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PRIVACY POLICY

INFORMATION PURSUANT TO ART. 13 OF REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

Air Corporate Srl ("AC") wishes to inform you that, pursuant to art. 13 of Regulation (EU) 2016/679 of the European Parliament and of the Council concerning the protection of individuals with regard to the processing of personal data (hereinafter "European Regulation"), you need to proceed with the processing of your personal data collected automatically or provided by you through navigation or use of the website https://www.aircorporate.it.

The policy at a glance

Personal Data processed for the following purposes and using the following services:

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Complete Policy

1. OWNER AND MANAGER OF THE TREATMENT

2. DATA PROTECTION OFFICER

3. COMPLIANCE WITH PRINCIPLES 

4. DEFINITION AND TYPE OF PERSONAL DATA PROCESSED

5. PURPOSE OF THE TREATMENT AND LEGAL BASIS

6. PERIOD OF STORAGE OF PERSONAL DATA

7. CATEGORIES OF DATA RECIPIENT PARTIES

8. TRANSFER OF PERSONAL DATA

9. ANY AUTOMATED DECISION-MAKING PROCESSES

10. NATURE OF THE PROVISION       _cc781905-5cde-31594-bb3bcfbad5cf

11. RIGHTS OF THE INTERESTED PARTY 

12. CHANGES TO THE CONSENT TO THE PROCESSING OF PERSONAL DATA     

1. OWNER OF THE TREATMENT

 

The Data Controller is Air Corporate Srl “AC”, in the person of its legal representative, domiciled at the registered office in Via Valosa di Sopra, n. 9, in Monza (MB), 20900, Tax Code 08115820154. and PI 02987430234 (hereinafter "AC" or "Data Controller") can also be contacted by e-mail:privacy@aircorporate.it.

2. DATA PROTECTION OFFICER

 

Due to the processing activities carried out by AC, the Data Controller has deemed it necessary to designate, pursuant to art. 37 of the European Regulation, a Data Protection Officer who can be contacted at the following address:maria.rocca@ordineavvgenova.it. 

 

3. COMPLIANCE WITH PRINCIPLES 

 

The treatment will be based on compliance with the Regulation and the principles of data minimization, accuracy, integrity, correctness, transparency and will be limited to the stated purposes, 

 The data will be processed in such a way as to guarantee adequate security, including protection, through appropriate technical and organizational measures, against unauthorized or unlawful processing and against accidental loss, destruction or damage; _cc781905 -5cde-3194-bb3b-136bad5cf58d_ the data will be kept for the time necessary to perform these purposes and which will subsequently be archived only for legal purposes. 

 

4. DEFINITION AND TYPE OF PERSONAL DATA PROCESSED

 

To allow you to use the air transport service offered by AC, the website www.aircorporate.itand related services, the Data Controller needs to know and process some of your personal data.

By personal data we mean information concerning an identified or identifiable natural person, such as, for example, the name, contact details and/or data relating to the purchase of the Service.

To purchase a Service, the data processed will be name, surname, telephone number, e-mail, information relating to the trip purchased, including any special assistance requests or meal preferences, and payment data. Furthermore, depending on the destination, further categories of personal data may be collected such as, for example, the date of birth (even of minors) and the passport number.

For simple navigation of the Website, the types of data processed are specified below: please refer to the specific information for "cookies" for further details.

 

SOCIAL MEDIA

We maintain pages or profiles on various social media platforms. Within this context, personal data is processed as described below.

If you interact with us through our social media sites or our posts, we will collect and process the information you provide us in connection with this, including your username and any profile picture if applicable, for example by tagging a post with a “Like”, “Share” or “Retweet”, commenting or providing other content. The data processing in this regard is carried out regularly on the basis of our legitimate interest in providing the relevant functions on our social media pages (Article 6 paragraph 1 letter f) GDPR) and, where applicable, on the basis of the user's consent to the operator of the respective network (Article 6 paragraph 1 letter a) GDPR) or the contractual relationship of the user with the operator (Article 6 paragraph 1 letter b) GDPR. Please note that this content is posted on our relevant social media in accordance with your account settings and anyone in the world can access it.

Further data processing by us may take place in order to be able to accept and process inquiries or messages via our social media sites (Article 6 paragraph 1 letter b) GDPR.

Furthermore, the respective operators collect and process your personal data under their own data protection responsibility when you visit and/or interact with our social media sites or our posts. This applies in particular if you are registered or logged in to the relevant network. While not registered to a network, operators collect some personal data when they access the page, such as unique identifiers linked to the user's browser or device. Note that this data could be aggregated on different platforms and services, if performed by the same operator. For example, both Facebook and Instagram are operated by Facebook Ireland Limited. Further information can be found in the data protection information of the respective operators referred to below.

Specifically, we manage the following social media presences:

1. Facebook;

Our Facebook fan page is available at: https://it-it.facebook.com/Aircorporate/

Facebook is operated by Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland ("Facebook"). If you visit or like our Facebook page as a registered Facebook user, Facebook collects your personal data. Even if you are not logged in to Facebook and visit our Facebook page, Facebook may collect pseudonymous usage data from you. For more information, see Facebook's privacy policy at https://www.facebook.com/about/privacy/ and at https://www.facebook.com/legal/terms/information_about_page_insights_data. In the privacy policy, the user will also find information about the configuration options for his Facebook account.

Your personal data may also be provided to other Facebook companies. This could include the transfer of personal data to the USA or to other countries, for which there are no adequacy decisions of the EU Commission. In this case, Facebook will use the standard contractual clauses approved by the EU Commission. Further information can be found in Facebook's privacy policy.

2. Instagram

Our Instagram page can be viewed at: https://www.instagram.com/aircorporate/.

Instagram is operated by Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland (“Facebook Ireland”). Instagram's privacy policy can be viewed at: https://help.instagram.com/519522125107875. Here the user will also find information about the configuration options for his account.

Your personal data may also be made available to other Facebook or Instagram companies. This could include the transfer of personal data to the USA or to other countries, for which there are no adequacy decisions of the EU Commission. In this case, Facebook will use the standard contractual clauses approved by the EU Commission. Further information can also be found in the Instagram privacy policy.

Furthermore, as part of the management of our Instagram page, we are jointly and severally liable with Facebook for the processing of so-called Instagram insights. With the help of Instagram Insights, Facebook analyzes the behavior on our Instagram page and provides us with this information in a non-personal form. Facebook undertakes to take primary responsibility under the GDPR for the processing of Instagram Insights and to comply with all obligations under the GDPR, with respect to the processing of Page Insights.

3. YouTube

Our YouTube page is available at: https://www.youtube.com/channel/UCnO38EHdYQzShLs0ws90ACw

YouTube is operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). You will find Google Ireland's privacy policy at https://policies.google.com/privacy?hl=en. Here the user will also find information about the configuration options for his Google account. Please note that your Google Account may be used for various Google services (e.g. Gmail, YouTube, Google Search) and that Google Ireland may combine personal data relating to the Google services you use in accordance with the configurations of the your Google account. Please note that Google also transfers personal data to Google LLC, based in the USA, and that there is no adequacy decision of the EU Commission for the USA.

Finally, we receive non-personally identifiable information and analytics from Google about the use of our account or interactions with our videos. This information allows us to analyze and optimize the effectiveness of our YouTube activities. The processing that takes place within this context is based on our legitimate interest in optimizing our YouTube activities (Article 6 paragraph 1 letter f) GDPR.

4. LinkedIn

Our LinkedIn account is available at:https://www.linkedin.com/company/aircorporate/

For users located in the European Economic Area and Switzerland, LinkedIn is operated by LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland (“LinkedIn Ireland”). You can find LinkedIn's data protection guidelines here: https://www.linkedin.com/legal/privacy-policy?trk=organization-guest_footer-privacy-policy. Here you will also find information about the configuration options for your LinkedIn profile.

Please note that LinkedIn also transfers personal data to third countries outside the European Economic Area, for which there is no adequacy decision of the EU Commission. To the extent such a transfer is made, LinkedIn will use standard contractual clauses approved by the EU Commission. Related information can be found at https://www.linkedin.com/help/linkedin/answer/62533.

Finally, we receive non-personally identifiable information and analytics from LinkedIn about your use of our account or for interactions with our posts. This information allows us to analyze and optimize the effectiveness of our LinkedIn activities. The processing that takes place within this context is based on our legitimate interest in optimizing our LinkedIn activities (Article 6 paragraph 1 letter f) GDPR.

 

Navigation data

The computer systems and software procedures used to operate AC acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.

This is information that is not collected to be associated with identified interested parties, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified.

This category of data includes the IP addresses of the computers used by users who connect to the Website, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used to submit the request to the server , the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user's IT environment.

These data are used by the Data Controller for the sole purpose of obtaining anonymous statistical information on the use of the Website and the App and to check their correct functioning. The data could also be used to ascertain responsibility in the event of hypothetical computer crimes against AC.

 

Data provided voluntarily by the user

The optional, explicit and voluntary sending of e-mails to the addresses indicated on this Website and on the App entails the subsequent acquisition of the sender's address, necessary to respond to requests, as well as any other personal data included in the communication.

 

Customer Service / Assistance Service / Toll Free Number

Calls to the toll-free number may involve processing of the user's personal data for the purpose of providing the Services requested by the same, such as, by way of example: purchase and sending of payment receipts for the air transport requested by the Customer, after-sales assistance, special assistance and purchases of complementary services on the flight.

With regard to the finalization of electronic transactions, it should be noted that the acquisition of customer credit card data will take place exclusively through the Bank's portal and that they will be treated with all the necessary precautions envisaged by sector legislation.

AC can also make use of third-party call centers that operate, always in full compliance with the legislation on the protection of personal data, with a specific service contract on behalf of the Data Controller, as Data Processors pursuant to Article 28 of the European Regulation . In the event that third-party call centers process data of which AC is the owner outside the EU, AC requires its suppliers to comply with the guarantees provided for by art. 46 of the European Regulation.

 

Registration for courses

Where you express interest in one of our courses ("Courses") and register to attend it, we may store and process the following information concerning you: your name, surname, telephone number, e-mail address, physical address, tax code /VAT number.

If the course is strictly connected to the professional activity or if the verification of the possession of a title is necessary for the purposes of enrollment, it is also possible to ask for data referring to the type of employment including its professional title: information on its qualifications and skills including references, licenses, certificates, and educational background.

 

Request Services

Where you express interest in one of our air transport services ("Services"), we may store and process the following information concerning you: your name, surname, telephone number, e-mail address, physical address, tax code/register VAT.

5. PURPOSE OF THE TREATMENT AND LEGAL BASIS

The personal data of which the Data Controller comes into possession are exclusively those provided by you during navigation and/or during the use of our Services or our Courses. Therefore, personal data will be processed for:

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E) Directly sell Services similar to those already purchased by the interested party, using the e-mail address provided by the same when purchasing an Air Transport Service, provided that the interested party, adequately informed, does not refuse subsequent communications .

F) Provide up-to-date news on AC activities and promotions, as well as on co-marketing promotions useful for enriching the travel experience, by sending newsletters, advertising material and/or communications and information of a commercial and direct marketing nature on our Services, related offers, discounts and any other promotional and loyalty initiatives adopted by AC, both through traditional and fully automated contact systems, such as, for example only, through  the address of residence and/or e-mail, or also through SMS messages. 

G) Personalize the content of the commercial communication and offer only dedicated offers, in line with the tastes and preferences expressed, as well as a better flight experience. 

H) allow you to enroll and attend courses; to communicate with us and we with you, for example to inform you if the date of the lessons is moved.


Your data will also be processed to allow us to correctly manage our accounts, for legal purposes. In this case, the legal basis of the processing is the fulfillment of legal obligations.

Your data may also be processed in the event that a dispute arises between us or there is a complaint on your part; in this case, we will process your data in order to defend our right in court including the extrajudicial phase.

 

6. PERIOD OF STORAGE OF PERSONAL DATA

 

The Data Controller intends to keep personal data for a period of time no longer than that necessary to achieve the purposes for which they were collected and processed.

With regard to the processing of personal data for direct marketing purposes, if it has been explicitly authorized, in compliance with the regulatory requirements in force, AC has established to provide for the cancellation of your personal data processed for direct marketing purposes following your explicit request.

Personal data processed for profiling purposes will instead be deleted 12 months after registration.

With regard to other personal data, not being able to precisely determine the retention period of your personal data, the Data Controller undertakes as of now to inspire the processing of your personal data to the principles of adequacy, pertinence and minimization of data, thus as required by the European Regulation, periodically verifying the need for their conservation. Therefore, once the purposes for which they were collected and processed have been achieved, we will remove them from our systems and records and/or take appropriate measures to make them anonymous, so as to prevent you from being identified.

Failure to consent to the processing of your data could affect the ability to access our Services and/or attend our Courses.

 

7. CATEGORIES OF DATA RECIPIENT PARTIES

 

The processed data will not be disclosed to third parties. However, they may become aware of your data, in relation to the processing purposes set out above:

  • Subjects who can access the data by virtue of the law provided for by the law of the European Union or by that of the Member State to which the Data Controller is subject.

  • Our employees, named as an authorized person;

  • External subjects who perform functions strictly connected or instrumental to AC's activities, as independent Data Controllers or Data Processors, who should be considered fundamental for the purposes of AC's operations;

  • Credit card companies and service providers for anti-fraud control connected to the payment process and (where necessary) activation of the anti-fraud control procedure;

  • Third parties such as law firms and public authorities to whom we turn to ensure that the stipulated contract is respected or applied;

  • Third parties such as the police and national authorities to protect our rights, property or safety of you, our staff and our assets;

  • Public authorities and law enforcement agencies, such as customs and immigration authorities, following a validly made request;

  • Subjects who carry out, in total autonomy, as separate Data Controllers, or as Data Processors appointed for this purpose by AC, auxiliary purposes to the activities and services referred to in paragraph 4, such as commercial partners, companies that offer advertising services , marketing and communication companies, companies that offer IT infrastructures and IT assistance and consultancy services as well as the design and creation of software and Internet sites, companies that offer services useful for personalizing and optimizing our services, including those for providing and managing the customer service, companies that offer useful services to analyze and develop data and process and conduct market research.

Any communication of personal data will take place in full compliance with the legal provisions established by the European Regulation and with the technical and organizational measures prepared by the Data Controller to guarantee an adequate level of security.

The data will be processed manually and electronically, by personnel authorized by us to access and subject to confidentiality obligations, solely for the purposes expressly indicated, they will be processed in compliance with current legislation, processed for the period necessary to fulfill these purposes, except for further conservation needs aimed at fulfilling administrative, fiscal and legal duties.

 

8. TRANSFER OF PERSONAL DATA

The Data Controller may transfer personal data to third countries for the purposes of the correct performance of AC's activities, as well as the fulfillment of the obligations deriving from the Customer's requests. Therefore, the transfer in question is necessary for the execution of the contract concluded between the Customer and AC and, in some cases, to fulfill the legal obligations to which the Data Controller is subject.

In case of transfer of personal information of data subjects outside the European Union, we undertake to:

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9. ANY AUTOMATED DECISION-MAKING PROCESSES

 

The Data Controller does not use automated decision-making processes, including the profiling referred to in article 22, paragraphs 1 and 4, of the European Regulation, without your consent.

 

If you consent to profiling, the data you provide may be used to analyze or predict preferences, behaviors and positions in order to be able to customize the content of the commercial communication and offer only dedicated offers in line with the tastes and preferences expressed, thus reducing the number of commercial communications that we will send, and offering a better flight experience.

Specifically, these processing activities involve analysis and profiling:

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Furthermore, the Data Controller, as required by art. 22, paragraph 3, of the European Regulation, implements all the most appropriate measures to protect your rights, your freedoms and your legitimate interests also within the profiling process, in addition to any further and legitimate right as better explained in the section of Paragraph 11 ("Rights of the interested party") of this Privacy Policy.

 

10. NATURE OF THE PROVISION

 

The provision of your personal data for the purposes referred to in paragraph 4.A – 4.B – 4.C – 4.D- is mandatory, as your refusal to provide the requested personal data would make it impossible for AC to provide the requested service.

The provision of personal data for the purposes referred to in paragraph 4.E is optional and the interested party always has the right to refuse such use of their personal data by the Data Controller.

The provision of personal data for the purposes referred to in paragraph 4.F is optional, but failure to provide it, while not impeding the use of the Website in any way, may not allow us to make full use of the advantages offered through the communications of an advertising, commercial and direct marketing nature, as well as to inform you about the additional services, discounts and promotions offered.

The provision of personal data for the purposes referred to in paragraph 4.G is optional, but failure to provide it prevents membership of the Program.

The provision of personal data for the purposes referred to in paragraph 4.H is mandatory, as your refusal to provide the requested personal data would make it impossible for AC to provide the requested service.

 

11. RIGHTS OF THE INTERESTED PARTY

In relation to the processing of your personal data, pursuant to the European Regulation, the interested party has the right to:

  • revoke consent to processing at any time, for all further and unnecessary processing for the purpose of providing the service contract. It should be noted, however, that the withdrawal of consent does not affect the lawfulness of the processing based on the consent before the withdrawal, as required by art. 7, paragraph 3, of the European Regulation;

  • ask the Data Controller for access to personal data, as required by art. 15 of the European Regulation;

  • obtain from the Data Controller the rectification and integration of personal data deemed inaccurate, even by providing a simple supplementary declaration, as required by art. 16 of the European Regulation;

  • obtain from the Data Controller the cancellation of personal data if there is even just one of the reasons provided for by art. 17 of the European Regulation, for all further and unnecessary processing for the purpose of providing the service contract;

  • obtain from the Data Controller the limitation of the processing of personal data if one of the hypotheses provided for by art. 18 of the European Regulation; for all further and unnecessary treatments for the purpose of providing the service contract;

  • receive from the Data Controller the personal data concerning you in a structured format, commonly used and readable by an automatic device, as well as have the right to transmit such data to another data controller without impediments, as required by art. 20 of the European Regulation;

  • oppose at any time, for reasons related to your particular situation, the processing of personal data carried out pursuant to art. 6, paragraph 1, letters e) of), including profiling on the basis of these provisions, as provided for by art. 21 of the European Regulation;

  • not be subjected to decisions based solely on automated processing, including profiling, which produce legal effects that concern you, if you have not previously and explicitly consented, as required by art. 22 of the European Regulation. By way of example but not limited to, this category includes any form of automated processing of personal data aimed at analyzing or predicting aspects concerning consumption and purchase choices, the economic situation, interests, reliability, behaviour;

  • propose a complaint to a supervisory authority, if it considers that the processing that concerns you violates the European Regulation. The complaint can be lodged in the Member State in which you habitually reside, work or in the place where the alleged violation occurred, as provided for by art. 77 of the European Regulation.

To exercise each of your rights, you can contact the Data Controller, in the person of the legal representative, by sending a communication to the registered office in Via Valosa di Sopra, n. 9. 20900 Monza (MB) - email:privacy@aircorporate.it

Alternatively, you can contact the Data Protection Officer by sending a communication to AC. Data Protection Officer, via Fiasella 1 int 18, 16121 Genova, or by sending an email to    maria.rocca@ordineavvgenova.itproviding us with the following data:

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This document is subject to change. Last revised October 18, 2022

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