Effective: May 25, 2018
Welcome to Travion Ltd. (“Travion”, “we”, “us” and “our”). Travion provides software (also referred to as Flight Management System or FMS) that tracks our activities related to the services (ground support operations) you’ve ordered under our contract, helping you to stay updated on the current status of your flight(s) or other related matters.
The “Websites” means Travion’s websites (including without limitation travion.uk, db.travion.uk and any successor URLS, mobile or localized versions and related domains and subdomains), and the “Services” means Travion’s products, applications and services, in each case in whatever format they may be offered now or in the future.
Personal data we collect
When you use our Services we collect personal data about you, described below. The term “Personal Data” means any data that enables a person to be identified. Personal Data that you provide to us. We collect Personal Data that you provide to us when you sign a contract with us and/or register for an FMS account, such as your family name, first name, profile photo, postal address, email address, telephone numbers, date of birth, data relating to the services you order under the contact as well as any other information about you that you choose to provide us with.
We also collect the information that you may choose to submit to our customer support team, for example regarding a problem you are experiencing with our Services. This may include your contact information, a summary of the problem you are experiencing, and any other documentation or information that would be helpful in resolving the issue.
How we use personal data
We collect Personal Data for the following purposes:
- To provide the Services and manage your access and use of the Services, including to process transactions with you, authenticate you when you log in, provide customer support, operate and maintain the Services, follow-up of the customer relations. This processing is necessary to perform the contract with you or to take steps prior to entering into a contract at your request, or it is necessary for our legitimate interests in responding to your requests.
- To communicate directly with you, including sending you newsletters, promotions and special offers or information about current products, current services, new products and services. This use of your data is in our legitimate interest in communicating with our customers about our products and services you may be interested into. You may at any time opt out of receiving such communications by (i) clicking the unsubscribe link included in all the emails you receive or (ii) contacting us as indicated under “Contact” section below. We will send you other information on our new products or services or other promotions only with your consent (and you have the right to withdraw your consent at any time).
- To comply with our legal and regulatory obligations.
- As necessary for certain legitimate business interests, which include the following:
- To better understand how visitors interact with our Services and ensure that our Websites are presented in the most effective manner for you, and as part of our efforts to keep our Websites, network and information systems secure.
- For providing, maintaining, protecting, developing, benchmarking and improving Travion’s offerings, in particular resolving any bugs and fixes, enhancing or improving features of existing products and developing new products and capabilities.
- To conduct analytics to inform our marketing strategy and enable us to enhance and personalize our communications and the experience we offer to our users.
- To manage unpaid invoices and possible disputes about the use of our products and services.
- To share Personal Data within our affiliates and subsidiaries for internal administrative purposes.
- If you ask us to delete your data or to be removed from our marketing lists and we are required to fulfil your request, we will keep basic data to identify you and prevent further unwanted processing.
- We may anonymize, de-identify and/or aggregate the information that we collect and use such anonymized, de-identified and/or aggregated data for commercial, statistical and market research purposes, including sharing it with affiliates and business partners.
- As used above, “legitimate interests” means our interests in conducting our business, managing and delivering the best Services to you. We will not use your Personal Data for activities where the impact on you overrides our interests unless we have your consent or those activities are otherwise required or permitted by law.
- With your consent, we use Personal Data about you where you have given us consent to do so for a specific purpose not listed above. For example, with your permission, we may publish testimonials or featured customer stories on our Websites to promote the Services, including names and profile photo of representatives of our customers alongside the testimonial.
- We will inform you when requesting your Personal Data, if certain data must be provided or if it is optional. We will also inform you of the consequences should you not wish to provide this data. While providing our Services, we may collect on behalf of our customers’ information related to our customers’ employees, customers and other individuals. Our use of information on behalf of our customers is governed by our contract with the applicable customer and the customer’s own privacy policies. We are not responsible for the privacy policies or privacy practices of customers or other third parties.
Travion and GDPR
This section applies if you are an individual in the EU (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, to the extent applicable, Switzerland). Travion is compliant with the EU General Data Protection Regulation (also known as GDPR).
Travion Ltd. is the data controller for processing of your Personal Data. We act as a data processor (or service provider) in relation to the Services we provide to our Customers. Our establishment in the EU is in the United Kingdom (Travion Ltd.). To find out our registered office and how to contact us, please see the “Contact” section below.
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of personal data, username, password and other data stored on our servers.
Sensitive and private data exchanges between Travion and its users happen over a TLS secured communication channel (also known as SSL) and is encrypted and protected with digital signatures.
We may be partnered with various providers to offer a reliable service. All of our partners have a great security track record, take personal data privacy seriously, and are fully compliant with GDPR.
Subject to EU data protection law, you have the following rights in relation to your Personal Data:
- Right of access: If you ask us, we will confirm whether we are processing your Personal Data and if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
- Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
- Right to erasure: You may ask us to delete or remove your Personal Data, such as where you withdraw your consent. If we shared your data with others, we will alert them to the need for erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly.
- Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
- Right to data portability: You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you where we process that Personal Data in an automated way. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
- Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
- If we are relying on a legitimate interest to process your Personal Data — unless we demonstrate compelling legitimate grounds for the processing; or
- If we are processing your Personal Data for direct marketing (you can always object using the unsubscribe link in our marketing communications).
- Right to withdraw consent: If you have consented to our use of your Personal Data for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing of your data that has already taken place.
- Right to make a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.
To learn more about the GDPR, please, visit https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en
Disclosure of personal data
Personnel, Service Providers. Only our personnel, service providers and trusted third-party applications have access to your Personal Data. These parties include hosting, back-up and other IT services providers, website analytics companies, providers of digital advertising services, providers of CRM, marketing and sales software solutions, billing and processing payments functions. We only provide such parties with the information that they need to perform the services we have hired them to provide.
Legal Requirements. We may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation or lawful requests by public authorities, including to meet national security or law enforcement requirements, (ii) protect and defend the rights or property of Travion, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.
Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
With Your Consent: We may share Personal Data about you with third parties when you give us consent to do so. For example, with your permission, we may publish and display testimonials or featured customer stories on our Websites, including names and profile photo of representatives of our customers alongside the testimonial.
Travion may retain your Personal Data for a period of time consistent with the original purpose of collection. For instance, we may retain your Personal Data during the time you have an account to use our Websites or Services, or as agreed in our subscription agreements, and for a reasonable period of time thereafter. We also may retain your Personal Data as necessary to comply with our legal obligations, to establish proof of a right or a contract, resolve disputes, enforce our agreements, in accordance with the law.
We take all necessary precautions, as well as appropriate organizational and technical measures, to maintain the security, integrity and confidentiality of your Personal Data, and in particular to prevent it from being altered or damaged and to prevent any unauthorized third party from accessing it. We also use secured payment systems consistent with the state of the art and the applicable laws and regulations.
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Our websites’ cookies
|Purpose||Vendor||How to refuse|
|Essential website cookies: These cookies are strictly necessary to provide you with services available through our Websites and to use some of its features.||Travion Ltd.||Because these cookies are strictly necessary to deliver the Websites and the Services to you, you cannot refuse them.|
|Analytics and customization cookies: These cookies collect information that is used either in aggregate form to help us understand how our Websites are being used or how effective are marketing campaigns are, or to help us customize our Websites for you.||Google Analytics||To refuse these cookies, please follow the instructions below under the heading “Managing Cookies” Alternatively, please click on the relevant opt-out link below:|
Managing cookies: Most internet browsers allow you to erase cookies from your computer hard drive, block all cookies (or just third-party cookies) or warn you before a cookie is stored on your device. Please note, if you choose to block all cookies, our site will not function as intended and you will not be able to use or access many of the services we provide. If you have blocked all cookies and wish to make full use of the features and services we offer, you will need to enable your cookies. You can do this in your browser. Rather than blocking all cookies, you can choose to only block third-party cookies which will still allow our website to function as intended.
Have questions or concerns about Travion Ltd. and privacy? Contact us by email at firstname.lastname@example.org or by post at:
London Oxford Airport
Kidlington, OX5 1RA