This Privacy Statement sets out how Gama Aviation Plc Group and/or its subsidiary companies (referred to individually and collectively in this Privacy Statement as “we”, and terms such as “us”, “our” and any other derivative terms are interpreted accordingly) use and protect personal information that clients or prospective clients and/or others interacting with us (referred to individually and collectively in this Privacy Statement as “you”) provide to us in various means and platforms, including (but not limited to) when you travel with us or use any of our services, when you use our website, use our online help or similar facilities, or interact with us via email, or by any other means.
We are committed to ensuring that your privacy is protected, and this Privacy Statement provides a summary of the types of personal information that we collect from you and for what it is used. The accompanying Sources and Uses of Personal Information document explains this in more detail and in tabular form, making it easier to navigate. We take the privacy and security of your personal details very seriously and are committed to keeping them secure.
WHO WE ARE?
Gama Aviation Plc is a company registered in the United Kingdom with registered number 07264678. Our registered address is at 1st Floor 25 Templer Avenue, Farnborough, Hampshire, GU14 6FE, England. Gama Aviation Plc is the ultimate holding company of a group of companies, but it does not trade. It has a number of direct and indirect subsidiary companies and for the purposes of data protection law, click here to see the list of subsidiary companies covered by this Privacy Statement. We (or alternatively the one or more listed subsidiary companies that you may interact with and provide personal data to) will each be a controller of your received personal information. (The term “controller” refers to the Gama Aviation Plc group company or companies that make(s) decisions about how and why the personal data received by it is used and has/have a duty to ensure your rights are protected), and/or that we and/or the group company or companies are a processor of that information on behalf of another group company, which is the controller.
WHAT IS PERSONAL DATA?
Personal data includes details which can identify you or could be used to distinguish or trace your identity, such as your name and contact details, your travel arrangements and services purchase history.
PERSONAL INFORMATION WE COLLECT FROM YOU
1) Any information you provide to us by various means and platforms, depending on the purpose and means of contact, examples of the types of information we collect can therefore include:
• your name and job title.
• contact details such as your e-mail address and phone number.
• information you provide relating to an enquiry, or when applying for a job with us.
• information you provide when completing and managing a charter booking you have made with us or in connection with a different service you may have requested from us.
• information collected during your travel with us and your travel arrangements.
• information about the services we have provided to you in the past or in the context of enquiries for future services.
• images captured by CCTV recordings when you visit a Gama Aviation managed site.
• information to conduct KYC/AML/Security* checks where applicable.
• financial details and payment information.
*Know Your Customer / Anti-Money Laundering/National Security Vetting
2) ‘Sensitive personal data’
There are certain special categories of data, which require additional attention and protection according to European Union and UK data protection law and due to its nature, and we refer to them in this Policy Statement as ‘sensitive personal data’.
These special categories encompass information related to race, ethnicity, religion, gender, medical condition and history, and biometric information. One example of where we may collect sensitive personal data is in connection with the provision of Special Missions services such as patient transfer via air ambulance, but we will endeavour to minimise the circumstances where we collect and process sensitive personal data.
3) Information about you provided by other parties, such as companies contracted by us to provide services to you and companies involved in your travel:
• we may be provided with personal information about you to carry out a contract that we have or are proposing to enter with the third-party provider of that information, and
• if you post on one of our social media pages, we may read your post and we may collect personal information about what country, city, and general area it came from.
4) Information we collect automatically when you use our website:
• information about the device you are using to access our website, including the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform; and
• information about your visit, including services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
HOW WE USE YOUR INFORMATION
1) We only ever use your personal information with your consent, or where it is necessary to:
• enter, or perform, a contract with you or a party you are representing.
• comply with a legal duty.
• protect your vital interests; or
• for our own (or a third party’s) lawful interests, provided your rights do not override these.
In any event, we will only use your information for the purpose or purposes it was collected for (or else for closely related purposes).
2) We may use your personal information in the following ways:
• to process your travel arrangements, provide you with the information, products, and services that you request from us.
• to help keep you safe when you fly with us.
• and to meet certain legal and regulatory requirements which apply to our company.
• to direct your inquiry appropriately e.g., we may use your IP address to determine your approximate location and forward your inquiry to our business located closest to you.
• to provide you with information about other goods and services we offer that are like those that you have already enquired about or purchased.
• provide you with information about goods or services we feel may interest you, where you have consented to this.
• to ensure that content from our website is presented in the most effective manner for you and the device you are using and to keep it safe and secure.
• to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes as further explained below.
• to measure or understand the effectiveness of our communication (both on and offline) and to deliver relevant content to you, where you have agreed to receive it and
• for management and administrative purpose including to attend any job application requirements under our HR guidelines.
We will sometimes analyse the personal data we have collected about you to serve advertisements and make suggestions which are more relevant to you. We may do this by determining your current location or evaluating the history of your interactions with us.
Our website uses Google Analytics to show relevant advertisements to users who have previously visited us as they browse the web. This enables us to tailor our marketing to better suit your needs and only display ads that are relevant to you. You may see our ads in search results pages (using Google Adwords), on YouTube, in banner adverts on Gmail and on other services run by Google.
Any information collected will be used in accordance with our own Privacy Statement and Google’s own privacy statement. If you do not wish to see advertisements, you can:
DISCLOSURE OF YOUR INFORMATION
We may share your personal information with any member of the Gama Aviation Plc Group, which means the direct or indirect subsidiaries of Gama Aviation Plc (the ultimate holding company).
We may share your information with analytics, communications and search engine providers that assist us in the improvement and optimisation of our website.
We do not sell personal information to third parties, and we only allow third parties to send you marketing information where we have your consent to do so.
We may disclose your personal information to third parties for the following purposes:
• if we sell or buy any company or business/assets or enter a joint venture, where we need to disclose your personal information to the prospective seller or buyer of such business or assets or to our business partner in a joint venture business.
• if sub-contractors are engaged to perform services to be provided under a contract between you or a party you represent and a Gama Aviation Plc Group company.
• If you are a supplier or a subcontractor to a Gama Aviation Plc Group company in relation to contract for the supply of goods or services to a third party who requires such information.
• if it is required by customs and immigration authorities of any country in your itinerary or to which your flight may fly over. We are required by laws in the UK, USA, and other countries to give border control agencies and customs authorities access to booking, travel information and passport details when you fly to and from certain countries.
We may rely on legitimate interests to process your personal information, provided that your interests do not override our own.
Where we rely on legitimate interests, these interests will include:
(a) to keep our records updated and to study how our website and other services are used.
(b) to administer and protect our business and web presence (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting).
(c) to inform our marketing strategies; and
(d) to grow our business.
(e ) to provide information to government agencies as and when required.
WHERE WE STORE YOUR INFORMATION
We comply with the standard procedures and requirements as laid down by applicable law to ensure that your personal information is transmitted securely using the latest in Secure Server Technology to ensure that all your personal and transactional information is protected to the highest standards.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Any data provided or shared by email will be held in Mimecast (an email security and compliance service) and in Office 365 Exchange online. In addition, data may be recorded and held in our internal on-premises Windows server environment and in external SaaS systems as appropriate.
Additionally, the personal information that we collect from you may be transferred to, and stored at, a destination outside the UK and European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of a service, the processing of your payment details and/or the provision of support services.
In these cases, we will take all steps reasonably necessary including through the terms of the applicable subcontracts to ensure that your personal information is treated securely and in accordance with this Privacy Statement and applicable law.
If you require further information regarding the transfer of your personal information outside of the UK and EEA, please contact us by writing to our Data Protection Officer at 1st Floor 25 Templer Avenue, Farnborough, Hampshire, GU14 6FE, England, or send an email to email@example.com.
The transmission of information via the internet is not completely secure. Although we will endeavour to protect your personal information, we cannot guarantee that it will be secure whilst in transit to our website, and any transmission is at your own risk.
Once we have received your information, we use robust procedures and security features to try to prevent unauthorised access.
HOW LONG DO WE KEEP DATA?
We store personal information only if it is required for the purpose(s) we collected it for (or for a related, compatible purpose).
Even after the end your relationship with us, your data might be kept for as long as it is necessary in connection with both our and your legal rights and obligations. We may keep certain information for longer depending on the circumstances, but we will retain your personal data for a limited period only and will actively review the information we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or customer need for it to be retained.
KEEPING IN TOUCH WITH YOU
Where you agree, we would like to keep you up to date with key information about our services and promotional offers via email, post, mobile phone or otherwise, e.g., social media.
Where you agree we may do so, we may also use your details to send you information via email for research purposes. You have the right to ask us not to process your personal information for such purposes and you can change your mind at any time.
If you have registered to receive information from us, you can remove your contact details from our list by updating your account, using the ‘unsubscribe’ links at the bottom of any promotional emails we send you.
Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates.
If you follow a link to any of these websites, please note that Gama Aviation Plc has no control over third party websites, which will have their own privacy policies and that we do not accept any responsibility or liability for these policies.
Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites and such websites are not governed by this Privacy Statement. You should exercise caution and please check these policies before you submit any personal data to the websites in question.
CONTROLLING YOUR PERSONAL INFORMATION
You may choose to restrict the collection or use of your personal information in the following ways:
• whenever you are asked to fill in one of our forms, you can mark a designated box to indicate that you do not want the information to be used for direct marketing purposes; or
• if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to us at the address shown at the bottom of this website’s home page or emailing us at firstname.lastname@example.org.
• We will not sell, distribute, or lease your personal information to third parties unless we have your permission or are required by law to do so.
• where your personal information is processed based on consent, the right to withdraw that consent.
• the right to confirmation as to whether we have your personal data and, if we do, to obtain a copy of it.
• the right to have inaccurate data rectified.
• the right to object to your data being used for marketing or profiling or based on our or a third party’s legitimate interest.
• the right to restrict how your personal information is used.
• the right to request that we transfer any data that we hold on them to another company.
• the right to object certain types of processing, such as direct marketing.
• the right to be forgotten, which allows you to have your data erased in certain circumstances (though this is not an absolute right and may not apply if we need to continue using it for a lawful reason).
Please note that before we can provide you with, correct or erase any personal information that we hold about you, we will ask you to verify your identity with documentary evidence and to provide other details that will help us to verify who we are providing information to, and to help us respond to your request appropriately. We will use this information solely to verify your identity before we process your information request.
YOUR RIGHT TO COMPLAIN TO THE SUPERVISORY AUTHORITY
If you have any questions about this policy or wish to exercise any of your rights, please contact our Data Protection Officer at the address detailed below.
We strive to handle your information responsibly. If you are not satisfied about the way we do this, please contact Gama’s Data Protection Officer who will address your concerns.
However, you have a right to complain to the UK’s Supervisory Authority for data protection, the Information Commissioner, at:
Information Commissioner’s Office
CHANGES TO THIS PRIVACY STATEMENT
We may update this Privacy Statement from time-to-time by posting an updated version on our website, please check regularly to be aware of any updates.
If you have any questions about our Privacy Statement or how we use your personal information, please contact us at email@example.com or alternatively send a signed letter addressed to:
Data Protection Officer, Gama Aviation, 1st Floor 25 Templer Avenue, Farnborough, Hampshire, GU14 6FE, England.
This Privacy Statement was last updated on 19 September 2023.
Sources and use of personal information is contained within this document.
Please also see: https://ico.org.uk/media/for-organisations/documents/4019538/international-data-transfer-agreement.pdf
(H) Holding company only, which does not process personal data (except, personal data relating to its employees, if any)
(A) Active trading entity, which either does or may process employee and/or third party personal data (but those marked * may be special purpose entities)
(D) Now dormant entity, which holds third party personal data in relation to historic transactions, but which will not be used for any new business.
(H) Gama Aviation Plc
(H) Gama Group Limited
(A) Gama Aviation (UK) Limited – Business Aviation (aircraft management and charter) and Special Missions (any or all of aircraft operation, management, airworthiness management and maintenance as a package)
(A) Gama Aviation (Engineering) Limited – Engineering Service Line (aircraft maintenance, repair, engine overhaul, hangarage, named tenant in relation to virtually all UK premises other than Farnborough office and Glasgow hangars)
(A) Gama Support Services Limited – (Hangarage, ground handling services, currently the named sub-tenant in relation to the Glasgow hangars)
(A) Airops Software Limited – Technology & Outsourcing (supply of aviation-related software)
(A) Gama Aviation (Asset 2) Limited*
(A) FlyerTech Limited – Technology & Outsourcing (supply of aircraft continuing airworthiness management)
(D) Hangar 8 Management Limited
(D) International JetClub Limited
(D) Aravco Limited
(A) FlyerTech Europe Sp. z o. o. – Technology & Outsourcing (supply of aircraft continuing airworthiness management)
(A) Gama Aviation (Beauport) Limited – Business Aviation (aircraft management and charter)
(A) Gama Aviation (Engineering) Jersey Limited – Engineering Service Line (aircraft maintenance, repair, engine overhaul, hangarage, named tenant in relation to the Jersey offices and hangars)
(H) Gama Group, Inc.
(A) Gama Aviation (Engineering), Inc. – Engineering Service Line (aircraft maintenance, repair, engine overhaul)
(A) Jet East Corporate Aviation, LLC
(D) Gama Aviation (Management), Inc.
MENA Region companies
(H) Gama Group MENA FZC
(A) Gama Support Services FZE- Engineering Service Line (aircraft maintenance, repair, engine overhaul)
(A) Gama Aviation FZC – Business Aviation (aircraft management and charter)
Cayman Islands company
(A) Gama Aviation (Cayman) SEZC- Business Aviation (aircraft management and charter)