Website Privacy Notice

CCL Aviation is committed to protecting the privacy and security of your personal data. This Website Privacy Notice describes how we collect, use and look after your personal data when you visit our website (regardless of where you visit it from). It also tells you about your rights and how the law protects you.

This Website Privacy Notice is provided in a layered format, so you can click through to the specific areas set out below.

Important information

The data we collect about you

How personal data is collected

How we use your personal data

Disclosure of personal data

International transfers

Data security

Data retention

Your legal rights

Schedule

  1. Important information

Our website is not intended for children and we do not knowingly collect data relating to children.

This Website Privacy Notice supplements the other notices or terms on our website and is not intended to override them. It is important that you read this Website Privacy Notice, together with any terms and conditions we may provide on specific occasions.

CCL Aviation is the controller and responsible for your personal data.

To assist you further in understanding this Website Privacy Notice, set out in the Schedule is a glossary of terms used in this Website Privacy Notice, examples of types of personal data we collect, how we use it, the lawful basis for processing such data and further details of your rights.

Controller

CCL Aviation is made up of different legal entities, Cambridge Communications Limited, CCL Aviation (UK) Limited (United Kingdom), CCL Aviation PTE. LTD (Singapore), CCL Aviation Limited (NZ) and CCL Aviation, Inc. (USA). This privacy notice is issued on behalf of CCL Aviation Group so when we mention CCL Aviation, we, us or our in this privacy notice, we are referring to the relevant company in the CCL Aviation Group responsible for processing your data.  Cambridge Communications Limited is responsible for the operation of this website.

We have appointed a data privacy manager (DPM). If you have any questions about this Website Privacy Notice, including any requests to exercise your legal rights, please contact our DPM in writing, either: by email to privacy@cclaviation.com; or by post to Bridgewater House, Caspian Road, Altrincham, Cheshire WA14 5HH.

You have the right to make a complaint at any time to the ICO (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact our DPM in the first instance.

We may change this Website Privacy Notice at any time by updating this page.  Please check our website from time to time to ensure you are aware of any changes.

This Website Privacy Notice was last updated on 1 June 2018.

Your duty to inform us of changes

It is important that the data we hold about you is accurate and current. Please keep us informed if your personal data changes during your time as a user of our website by updating your information in the user portal or by emailing us at privacy@cclaviation.com.

Third-party links

Our website includes links to third-party websites, plug-ins and applications. By clicking on these links or enabling connections you may be allowing third parties to collect or share your personal data. We have no control over these third-party websites, plug-ins or applications and are not responsible for their privacy notices, therefore you should also read their privacy notices to understand what personal data they collect about you and how they use it.

  1. The data we collect about you

We collect, use, store and transfer the types of personal data about you listed in Part 1of Schedule 1.

We also collect, use and share aggregated data. However, if we combine aggregated data with your personal data so that it can directly or indirectly identify you, we treat this as your personal data.

We do not collect any information about criminal convictions and offences, unless you apply to become a registered user of connect.cclaviation.com (CCL Connect). Further details of the type of information we collect in this instance can be found in our Applicant Privacy Notice.

Failure to provide personal data

If we are required by law, or under the terms of a contract we have with you, to collect your personal data and you fail to provide it, we may not be able to enter into or perform the contract with you. We will notify you of this at the relevant time.

  1. How personal data is collected

We collect personal data in the following ways:

directly 

you may provide personal data when you complete online forms, create a user account, register as a user of our portal, join our mailing list or otherwise or correspond with us (by post, phone or email).

automated technology

we automatically collect personal data (technical and usage) when you browse or interact with our website by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites which use our cookies. Please see our cookie policy for further details.

publicly available sources

we may collect personal data from publicly availably sources based inside the EU, such as Companies House, the Electoral Register and credit reference agencies.

third parties

we may receive personal data from:

  1. analytics providers such as Google, which may be based inside or outside the EU;
  2. search information providers such as Google, which may be based inside or outside the EU;
  3. our suppliers such as payment providers, website hosting, support and maintenance providers based inside and outside the EU.
  1. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:

  • to perform the contract we may enter into or have entered into with you;
  • to comply with a legal obligation; and
  • where it is necessary to carry out our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Part 2of Schedule 1sets out the lawful basis we will rely on to process your personal data.

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your information.

Marketing

We will not contact you for marketing purposes and we will not share your personal data with third parties for their marketing purposes.

Change of purpose

We will only use your personal data for the purpose that we originally collected it for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to use your personal data in this manner.

We may process your personal data (without your knowledge or consent) where this is required or permitted by law.

  1. Disclosure of your personal data

We may need to share your personal data with third parties, further details of which are set out in Part 4of Schedule 1. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes. They can only process your personal data for specified purposes and in accordance with our instructions.

By submitting your personal data to our website, you are consenting to us sharing your personal data with these third parties. Please note that their use of your information will be governed by their privacy policies and terms, which you should review if you would like further information on how they will use your data.

  1. International transfers

We share your personal data within the CCL Aviation group companies. This will involve transferring your data outside the European Economic Area (EEA).  We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data.  Our servers which host data collected from our website are located within the EEA but these can be accessed by our group companies located inside and outside the EEA.

Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.  Whilst we will take all steps reasonably necessary to ensure that your personal information is treated securely, we do not guarantee that the countries your personal data may need to be transferred to, treat personal data with the same level of protection as is required by companies operating within the EEA. You should also note that if you do not wish for your personal data to be transferred to a third country or third party then we may not be able to deal with your query.  By submitting your personal data to our website, you are consenting to the transfer of your personal data outside of the EEA.  If you do not want your personal data to be transferred, please do not interact with our website or upload data to our website.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

  1. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for your personal data, we consider the amount, nature and sensitivity of the personal data, the potential harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. We can use anonymised information indefinitely without further notice to you.

  1. Your legal rights

You have certain rights in certain circumstances under data protection law.  These are set out in full in Part 3 of Schedule 1. If you wish to exercise any of your rights, please contact our DPM.

You will not have to pay a fee to exercise any of your rights. However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee for this information or refuse to comply with your request.

We may request specific information from you to help us confirm your identity when you contact us and ensure. This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

Schedule 1 

Part 1 Types of personal data

contact data

email address

identity data

first name and last name

profile data

username and password

technical data

internet protocol (IP) address, log-in data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website

 

Part 2 Lawful basis for processing and processing activities

The lawful basis upon which we may rely on to process your personal data are set out below.

consent

you have given your express consent for us to process your personal data for a specific purpose

contract

the processing is necessary for us to perform our contractual obligations with you under our contract, or because you have asked us to take specific steps before entering into a contract with you

legal obligation

the processing is necessary for us to comply with legal or regulatory obligation

legitimate interests

the processing is necessary for our or a third party’s legitimate interest, e.g. for us to provide the best service to you via our website. Before we process your personal data on this basis we make sure we consider and balance any potential impact on you, and we will not use your personal data on this basis where such impact outweighs our interest

 

Set out below are specific details of the processing activities we undertake with your personal data and the lawful basis for doing this.

Purpose/Activity

Type of data

Lawful basis for processing

to register you as a new user

identity & contact

to perform our contract with you

to manage our relationship with you

identity, contact & profile

(i) to perform our contract with you

(ii) as necessary to comply with a legal obligation

(iii) as necessary for our legitimate interests in keeping our records updated and analysing how our services are being used

to administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

identity, contact & technical

(i) as necessary for our legitimate interests in 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

(ii) as necessary to comply with any legal obligations

to deliver relevant website content/advertisements to you and measure or understand the effectiveness of our advertising

identity, contact, profile & technical

as necessary for our legitimate interests in studying how our services are being used, to develop them, to grow our business and to inform our marketing strategy

to use data analytics to improve our website, services, user relationships and experiences

technical

as necessary for our legitimate interests to define types of users of our services, to keep our website updated and relevant, to develop our business

to make suggestions and recommendations to you about services that may be of interest to you

identity, contact, technical & profile

as necessary for our legitimate interests to develop our services and grow our business

 

Part 3 Your legal rights

You have the following legal rights in relation to your personal data:

access your data

you can ask for access to and a copy of your personal data and can check we are lawfully processing it

correction

you can ask us to correct any incomplete or inaccurate personal data we hold about you

erasure

you can ask us to delete or remove your personal data where:

  1. there is no good reason for us continuing to process it;
  2. you have successfully exercised your right to object (see below);
  3. we may have processed your information unlawfully; or
  4. we are required to erase your personal data to comply with local law.

We may not always be able to comply with your request for specific legal reasons, which will be notified to you at the time of your request

object

you can object to the processing of your personal data where:

  1. we are relying on our legitimate interests (or those of a third party) as the basis for processing your personal data, if you feel it impacts on your fundamental rights and freedoms;
  2. we are processing your personal data for direct marketing purposes.

In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms and, in such circumstances, we can continue to process your personal data for such purposes

restrict processing

you can ask us to suspend or restrict the processing of your personal data, if:

  1. you want us to establish the accuracy of your personal data;
  2. our use of your personal data is unlawful, but you do not want us to erase it;
  3. you need us to hold your personal data (where we no longer require it) as you need it to establish, exercise or defend legal claims; or
  4. you have objected to our use of your personal data, but we need to verify whether we have overriding legitimate grounds to use it

request a transfer

you can request a transfer of your personal data, which is held in an automated manner, and which you provided your consent for us to process, or which we need to process to perform our contact with you, to you or a third party. We will provide your personal data in a structured, commonly used, machine-readable format

withdraw your consent

you can withdraw your consent at any time (where we are relying on consent to process your personal data). This does not affect the lawfulness of any processing carried out before you withdraw your consent

 

Part 4 Third Parties

group companies

other companies in the CCL Aviation Group acting as joint controllers or processors and who are based in the United Kingdom, Singapore, New Zealand and the United States of America and provide contract management and administrative services

service providers

acting as processors based in the United Kingdom, Singapore, New Zealand and the United States of America who provide IT and system administration services

HM Revenue & Customs, regulators and other authorities

acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances

third parties 

third parties whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may also use your personal data in the ways set out in this Website Privacy Notice

 

Part 5 Glossary

aggregated data

information such as statistical or demographic data which may be derived from personal data, but which cannot by itself identify a data subject

controller

a body that determines the purposes and means of processing personal data

data subject

an individual living person identified by personal data (this will generally be you)

personal data

information identifying a data subject from that data alone or with other data we may hold but it does not include anonymised or aggregated data

processor

a body that is responsible for processing personal data on behalf of a controller

ICO

Information Commissioner’s Office, the UK supervisory authority for data protection issues

 

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