (Articles 28, 32).
Moreover, the Company transmits your data to public services and bodies, when and where provided for under applicable law.
7. How long do we retain your data for?
JETSTREAM retains your personal data in accordance with legislative requirements and its Retention Policy, particularly for as long as provided for per case, for as long as the nature and purpose of the processing require, for as long as defined by the existing legislative and regulatory framework and in any case for the entire duration of our commercial relationship and its individual contractual commitments.
In any case, we apply a maximum retention period of twenty (20) years (General Limitation Period for Claims) with the possibility of extending the above period in the event of any kind of claim or pending lawsuit or audit by public authorities. Upon expiry of the above time period, they shall be erased in a secure and non-recoverable manner.
In case you have given your consent in view of a specific processing, you have the right to revoke it at any time with a simple revocation declaration, which will be addressed to JETSTREAM by completing a form of exercise of rights or by selecting unsubscribe or by any other means, without prejudice to the lawfulness of the processing based on it until its revocation.
8. How do we secure you data?
JETSTREAM ensures that adequate technical and organizational measures are implemented to safeguard both technical and physical security pursuant to Article 32 of GDPR. It has relevant Policies and generally respects the principles of processing in compliance with the letter of GDPR (Article 5 of the GDPR) to ensure availability, integrity and confidentiality of your data. For instance, an Antivirus Firewall is installed for the protection of information infrastructure against internal and external threats, regular update of information operating systems, access matrix, backups are kept and relevant policies are applied within the Company for the electronic and physical security of the infrastructure and for data protection.
In particular, regarding its website, JETSTREAM applies a Secure Sockets Layer (SSL) protocol with strong encryption, which enhances security when transmitting data on the Internet.
9. Which are your rights and how can you exercise them?
In any case, you shall have control over the processing of your personal data. More specifically, pursuant to the applicable provisions of the General Regulation on Data Protection of natural persons (EU 679/2016), as a personal data processing subject you retain the following rights:
1. Right to information, communication and modalities for the exercise of your rights (Articles 12, 13, 14 GDPR), namely your right to be informed on how your personal data are being used (as explained in detail in the present document).
2. Right to access personal data concerning you, provided thatthe Company processes them as Controller (Article 15 GDPR). The Company will provide a copy of your personal data upon your request.
3. Right to rectification of inaccurate personal data as well as completion of incomplete personal data(Article 16 GDPR).
4. Right to erasure of your personal data (‘right to be forgotten’), without prejudice to the Company's obligations and legal rights for their retention, pursuant to the applicable laws and regulations (Article 17 GDPR).
5. Right to restriction of processing your personal data since, either the accuracy of the personal data is contested, the processing is unlawful or there is no longer a processing purpose, but their erasure is not appropriate (Article 18 GDPR).
6. Right to data portability, i.e. the right to have your personal data transmitted to another controller, if the processing is based on your consent and is carried out by automated means or for the execution of our agreement (Article 20 GDPR).
7. Right to object, for reasons relating to the special circumstances of your situation, in case your data are being processed for purposes of the Company’s legitimate interests (Article 21) and, in particular, to object to automated individual decision-making (Article 22).
8. Right to withdraw your already given consent (Article 7 GDPR) at any time for processing based on consent. The lawfulness of your data processing shall not be affected by the withdrawal of consent until the time you requested the withdrawal.
9. Right to have recourse to the competent supervisory authority, namely the Hellenic Data Protection Authority (1-3, Kifissias Avenue, Athens, P.C. 115 23, +30 210 6475600, email@example.com)
You shall have every right to exercise your rights by sending an email to firstname.lastname@example.org or a letter to our address in Spata, Attica, 198, Vassileos Pavlou Str., P.C. 19004, by completing the relevant rights exercise form we provide you
10. More specific declarations of JETSTREAM S.A.
1. Declares that it does not process personal data of website visitors/users under the age of sixteen (16).
2. Declares that it is not responsible for any damage (direct, indirect, positive, negative) that may be caused to the visitor during website navigation or use. The visitor is solely responsible for the protection of his/her system against viruses.
3. Declares that it does not proceed to decision-making or profiling based on automated processing of your data.
4. Declares that the present policy may be modified/updated at any time. The visitor shall be informed of all significant changes, and the updated version shall be posted each time on the website. For this reason, the website visitor should be constantly informed and regularly consult the present policy.
5. For the customers - trainees of our company we have posted specific Imformation Policy here.
6. For the business partners of our company we have posted specific Information Policy here.
12. Useful contact information:
JETSTREAM AVIATION TRAINING AND SERVICES SOCIETE ANONYME
Distinctive title: JETSTREAM
Address: 198, Vasileos Pavlou street, Spata, Attica, P.C 19004
Hellenic Data Protection Authority information (HDPA, competent national supervisory authority):
Offices: 1 – 3, Kifissias Avenue, P.C. 115 23, Athens
Call Centre: +30 2106475600
Fax: +30 2106475628