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Privacy Policy

Privacy Policy

 

Company – Who are we?

We (Flyinsite VOF) are a privately held, privately financed and consistently profitable company with headquarter in Belgium. You can reach out to us via e-mail to support@crewlounge.shop and through several social media channels.

 

Your Personal Data is processed by our company. This policy explains why and how we collect and store Personal Data and your rights in relation thereto. This policy is in line with the General Data Protection Regulation (GDPR – Europe).

 

 

Type of Data – What data do we collect from you?

We limit the collection of your Personal Data to what is necessary for performing the contractual agreement between you and us, and what is necessary to comply with legal obligations we face.

 

We collect different types of Personal Data, namely :

  • Technical Data
  • Profile Data / Identity Information
  • Financial Data

Whenever you visit the Website, we may collect:

  • Technical Data: information associated with the device you use, such as the type of device, your IP address, browser type, time, current geographical location and operating system;
  • any other Personal Data you choose to provide to us.

Whenever you fill-out the contact form on the Website or contact us via e-mail, phone, chat or social media, we may collect:

  • Profile Data and basic Identity Information you provide to us, such as: your name, function, airline company, gender, date of birth, postal address, phone number, e-mail address, your order history, contents of your shopping cart and wishlist, Facebook account, Linked-In account, interests, a picture of yourself;
  • the Content of your communication and the technical details of the communication message itself (with whom you correspond at our end, date and time, etc.);
  • your preferences regarding receiving our e-mail communications, such as newsletters, promotions, advertisements, etc.
  • publically available information of your profile on social media, when you use that channel to contact us;
  • any other Personal Data you choose to provide to us.

When you purchase physical goods, virtual goods or services, we additionally collect :

  • Minimal Financial Data that is needed for completing your order or purchase.

Data Collection – How do we collect this Data?

 

Basic identity information and Profile Data are manually registered by yourself when you create an account with CrewLounge. Profile Data can be left blank at your discretion, knowing that this may render some functions of the Services inoperative.

 

Basic identity information may also be provided to us when you choose to login to our Website or Software by using third party sign-in services, such as Facebook®, Google®, Twitter®, Linked-In® or any other Open ID provider. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form. Services like Facebook® Connect give you the option to post information about your activities to your profile page to share with others within your network.

 

Technical Data is received as soon as you connect your Devices with your account. Technical Data is collected through built-in automatic background processes on the Website, the Software and the Devices that you use.  We use analytics software to allow us to better understand the functionality of our Software on your Device. These tools record information such as how often the application is used, the events that occur within the application, aggregated usage, performance data and application malfunctions. Anonymized data is  automatically send to us with the sole purpose of monitoring the Software and fixing bugs. The same analytic data and a copy of the local database, is received by us when you contact Customer Support straight from the Software application. The files are then attached to the e-mail message that you send.

 

Financial Data is received as soon as you confirm your order on-line for purchasing any of our services.  Online payments are handled by trusted third party PSP (Payment Service Providers), typically Paypal® and Mollie®. You may also purchase some of the licenses through Apple® iTunes® and Google® Play® Services. You find the Privacy Policy of these PSP on their respective website.

 

We do not receive any details from these PSP, such as your credit card number or any pin code, other than the type of payment method you selected and whether or not the payment was successful. As such, we do not store any sensitive financial data on our own servers.

 

We will never contact you with a request to submit your credit card number or any other sensitive financial data.  Should you receive such request, consider the message as illegal and do not reply!  Instead forward the message to our Customer Support for investigation.

 

 

Purpose – Why do we collect your Data?

 

The collection and processing of your Personal Data is necessary for performing the contractual agreement between you and us, and is also necessary to allow us to comply with legal obligations.

 

We process your Personal Data (Profile Data, Identity Information, Technical Data, Financial Data) to provide you in a personalized and efficient way with the information and services you request from us through the Website, social media, via e-mail, phone or chat. It is being used in order for us to be able to pack and ship your order and to allow a tracking and tracing of the parcel.

 

Technical Data is used only for the purpose of investigating and resolving bugs with the Software and the Services.

 

Financial Data is used for, and only while completing your order.  We do not store this information.

 

We additionally process your Personal Data to comply with legal obligations and to comply with any reasonable request from competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities.

 

We may process your Personal Data for marketing purposes, in especially to provide you with targeted communications, promotions, offers and other advertisements.  By consenting to our processing of your Personal Data for sending you communications, promotions, offerings, newsletters and other advertisements via e-mail or other person-to-person electronic communication channels, you agree that we are allowed to process your Personal Data for this purpose in the manner and under the conditions outlined in this Privacy Policy.

 

Unless you are an existing customer who has already purchased similar goods or services from us and who we wish to target with our own marketing material, we will only send you communications, promotions, offerings, newsletters and other advertisements via e-mail or other person-to-person electronic communications channels if (and only if) you have explicitly consented to receive such communications, promotions, offerings, newsletters and other advertisements.

 

 

Data Storage – Where do we store your data?

 

From a geographical point of view, we process your Personal Data first and foremost within the European Economic Area.

 

However, in order to process your Personal Data for the purposes outlined above, we may transfer your Personal Data to third parties that are located outside Europe. Each entity outside Europe that processes your Personal Data shall be bound to observe adequate safeguards with regard to the processing of your Personal Data.

 

To provide you with the Services, we store, process and transmit Personal Data to different locations around the world, and outside the country of your residence. When transferring data from the European Union, the European Economic Area, and Switzerland, we rely upon a variety of legal mechanisms, including contracts with third parties, in line with the European Union – United States and the Swiss – United States Privacy Shield Frameworks.

 

From a technical point of view, your Personal Data is stored in the Cloud, with a local copy on the Devices that you use to access our Services, visit the Website or run the Software.

 

 

Data Protection – How do we protect your Data?

 

We take appropriate technical and organizational measures to keep your Personal Data safe from unauthorized access or theft, as well as accidental loss, tampering or destruction.

 

Access by our personnel, or third party processors, will only be on a need-to-know basis and subject to strict confidentiality obligations and discretion.

 

You understand, however, that safety and security are best efforts obligations only, which can never be guaranteed.  We have the obligation to inform you immediately about any data breach, should this ever occur.

 

We have implemented generally accepted modern standards of technology and operational security in order to protect Personal Data from loss, misuse, or unauthorized access, alteration or destruction.

 

Nevertheless, you must note that :

  • we have limited control over Personal Data installed on your Devices. You are fully responsible yourself for any malware or security breach that occurs on the Devices that you use !
  • internet data transmissions can never be guaranteed to be 100% secure, despite encryption technologies that we have implemented to protect your data
  • e-mail and chat communication with Customer Support is never secure

To this aim, we have appointed an internal Privacy Officer. Our Privacy Officer will supervise the processing of Personal Data, taking stock of data processing and advising on technology and security.

 

If, in spite of the above, you suspect that your data is not properly secured, has been misused or if you believe that we do not adequately guarantee the correct processing of Personal Data, please address your concern immediately to the Privacy Officer via my.privacy@crewlounge.shop.

 

 

Data Recipients – Who else has access to the Data you provide us?

 

The shipping company who is responsible for the delivery of your order has limited access to that part of your Identity Data which is required to fulfil the service (name, address, telephone number and e-mail address).

 

Furthermore, the CrewLounge suite enables you to access a wide range of applications with a single user account. When you register an account with CrewLounge, your account is valid for and visible in all modules.

 

For instance, if you are using the CrewLounge PILOTLOG module, your Profile Data will also appear in the CrewLounge CONNECT app, even if you are not using the CrewLounge CONNECT module yourself.

 

If you do not agree with this policy, you should immediately stop using the Services from CrewLounge and delete your account as explained below.

 

All other registered users of the Software have access to certain Personal Data relating to you, more specifically and limited to your name, your function, your airline company and employee ID and a picture of yourself.

 

Other Profile Data (like your place of residence, your e-mail address, your interests, etc), can also be shared with, or kept hidden from, other registered users, at your explicit discretion. You have full control over your Privacy (what information you share with who), straight from the Privacy Settings page inside the Software and/or on the Cloud. Login here to review and modify your preferences.

 

We do not distribute or sell your Personal Data to third parties, or to other users, for the purpose of marketing or data mining.  We do share basic information about your Personal Data to partners that provide services under the Trademark, as far as needed for rendering those services, such as your postal address when you order goods from “Crewlounge SHOP”.

 

We do not share your Personal Data with any third parties without your prior consent, except where necessary for the performance of this agreement or where required to do so by law, in especially :

 

  • We do pass some part of your Personal Data to other companies that we rely on to providing you with the Services of the contractual agreement. In especially services for handling secure payments with online orders, for handling support tickets, for storing large amounts of electronic cloud data, for chat messaging, and for other functions that are part of the Software, the Website or Customer Support. These third party processors are only allowed to process your Personal Data on behalf of our company upon explicit written instruction of our company. We warrant that all third party processors are selected with due care and are obliged to observe the safety and integrity of your Personal Data, in line with the European General Data Protection Regulations.
  • It is possible that we will need to disclose information about you when required by law or other legal process, or if we have a good faith belief that disclosure is reasonably necessary to investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies, or to investigate and defend ourselves against any third-party claims or allegations, or to protect the security or integrity of our Services.
  • Your Personal Data may be transmitted upon our own initiative to the police or the judicial authorities as evidence or if there are justified suspicions of an unlawful act or crime committed by you through your registration with or use of the Software, the Website, social media or other communication with us.
  • We may be required to collect and transmitted your Personal Data to the financial institution or payment service provider to allow your financial institution and the payment service provider to comply with their legal obligations, such as obligations under applicable anti-money laundering and counter-terrorism financing legislation.

Some Personal Data is shared with third parties that deliver services as subcontractor, as part of the services that we deliver to you.  By using these external services, you agree that we send limited personal data to these parties and you accept the privacy policy of the external party :

 

  • The Chat function in CrewLounge CONNECT is an in-app messaging service from a subcontractor Applozic. We send your name and your picture to this party to configure your chat account. All chat messages that you send and receive are stored and handled by AppLozic, not by us. By using the Chat function, you accept the privacy policy from AppLozic

Only with your explicit and prior consent, we may also share your Personal Data with third parties which are not necessarily part of the Services that we offer to you, such as social media.

 

We may process your Personal Data for the preservation of the legitimate interests of our company, our partners or a third party if and when your registration with or use of the Software, the Website, social media or other communication channels can be considered ;

 

  • a violation of any applicable terms of use or the intellectual property rights or any other right of a third party,
  • a threat to the security or integrity of the Software, the Website, social media or other communication channels,
  • a danger to the Software, the Website, social media or other communication channels or any of our company’s or our subcontractors’ underlying systems due to viruses, Trojan horses, spyware, malware or any other form of malicious code, or
  • in any way hateful, obscene, discriminating, racist, slanderous, spiteful, hurtful or in some other way inappropriate or illegal.

We may process your Personal Data for informing any third party in the context of a possible merger with, acquisition from/by or demerger by that third party, even if that third party is located outside the European Union.

 

We may carry-over your Personal Data to another company, in case that company acquires the Software and the Services that we offer to you today. Any other entity which buys us, or part of our business, will have the right to continue to use your data, but only in the manner set out in this Privacy Policy, or otherwise with your approval.

 

 

Data Access – How can you access the Data that we hold about you?

 

You can review, edit and delete all Personal Data yourself, either through the Software, or through the Cloud.

 

You can also send your request for access, correction, limitation or deletion to Customer Support. To establish the legitimacy of your request, we do ask you to send a copy of your identification (your passport, identity card or company badge) along with the request. We will then respond to your request as soon as possible.

 

 

Data Retention – How long do we keep hold of your Data?

 

We keep hold of your Personal Data, as long as you continue using the Services. This is valid for free users and for users with a paid subscription.

 

In case you stop using the Services, all Personal Data remains safely stored on the Cloud for a period of 18 months. This period is to make sure your data is still available should you not be using our services for any reason whatsoever and then decide to continue using or return back to our Services. After this period of 18 months (550 days of inactivity), all Personal Data (including all backups and other files) is automatically deleted and your account with CrewLounge is permanently removed.

 

Chat messages are automatically deleted after 100 days, regardless of your account being active or not active.

 

Your Personal Data are furthermore only processed up until time where you withdraw your consent for processing them. Note that withdrawal of consent may imply that you can no longer use or restore the whole or part of the Software or the Services.

 

Besides automatic deletion of your Personal Data, you can manually delete your Personal Data, at all times, as explained below.

 

Notice that, even after deleting your account, copies of your Personal Data may remain available through other channels (like social media), to the extent that it has been shared with others, it was otherwise distributed pursuant to your privacy settings, or a copy was taken and stored by other registered users whom you granted access to, or shared with, your Personal Data.

 

 

Data Removal – How can you delete your account and your data?

 

You can cancel your account and delete all Personal Data from the Cloud at any time, while the Services are still being used or when the Services are no longer used, by sending a request to Customer Support through e-mail support@crewlounge.shop.

 

You have the right to obtain a free copy of all Personal Data when you stop using the Services. You can obtain that copy by sending a request to Customer Support through e-mail support@crewlounge.shop. It speaks for itself that you must request and obtain this copy before your Personal Data is deleted from the Cloud!

 

 

Privacy Rights – What are your rights about the Data we hold on you?

 

You have the right to request access to all Personal Data processed by us pertaining to you. You have the right to receive from us, in a structured electronic format, all Personal Data you have provided to us or that we have collected about you.

 

You have the right to ask that any Personal Data pertaining to you that are inaccurate, is corrected, free of charge. If a request for correction is submitted, such request shall be accompanied of proof of the flawed nature of the data for which correction is asked.

 

You can also review, edit and delete Personal Data yourself through the Software and the Website at any time, through the ‘Delete my account’ function or by sending to Customer Support.

 

You have the right to withdraw your earlier given consent for processing your Personal Data.  You have the right to object (refuse) any kind of commercial messages (direct marketing), alerts or other notifications that we send to you.

 

You have the right to “be forgotten”, that is, you have the right to request that Personal Data pertaining to you will be deleted if they are no longer required in light of the purposes which are outlined above or if you withdraw your consent for processing them. However, you need to keep in mind that a request for deletion will be evaluated by us against overriding interests of our company or any other third party, and against legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.

 

You have the right to export and transmit your Personal Data to another company (controller), even if that company is in competition with us.

 

Instead of deletion you can also ask that we limit the processing of your Personal Data, if and when :

 

  • you contest the accuracy of that data,
  • the processing is illegitimate, or
  • the data are no longer needed for the purposes which are outlined above, but you need them to defend yourself in judicial proceedings

You have the right to oppose the processing of Personal Data if you are able to prove that there are serious and justified reasons connected with his particular circumstances that warrant such opposition. However, if the intended processing qualifies as direct marketing, you have the right to oppose such processing free of charge and without justification.

 

An e-mail or chat message requesting to exercise a right shall not be construed as consent with the processing of your Personal Data beyond what is required for handling your request. Such request should clearly state and specify which right you wish to exercise and the reasons for it if such is required. It should also be dated and signed, and accompanied by a digitally scanned copy of your valid identity card proving your identity.

 

If you wish to submit a request to exercise one or more of the rights listed above, you can contact Customer Support for all data subject rights matters.

 

We will promptly inform you of having received this request. If the request proves valid, we shall notify it as soon as reasonably possible and at the latest thirty (30) days after having received the request.

 

We reserve the right to charge an administrative fee for multiple subsequent requests for access or modification that are appear to be submitted for causing nuisance or harm to our company.

 

If you have any complaints regarding the processing of your Personal Data, please address your concern immediately to the Privacy Officer via my.privacy@crewlounge.shop.

 

If you remain unsatisfied with our response, you can file a complaint with the data protection authority in Belgium (Europe). For more information, visit http://www.privacycommission.be.  All costs associated with such complaint are at the expense of yourself.

 

 

Data Analytics – Statistical Analysis, Marketing, Direct Mailing

 

We may use anonymized Personal Data to perform statistical and graphical analysis, reports, create video tutorials and other documentation for editorial or commercial use, with the purpose of improving or further developing the Software, the Website and Customer Support.  We shall not use any images or pictures from you, without your prior written approval.

 

With your prior consent, we will contact you through e-mail with support information, notifications about the Services (or a breakdown of the Services), newsletters and commercial offers.

 

We will never contact you through phone call, video call or postal mail for the purpose of Direct Marketing.

 

Commercial (Direct Mailing) messages are in line with the Privacy and Electronic Communications Regulations (PECR). You can modify your preferences through the Notifications page in the Cloud, or by sending a request to Customer Support.

 

 

Other Data – Referral Program

 

If you choose to use our referral service to tell a friend about our Services, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the Website and create an account with us.

 

We store the information about your friend for the sole purpose of sending this one-time email and tracking the success of our referral program.  The information is automatically deleted after a period of 90 days.

 

You or your friend may contact us through the Contact form on the Website to request that we remove this information from our database, which we will then do so.

 

 

Children – Parental Control

 

We do not intend to solicit or collect Personal Information from anyone under the age of 18. If you are under 18, do not enter information on this site or engage our Services.

 

If you believe a child of yours under the age of 18 has entered Personal Information please contact us through the Contact form on the Website to request to have the data about your child removed and terminate the child’s account.

 

 

 


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