Website Privacy Notice
We are committed to protecting your personal information in accordance with applicable privacy laws, including the General Data Protection Regulation. This privacy notice applies to your use of the website (https://www.starliteaviation.com/) (the “Website”) and any communication shared between you and Starlite. This privacy notice explains how we collect and use your personal data, why we use it, and how you can contact us in relation to the use of your personal data.
- Who we are
The Starlite Aviation Group is a multi-faceted aviation company that offers a wide range of helicopter and fixed wing services worldwide, through our head office in Ireland, regional offices in South Africa and Mauritius and other locations around the world. The Website is operated by Starlite Group, (Pty) Ltd (“Starlite”, “we” or “us”), a South African company registered at Hangar 123, Virginia Airport, Durban North 4051, South Africa. Starlite is the controller of your personal data.
- How is your personal data collected?
We collect personal data: (i) through our Website; and (ii) when you communicate with us. We may sometimes collect additional information from third parties, including, for example, business partners, sub-contractors in technical services, advertising networks, analytics providers or reporting agencies.
- The purpose and legal basis for processing your personal data
Personal data, or personal information, means any information about an individual from which that person can be identified. We have detailed in the table below, your personal data which we may from time to time collect, the purpose or purposes for which we process this personal data, as well as the legal basis for such processing:
|Personal data||Purpose for Processing||Legal Basis for Processing|
|Biographical and demographic information (such as date of birth, age, gender and job title/position).||Process, evaluate and respond to requests, inquiries and applications.||In order to pursue our legitimate interests of effectively managing our business operations.|
|Contact information (such as name, phone and fax number, email and postal address) for you or for others (e.g., principals in your business).||To respond to any queries or other communications you submit to us and to conclude contracts and agreements.||In order to ensure the performance of a contract to which you are a party and to comply with our legal obligations and to pursue our legitimate interests of effectively managing our business operations.|
|Information you provide about friends or other people you would like us to contact.||To respond to any queries or other communications you submit to us.||In order to pursue our legitimate interests of effectively managing our business operations.|
|Purchase and customer service history.||To process and fulfil orders and keep you informed about the status of your order.||In order to ensure the performance of a contract to which you are a party and to comply with our legal obligations and to pursue our legitimate interests of effectively managing our business operations|
|Financial information (such as payment information, including name, billing address and payment card details (i.e., card number, expiration date and security code); bank account information; financial statements; income; and credit score).||To process and fulfil orders and keep you informed about the status of your order.||In order to ensure the performance of a contract to which you are a party and to comply with our legal obligations and to pursue our legitimate interests of effectively managing our business operations.|
|Location data (such as data derived from your IP address, country and zip code) and the precise geolocation of your mobile device where we have provided notice and choice, as appropriate.||To operate, evaluate and improve our business (such as by administering, enhancing and improving our products and services; developing new products, services and Online Channels; managing our communications and customer relationships; and performing accounting, auditing, billing, reconciliation and collection activities.||In order to pursue our legitimate interests of effectively managing our business operations.|
|Other personal information contained in content you submit to us (such as through our “How to Contact Us” feature)||To respond to any queries or other communications you submit to us.||In order to pursue our legitimate interests of effectively managing our business operations.|
- If you fail to provide personal data
If you fail to provide certain information when requested, we may not be able to perform a contract we have entered into with you (such as providing goods or services in return for payment), or we may be prevented from complying with our legal obligations.
- Automated decision-making
We do not envisage that any decisions will be taken about you using automated means.
- Recipients of personal data
We will from time to time, send personal data to certain recipients as detailed below.
- Other group companies: We may transfer your personal data to other Starlite group companies as permitted under applicable data privacy law for the legitimate interests of Starlite. You can ask for further information in relation to these group companies through the ‘Contact us’ section on the Website.
- Transfers to third parties: We may transfer your personal data to other third parties, such as governmental agencies and regulators (eg, tax authorities), social insurance carriers, courts, government authorities and to external advisors acting as controllers (eg, lawyers, accountants, auditors etc.). Such transfers are made in order to comply with our legal obligations and for the legitimate interests pursued by Starlite or a third party to ensure the effective operation of our business. You can ask for further information in relation to these third parties through the ‘Contact us’ section on the Website.
- Transfers to other service providers and business partners: Starlite may contract with other third party service providers and business partners, such as companies working with IT and cloud services, product and service providers and insurance companies. This may be done in order to ensure the performance of contracts and for our legitimate interest in effectively conducting, streamlining, operating and further improving our business. When such third party data processors process personal data on our behalf, we enter into agreements with them to ensure that they only process personal data in accordance with applicable laws.
We may also transfer or submit your personal data to a buyer / investor or potential buyer / investor in connection with a sale or other transfer of all or part of our shares, assets or business. Upon such transfer, we will take such reasonable measures to ensure that any receiving parties process your information in a manner that complies with this privacy notice. The purpose of such processing is to allow for the sale or transfer of our shares, assets or business and the legal basis for doing so is our legitimate interest in being able to manage our business by conducting such a sale or transfer.
- International transfers
We will, from time to time, send some of your personal data to other Starlite Group companies. As certain countries are not within the European Economic Area (“EEA”), this may mean that such countries are not deemed to provide an adequate level of protection for your personal information. To ensure that your personal data receives an adequate level of protection we will put in place appropriate measures for any international transfers, as provided for under data protection laws, in order to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects EU data protection laws.
- Data security
We have put in place appropriate security measures to protect your personal data, including measures preventing your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to only those employees, agents and contractors who are authorised to access your data.
- How long we retain your personal data
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
For further information on the length of time in which we may retain your personal information, please contact us using the details contained below in the ‘Contact us’ section on the Website.
- Your rights
If you are located in the EU, you have certain rights under data protection legislation as summarised below:
- Right of access: You have the right to obtain from us confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, to request access to the personal data, as well as certain information on how we are processing such data.
- Right to rectification: You have the right to obtain from us the rectification of inaccurate personal data concerning you. Considering the purpose of the processing, you may also, in some cases, be entitled to supplemental information regarding incomplete personal data.
- Right to erasure (right to be forgotten): You may, in certain circumstances, have your personal data deleted, for example if your personal information is no longer necessary in relation to the purpose for which it was collected, if you have objected to the processing of personal data and we do not have a legitimate interest which outweighs your interest, if the personal data has been processed unlawfully, or if the personal data must be deleted to comply with a legal obligation.
- Right to restriction of processing: You may require that we restrict the processing of your personal data in certain cases, for example where we no longer need your personal data but you need it to determine, enforce or defend legal claims or you have objected to processing based on our legitimate interest in order to enable us to check if our interest overrides your interest.
- Right to data portability: In some circumstances, you may be entitled to receive the personal data concerning you which you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit those personal data to another controller.
- Right to object: You have the right to object to the processing of your personal data in certain circumstances, for example where the processing is based on our legitimate interest. If so, in order to continue processing, we must be able to show compelling legitimate grounds that override your interests, rights and freedoms.
In any case, where you are located in the EU and Starlite is relying on consent to process your personal data, you have the right to change your mind and withdraw consent through the Website.
Your rights will in each case be 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 our processing of your personal data, can be obtained by contacting us using the details in the ‘Contact us’ section on the Website. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us using the details in the ‘Contact us’ section on the Website.
If you are located in the EU and have any grievance, issue or problem in respect of our handling or processing of your personal data in any way, you have the right to lodge a complaint to the Data Protection Commission, by contacting them through their website or by email: firstname.lastname@example.org.
- Additions and changes
We may change or update this privacy notice at any time. We encourage you to review this privacy notice regularly for any changes.
- Contact us
In order to make a query, raise a concern, avail of your data protection rights or for any other reason related to this privacy notice, please contact us at email@example.com.