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Privacy Policy

 

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1. Introduction

This Policy outlines the obligations of Fly Pro SRL, a company registered in the Republic of Moldova, with its office located at Dacia street, 35, Chisinau, MD 2060 (“the Company”), in relation to data protection and the rights of benefactors, members, associates, and beneficiaries (“data subjects”) concerning their personal data under applicable Data Protection Law. This includes all current and future legislation and regulations governing the use of personal data and the privacy of electronic communications, such as the EU Regulation 2016/679 General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 (for UK-related data), and any successor legislation or directly applicable EU laws as long as EU law remains enforceable in the UK.

This Policy establishes the Company’s commitments concerning the collection, processing, transfer, storage, and disposal of personal data. These procedures and principles apply at all times to the Company, its employees, agents, contractors, or any other parties acting on the Company’s behalf, including when working remotely.

2. Definitions

  • “consent”: A freely given, specific, informed, and unambiguous indication by the data subject, given through a statement or a clear affirmative action, that they agree to the processing of their personal data.
  • “data controller”: An individual or organisation that determines the purposes and methods of processing personal data. In this Policy, the Company is the data controller of all personal data it handles for business and operational purposes.
  • “data processor”: A person or organisation that processes personal data on behalf of a data controller.
  • “data subject”: Any living individual identifiable by the personal data held by the Company.
  • “EEA”: The European Economic Area, including all EU Member States, Iceland, Liechtenstein, and Norway.
  • “personal data”: Information relating to an identifiable individual, either directly or indirectly, through identifiers such as names, ID numbers, location data, online identifiers, or attributes tied to that person’s physical, economic, cultural, or social identity.
  • “personal data breach”: Any security incident leading to the accidental or unlawful destruction, loss, alteration, or unauthorised disclosure or access to personal data.
  • “processing”: Any operation performed on personal data, whether automated or manual, including collection, recording, organisation, storage, alteration, retrieval, consultation, use, dissemination, restriction, or destruction.
  • “pseudonymisation”: The process of modifying personal data so that it cannot be linked to a specific individual without additional information, which must be stored separately with protective measures in place.
  • “special category personal data”: Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health information, sexual orientation, or biometric or genetic data.

3. Scope

3.1 The Company is committed not only to the legal requirements of data protection but also to upholding the spirit of these laws by treating all personal data with care, lawfulness, and fairness, and by respecting the privacy and rights of all individuals.

3.2 The Company recognises the value of flexible working arrangements, particularly remote work, in supporting employee well-being. Nonetheless, personal data must continue to be safeguarded, and individuals’ rights must be upheld in line with this Policy.

3.3 The Company’s Data Protection Officer (DPO) can be reached at otc@flypro.aero. The DPO is responsible for overseeing this Policy and any related policies, procedures, or guidance.

3.4 All Directors and associates are responsible for ensuring that all staff, agents, contractors, and third parties working with the Company understand and follow this Policy. Where applicable, suitable processes, controls, and training—especially for remote workers—must be implemented.

3.5 Any queries regarding this Policy or data protection matters should be directed to the Data Protection Officer. The DPO should especially be consulted in the following scenarios:

  • a) Uncertainty about the legal basis for data collection or processing.
  • b) When consent is the basis for processing.
  • c) Questions about data retention timelines.
  • d) Need for new or updated privacy notices.
  • e) Requests from data subjects to exercise their rights (e.g., access requests).
  • f) A suspected or actual personal data breach.
  • g) Questions about security measures for data protection.
  • h) Implementation of data protection in remote working environments.
  • i) Sharing of personal data with third parties (controllers or processors).
  • j) Data transfers outside the EEA.
  • k) Significant new data processing activities or changes requiring a Data Protection Impact Assessment.
  • l) Changes in the purpose of data use from that originally stated.
  • m) Plans to carry out automated processing or decision-making.
  • n) Compliance with rules on direct marketing.

4. The Data Protection Principles

This Policy is designed to ensure compliance with applicable Data Protection Law. The GDPR defines the following key principles, all of which must be upheld by those processing personal data. The Company, as a data controller, is responsible for and must be able to demonstrate compliance with these principles:

  • 4.1 Personal data must be processed lawfully, fairly, and transparently.
  • 4.2 Data must be collected for specific, explicit, and legitimate purposes and not used in a manner incompatible with those purposes. Processing for public interest archiving, scientific or historical research, or statistical analysis is not considered incompatible.
  • 4.3 Personal data must be adequate, relevant, and limited to what is necessary for the stated purposes.
  • 4.4 Personal data must be accurate and kept up to date. Every reasonable step must be taken to erase or rectify inaccurate data without delay.
  • 4.5 Personal data should be kept in a form permitting identification of data subjects for no longer than necessary. Longer storage is permitted only for archiving in the public interest, scientific or historical research, or statistical purposes, subject to appropriate safeguards.
  • 4.6 Personal data must be processed securely, with appropriate technical and organisational measures to protect against unauthorised or unlawful processing, loss, destruction, or damage.

5. The Rights of Data Subjects

The GDPR sets out the following key rights applicable to data subjects:

  1. The right to be informed;
  2. The right of access;
  3. The right to rectification;
  4. The right to erasure (also known as the ‘right to be forgotten’);
  5. The right to restrict processing;
  6. The right to data portability;
  7. The right to object; and
  8. Rights with respect to automated decision-making and profiling.

6. Lawful, Fair, and Transparent Data Processing

6.1 Data Protection Law seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. Specifically, the GDPR states that processing of personal data shall be lawful if at least one of the following applies:

  1. The data subject has given consent to the processing of their personal data for one or more specific purposes;
  2. The processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract;
  3. The processing is necessary for compliance with a legal obligation to which the data controller is subject;
  4. The processing is necessary to protect the vital interests of the data subject or of another natural person;
  5. The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller; or
  6. The processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

6.2 If the personal data in question is special category personal data (also known as “sensitive personal data”), at least one of the following conditions must be met:

  1. The data subject has given their explicit consent to the processing of such data for one or more specified purposes (the law prohibits them from doing so);
  2. The processing is necessary for the purpose of carrying out the obligations and exercising specific rights of the data controller or of the data subject in the field of employment, social security, and social protection law (insofar as it is authorised law);
  3. The processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent;
  4. The data controller is a foundation, association, or other non-profit body with a political, philosophical, religious, or trade union aim, and the processing is carried out in the course of its legitimate activities, provided that the processing relates solely to the members or former members of that body or to persons who have regular contact with it in connection with its purposes and that the personal data is not disclosed outside the body without the consent of the data subjects;
  5. The processing relates to personal data which is manifestly made public by the data subject;
  6. The processing is necessary for the conduct of legal claims or whenever courts are acting in their judicial capacity;
  7. The processing is necessary for substantial public interest reasons, on the basis of law which shall be proportionate to the aim pursued, shall respect the essence of the right to data protection, and shall provide for suitable and specific measures to safeguard the fundamental rights and interests of the data subject;
  8. The processing is necessary for the purposes of preventative or occupational medicine, for the assessment of the working capacity of an employee, for medical diagnosis, for the provision of health or social care or treatment, or the management of health or social care systems or services on the basis of law or pursuant to a contract with a health professional, subject to further conditions and safeguards set out in Data Protection Law;
  9. The processing is necessary for public interest reasons in the area of public health, for example, protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject (in particular, professional secrecy); or
  10. The processing is necessary for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes with a basis in law which shall be proportionate to the aim pursued, respect the essence of the right to data protection, and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

7. Consent

If consent is relied upon as the lawful basis for collecting, holding, and/or processing personal data, the following shall apply:

  1. Consent is a clear indication by the data subject that they agree to the processing of their personal data. Such a clear indication may take the form of a statement or a positive action. Silence, pre-ticked boxes, or inactivity are unlikely to amount to consent.
  2. Where consent is given in a document which includes other matters, the section dealing with consent must be kept clearly separate from such other matters.
  3. Data subjects are free to withdraw consent at any time and it must be made easy for them to do so. If a data subject withdraws consent, their request must be honoured promptly.
  4. If personal data is to be processed for a different purpose that is incompatible with the purpose or purposes for which that personal data was originally collected that was not disclosed to the data subject when they first provided their consent, consent to the new purpose or purposes may need to be obtained from the data subject.
  5. If special category personal data is processed, the Company shall normally rely on a lawful basis other than explicit consent. If explicit consent is relied upon, the data subject in question must be issued with a suitable privacy notice in order to capture their consent.
  6. In all cases where consent is relied upon as the lawful basis for collecting, holding, and/or processing personal data, records must be kept of all consents obtained in order to ensure that the Company can demonstrate its compliance with consent requirements.

8. Specified, Explicit, and Legitimate Purposes

8.1 The Company collects and processes the personal data set out in Part 24 of this Policy. This includes:

  1. Personal data collected directly from data subjects; and
  2. Personal data obtained from third parties.

8.2 The Company only collects, processes, and holds personal data for the specific purposes set out in Part 24 of this Policy (or for other purposes expressly permitted by Data Protection Law).

8.3 Data subjects must be kept informed at all times of the purpose or purposes for which the Company uses their personal data. Please refer to Part 15 for more information on keeping data subjects informed.

9. Adequate, Relevant, and Limited Data Processing

9.1 The Company will only collect and process personal data for and to the extent necessary for the specific purpose or purposes of which data subjects have been informed (or will be informed) as under Part 8, above, and as set out in Part 24, below.

9.2 Employees, agents, contractors, or other parties working on behalf of the Company may collect personal data only to the extent required for the performance of their job duties and only in accordance with this Policy. Excessive personal data must not be collected.

9.3 Employees, agents, contractors, or other parties working on behalf of the Company may process personal data only when the performance of their job duties requires it. Personal data held by the Company cannot be processed for any unrelated reasons.

10. Accuracy of Data and Keeping Data Up to Date

10.1 The Company shall ensure that all personal data collected, processed, and held by it is kept accurate and up to date. This includes, but is not limited to, the rectification of personal data at the request of a data subject, as set out in Part 17, below.

10.2 The accuracy of personal data shall be checked when it is collected and at regular intervals thereafter. If any personal data is found to be inaccurate or out-of-date, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.

11. Data Retention

11.1 The Company shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed.

11.2 When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay. Further detail is provided in Part 27 of this Policy (including the disposal of personal data for home workers) and in our Data Retention Policy.

11.3 For full details of the Company’s approach to data retention, including retention periods for specific personal data types held by the Company, please refer to our Data Retention Policy.

12. Secure Processing

12.1 Fly Pro SRL shall ensure that all personal data collected, held, and processed is maintained securely and protected against unauthorized or unlawful processing, as well as against accidental loss, destruction, or damage. Further details on the technical and organizational measures implemented can be found in Parts 25 to 30 of this Policy.

12.2 All technical and organizational measures taken to protect personal data will be regularly reviewed and evaluated to ensure their continued effectiveness and to maintain the security of personal data.

12.3 Data security will be upheld at all times by safeguarding the confidentiality, integrity, and availability of personal data through the following principles:

  • a) Access to and use of personal data shall be granted only to authorized individuals with a legitimate need;
  • b) Personal data must be accurate and appropriate for the purposes for which it is collected, held, and processed;
  • c) Authorized users must always have timely access to personal data as needed for the purposes for which they are authorized.

13. Accountability and Record-Keeping

13.1 The Data Protection Officer (DPO) of Fly Pro SRL is responsible for overseeing the administration of this Policy and for developing and implementing related policies, procedures, and guidelines.

13.2 Fly Pro SRL adopts a privacy by design approach in all activities involving personal data collection, holding, and processing. Data Protection Impact Assessments (DPIAs) will be conducted when any processing poses a significant risk to data subjects’ rights and freedoms (see Part 14).

13.3 All employees, agents, contractors, and other representatives working on behalf of Fly Pro SRL shall receive appropriate training on data protection and privacy, including relevant aspects of Data Protection Law and this Policy.

13.4 Regular Data Protection Audits will be conducted to assess and ensure compliance with data protection requirements.

13.5 Fly Pro SRL shall maintain written internal records of all personal data processing activities, including:

  • 13.5.1 Company details, including the DPO and any third-party data transfers (e.g., data processors and other controllers);
  • 13.5.2 Purposes for which personal data is collected, held, and processed;
  • 13.5.3 Legal basis or bases for processing personal data, including consent mechanisms and records thereof;
  • 13.5.4 Categories of personal data and data subjects involved;
  • 13.5.5 Details of any transfers of personal data outside the EEA, including safeguards;
  • 13.5.6 Retention periods for personal data (refer to Fly Pro SRL’s Data Retention Policy);
  • 13.5.7 Locations where personal data is stored;
  • 13.5.8 Descriptions of technical and organizational security measures applied.

14. Data Protection Impact Assessments and Privacy by Design

14.1 In line with privacy by design principles, Fly Pro SRL will perform Data Protection Impact Assessments (DPIAs) for any new projects or uses of personal data involving new technologies or where processing is likely to pose a high risk to data subjects’ rights and freedoms.

14.2 Privacy by design principles will be integrated throughout all stages of data processing, taking into account:

  • a) The nature, scope, context, and purposes of processing;
  • b) The latest technical and organizational measures available;
  • c) The costs of implementing such measures;
  • d) Risks to data subjects and Fly Pro SRL, including their likelihood and severity.

14.3 DPIAs, overseen by the Data Protection Officer, will include consideration of:

  • a) Types of personal data involved;
  • b) Processing purposes;
  • c) Company objectives;
  • d) Data usage methods;
  • e) Parties consulted internally and externally;
  • f) Necessity and proportionality of the processing;
  • g) Risks to data subjects;
  • h) Risks to Fly Pro SRL;
  • i) Proposed risk mitigation measures.

15. Keeping Data Subjects Informed

15.1 Fly Pro SRL will provide the information set out below to every data subject:

  • a) When personal data is collected directly from data subjects, they will be informed of the purpose at the time of collection;
  • b) When personal data is obtained from third parties, data subjects will be informed of the purpose:
    • i) When the Company first communicates with the data subject;
    • ii) Before the personal data is transferred to another party;
    • iii) As soon as reasonably possible, and no later than one month after the data is obtained.

15.2 The information provided in the privacy notice will include:

  • a) Fly Pro SRL’s identity and contact details, including those of the Data Protection Officer;
  • b) Purpose(s) for collecting and processing personal data (as detailed in Part 24) and the lawful basis for such processing;
  • c) Where relevant, the legitimate interests justifying data processing;
  • d) If data is not collected directly, the categories of personal data processed;
  • e) Details of third parties to whom personal data may be transferred;
  • f) Information on transfers outside the EEA, including safeguards in place;
  • g) Retention periods applicable to personal data;
  • h) Data subject rights under applicable data protection laws;
  • i) The right to withdraw consent at any time, if applicable;
  • j) The right to lodge complaints with the Information Commissioner’s Office or relevant supervisory authority;
  • k) Source of personal data if not collected directly from the data subject;
  • l) Any legal or contractual obligations necessitating the collection of personal data and consequences of refusal;
  • m) Information about automated decision-making or profiling, including how decisions are made and their potential effects.

16. Data Subject Access

16.1 Data subjects may make subject access requests (“SARs”) at any time to find out more about the personal data which the Company holds about them, what it is doing with that personal data, and why.

16.2 Anyone wishing to make a SAR should do so using a Subject Access Request Form, sending the form to the Company’s Data Protection Officer at the registered Company address.

16.3 Responses to SARs must normally be made within one month of receipt; however, this may be extended by up to two months if the SAR is complex and/or numerous requests are made. If such additional time is required, the data subject shall be informed.

16.4 All SARs received shall be handled by the Company’s Data Protection Officer.

16.5 All employees, agents, contractors, or other parties working on behalf of the Company from home must ensure that all personal data they are working with is kept organised and, wherever possible, only stored and processed to enable rapid search and retrieval, and must cooperate fully with the Company’s Data Protection Officer in handling any SAR received within the time limit.

16.6 The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.

17. Rectification of Personal Data

17.1 Data subjects have the right to require the Company to rectify any of their personal data that is inaccurate or incomplete.

17.2 The Company shall rectify the personal data in question, and inform the data subject of that rectification, within one month of the data subject informing the Company of the issue. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.

17.3 In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification that must be made to that personal data.

17.4 All employees, agents, contractors, or other parties working on behalf of the Company from home must ensure that all personal data they are working with is kept organised and, wherever possible, only stored and processed to enable rapid and/or centralised rectification, and must cooperate fully with the Company’s Data Protection Officer in ensuring that any personal data held by them at home is rectified within the time limit.

18. Erasure of Personal Data

18.1 Data subjects have the right to request that the Company erases the personal data it holds about them in the following circumstances:

  • a) It is no longer necessary for the Company to hold that personal data with respect to the purpose(s) for which it was originally collected or processed;
  • b) The data subject wishes to withdraw their consent to the Company holding and processing their personal data;
  • c) The data subject objects to the Company holding and processing their personal data (and there is no overriding legitimate interest to allow the Company to continue doing so) (see Part 21 of this Policy for further details concerning the right to object);
  • d) The personal data has been processed unlawfully;
  • e) The personal data needs to be erased in order for the Company to comply with a particular legal obligation.

18.2 Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.

18.3 In the event that any personal data that is to be erased in response to a data subject’s request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).

18.4 All employees, agents, contractors, or other parties working on behalf of the Company from home must ensure that all personal data they are working with is kept organised and, wherever possible, only stored and processed to enable rapid and/or centralised erasure, and must cooperate fully with the Company’s Data Protection Officer in ensuring that any personal data held by them at home is erased within the time limit.

19. Restriction of Personal Data Processing

19.1 Data subjects may request that the Company ceases processing the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount of personal data concerning that data subject (if any) that is necessary to ensure that the personal data in question is not processed further.

19.2 In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).

19.3 All employees, agents, contractors, or other parties working on behalf of the Company from home must ensure that all personal data they are working with is kept organised and, wherever possible, only stored and processed to enable the rapid and/or centralised application of restrictions, and must cooperate fully with the Company’s Data Protection Officer in ensuring that any personal data held by them at home is not processed further (including, where appropriate, erasing such data from computers or devices used at home).

20. Objections to Personal Data Processing

20.1 Data subjects have the right to object to the Company processing their personal data based on legitimate interests, for direct marketing (including profiling), and processing for scientific and/or historical research and statistics purposes.

20.2 Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing immediately, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights, and freedoms, or that the processing is necessary for the conduct of legal claims.

20.3 Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing promptly.

21. Direct Marketing

21.1 The Company is subject to certain rules and regulations when marketing its services.

21.2 The prior consent of data subjects is required for electronic direct marketing including email, text messaging, and automated telephone calls subject to the following limited exception:

  • 21.2a The Company may send marketing text messages or emails to a customer provided that that customer’s contact details have been obtained in the course of a sale, the marketing relates to similar products or services, and the customer in question has been given the opportunity to opt-out of marketing when their details were first collected and in every subsequent communication from the Company.

21.3 The right to object to direct marketing shall be explicitly offered to data subjects in a clear and intelligible manner and must be kept separate from other information in order to preserve its clarity.

21.4 If a data subject objects to direct marketing, their request must be complied with promptly. A limited amount of personal data may be retained in such circumstances to the extent required to ensure that the data subject’s marketing preferences continue to be complied with.

22. Personal Data Collected, Held, and Processed

The following personal data is collected, held, and processed by the Company (for details of data retention, please refer to the Company’s Data Retention Policy):

  • 22.1 Comments:
    When visitors leave comments on the site, we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
    An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/.
    After approval of your comment, your profile picture is visible to the public in the context of your comment.
  • 22.2 Media:
    If you upload images or other media to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website. All uploaded media is visible to any other website visitor except that uploaded to private pages.
  • 22.3 Cookies:
    If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
    If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
    When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
    If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
    This site adds the following cookies to help users resume job submissions that they have started but have not completed: wp-job-manager-submitting-job-id and wp-job-manager-submitting-job-key
  • 22.4 Embedded content from other websites:
    Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
    These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
  • 22.5 Registration Data:
    When you complete a registration form on this website, we store the information that you give us in our database. The storage and manipulation of this data is governed by this privacy policy.
  • 22.6 Contribution Data:
    We collect information about you during the contribution process on our website. This information may include, but is not limited to, your name, address, phone number, credit card/payment details and any other details that might be requested from you for the purpose of processing your contributions.
    Handling this data allows us to:
    – Send you important account/contribution/service information.
    – Respond to your queries, refund requests or complaints.
    – Process payments and prevent fraudulent transactions. We do this on the basis of our legitimate organisational interests.
    – Set up and administer your account, provide technical and donor support, and to verify your identity.
    Additionally, we may also collect the following information:
    – Your comments if you choose to leave them on our website.
    – Cookies which are essential to keep track of your contribution history whilst your session is active. This allows you to access your contribution receipt without being a registered, logged in user.
    – Account E-mail/Password to allow access to your account, if you have one.
    – If you choose to create an account with us, your name, address, e-mail and phone number, which will be used to populate the contribution form for future contributions.
  • 22.7 Payment Data:
    If you make payment by entering your credit card and billing information directly on https://kurahumanfactors.com, the credit card information won’t be stored but it will be shared through a secure connection with the following payment gateways to process the payment:
    • Stripe — https://stripe.com/us/privacy/
  • 22.8 Listing Data:
    This website currently does not support listing. Should this change in the future, the following will be how the data will be managed. When you submit a listing, the content of the listing and its metadata are retained indefinitely. All users can see, edit, or delete the personal information included on their listings at any time. Website administrators can also see and edit that information.
    Website visitors can see the contact name, website URL, phone number, address and other information included in your submission to describe the listing.
  • 22.9 Google Web Fonts:
    For uniform representation of fonts, this page uses web fonts provided by Google. When you open a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly.
    For this purpose, your browser has to establish a direct connection to Google servers. Google thus becomes aware that our web page was accessed via your IP address. The use of Google Web fonts is done in the interest of a uniform and attractive presentation of our plugin. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO.
    If your browser does not support web fonts, a standard font is used by your computer.
    Further information about handling user data, can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy at https://www.google.com/policies/privacy/.
  • 22.10 HubSpot:
    We share the data collected via our forms with the Dynamics 365 Subscription Service. This service allows us to create and share marketing, sales, and customer service content. The Subscription Service can also be used to help organize sales data about our sales pipeline (e.g., leads, customers, deals, etc.). The information added to the Subscription Service, either by site visitors providing their contact information or when we add the information, is stored and managed on our service providers’ servers. Dynamics provides the Subscription Service to us for our own marketing, sales, CRM, and customer service needs. Full details of the HubSpot Privacy Policy can be found at Dynamics 365 privacy, data security, and GDPR compliance | Microsoft Learn
  • 22.11 Google Services
    Our website uses Google services to improve our content. To integrate these services, your web browser automatically sends certain information to Google. This includes the URL of the page you are visiting and your IP address. Google may also set cookies on your browser or read cookies that are already there. Google uses the information shared by us to deliver their services, maintain and improve them, develop new services, measure the effectiveness of advertising, protect against fraud and abuse, and personalize content and ads you see on Google and on our partners’ sites and apps. See Google’s Privacy Policy to learn more about how they process data for each of these purposes.

23. Data Security – Transferring Personal Data and Communications

The Company shall ensure that the following measures are taken with respect to all communications and other transfers involving personal data:

  • 23.1 All emails containing personal data must be encrypted using password protected documents;
  • 23.2 Employees, agents, contractors, or other parties working on behalf of the Company working from home should, whenever possible and practical, only access and process personal data when required;
  • 23.3 All emails containing personal data must be marked “confidential”;
  • 23.4 Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances.

All employees, agents, contractors, or other parties working on behalf of the Company working from home must ensure that their home network is secure at all times and that, where applicable and reasonably possible, any and all security software or firmware updates for network equipment such as modems and routers are installed. Advice and assistance is available from the Company’s Data Protection Officer. Personal data should not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;

  • 23.5 Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted;
  • 23.6 Where personal data is to be transferred in hardcopy form it should be passed directly to the recipient or sent using Royal Mail Special Delivery service;
  • 23.7 All personal data to be transferred physically, whether in hardcopy form or on removable electronic media shall be transferred in a suitable container marked “confidential”;

24. Data Security – Storage

The Company shall ensure that the following measures are taken with respect to the storage of personal data:

  • 24.1 All electronic copies of personal data should be stored securely using passwords;
  • 24.2 All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet, or similar;
  • 24.3 The storage of personal data on mobile devices (including, but not limited to, laptops, tablets, and smartphones), whether such device belongs to the Company or otherwise, should be limited to the extent absolutely necessary for the performance of the relevant work;
  • 24.4 Personal data may only be transferred to, stored on, accessed from, or processed on devices personally belonging to employees to the extent absolutely necessary for the performance of the relevant work, and only where the work in question is being undertaken by a home worker. In the case of devices belonging to agents, contractors, or other parties working on behalf of the Company, personal data may only be transferred to, stored on, accessed from, or processed on such devices where the party in question has agreed to comply fully with the letter and spirit of this Policy and Data Protection Law (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken);

25. Data Security – Disposal

  • 25.1 When any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of.
  • 25.2 Personal data stored electronically should be securely erased using industry standard deletion programs.
  • 25.3 Personal data stored in hardcopy form should be disposed of using cross paper shredding device. Employees, agents, contractors, or other parties working on behalf of the Company working from home should only dispose of personal data stored in hardcopy form at home if it is possible to do so as described above. If it is not possible to do so, such personal data should be retained securely until it is possible to dispose of it in the correct way, for example, at the Company’s premises and should under no circumstances be disposed of in normal household rubbish or recycling.
  • 25.4 For further information on the deletion and disposal of personal data, please refer to the Company’s Data Retention Policy.

26. Data Security – Use of Personal Data

The Company shall ensure that the following measures are taken with respect to the use of personal data:

  • 26.1 No personal data may be shared informally and if an employee, agent, contractor, or other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from the Data Protection Officer;
  • 26.2 No personal data may be transferred to any employee, agent, contractor, or other party, whether such parties are working on behalf of the Company or not, without the authorisation of the Data Protection Officer;
  • 26.3 Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, contractors, or other parties at any time;
  • 26.4 If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it;
  • 26.5 All employees, agents, contractors, or other parties working on behalf of the Company working from home must ensure that they use all reasonable efforts to comply with Parts 28.3 and 28.4 above including, for example, setting aside a specific room or part of their home (ideally behind a lockable door, in a room with lockable windows) for home working, particularly when handling personal data. The Company recognises that home workers may not always be able to ensure a degree of security comparable to the Company’s premises, but all reasonably practicable efforts should be made to ensure the best security possible in the circumstances;
  • 26.6 Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of the user to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS;

27. Data Security – IT Security

The Company shall ensure that the following measures are taken with respect to IT and information security:

  1. All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols;
  2. Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method;
  3. All software (including, but not limited to, applications and operating systems) installed on IT equipment personally belonging to employees, agents, contractors, or other parties working on behalf of the Company working from home should be kept up-to-date by the home worker in question. Software updates should be installed as they become available or, as applicable, when automatically scheduled on the computer or device in question. Advice and assistance is available from the Company’s Data Protection Officer.

28. Organisational Measures

The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:

  1. All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under Data Protection Law and under this Policy, and shall be provided with a copy of this Policy;
  2. Only employees, agents, contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;
  3. All sharing of personal data shall comply with the information provided to the relevant data subjects and, if required, the consent of such data subjects shall be obtained prior to the sharing of their personal data;
  4. All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;
  5. All employees, agents, contractors, or other parties working on behalf of the Company handling personal data (including those working from home) will be appropriately supervised via appropriate methods;
  6. All employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to personal data, whether in the workplace or otherwise;
  7. Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;
  8. All personal data held by the Company shall be reviewed periodically, as set out in the Company’s Data Retention Policy;
  9. The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;
  10. All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of Data Protection Law and this Policy by contract;
  11. All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and Data Protection Law;
  12. Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure;

29. Transferring Personal Data to a Country Outside the EEA

  1. The Company may from time to time transfer (‘transfer’ includes making available remotely) personal data to countries outside of the EEA.
  2. The transfer of personal data to a country outside of the EEA shall take place only if one or more of the following applies:
    1. the transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that the European Commission has determined ensures an adequate level of protection for personal data;
    2. the transfer is to a country (or international organisation) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses adopted by the European Commission; compliance with an approved code of conduct approved by a supervisory authority (e.g. the Information Commissioner’s Office); certification under an approved certification mechanism (as provided for in Data Protection Law); contractual clauses agreed and authorised by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;
    3. the transfer is made with the informed and explicit consent of the relevant data subject(s);
    4. the transfer is necessary for the performance of a contract between the data subject and the Company (or for pre-contractual steps taken at the request of the data subject);
    5. the transfer is necessary for important public interest reasons;
    6. the transfer is necessary for the conduct of legal claims;
    7. the transfer is necessary to protect the vital interests of the data subject or other individuals where the data subject is physically or legally unable to give their consent; or
    8. the transfer is made from a register that, under UK or EU law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.

30. Data Breach Notification

  1. All personal data breaches must be reported immediately to the Company’s Data Protection Officer. This includes personal data breaches which relate to personal data being handled by employees, agents, contractors, or other parties working on behalf of the Company from home, using either personal computers or devices or those provided by the Company.
  2. If an employee, agent, contractor, or other party working on behalf of the Company becomes aware of or suspects that a personal data breach has occurred, they must not attempt to investigate it themselves. Any and all evidence relating to the personal data breach in question should be carefully retained.
  3. If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the Data Protection Officer must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.
  4. In the event that a personal data breach is likely to result in a high risk (that is, a higher risk than that described under Part 32.3) to the rights and freedoms of data subjects, the Data Protection Officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.
  5. Data breach notifications shall include the following information:
    1. The categories and approximate number of data subjects concerned;
    2. The categories and approximate number of personal data records concerned;
    3. The name and contact details of the Company’s Data Protection Officer (or other contact point where more information can be obtained);
    4. The likely consequences of the breach;
    5. Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.
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