PASSENGERS PRIVACY POLICY

PASSENGER PRIVACY NOTICE – INFORMATION DOCUMENT ART. 13 REG. EU 2016/679 GDPR – FOR THE PROCESSING OF PERSONAL DATA COLLECTED FROM THE DATA SUBJECT

In compliance with the provisions of Reg. EU 2016/679 (European Regulation for the protection of personal data), we provide you with the necessary information regarding the processing of personal data. This notice is provided pursuant to Article 13 of Reg. EU 2016/679 (European Regulation for the protection of personal data).

data controller

AVIONORD SRL, with registered office at Viale dell’Aviazione 65, 20138 Milan (MI), Email: privacy@avionord.com, represented by the Legal Representative pro tempore.

personal data processable

“Personal data”: any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, particularly by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person; (C26, C27, C30).

 

PURPOSE OF PROCESSING

LEGAL BASIS

DATA RETENTION PERIOD

NATURE OF CONFERRAL
A) Fulfillment of contractual, pre-contractual, legal, and administrative-accounting obligations Contract
Article 6, letter b) GDPR: the processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the request of the data subject.		 10 years or different legal obligation

Art. 2220 Civil Code

 Necessary for the purpose of entering into the contract between the parties and for the management of the fulfillment of administrative/accounting obligations; the refusal of the conferment will prevent the conclusion of the contract.
B) Soft spam: commercial/promotional information activities, newsletters sent via email to the email address provided during the sales process, concerning the same type of product and/or service (Soft Spam) similar to the product/service that is the subject of the sale – Article 130, paragraph 4 of Legislative Decree 196/03 / legitimate interest (Article 6, letter f) of EU Regulation 2016/679), unless opposed Legitimate interest
Article 6 letter f) and Recital 47:The processing is necessary for the purposes of the legitimate interests pursued by the data controller or a third party, provided that such interests are not overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data, taking into account the reasonable expectations of the data subject based on their relationship with the data controller.		 Until his/her opposition Optional: The data subject has the right to object at any time to the processing of their data; the objection, even if made after these email communications, will not affect the contract.

 

RECIPIENTS OR CATEGORIES OF RECIPIENTS OF THE DATA

The personal data provided will be communicated to recipients, who will process the data as data processors (Article 28 of EU Regulation 2016/679) and/or as natural persons acting under the authority of the Data Controller and the Processor (Article 29 of EU Regulation 2016/679), for the purposes outlined above. The data will be communicated to recipients based in Italy, belonging to the following categories:

  • Entities providing services for the management of the information system and communication networks (including email);
  • Firms or Companies in the context of assistance and consultancy relationships;
  • Competent authorities for compliance with legal obligations and/or provisions of public bodies, upon request;
  • In case of administrative and accounting purposes, the data may eventually be transmitted to credit reporting companies for the assessment of creditworthiness and payment habits and/or to entities for debt recovery purposes.

The entities belonging to the aforementioned categories act as Data Processors or operate independently as separate Data Controllers.

TRANSFER OF DATA TO A THIRD COUNTRY AND/OR AN INTERNATIONAL ORGANIZATION AND GUARANTEES

The personal data provided will not be transferred abroad to countries outside the EEA

RIGHTS OF THE DATA SUBJECTS

You may exercise your rights as expressed in Articles 15 and following of the GDPR by contacting the Data Controller at the email address privacy@avionord.com.

You have the right, at any time, to request access to your personal data (Article 15), rectification (Article 16), erasure of the same (Article 17), and restriction of processing (Article 18). The Data Controller shall communicate (Article 19) to each of the recipients to whom personal data has been disclosed any rectifications or erasures or restrictions on processing carried out in accordance with Article 16, Article 17, paragraph 1, and Article 18. The Data Controller will inform the data subject of such recipients if requested. Furthermore, in cases provided for by forms in specific areas, you have the right to data portability (Article 20), and in this case, your data will be provided in a structured, commonly used, and machine-readable format. You have the right to object (Article 21), at any time, to the processing of data based on legitimate interest, as well as, for forms in specific areas, to withdraw consent given without affecting the lawfulness of processing based on consent before its withdrawal.

If you believe that the processing of personal data carried out by the Data Controller is in violation of the provisions of Regulation (EU) 2016/679, the data subject has the right to lodge a complaint with the Data Protection Authority (https://www.garanteprivacy.it) or to seek appropriate judicial remedies.

Modifiche all’informativa

The Data Controller reserves the right to modify, update, add, or remove parts of this notice. To facilitate the verification and modification of the text, the notice will contain the date of the update.

Date of update: May 13, 2021

AVIONORD SRL