(in force as of 01/05/2021)
1. This Privacy Policy shall apply to processing of personal data performed by UNION AVIATION JSC, registration No. 40203294676, legal address: Riga Airport, 4 Ziemelu Str., LV-1053, Latvia, hereinafter in the text referred to as – “the Company”, including the processing of the personal data of visitors on the Company's website www.unionaviation.aero
2. The Company is aware of importance of the personal data protection,therefore it shall take care of the proper data protection and work to comply with applicable regulatory enactments, and apply data protection regulation in its daily work.
3. The Company shall be bound by General Data Protection Regulation No. 679/2016(GDPR) of the European Parliament and the Council, and by the relevant national regulatory enactments, which stipulate the obligation to ensure the proper processing and protection of the personal data.
4. The Company shall ensure the true and correct processing of the personal data, relying on that the information and data provided by a person are accurate and true. In the event when the person indicates the data of anothe rperson (for example, within the framework of a service reservation), theCompany shall suppose that the persons, whose data are provided, haveauthorized to provide these data to the Company and have been informed andacquainted with this Privacy Policy, and agree with it.
5. The Company shall collect personal data in the following ways:
· when a person uses the Company's website www.unionaviation.aero or enters information in it;
· when the person uses the Company's flight services or one of the Company's additional services;
· when the Company receives personal data from the third parties;
· when the person has contacted one of the Company's employees by phone or e-mail;
· when the person has submitted a complaint or any other statement to the Company;
· when the person's participation has been applied for in an event organized by the Company;
· when the person attends the event organized by the Company;
· when the Company's business partner has provided information about the person as its representative;
· when the Company asks the person to provide data to authenticate the person who has made the reservation or the person named in the reservation;
· when the Company has contacted the person within the framework of cooperation communication (for example, having obtained personal contact information);
· when the Company obtains personal data from publicly available information sources.
6. The Company shall collect the following categories of personal data:
· basic data (person's name, surname, gender, age);
· identification data (date of birth, identification data, passport data, travel document data);
· contact information data (e-mail address, telephone number);
· flight data (booking information, invoice information, route);
· data on additional services (information on the additional services and the related data);
· data of special categories (information on need to use assistive means, information on need for specific medical support or use of equipment);
· accommodation information (place, duration and time of accommodation);
· settlement information (information on payments, amounts their of, bank account information);
· visual and content data (photo, video images, audio recordings, video surveillance data);
· communication data (communication language,communication channels, consents);
· web data (IP addresses, operating systems, menus made by cookies, accesses, website visit sessions, visited sections of the website, views, searched ultimate objectives);
· data on behavior (the behavior of a person who has violated the rules or otherwise created safety risks during a flight);
· authentication data (information which is obtained and processed to make sure that a particular person is the one it impersonates);
· loyalty data (information on a person's frequency of use of flights).
7. The Company shall process the personal data for such purposes and on such a legal basis:
. Conclusion and execution of a contract (to ensure a flight, luggage transportation). Legal basis – a contract with a data subject or its consent.
· Fulfillment of legal obligations (provision of information to the relevant institutions upon receipt of their respective request, sending the personal data in accordance with the law on transfer of passenger data, provision of information to the relevant institutions in connection with the carriage of passengers and luggage). Legal basis – fulfill ment of a legal obligation.
· Supervising execution of a contract (a person's behavior on an aircraft). Legal basis – execution of the contract with a data subject and of a legal obligation on ensuring flight safety.
· Ensuring aviation and personal safety. Legal basis – a legal obligation and a legitimate interest in ensuring aviation safety.
· Provision of services, their administration and improvement (in connection with the services provided by the Company and administrationtheirof). Legal basis – execution of a contract with a data subject and a legitimate interest in the improvement of the services.
· Quality and experience control and improvement (surveys,customer satisfaction evaluation). Legal basis – a legitimate interest in improving quality of the services.
· Ensuring, maintaining and improving operation of the Website, as well as ensuring continuity and safety of its operation. Legal basis – a legitimate interest in ensuring the operation, safety and improvement of the website.
· Statistics and analysis of the services and website experience. Legal basis – a legitimate interest.
· Management of claims and complaints, and recovery of losses (bringing the complaint, the claim against a person in connection with the losses caused as a result of its actions). Legal basis – a contract with a data subject.
· Administration and management of payments,settlements and transactions. Legal basis – a contract with a data subject.
· Protection of the company's legal interests. Legal basis – a contract with a data subject.
8. The Company shall retain the personal data for a period of time until the purposes, for which we shall process them, have been achieved. In this regard,the Company shall apply the following criteria when determining the period oftime for the processing and storage of the personal data:
· data shall be processed / stored for as long as necessary to achieve the purpose;
· during the period of time required to ensure compliance with the contractual obligations;
· during the period of time required to ensure the processing based on the person's submitted consent;
· during the period of time specified in the regulatory enactments;
· during the period of time required to protect the legitimate interests;
· during time limitation period, for different types of claims.
9. TheCompany shall disclose personal data to the following data recipients only when there is a legal basis for the disclosure of such data, including, in certain cases, to the data recipients outside the EU:
· state and / or local government institutions, in cases and in accordance with theprocedures specified in legislative acts;
· payment service providers;
· insurers;
· marketing service providers;
· website maintainers;
· airport service companies, ground handling service providers,
· travel agents;
· IT and telecommunication service providers and maintainers;
· hotel service providers;
· various additional service providers;
· various other aviation branch business partners;
· accountant officers, auditors, accounting and financial consultants and service providers;
· debt collectors, lawyers.
10. For the purposes of the personal data protection and safety provision, the Company shall take appropriate technical and organizational measures:
· the Company shall regularly update and inspect safety systems;
· the Company shall use various encryption solutions;
· access to the personal data shall be available only to those employees who need this information to perform their direct duties;
· the Company shall regularly organize training for its employees, on the personal data protection issues.
11. The Company shall be entitled to implement video surveillance in the Company's objects (office premises and adjacent territory) for the purpose ofensuring the security of persons, information, property, aviation andinfrastructure, prevention (including preventive measures) of illegal or otherthreats, as well as facilitating the solution of criminal offenses at the objectsand the adjacent territory.
Warning signs shall be placed in the Company's objects where video surveillance is implemented.
Video surveillance data may be disclosed only to those employees who need such information for performance of their direct duties, as well as to security,safety and consulting service providers, law enforcement authorities and in other cases when it is required by the applicable regulatory enactments.
Video surveillance recordings shall be kept for the period of time necessary to achieve the purpose, taking into account the specifics, condition sand related risks in the observed object, however, in any case, the storage period of the video surveillance recordings shall not exceed 1 (one) month.
12. Under data protection regulatory enactments,a personal data subject shall be entitled for the following:
· to request an access to its personal data;
· to oppose the processing of the personal data where it is justified by a legitimate interest;
· to revoke its consent to the data processing;
· to correct its personal data;
· to restrict the processing of the personal data;
· to request the deletion of its personal data.
13. The personal data subject may exercise its rights by submitting a written request to the Company, and such a request shall be signed with a secure electronic signature and sent to ops@unionaviation.aero, or a statement original shall be submitted at the Company's office, in paper form, with a hand written personal signature.
14. Contact information of the Company's data protection specialist:
E-mail: ops@unionaviation.aero
Address: Ziemelu street 4, Riga. Int. Airport, Marupes Parish, LV-1053, Latvia
