Privacy and Cookies Policy
ASL Airlines (Ireland) Limited
ASL Airlines (Ireland) Limited, whose registered office is at 3 Malahide Road, Swords, Co. Dublin (referred to as “ASL”), respects your privacy and is committed to protecting your Personal Data. ASL is classified as a “Controller” under the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and any data protection legislation from time to time in force in Ireland including the Data Protection Act 2018 and/or any successor legislation in respect of Personal Data you may furnish to us.
We will use your Personal Data only for the purposes and in the manner set forth below, which describes the steps we take to ensure our processing of Personal Data is in compliance with the GDPR and implementing legislation.
1. Personal Data
“Personal Data” is any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier such as a user IP addresses or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
2. Personal Data collected and processed
The ASL website does not store or collect any Personal Data about site users. Any Personal Data sent via the website will be treated with the highest standards of security and confidentiality, strictly in accordance with the GDPR.
3. Technical data collected
The website does not use cookies, apart from temporary “session” cookies which enable a user’s web browser to remember which pages on the website have already been visited. A cookie is a piece of data stored on the user’s hard drive while they are visiting a particular website. It contains simple information about the user’s identity but no personal information. When the user closes their browser, the cookie is destroyed. Users can set a computer not to accept cookies without a loss of functionality on ASL’s website.
Technical details in connection with visits to the website are logged for statistical purposes. No information is collected that could be used to identify website users. Log records do not contain any personal information about users. Statistical information that is gathered does not include Personal Data.
4. Sources of Personal Data
There are instances where we invite or request you to provide us with Personal Data such as your name, email address, job title, company and location.
The purposes for which we use Personal Data and the legal basis for why that processing is necessary or permitted are:
| Purpose(s) for Processing | Legal Basis |
|---|---|
| Applying for services. | —Where we need to perform a contract we are about to enter into or have entered into with you; and/or —Where it is necessary for our legitimate interests in managing our business (or those of a third party) and your interests and fundamental rights do not override those interests.** |
| Giving us feedback. | |
| Requesting marketing materials to be sent to you. | Consent – which you may withdraw at any time. |
The Personal Data that is referred to above will be processed for the purposes of providing you with information that you have requested from us.
We do not collect any Special Categories of Personal Data about you (this includes your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions or offences.
5. Disclosure of your Personal Data to third parties
We disclose your Personal Data to:
a. Internal third parties, being other companies in the ASL group; and
b.our trusted third party service providers who are responsible for managing this website and for providing services to you. We take all reasonable steps to ensure that our third party providers will process and store your Personal Data to the same high standard that we do.
We will disclose your Personal Data if we believe in good faith that we are required to access, use, preserve or disclose it in order to comply with any applicable law or regulation, a summons, a search warrant, a court or regulatory order, or other statutory requirement.
We will not share your Personal Data with companies, organisations or individuals other than our trusted third party service providers.
6. Transfers of your personal data outside of the European Union
We may share your Personal Data within the ASL group, including subsidiaries and affiliates based outside of the European Union such as Switzerland, the Republic of South Africa and Thailand. In connection with the above we may transfer and store your Personal Data outside the European Economic Area (“EEA“), including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for Personal Data as is provided for in the European Union. Your Personal Data may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.
If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which include entering into a contract governing the transfer which contains the ‘standard contractual clauses’ approved for this purpose by the European Commission.
7. How we secure your Personal Data
Your Personal Data that we capture may be held at our offices and those of our group companies and may also be stored on the document storage platforms of those companies located in Ireland and in the other countries in which we operate.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to this website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
8. Your rights
You have certain rights in relation to your Personal Data held by us, including in particular the right to object to your Personal Data being processed on the basis of our legitimate interests and / or for direct marketing purposes. You have the following rights, in certain circumstances and subject to certain restrictions, in relation to your Personal Data:
a) The right to access your Personal Data;
b)The right to request the rectification and/or erasure of your Personal Data;
c) The right to restrict the use of your Personal Data;
d) **The right to object enables you to object to your personal data being processed on the basis of our legitimate interests (or those of a third party). You also have the right to object to us processing your personal data for direct marketing purposes;
e) The right to be forgotten in certain circumstances; and
f) The right to receive your Personal Data, which you have provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller.
Generally, we do not rely on consent as a legal basis for processing your Personal Data, but where you have provided consent for the use of your Personal Data you can withdraw it at any time by writing to us at the details provided in the 'Contact Us' section.
9. Contact Us
In order to exercise any of the rights set out above, please contact us at privacy@aslaviationholdings.com.
10. How long we retain your Personal Data
We are required to ensure that your personal data is accurate and maintained in a secure environment for a period of time no longer than necessary for the purposes for which we are processing your personal data.
We generally retain your personal data for the following periods:
— Where applying for services - a period of at least 7 years after the end of our relationship.
— Where giving us feedback - a period of at least 7 years after the end of our relationship.
— Where you have requested marketing materials to be sent to you – 1 year after sending the most recent marketing message or earlier if you object to receiving direct marketing.
However, in some cases we may need to keep personal data for longer than the above stated periods (e.g., where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or dealing with complaints, legal challenges or prospective litigation).
11. Links to other websites
This Privacy Policy applies only to the ASL website. The website may contain links to other web sites not operated or controlled by us (“Third Party Sites”). The policies and procedures we describe here do not apply to Third Party Sites and we are not responsible for Third Party Sites’ content, any use of Third Party Sites, or the privacy practices of Third Party Sites. Any links from this website do not imply that we endorse or have reviewed Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.
12. Changes to this privacy policy
We reserve the right to make changes to this Privacy Policy at any time without prior consultation. Any changes to this Privacy Policy will be posted on this website so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.
If at any time we decide to use your Personal Data in a manner materially or substantively different from that stated in this Privacy Policy, or otherwise disclosed to you at the time it was collected, we will notify you at the last email address that you provided to us, and you will have a choice as to whether or not we use your Personal Data in the new manner.
13. Questions and complaints
Our Privacy Officer should be able to answer any queries or resolve any concerns you have regarding the use of your Personal Data, and is contactable at privacy@aslaviationholdings.com
You have the right to lodge a complaint with your local supervisory authority, the Office of the Data Protection Commissioner, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland if you consider that the processing of your personal data infringes the GDPR.
The Irish Data Protection Commission can also be contacted at info@dataprotection.ie.
