Privacy Policy

9. August 2023

PRIVACY POLICY

WHO WE ARE AND HOW TO CONTACT US

Contact details of the data controller: AirExplore, s. r. o., IČO: 44 168 802, Krajná 29, 821 04 Bratislava, Section Sro, File no.: 54013/B, +421 905 771 874 info@airexplore.sk (hereinafter referred to as “we”, “our”, “Company”, “Data Controller”) processes personal data of its’ customers, potential customer, employees, employee candidates, suppliers, partners etc. (hereinafter referred to as “you”, “your”) pursuant to the provisions of the legislation governing the legal protection of personal data, by applying the highest technical and legal standards of protection and taking all the necessary measures to prevent any possible personal data breach. This Privacy Policy (hereinafter referred to as “Privacy Policy”) sets out the basic rules for the collection, processing and storage of your personal data and other information related to you, the scope, purposes, sources, and recipients of your personal data, and your rights as a data subject, and any other important aspects of the use of the Company’s services. This information is important, so we hope you read it carefully.

As used herein, the term “personal data” (hereinafter referred to as “Personal Data”) means any information about you that relates to you as a natural person, a data subject whose identity is known or can be directly or indirectly identified through the use of certain data (e.g. name, surname, personal identification number, address, telephone number, etc.).

In processing the Personal Data, we responsibly comply with the Regulation No. 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC [1](hereinafter referred to as “GDPR Regulation”) and Slovak law related to protection of general data pursuant to Act No. 18/2018 Coll., the General Data Protection Regulation[2] (hereinafter referred to as „GDPR Law“) other directly applicable legislation governing the protection of Personal Data, as well as the instructions of the competent authorities. GDPR Regulation and GDPR Law together as the GDPR.

If you provide us with Personal Data other than your own (for example, you indicate a person other than the recipient), please, inform those persons of this Privacy Policy and contents hereof.

If the service user is a legal entity, this Privacy Policy applies to natural persons whose Personal Data is transferred to us by a legal entity. The user shall duly comply with Article 14 of the GDPR Regulation/ §20 of the GDPR Law and inform the data subjects (managers, recipients, representatives, etc.) about the transfer of their Personal Data to the Company.

If you have any questions about this Privacy Policy or requests regarding the processing of your Personal Data, please contact our Data Protection Officer by e-mail at: zo@eurotrading.sk or privacy@airexplore.sk .

By visiting the Company’s website and/or using the information on the website and/or our services, you acknowledge and confirm that you have read and understood this Privacy Policy.

TO WHOM THE PRIVACY POLICY APPLIES

This Privacy Policy applies to our website https://airexplore.sk/ (hereinafter referred to as “Website”) and any services provided by the Company, or other activities of the Company where Personal Data is being processed.

This Privacy Policy applies to you whenever you access the content and/or service we provide, regardless of what device (computer, mobile phone, tablet, TV, etc.) you are using.

This Privacy Policy does not apply to the links to the websites of other entities provided on our Website; therefore, we recommend that you read the privacy policies and other personal data processing rules applicable to such websites.

WHAT PRINCIPLES DO WE FOLLOW?

When processing your Personal Data, we:

will comply with the applicable and effective legislation, including GDPR Regulation and GDPR Law;
will process your Personal Data in a lawful, fair and transparent manner;
will collect your Personal Data for the specific, clearly defined and legitimate purposes and will not further process it in a way that is inconsistent with those purposes, except to the extent permitted by law;
will take all reasonable steps to ensure that Personal Data, which are inaccurate or incomplete in relation to the purposes, for which they are processed, are rectified, completed, suspended or destroyed without delay;
will keep them in such a form that your identity can be established for no longer than is necessary for the purposes, for which the Personal Data is processed;
will not disclose to, or share Personal Data with, any third parties except as provided in the Privacy Policy or applicable law;
will ensure that your Personal Data is processed in a manner that ensures adequate security of Personal Data through appropriate technical or organizational measures, including protection against unauthorized or unlawful processing of Personal Data, and against accidental loss, destruction, or damage. Contact details of our Data Protection Officer: zo@eurotrading.sk or privacy@airexplore.sk.

WHAT PERSONAL DATA, FOR WHAT PURPOSE AND BASIS DO WE PROCESS

The purpose of the processing of Personal Data. Why we process Personal Data?	The categories of processed Personal Data. What kind of categories of Personal Data we process?	On what legal basis do we process Personal Data?	The period of processing
Administration of our website	When you visit our website, data about your browsing on the Website is collected using cookies. We use necessary / technical cookies to ensure the proper functioning of the Website and / or other third-party cookies to improve your browsing experience (i.e., to consider your needs, to continuously improve the website and to make offers that suit your interests).	Data using cookies and similar technologies related to Internet browsing, etc. are collected (processed) in accordance with Article 6 Part 1. a) of the GDPR Regulation/ §13 part 1 a) of the GDPR Law, i.e., with your consent (except for necessary cookies).	You can find more information about cookies and their storage terms on our website Cookie Settings: https://airexplore.aero/cookie-policy/
Responding to your general enquiries or requests of information	Our website or other public business channels provide contacts where you can contact us to consult us on issues that concern you. We will accept, review, and respond to all your messages. If you contact us by e-mail, regular mail, or phone, we may process the following Personal Data of yours: name, surname, e-mail, phone number, postal address, information provided in your signature and the text of the correspondence and / or attached documents. This data will be processed for the administration of your enquiry. Please note that we may need to contact you to provide with a reply to your enquiry so be sure to share accurate contact data of yours.	All Personal Data you provide when communicating with us is used only for the purposes of reviewing, and responding messages, administering (managing) communication flows and providing you with a response. We will process the said Personal Data in accordance with Article 6 Part 1. a) of the GDPR Regulation/ §13 part 1 a) of the GDPR Law, i.e., with your consent, which you express by contacting us by e-mail, mail, or phone.	Communication with you will be handled until the enquiry is fully processed and stored for one year from the date of the last communication with you unless there is another legitimate purpose for storing it longer (e. g. business contract with you has been concluded and communication material can be considered as the proof of negotiation).
Drawing up and executing contracts for the purchase and sale of services	We may process name, surname, contact information, position in the company you represent, signature, other information required for negotiations, concluding, and performing of contracts.	We will process in accordance with Article 6 Part 1. b) of the GDPR, i. e. to conclude a contract with you and perform it, as well as Article 6 Part 1. c) of the GDPR., i.e., we are subject to a legal obligation to keep contracts and accounting documents and Article 6 Part 1. f) of the GDPR, i.e., our legitimate interest in asserting and / or defending our legal claims (where applicable).	Contracts and accounting documents (in physical and electronic form) are kept for 10 years from the date of full performance of the contract.
Onboarding and due diligence procedure for counterparties	Depending on whether a counterparty is a natural person or legal entity and if the latter depending on your status in the company, we may process the following personal data: Name, surname, date of birth, nationality, occupation, valid ID/passport number, data on whether the client is a politically exposed person, residential and registered address details, phone number, e-mail address, bank information (account number), relationship with the third party (if payment will be made by the third party), source of funds/wealth (if payment will be made in cash), signature, role/position in the company, occupation, information about reputation from public sources. We also process personal data collected within provided copies of documents: Identity Card or Passport; Official documents of authorities verifying the identity and the place of residence; Documentation proving the source of funds/wealth; Articles of Association authorizing the representative of a legal entity; Certificate of Incorporation or its equivalent; Certificate of Directors or copy of CEO (or other principal management body) appointment document.	Personal data for onboarding and due diligence is processed in accordance with: – Article 6 Part 1. c) of the GDPR, i.e., our legal obligation to monitor and implement the international and/or national sanctions. – Article 6 Part 1. f) of the GDPR, i.e., our legitimate interest to fulfil the requirements for money laundering and financing terrorism prevention, prevention of corruption, bribery, and fraud to be legitimate, reliable, and reputable business to our counterparties and authorities.	We will process for no longer than 5 years unless longer storage of personal data and related documents will be required by applicable laws, legal regulations, or institutional/state authorities, or will be necessary for the defence in the judicial process.
Whistleblowing Policy – prevention of adverse effects to whistle-blower, investigation of disclosure and perpetrated or suspected infringement.	We may process name, surname, contact information, position in the company, other information provided voluntarily by a whistle-blower or processed by ASG or any of its subsidiaries – for the purpose of investigation of the perpetrated or suspected infringement. In principle, we do not request or process any special categories of personal data (e.g., information about health, racial and/or ethnic origin, religious and/or ideological convictions, trade union membership or sexual orientation), unless such special categories of personal data are voluntarily disclosed by the whistle-blower or other concerned persons.	Your personal data shall be processed in accordance with: – Article 6 Part 1. c) of the GDPR, i.e., legal obligation to establish an internal reporting channel to which we are subject. – Article 6 Part 1. f) of the GDPR, i.e., our legitimate interest to handle fraud, corruption or other wrongdoings in the Company and to defend against requirements and/or claims and investigations of the competent authorities, litigations (if any) or, if necessary, to keep such data regarding possible investigations on allegedly illegal or criminal acts.	We will process your personal data collected during the whistleblowing procedure no longer than 5 years unless longer storage of personal data and related documents will be required by applicable laws, legal regulations, or authorities, or will be necessary for the judicial process. For more details of personal data processing for whistleblowing procedure please check https://airexplore.aero/wp-content/uploads/2024/02/Whistleblowing-policy-003.pdf
Selection of candidates for employees (recruiting)	Considering the requirements of the position applied we may collect, assess, and store the following personal data about you: name, surname, age or date of birth, your e-mail address, phone number, address of the place of residence, information on language proficiency, computer skills, information about expected salary, educational background, profession, working experience and projects you have been involved with, attended courses, training sessions, seminars, development of qualification, licenses held, accumulated hours on A/C and other information regarding flights (for pilots and cabin crew), social media accounts, pictures and other information that you may wish to provide in your CV, motivation letter, interviews, also our remarks and assessment of your suitability to perform the duties of a particular position.	We will process the said personal data in accordance with: – Article 6 Part 1. a) of the GDPR, i.e., with your consent, which we presume when you proactively apply for a job or when we get information about your candidacy data from job search portals, recruiting agencies or from publicly accessible sources, business-related social media or platforms we presume that you are aware and consented or there is an assessed legitimate interest where you had the right to object. – Article 6 Part 1. f) of the GDPR, i.e., our legitimate interest to have a common and coordinated policy on the selection of personnel and human resources management and to share the information about your candidacy within other Avia Solutions Group companies.	We will process the personal information for the recruiting process for 6 (six) months from getting your application unless the selection process continues longer than the indicated period. When you are unsuccessful in your application for a concrete position and you do not object for further sharing your data within all Avia Solutions Group companies or you provide your candidacy information to dispose to Avia Solutions Group companies by your consent the personal data will be stored for 3 years from the end of selection process for the position you applied or from receiving the data.

Please be additionally advised that if you do not provide Personal Data, the provision of which to the Company is necessary to ensure compliance with the requirements of legal acts and / or the conclusion and / or performance of the contract, we will not be able to provide you with services or conclude another transaction.

We also particularly note that when you contact details are processed for direct marketing you may at any time refuse our newsletters or other promotional messages by clicking on a link in our outgoing newsletters and/or messages or write privacy@airexplore.sk

Be informed as well that we will retain your Personal Data for as long as necessary to achieve and fulfil the purposes following the terms set out in this Privacy Policy, unless longer storage of Personal Data and related documents is required by applicable laws and regulations or is required for the defense of the Company’s legitimate interests in judicial, other public institutions etc. We ensure and take all necessary measures to avoid storing outdated or unnecessary Personal Data about you.

OUR LEGITIMATE INTEREST

Please know that “Legitimate interest” means our interest to enhance our services, products, to manage the processes of businesses and activities. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests.

HOW DO WE PROTECT YOUR DATA?

We responsibly implement the appropriate technical and organizational data security measures designed to protect Personal Data against accidental or unlawful destruction, alteration, and disclosure, as well as against any other unlawful processing. The security measures we put in place include the protection of employees, information, IT infrastructure, internal and public networks, as well as office buildings and technical equipment.

In the event of a Personal Data breach that could seriously jeopardize your rights or freedoms, and after becoming aware of the circumstances, under which the unauthorized access to Personal Data was obtained, we will inform you without delay.

TO WHOM YOUR DATA IS DISCLOSED

We may share some of your Personal Data with the following categories of third parties:

any Avia Solutions Group company[3] (listed at https://aviasg.com/en/the-group/general-contacts) for the purposes set out herein (for example, for the purposes of contract performance and customer relationship management, onboarding and due diligence of the counterparty, whistleblowing policy, recruitment);
agents acting on our behalf in connection with the promotion of our services in specific territories;
companies providing the data centers, hosting, cloud, site management and related services; companies developing, providing, maintaining and developing software; companies providing the information technology infrastructure services; companies providing communication services;
companies issuing the credit and debit cards that are used to process payment transactions related to the provision of our services, banks and other credit and/or payment companies;
our professional advisors, auditors, lawyers and/or financial advisors;
our other service providers (data processors) or our subcontractors;
notaries, if the contract concluded with you requires a notarial form;
court officials; entities providing legal and/or debt recovery services; subrogation of the right to claim;
companies providing the advertising and marketing services;
companies providing archiving, physical and/or electronic security, asset management and/or other business services;
pursuant to the law, the state institutions, facilities, etc.;
law enforcement authorities, at their request or on their own initiative, if suspecting that a criminal offence has been committed, as well as courts and other dispute resolution bodies; tax administrators;
in the event of a corporate restructuring, transfer/acquisition and/or transfer/acquisition of the business to a third party that obtains and processes Personal Data for the same purposes as set out herein, and/or performs due diligence by our and/or their legal and/or financial advisors, etc.

DATA TRANSFER OUTSIDE OF THE EUROPEAN ECONOMIC AREA

Your Personal Data are generally processed in countries of the European Economic Area (hereinafter referred to as “EEA”). However, in certain cases, your Personal Data may be transferred to the countries outside the EEA. Please, note that Personal Data may be subject to less protection in the countries outside than within the EEA, but we carefully evaluate the conditions, under which this data will be processed and stored when transferred to the above entities.

Please, note that if the European Commission has determined that a third country, territory or one or more designated sectors in that third country or international organization provides an adequate level of protection for Personal Data, the transfer must take place in the same way as in the EEA. Please, be informed that the information on the countries, in respect of which the European Commission decision has been adopted, can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.

In other cases, we take all necessary measures to ensure the secure transfer of your Personal Data to the recipient, who processes it. Tools we use: the contract with the non-European recipient of the Personal Data contains specific provisions on secure data processing. In certain cases, we ask for your consent to the transfer of your data outside the Slovak Republic or the EEA.

DO WE USE AUTOMATED DECISION-MAKING OR PROFILING?

We do not usually use any automated decision-making under Article 22 of the GDPR Regulation/ §28 GDPR Law to initiate and implement the contractual relationships. If we apply this procedure on a case-by-case basis, we will inform you separately if required by law.

We process your Personal Data in a partially automated manner in order to assess certain personal aspects (hereinafter referred to as “Profiling”). For example, we use Profiling when we are required to do so by law, to prevent money laundering or to manage financial risk.

GUARANTEED RIGHTS

We guarantee the exercise of the following rights and the provision of all related information at your request or in case of your questions:

to know (be informed) about the processing of your Personal Data;
to gain access to your Personal Data processed by the Data Controller;
to request the rectification or completion, modification of your inaccurate/incomplete Personal Data;
to request the destruction of Personal Data when they are no longer necessary for the purposes, for which they were collected;
to request the destruction of Personal Data if it was processed unlawfully, or if you withdraw your consent to the processing of Personal Data or do not provide such consent, if necessary;
not to consent to the processing of Personal Data, or to withdraw the consent previously given;
to request the provision of your Personal Data in an easy-to-read format as agreed by you or for the performance of a contract, if technically feasible, or to request the transfer of the data to another controller.

If you wish to exercise your rights, please, send us a request by email at zo@eurotrading.sk or privacy@airexplore.sk or come directly to the Company at Krajná 29, Bratislava 821 04.

Upon receipt of your request, we may ask you to provide proof of your identity or other identifying information to ensure that we are exercising your rights as a data subject, and to prevent the unauthorized disclosure of Personal Data or information to others, who are not entitled to it. If we cannot identify you, we will not be able to exercise your rights as a data subject.

We provide information about the processing of your Personal Data free of charge. If your request is unfounded, repetitive or excessive, we may charge a fee equivalent to our administrative costs.

Upon receipt of your request, we will respond to you within thirty (30) calendar days of receipt of your request, and from the due date for submission of all documents necessary to prepare a response.

In exceptional circumstances, which may require additional time, the deadline for responding may be extended by a further two (2) months depending on the complexity of the situation. In such case, the data subject shall be informed in writing of such extension within one (1) month of receipt of the request, along with reasons for the delay. If we believe it is necessary, we will stop processing your Personal Data, except for storing it, until we have resolved your request. If you have lawfully withdrawn your consent, we will immediately cease processing your Personal Data within thirty (30) calendar days at the latest, except as set out herein, and unless we are required by law to continue to process your Personal Data under applicable law, legal obligations we face, court decisions, or binding instructions from the authorities. The response will be given in the same way as your request was received.

If we refuse to comply with your request, we will clearly state the reasons for such refusal.

If you disagree with our action or the response to your request, you can lodge a complaint with the relevant national authority (list of supervisory authorities by EU country: https://edpb.europa.eu/about-edpb/board/members_en). In all cases, we recommend that you contact us before making a formal complaint so that we can find the right solution.

WHAT HAPPENS IF OUR COMPANY CHANGES ITS OWNER?

From time to time, we may expand or limit the scope of our business activities, which may include the sale and/or transfer of control of all or part of our business. Where relevant to any part of our business that is being transferred, any Personal Data provided by you will be transferred with that part; the new owner or a new controlling party will have the right to use that data only for the same purposes, for which we originally collected it, subject to the terms hereof.

LINKS TO OTHER WEBSITES

Our Website may contain links to other websites that are not operated by us. We have no control over how such websites collect, store or use your data; we encourage you to check their privacy policies before providing any information to such websites.

SOCIAL NETWORKS

When you visit social networks, your Personal Data is processed by the specific social network; we start processing your Personal Data when you visit AirExplore, s. r. o. on social networks. We want to introduce you to our wide range of services/products and exchange views with you on important topics through various social media channels.

Your Personal Data provided on the social network is processed for the following purposes:

communication with visitors to our social networks;
answers to visitors’ questions;
gathering statistical information;
conducting customer surveys, marketing campaigns, market analyses, sweepstakes, contests, or similar promotions or events;
if necessary, defending the legitimate interests of the Company in institutions and other cases;

Unless explicitly stated otherwise, the legal basis for the processing of data is referred to in Article 6 part 1 point (f) of the GDPR Regulation/ §13 part 1 point (f) of the GDPR Law. We have a legitimate interest in being able to respond to your messages or queries and to analyze our availability on social networks, to present our products and services. If you wish to enter into a contractual relationship with us upon your request, the legal basis for such processing is referred to in Article 6 part 1 point (b) of the GDPR Regulation/ §13 part 1 point (b) GDPR Law.

If we intend to process your Personal Data for any other purpose not listed above, we will inform you before such processing.

Our social networking sites are managed by specific social networks; when you visit them, the processing of your Personal Data is governed by the privacy policies of the social networking sites. In some social networks, we are considered to be joint data controllers depending on the social network’s policies, purposes and scope of processing.

Currently we use these social networks:

FB: https://www.facebook.com/airexploreairlines
Linkedin: https://www.linkedin.com/company/airexplore
Instagram: https://www.instagram.com/airexploreairlines/
Youtube: https://www.youtube.com/@airexplore7998/
X platform: https://twitter.com/airexplore

Name of the social network and its Privacy Policy	Personal Data we process	Personal Data we process as joint data controllers
Facebook You can read their privacy policy by clicking here: https://www.facebook.com/policy.php	Your Facebook name, surname or username, when you comment, react to the publication, share posts, write us messages, Your activities on our site, e.g. Your page views, duration statistics, query, comment information, and more.	We use statistical information (visits to our website, range of contributions, visits and average video transmission times, information about the countries and cities from which our visitors come, age range, gender). We receive anonymous statistics from Facebook through their service. The data controllers’ agreement can be found here: https://www.facebook.com/legal/terms/page_controller_addendum.
Instagram You can read their privacy policy by clicking here: https://help.instagram.com/519522125107875/?helpref=uf_share	Your Instagram name, surname or username, when you comment, react to the publication, share posts, share content in stories section, write us messages, Your activities on our site, e.g. Your page views, duration statistics, query, comment information, and more.	We use statistical information (visits to our website, range of contributions, visits and average video transmission times, information about the countries and cities from which our visitors come, age range, gender). We receive anonymous statistics from Instagram through their service. The data controllers’ agreement can be found here: https://help.instagram.com/494561080557017/?helpref=hc_fnav.
LinkedIn You can read their privacy policy by clicking here: https://www.linkedin.com/legal/privacy-policy	Your LinkedIn name, surname or username, when you comment, react to the publication, share posts, write us messages, Your location indicated on the personal account, Your activities on our site, e.g. Your page views, duration statistics, query, comment information, and more.	We use statistical information (visits to our website, range of contributions, visits and average video transmission times, information about the countries and cities from which our visitors come, age range, gender). We receive anonymous statistics from LinkedIn through their service. The data controllers’ agreement can be found here: https://www.linkedin.com/legal/l/dpa.
X (ex Twitter) You can read their privacy policy by clicking here: https://x.com/en/privacy	Your X name, surname or username, when you post, share, quote, mention, write us messages, Your activities on our site, e.g. Your page views, duration statistics, query, comment information, and more.	We use statistical information (visits to our website, range of contributions, visits and average video transmission times, information about the countries and cities from which our visitors come, age range, gender). We receive anonymous statistics from X platform through their service. The data controllers’ agreement can be found here: https://gdpr.x.com/en/controller-to-controller-transfers.html
YouTube You can read their privacy policy by clicking here: https://www.youtube.com/howyoutubeworks/our-commitments/protecting-user-data/	Your YouTube name, surname or username, when you comment, interact with content.	If you are logged in with YouTube, you agree to YouTubes terms of use, privacy and cookie policies and to YouTubes processing of your personal data, at which we have no control over. If you are not registered with YouTube, YouTube may still perform statistical analysis of your personal data when you access our YouTube channel and provide us with anonymized statistics on this. We use statistical information. Processed data types: – Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers); – Content data (videos etc.); – Usage data (e.g. websites visited, interest in content, access times, video views, video likes, comments, purchases etc.), meta/communication data (e.g. device information, IP addresses). Video Statistics: – Number of subscribers and changes – Watch time data (duration, stoppage time, retention rate) – Demographics (gender distribution, age, places of origin, use of devices etc.) We receive anonymous statistics from Youtube through their service. The data controllers’ agreement can be found here: https://business.safety.google/controllerterms/

CHANGES TO OUR PRIVACY POLICY

We reserve the right to unilaterally change this Privacy Policy from time to time (for example, in the event of a change in the law). Any changes will be posted immediately on our Website. We encourage you to check this page regularly to keep up-to-date.

This Privacy Policy applies from the date of publication hereof on the Website. The latest revision of the Privacy Policy: 12.11.2024. If you continue to use our services (such as the Website) after the terms of the Privacy Policy has changed, you will be deemed to have read and understood the changed terms of the Privacy Policy.

AirExplore, s. r. o., a private limited liability company, established and acting under the laws of the Republic of Slovak, ID: 44168802, registration address Krajná 29, 821 04 Bratislava; +421 905 771874; info@airexplore.sk

[1] Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 94/46/EC (General Data Protection Regulation)

[2] ZÁKON z 29. novembra 2017 o ochrane osobných údajov a o zmene a doplnení niektorých zákonov, https://www.slov-lex.sk/pravne-predpisy/SK/ZZ/2018/18/20180525

[3] AVIA SOLUTIONS GROUP PLC, a private limited liability company, established and acting under the laws of the Republic of Ireland, registration code 727348, registration address Building 9, Vantage West, Central park, Dublin 18, D18 FT0C.