BackgroundFlynet Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, support.flynet.uk/support ("Our Site") and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
ContentsDefinitions and Interpretation
Information About Us
What Does This Policy Cover?
What is Personal Data?
What Are My Rights?
What Data Do We Collect?
How Do You Use My Personal Data?
How Long Will You Keep My Personal Data?
How and Where Do You Store or Transfer My Personal Data
Do You Share My Personal Data?
How Can I Control My Personal Data?
Can I Withhold Information?
How Can I Access My Personal Data?
How Do I Contact You?
1. Definitions and InterpretationIn this Policy the following terms shall have the following meanings:
|"Account"||means an account required to access and/or use certain areas and features of Our Site;|
|"Cookie"||"Cookie" means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and|
|"Cookie Law"||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;|
2. Information About UsOur Site is owned and operated by Flynet Limited, a limited company registered in England under company number 3155221.
King William House
6 The Causeway
VAT number: GB665632320.
Email address: firstname.lastname@example.org.
King William House
6 The Causeway
4. What is Personal Data?Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the "GDPR") as 'any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier'.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to access the personal data we hold about you. part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling.
Further information about your rights can also be obtained from the Information Commissioner's Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner's Office.
- Email address;
- Telephone number;
- Business name;
- Business country;
- Business city;
- Job title;
- IP address;
- Web browser type and version;
- Operating system;
- A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
7. How Do You Use My Personal Data?Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for the following purposes:
- Providing and managing your Account;
- Providing and managing your access to Our Site;
- Personalising and tailoring your experience on Our Site;
- Supplying our products and services to you. Your personal details are required in order for us to enter into a contract with you.
- Personalising and tailoring our products and services for you.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email and post that you have opted-in to (you may unsubscribe or opt-out at any time by clicking on the unsubscribe link at the bottom of email correspondence or by contacting us using the details in Part 15).
- Analysing your use of Our Site to enable us to continually improve Our Site and your user experience.
8. How Long Will You Keep My Personal Data?We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
- We will keep your personal and non-personal data as outlined in Part 6 from initial collection for a maximum of 12 months.
- If you have opted-in to communications, and subsequently opt-out, we will keep your personal and non-personal data as outlined in Part 6 from when you opt-out for a maximum of 12 months.
- If you have an active contract with us, we will keep your personal and non-personal data for a maximum of 3 years after the end of your contract.
9. How and Where Do You Store or Transfer My Personal DataWe store or transfer your personal data within the UK and European Economic Area (the "EEA"). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.
We may share your data with external third parties, as detailed below in Part 10, that are based outside of the EEA. The following safeguards are applied to such transfers:
Where we transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.
Please contact us using the details below in Part 15 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.
The security of your personal data is essential to us and to protect your data, we take a number of important measures, including the following:
- Regular GDPR training and awareness for Flynet staff.
- Regular review of Flynet GDPR data security policies.
- Constant monitoring Flynet data security to ensure GDPR rules are being adhered to.
- Regular review of data storage and processing locations to ensure they are GDPR compatible.
- Using the best available encryption and authentication/authorisation technology to safeguard all data.
- Review of third party data security policies to ensure they are GDPR compatible.
- Review of third party GDPR awareness and training to ensure that staff are able to enforce GDPR compatible rules.
- Review of third party data storage and processing locations to ensure they are GDPR compatible.
- Review of third party data protection rules to ensure the same levels of personal data protection that would apply under GDPR. We require third parties to provide data protection to standards similar to those in Europe / GDPR.
10. Do You Share My Personal Data?We may sometimes contract with the following third parties to supply certain products and services. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.
- Campaign Monitor Pty Ltd
- Email marketing tool.
- Used for sending newsletters and similar bulk emails.
- Data is stored in a US data centre (Name and email address only).
- Data processing is in multiple locations: USA, Australia and Germany.
- Content delivery via Fastly: https://www.fastly.com/network-map
- Security and privacy information can be found at https://www.campaignmonitor.com/trust
- Professional services.
- Used to provide third-level technical support.
- Data is stored within the UK and EU.
- Data processing occurs in the USA.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 9.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
11. How Can I Control My Personal Data?In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details and by managing your Account).
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service ("the TPS"), the Corporate Telephone Preference Service ("the CTPS"), and the Mailing Preference Service ("the MPS"). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
12. Can I Withhold Information?You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
13. How Can I Access My Personal Data?If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a "subject access request".
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.
There is not normally any charge for a subject access request. If your request is 'manifestly unfounded or excessive' (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop-up prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
The following first-party Cookies may be placed on your computer or device:
|Name of Cookie||Purpose||Strictly Necessary|
Our Site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the products and services offered through it.
The analytics service used by Our Site use the following Cookies:
|Name of Cookie||First / Third Party||Provider||Purpose|
|_ga||first||Google Analytics||Used to distinguish users and has an expiration of 2-years.|
|_gid||first||Google Analytics||Used to distinguish users and has an expiration of 24-hours.|
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
15. How Do I Contact You?To contact us about anything to do with your personal data and data protection, including to make a subject access request or to ask to be unsubscribed from one of our mailing lists, please use the following details:
Email address: email@example.com.
Telephone number: +44 (0)1638 611 111.
King William House
6 The Causeway