Last updated: January 2019
CDB Aviation group of companies (“we” or “us”) may have your information because you are a director, officer, candidate, employee, agent and / or authorised signatory of our customers, suppliers, service providers, vendors and other commercial partners, and because we need to use that information for the purposes of and in connection with our dealings with those commercial entities and operating our business. This privacy statement explains how we will manage your Personal Data, why we use it, and how you may contact us in relation to the use of your Personal Data.
Types of Information We Collect
We collect information, which includes Personal Data, about directors, officers, employees, agents and / or authorised signatories of CDB Aviation’s customers, prospective customers, suppliers, service providers, vendors and other commercial partners (“Individuals”) for the purposes of and in connection with CDB Aviation’s dealings with those relevant commercial entities. You may be such an Individual.
Personal Data means any information which CDB Aviation has or obtains, or which you provide to CDB Aviation, and may include your name, address, email address, phone number(s), title or position, from which you can be directly or indirectly personally identified.
We may also collect data that includes the name of pages (URLs) that you view on our websites and whether or not you open or click-through to read marketing emails sent to you.
We may also collect certain statistical and other analytical information collected on an aggregate basis relating to all visitors to the website. This Non-Personal Data comprises information that cannot be used to identify or contact you, such as demographic information regarding browser types, mobile device equipment, mobile network and other anonymous statistical data involving the use of the website. We collect this information to help us monitor traffic and enhance your experience of the website.
Please see further detail on this in our Cookie Notice.
How We Obtain Your Information
We will obtain some of your Personal Data directly from you where we interact directly with you in the course of our business. We may also obtain Personal Data directly from you through the website, such as (i) when you sign up to our mailing list, (ii) when you sign up to receive marketing materials or attend a webinar, or (iii) when you apply for a position with CDB Aviation.
This information may also be collected indirectly from a variety of sources, such as the commercial entity which you represent, and publicly available sources including media reports and social media, such as LinkedIn with which you interact.
Use of Personal Data and Basis of Processing
We will use the Personal Data where necessary:
- where we have a legitimate purpose in using it, including:
- for the purposes of managing our contracts and relationships with our customers, suppliers, service providers, vendors and other commercial partners;
- for day to day operational and business purposes;
- board reporting and management purposes, including quality assurance;
- in the event of a merger, reorganisation or disposal of, or a proposed merger, reorganisation of disposal of CDB Aviation;
- to take advice from our external legal and other advisors;
- for compliance with our legal obligations, including:
- compliance with applicable tax and regulatory reporting obligations;
- where we are ordered to disclose information by a court with appropriate jurisdiction;
- where necessary to establish, exercise or defend legal rights or for the purpose of legal proceedings;
- where you have consented to use of your Personal Data for a particular purpose. If you have given us consent to use your Personal Data for a particular purpose, you have the right at any time to withdraw consent to the future use of your Personal Data for some or all of those purposes by writing to the address specified below.
Applicants for jobs
Where you, or a third party recruitment agent acting for you, provide us with your CV and other Personal Data through our website, we will use that information solely for the purposes of considering your application for a position with CDB Aviation, including checking your references, and keeping you informed of career opportunities and for hiring purposes. This may include providing such data to external consultants who assist us in our hiring processes. However, we will only hold Personal Data of applicants for positions for a period of 12 months from our final interaction with a candidate during the recruitment process. You may withdraw your consent to this processing at any time by emailing Careers@CDBAviation.aero. If you are a successful candidate, some of the Personal Data we obtain during the recruitment process will be held on your personnel file, which will be subject to our separate employee privacy statement.
Sharing Personal Data
We will not disclose any Personal Data to any third party, except as outlined above and / or as follows:
- to enable us to carry out the obligations under and enforce our contracts with our customers, suppliers, service providers, vendors and other commercial partners;
- to anyone providing a service to us or acting as our agent, as data processors, for the purposes of providing services to us and on the understanding that they will keep the Personal Data confidential;
- where we need to share Personal Data with our auditors, and legal and other advisors;
- in the event of a merger or proposed merger, any (or any proposed) transferee of, or successor in title to, the whole or any part of CDB Aviation’s business, and their respective officers, employees, agents and advisers, to the extent necessary to give effect to such merger;
- if the disclosure is required by law or regulation, or court or administrative order having force of law, or is required to be made to any of our regulators.
Personal Data may be transferred outside the European Economic Area (the “EEA”) in connection with the uses described above, where you have explicitly consented, and / or as otherwise required or permitted by law.
Many of the countries will be within the EEA, or will be ones which the European Commission has approved, and will have data protection laws which are the same as or broadly equivalent to those in the European Union. However, some transfers may be to countries which do not have equivalent protections, and in that case we shall use reasonable efforts to implement contractual protections for the Personal Data. While this may not always be possible, any transfers will be done in accordance with applicable data protection laws, including through the implementation of appropriate or suitable safeguards in accordance with such applicable data protection laws.
Third Party Providers of Information
We may obtain Personal Data relating to you indirectly, such as where your employer provides your contact details to us in connection with our business dealings. The person providing the information will be asked to warrant that it will only do so in accordance with applicable data protection laws, and that it will ensure that before doing so, any individuals in question are made aware of the fact that we will hold information relating to them and that we may use it for any of the purposes set out in this privacy statement, and where necessary that it will obtain consent to our use of the information.
Recipient of the Personal Data
In any case where we share Personal Data with a third party data controller (including, as appropriate, our service providers), the use by that third party of the Personal Data will be subject to the third party’s own privacy policies.
Updates to Personal Data
We will use reasonable efforts to keep Personal Data up to date. However, you will need to notify us without delay in the event of any change in your personal or business circumstances, so that we can keep the Personal Data up to date.
Retention of Personal Data
We are obliged to retain certain information to ensure accuracy, to help maintain quality of service and for legal and regulatory purposes, and for legitimate business purposes.
Information will be retained for no longer than is necessary for the purpose for which it was obtained by us or as required or permitted for legal and regulatory purposes, and for legitimate business purposes. In general, we (or our service providers on our behalf) will hold this information for a period of seven years after you cease to interact with CDB Aviation, unless we are obliged to hold it for a longer period under law or applicable regulations.
Your Rights in relation to your Personal Data
You may at any time request a copy of your Personal Data from CDB Aviation. This right can be exercised by writing to CDB Aviation at the address specified below.
You also have the right to correct any inaccuracies in, and in certain circumstances, to request erasure, or restriction on the use, of your Personal Data, and to object to certain uses of your Personal Data, in each case subject to the restrictions set out in applicable data protection laws. Further information on these rights, and the circumstances in which they may arise in connection with CDB Aviation’s processing of Personal Data can be obtained by writing to CDB Aviation at the address specified below.
In any case where we are relying on your consent to process your Personal Data, you have the right to change your mind and withdraw consent by writing to the address specified below.
Where we are relying on a legitimate purpose of CDB Aviation or a third party recipient of the Personal Data, in order to use and disclose Personal Data, you are entitled to object to such use or disclosure of your Personal Data, and if you do object, we will cease to use and process the Personal Data for that purpose unless we can show there are compelling legitimate reasons for us to continue or we need to use the Personal Data for the purposes of legal claims.
You also have the right to lodge a complaint about the processing of your Personal Data by CDB Aviation with the Data Protection Commission at Canal House, Station Road, Portarlington, Co. Laois, R32 AP23, Ireland or firstname.lastname@example.org.
Contacting CDB Aviation
Any queries or complaints regarding our use of your Personal Data and / or the exercise of individual rights should be addressed to CDB Aviation at 1GQ, George’s Quay, Dublin 2.
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