Avion Express Malta Ltd., a limited liability company duly registered and existing under the Laws of Malta, Registration No C87300 and having its registered address at NuBis Centre, Mosta Road, Lija LJA 9012, Malta (hereinafter referred to as the Company) commits to ensure the security of visitors personal data and protection of rights when visitors use and navigate the Company’s website www.avionexpressmalta.aero (hereinafter referred to as the Website).

This Privacy Policy (hereinafter referred to as the Privacy Policy) specifies the data collected by the Company, means and sources wherefrom this data is obtained, legal basis for processing of personal data as well as actions and measures, which have been taken by the Company to protect the collected data. By using the Company’s services and/or browsing the Website, visitors agree to the terms of this Privacy Policy as well as the other general rules for using the site. All personal data are processed in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR), the Data Protection Act (Chapter 440 of the Laws of Malta) and other legal acts. For any questions regarding this Privacy Policy or any requests regarding the processing of personal data, please contact us at [email protected].

1. USE AND COLLECTION OF PERSONAL DATA

1.1. The data controller, data processors, and scope of the privacy policy

Personal data provided on or through the Website are managed and controlled by the Company.

This Privacy Policy applies to any website managed by the Company and to any service provided by the Company, regardless of which facilities the visitor of our Website (hereinafter referred to as the Visitor) uses to access, visit or navigate the Website or use any of the services.

This Privacy Policy does not apply to links to websites provided by third parties on our Website, therefore we recommend that the Visitor directly and individually consult the privacy policies or policies applicable to such third-party websites or services.

The Company may engage third parties in the processing of Visitor’s personal data and, for this purpose, transfer their personal data to other legal entities, complying with the conditions set forth in this Privacy Policy. 

1.2 Collected information

Technical information, cookies  

Each time Visitor access or visits our Website, our Website automatically collects and manages the following technical personal data:

• IP address;
• date and time of access;
• the name and URL of the webpage that connects to the Website;
• Visitor’s device operating system data;
• information of the Visitor’s internet provider;
• Visitor’s geo-location data, language settings;
• other relevant technical information.

The Company also collects and manages the technical data of the Visitors using the cookies. To learn more about cookies and processing of personal data, see the Company’s Cookie Policy.

Information provided by the Visitor 

The Company may also collect and process other personal data of the Visitor, provided on its own initiative by e-mail or another information system available on the Website. Such personal data may include:

• Visitor’s name, surname;
• contact information (telephone, e-mail address, home address);
• other personal information identifying the Visitor;
• content of the request, report, complaint or any other relevant message.

The above list is not exhaustive, the Company may need to collect additional information in special cases, which depends on the reason of the Visitor’s request, or in other cases, where it is required to achieve the objectives of this Privacy Policy.

Use of personal data for direct marketing purposes

The Company also handles and processes your personal data for direct marketing purposes in the following cases:

• when you provide your explicit consent to such processing (the basis for the processing is consent);
• when you are the Company’s client without expressly objecting to processing your data for direct marketing purposes, marketing of similar services, where the client has been duly notified of such processing beforehand (the basis of the processing is the legitimate interest of the Company).

For the purposes of direct marketing, the Company processes the following personal data:

• your name;
• e-mail address;
• phone number.

Your personal data for direct marketing purposes can be processed in the following ways:

• you may receive a newsletter with our offers, promotions, products and news by e-mail;
• you may receive invitations to events and similar information by e-mail;
• you may be called by phone with invitation, proposal or offer.

We inform you that you are free to opt out of our newsletters at any time. You can do this by clicking on a link for that purpose at the bottom of our e-mail with the newsletters.

You may at any time refuse to receive information about events or any other information from us by sending an email to [email protected].

Use of information for recruitment purposes and career opportunities

On our websites, you may submit your data to join our team.

We inform you that we will process your personal data for the purposes of the recruitment based on your consent, expressed by submitting this data, and we will store such submitted information until the end of a specific job offer or recruitment unless you specifically agree with the longer storage periods.

Please note that in order to evaluate your candidacy, we may contact the former employers / clients about your qualifications, professional skills and business characteristics. We can ask you for such information from your current employer / client only with your own consent.

1.3. Discretion and care when providing your personal details

Please always use discretion, care and observe at least the following minimum requirements for the protection of your personal information:

• please omit using your name, address, telephone number, e-mail, personal identification number, date of birth, bank account number, car number, real estate data, health data, other special (sensitive) data, etc. in the subject of the request or file name;
• please omit using your personal code, payment card number, and other financial information and details, health, family member details, other specific (sensitive) data, any other excessive information or data in the CV, motivation letters, any other files, texts of requests, e-mails or similar communication you sent to us, and
• please make sure that the remaining personal data is only indicated to the extent necessary for the purposes for which the letter, request or request is sent.

1.4. Use of personal data 

The main purpose of the processing of personal data is to enable efficient, optimal and adapted use of the Website for the personal needs of the Visitor. Personal data is used:

• for convenient, efficient and functional use of the Visitors’ needs;
• to ensure smooth administration of the Website;
• to ensure functionality of the Website;
• to ensure timely and appropriate processing of Visitor’s queries, requests, and replies;
• to contact Visitor regarding any information he/she provides;
• to enable the Company to perform statistical and other analysis by continuously improving the content of the Website and the services provided by the Company;
• for other purposes disclosed to the Visitor at the time of submitting personal data.

1.5. Storage of the personal data 

Visitor’s personal data will not be processed beyond what is necessary for the purposes laid down in this Privacy Policy.  Personal data collected through the Website will be stored for no longer than 3 years.

Your personal data processed for the purposes of direct marketing will be stored for 5 years from the date of the consent (if you have provided a separate consent) or the date of completion or expiration of the relevant contract.

Longer periods of personal data retention may be applied where:

• there is a reasonable suspicion of an unlawful act which subjects to investigation;
• Visitor’s data is necessary for the proper resolution of the dispute, complaint or claim;
• the Company has received complaints related to the Visitor or if the Company has noticed any violations committed by the Visitor;
• it is necessary for back-up copies or related purposes of functioning of information systems of the Company;
• it is mandatorily required by applicable laws.

Your personal data will be destroyed within a reasonable time after the specified deadline.

1.6. The legal basis for the processing of personal data 

The Company controls and processes Visitor’s personal data:

• on the basis of consent, which is expressed by Visitor’s active actions, e. g., referrals to the Company and submission of personal data, other active actions;
• exercise of the Company’s legitimate interests (e. g., managing and administering a Website);
• in order to comply with other legal obligations.

Visitors may revoke their consent to process their personal data at any time. If the Company has no other legal basis for the processing of personal data, the Company will cease processing of personal data immediately (subject to technical feasibility) after the cancellation / revocation of the consent provided by the Visitor.

1.7. Data transmission to third parties 

The Company does not transfer Visitors personal data to any third parties without prior Visitor’s consent, except as described below.

In the light of investigations or other cases provided by law, personal data may be submitted to the law enforcement, judicial or pre-trial institutions without any specific consent of the Visitor.

In addition, particular technical data pertaining to the Visitors’ visits on the Website (such as IP address, data collected or placed on the devices of the Visitors by the cookies, technical information of the browser, other information related to Visitor’s browsing activities, etc.) may be transferred or made available to the entities in the EEA as well as outside the EEA (e. g., we use the Google Analytics service) for the purposes related to statistics, analysis and other related purposes. Please note that the personal data in non-EU countries may be subject to less protection than the EU. The Company will carefully assess the conditions under which such data will be processed and stored after transfer to the above entities.

The Company also uses the services provided by third parties (such as third-party data centres, servers, website design, administration services, online traffic and website analysis, statistics, direct marketing services, etc.) that may require access to the Visitor’s personal data to the appropriate extent. In this case, the Company ensures that the data processors comply with the obligations of confidentiality and adequate personal data protection.

2. THE RIGHTS OF THE VISITORS 

Visitors have certain rights related to the protection of their personal data. These rights are:

• the right of access to the personal data;
• the right to rectification;
• the right to erasure (right to be forgotten);
• the right to restriction of processing;
• the right to data portability;
• the right to object;
• in case the Visitor deems that his/her rights have been violated, he/she has the right to file a complaint to the Information and Data Protection Commissioner (IDPC) whose office is situated at Level 2, Airways House, High Street, Sliema SLM 1549, Malta, (+356) 2328 7100, [email protected].

To enforce his/her rights, Visitor may contact the Company by e-mail: [email protected]. 

3. DATA SECURITY 

By implementing appropriate technical and organizational measures, the Company protects Visitor’s personal data from loss, misuse, unauthorized access, disclosure or alteration.

The Company recommends that the Visitors comply with the following minimum safeguards for their personal data protection:

• do not visit suspicious websites;
• update their software and anti-virus protection as recommended by software providers and vendors.

4. FINAL PROVISIONS 

This Privacy Policy applies from 14^th December 2020.

This Privacy Policy may be from time to time updated by the Company.

The Company will inform Visitors about the updates by submitting a new version of the Privacy Policy along with the dates of the corrections made.  Visitors understand and accept that by continuing to use the Website, they agree to any changes or updates to the Privacy Policy.

If any provision of the Privacy Policy is deemed void or inapplicable, such provision shall not affect the legality and validity of the remaining provisions of the Privacy Policy.