1.4. airBaltic knows the importance of personal data protection in this modern information age. airBaltic understands that appropriate data protection has impact on trust of its customers and employees, as well as on reputation and sustainability of the company. Therefore, airBaltic pays attention to appropriate data protection and is working to comply with the applicable regulatory enactments and apply data protection regulations in everyday work.
1.5. airBaltic is a subject to the General Data Protection Regulation No. 679/2016 (GDPR) of the European Parliament and of the Council as well as relevant national regulatory enactments, which impose obligations to ensure appropriate processing and protection of personal data. airBaltic aims to ensure inter alia:
- Lawfulness – airBaltic respects data protection and privacy laws and aim to comply with obligation provided by such laws;
- Security – airBaltic aims to protect personal data pursuant to the industry standards, including having access control in place and encryption solutions, as well as updating security measures when necessary to comply with industry standards.
1.6. We aim to ensure processing of accurate and true personal data. However – as it is in any relationships – also in our cooperation you may help us to achieve this. Therefore, each time you provide us with your data, please verify accuracy of such information with due care, for example, when you make reservation or apply for any service, in particular, when you provide airBaltic with contact information. We rely that information provided by you is accurate and true. If you notice any mistake, please feel free to contact us as soon as possible in order we could make appropriate changes to the data and thus ensuring processing of accurate data, in particular – accurate contact details. In case you mistakenly indicate wrong contact details, information on service may be sent to wrong recipient and accordingly you may not receive important information from us concerning the service (e.g. flight).
We collect information about you in the following ways:
- you visit websites on any airBaltic Training domain or enter information into them;
- you send us an inquiry about or an application for training;
- you sign the Training Service Agreement;
- you act as an instructor during our training;
- you subscribe to to newsletters;
- you purchase the services.
- third parties provide us with information about you;
- you talk with us or our agents and employees on the phone or contact them by e-mail;
- you file a claim or any other request with us, or you have contacted us;
- your participation is registered for event organized by us;
- you participate in any event organized by us;
- our partner has shared information about you as its representative;
- we may ask you to provide us with data for autentification purposes and to verify whether you are a person who made reservation or to verify whether you are the individual who you declare to be;
- we may contact you in course of cooperation or corporate communication (for example, we may obtain contact information);
- you ask us to delivery to someone package or your data are on the package (when we offer such services).
Information provided by you:
- Name, surname, personal identity number;
- Date of birth;
- Place of birth;
- Phone number;
- Home address;
- Information about your education;
- Your medical records;
- Information about your criminal records;
- Details from your passport and flight crew license;
- Your flight and training records if you apply for a type rating training.
In general, we shall store your personal data until we have fulfilled the purpose, for which the data has been collected, e.g. after your Training Service Agreement becomes invalid. We shall store information, which you have provided to us based on consent, until you revoke it.
In this regard we apply the following criteria when we determine period of time for processing and storage of the data:
4.1. we process/store the data until fulfilment of the purpose;
4.2. period of time, which is necessary to ensure fulfilment of contractual relationships, for example, to allow you to use the service and provide the service for you;
4.3. period of time necessary to ensure processing, which is based on your consent. If the consent is withdrawn, processing, which is based on such a consent, is terminated;
4.4. period of time necessary to protect lawful interests, including period of time necessary to review and resolve the dispute or claim, as well as period of time necessary to prove that appropriate processing was carried out and appropriate measures taken (including, to have proofs to present to appropriate competent authorities that airBaltic Training has complied with its lawful obligations);
4.5. limitation period for different requests and claims, including those, which may be addressed towards airBaltic Training by data subject and those, which airBaltic Training may address to data subjects when exercising its lawful rights – for example, requesting data subject to cover the debt;
4.6. period of time during which a person or authority may exercise its rights and contact airBaltic Training.
We have implemented various tools and services that facilitate our cooperation and communication and achievement of purposes of personal data processing. Therefore, we may disclose your data to the categories of data recipient as mentioned below.
Please note that we disclose your personal data only when there is a legal ground for disclosure of data.
The categories of data recipients:
5.1. we may disclose your data to medical institutions or other training providers, if it is necessary to assess your eligibility to participate in the training, to perform the contract or to record your flights and training in Flight Logger.
5.2. we may disclose your data to communication services providers like hotels, insurers and IT support companies and the headquarters of our group of companies – Air Baltic Corporation.
5.3. we may disclose your data to auditors, service provider of accountancy and financial services, as well as payment service providers (for example, to bank or other financial institution) to ensure payment;
5.4. we may disclose your data to marketing service providers, for example, companies which provide consultations on marketing, IT solutions for marketing needs, service providers, which ensures solution for sending newsletters, offers and information (Mailchimp service provider, Rocket Science Group LLC service provider, which data centres are located outside European Union in United States of America, information on privacy protection measures are available at: https://mailchimp.com/legal/privacy/ . Rocket Science Group LLC, MailChimp are relying on Standard Contractual Clauses approved by European Union’s Commission to protection personal data, when data are transferred to USA;
5.5. we may disclose your data to partners, which provide us with the following services – insurance services providers, IT service and support providers and telecommunication companies.
5.6. your data may be disclosed to the website service providers, with whom we have concluded the agreement to ensure operation of the website;
5.6. hotels and accommodation service providers may receive information about you in some specific cases, for example, you are representative of our partner and we have arrangement that we will organize accommodation reservation for you.
5.7. social network and social media as categories of data recipients, for example, Facebook, Google or other social media. We may provide you with an opportunity to access social media by using our website. As well as we may ensure you with an opportunity to access your account within airBaltic loyalty program by using autentification provided by social media – in such a case we may receive data you have allowed us to receive according to the privacy setting of the respective social media service. Similarly as other companies, we may introduce scripts on or website, which becomes active when you have consented to certain preferences at our website (cookies and other technologies), thus providing consent on sharing such data. In such a case information you have entered in our website may be sent to such service providers in accordance to the preferences you have accepted(cookies and other technologies), further appropriate information may be reflected in your social network and media profiles according to the services offered by such social network or media service provider (for example, in your profile of the relevant social media, advertisement may be reflected, which corresponds to your latest searches in our website). More detailed information on such social network and media services you may acquire by approaching your social network and media service provider and in accordance to your privacy settings with such service providers.
5.8.we may disclose personal data in certain cases to consultants, debt recovery service providers, lawyers;
Our partners are always obliged to adequately safeguard your personal information and process it in accordance with instructions stated in our mutual agreement.
We do not share personal information with unaffiliated third parties, except as necessary for our legitimate professional and business interests, to carry out your requests, and/or as required or permitted by law or professional standards. We do not sell personal information to any third parties. In addition, air Baltic Training SIA will not transfer the personal information you provide to any third parties for their own direct marketing use.
We apply technical and organizational measures to protect your privacy and data.
We update and test our security technology on a regular basis. We restrict access to your personal data only to authorized staff in order to provide services to you. We also train our staff about personal data protection, the importance of confidentiality to ensure the privacy and security of your information.
We use different encryption solutions to ensure security of information.
We have implemented the Privacy Program, within which we have approved several policies and procedures aiming to support personal data processing in accordance to the provisions of the regulatory enactments, including with the purpose to ensure secure processing data. As well as we have implemented procedure, which ensure that in case of suspected data breach, such events are investigated with due care and steps are taken to ensure protection of your data.
It is important for us that you receive information you are interested in and that you are informed about possibilities and offers thus you have possibility to choose most suitable solution for your travel. Meanwhile, it is important for as to respect your opinion and privacy in this regard.
We may approach you in the following situations:
7.1. General information and confirmation on service you have bought with us. For example, confirmation of your reservation, information about reservation, invoice on purchased services, description of services, conditions, information about execution of your order, information about irregularities or any other changes or information which may have impact to service ordered by you.
Legal ground and your rights: Legal ground for providing such information is the performance of a contract or in order to take steps prior to entering into a contract. Such communication is essential for our mutual contractual relationships.
7.2. We may invite you to participate in a survey and give your opinion on our offered or provided service, or invite you to participate in any other survey with the purpose to improve our operation and services.
Legal ground and your rights: Legitimate interest to evaluate and improve our operation and quality of services. You have rights to choose freely whether you would like to participate in such a survey or refuse participation. You may also object and refuse any further communication in relation to particular survey by unsubscribing from reminders about survey in e-mail received from us. In case you do not want to receive any further invitation to participate in any further surveys, then write an e-mail to [email protected] at any time (writing e-mail from e-mail address to which you would not like to receive invitations to survey), by indicating your objection (for example, I object receiving any invitation to surveys in a future).
7.3. Sending newsletters and offers on regular basis, as well as confirmation on subscription to newsletter subscriber list. We may inform you about different offers.
This information is very useful, in particular when planning your future training. Such offers may be offered at favourable prices and conditions.
Legal ground and your rights: Your consent, which may be given in several ways – by applying to newsletters at our webpage, or by making appropriate choices (ticking boxes) during reservation, as well as by making appropriate choices (ticking boxes) in your profile registered with our webpage (if any registered).
! You have rights to change your mind at any time and withdrawn your consent at the same ease as it was given and you may do that in different ways:
- You may unsubscribe from such communication in e-mail received from us;
- In case your profile is registered with our webpage, you may change choices marked therein (by “taking out” ticks from the relevant boxes).
The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
7.4. We may contact you in relation to some complaint or application, or request, or any liabilities. During business, there might be a necessity to contact you in relation to different matters, for example, to answer to your claim, to contact you in case there is some debt, to contact you in case of your request or application, to provide you with answer. The purpose of such communication is to ensure contact with you and provide you with necessary information. Such communication may be based on requirement of law (for example, obligation to answer of consumer claims), based on conclusion or execution of contract with you, as well as in separate situations based on legitimate interest to contact you for different matters.
Legal ground and your rights: You have rights to object communication when it is based on legitimate interest. However, in case of objections we may not be able to ensure you with requested answer if provision of answer is based on legitimate interest. Therefore, in case there are some objections towards our communication, please do not hesitate to contact us to [email protected] and we will investigate situation with due care and try to find the best solution in a particular situation.
7.5. We may contact you in any other meaningful situations, for example, to inform you on changes in operation of the company, to inform you on some restrictions in country due to emergency state.
Legal ground for such communication is legitimate interest to ensure clients with meaningful information in relation to the company and its operation, as well as in some specific situations it may be requirement of law, when applicable regulatory enactments imposes obligation to provide certain information. In case information is provided due to obligation of law, then rights to object do not apply (unless clearly stated by law). In case of legitimate interest, you have rights to object.
Legal ground and your rights: You have rights to object communication when it is based on legitimate interest, by following the scope of law and writing to [email protected].
airBaltic may conduct video surveillance at airBaltic facilities, such as the airBaltic administration office and its adjoining area, to ensure the security of persons, information, property, aviation and infrastructure, prevention of illegal or other threats (including preventive), as well as facilitating the detection of criminal offenses at the facilities and adjacent territory. Video surveillance may be carried out based on a legitimate interest.
We place warning signs at airBaltic facilities, which are under video surveillance.
airBaltic ensures that video cameras are not placed in areas with increased level of privacy, such as lounges, toilets, changing rooms. Before the video cameras are placed, the surveillance area is carefully selected to minimize monitoring of areas that are not relevant to reaching the purpose.
The data on video surveillance may be accessed only by the authorized persons for performance of direct duties, as well as by security guard and security and consultation service providers, law enforcement authorities and others in case provided under the applicable regulatory enactments (the mentioned may involve inter alia data subjects when they lawfully request access to such records, as far as it may not harm rights and freedoms of any other individual).
airBaltic carefully evaluates the facilities where video surveillance cameras are located, assessing the surveillance area and the risks associated with it. Video surveillance records may be kept for the period necessary to achieve the purpose, taking into account the specifics of the observed objects, the conditions and the risks associated with them. Depending on the observed object and its specifics, the storage times of records may differ. However, in any case the retention period for video surveillance records shall not exceed two months.
In exceptional cases, for example, if request from court or law enforcement authority is received, in case of theft or in case of suspected unlawful behavior, specific records may be stored for longer period of time (exceeding two month) necessary for execution of request and protecting of lawful interest (for example, in order airBaltic would be able to demonstrate proofs on illegal behavior or criminal offence or in case of suspicious on any of the mentioned, as well as to investigate some potential incident in relation to the purposes mentioned above).
We process your data; therefore, you have the opportunity to request what we do with it and how, and in some cases ask us to process it to a lesser extent by complying with the applicable regulatory enactments.
9.1. Your rights. You have the following rights according to the applicable regulatory enactments:
- to access your personal data (receive a copy of your personal data and request the purpose and basis of the data processing);
- to object the processing of your personal data when its based on a legitimate interest. In case you address to [email protected] objection towards processing of your personal data, please specify the processing towards which you address your objection.
- to withdraw consent (refuse from receiving newsletters, cookies); Take into account that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
- to rectification (change your contact information, submit current information in case of change);
- to be forgotten or erased (request to delete your information from our databases, in compliance with the scope determined under the applicable regulatory enactments). Please be informed that according to the applicable regulatory enactments we may keep certain information also after the request on rights to be forgotten or erasure, for example, when the applicable regulatory enactments impose obligation to store certain information for specified period of time, for example, the Accountancy Law may impose obligation to store information on our transaction. As well as we may continue storage of information for the establishment, exercise or defense of legal claims and in other cases provided under the applicable regulatory enactments. We will examine each request with due care and will exercise your rights to be forgotten towards information which shall be deleted according to GDPR.
- to restrict processing of personal data (ask us not to use certain information about you for limited period of time);
- to data portability (receive information about yourself which you have provided to us and ask to deliver such information to another controller if it is technically feasible);
- in case you have any concerns or objections or complaints on processing of personal data carried out by airBaltic, we invite you to turn to us by writing message to [email protected] and we will review the issue with due care and will take steps to solve the issues as soon as possible. Nevertheless, data subjects are entitled to lodge a complaint with a supervisory authority.
Depending on the nature of information you want to access, some authentication requirements may apply to allow airBaltic to verify whether you are the person you declare to be, for example, if you want to obtain data generated while receiving the service or obtain special category personal data, more strict authentication requirements may be applied comparing to procedure applied in a daily course of business.
9.2. Requests by data subjects and its form
9.2.1. General Procedure
Please take into account that in most cases we commence exercise of data subject rights, including providing information on clients if we have received request from the data subject, and such request is signed with a secure digital signature and sent to [email protected], or if the original request with handwritten personal signature has been submitted to the administration of airBaltic.
In such cases, please include the following information in your requests:
a) clearly state, which rights you would like to exercise (for example, whether you object to the processing, specifying – towards which processing you would like to address the request; whether you want to delete the data, specifying – whether you ask to delete all data or address the request only to certain processing; whether you want to transfer the data to another controller etc.);
b) to submit and include in the request certain information about you so that we can identify your data in our databases, for example, please indicate:
- name, surname, date of birth, address (address required for the purpose to send to you the answer to your request);
- all e-mail addresses and phone numbers registered with us by you during booking process (in case you address the request towards all data and any reservation you have made). If you address the request towards some particular reservation – then indicate only data related to this particular reservation.
- reservation number or ticket number for which you want to receive information. In case you want to apply the request to all flights, but only remember the reservation number of the last flight, then please do not hesitate to include information you remember;
- in case you were a passenger on a reservation made by another person and you want to address the request also towards such flights, please provide us with the following additional information – reservation number or ticket number of the flight or place of departure and arrival, its date and time and other information about the specific reservation, which you hold – for example, the e-mail address that was registered with this reservation, or the person who made the reservation on your behalf;
- if you wish to access records of video surveillance containing your personal data, please indicate the specific date, time, exact location and possible content of the recordings, as well as your clothing and specific features that would allow us to identify you in those records. In addition, depending on the specific records, we may ask you to provide us with additional information to make sure that you are a person in those records. We will provide you with such records by issuing them in person and verifying your identity. However, we can also hand them over in another secure way, with prior agreement with us;
- in case you want to access the records of the call, indicate the phone number, from which the call was made, as well as the date and preferably the time of the conversation and approximate content of the conversation;
- in other cases, we may ask you to provide us with other information, depending on the nature and specifics of the request, in order to ensure exercise of your request.
We will send the answer to your request within the terms specified by the applicable regulatory enactments.
It is important for us to make sure that we deliver the answer to you in a secure way. Therefore, in most cases we will reply in the form of a registered letter to the address you have provided in the request. In such a way we can be sure that you will receive the answer, because employees of postal office will verify your identity as it is a common practice in case of registered mail. We may issue the response also at airBaltic head office, with data subject appearing in person at airBaltic and presenting the document verifying identity of the data subject.
If you prefer to receive the response in other way, please write to [email protected] and we will evaluate other possibilities, taking into account the nature of the request and data requested.
There are some exceptions to the procedure set above, which are applicable according to the sub-section 10.2.2.
10.2.2. Procedure for handling the request in individual cases (for example, unsubscribing from news, etc.)
a) Information on subscription to newsletters, offers, and unsubscription.
If you want to know if your e-mail address is registered in the list of news and offer recipients, you can send a relevant question to [email protected] from the e-mail address for which you want to know this information.
If you wish to withdraw your consent to receive newsletters, you can do so in the e-mail you received from us (unsubscribing from receiving news) or send an e-mail to [email protected] from the e-mail to which you want to apply the withdrawal.
In this case, we will exercise your rights and respond you as soon as possible to the e-mail address from which we received the request.
b) If you object to receiving a communication when processing is based on a legitimate interest (for example, receiving offers and information related to a particular travel (i.e. a service already purchased by you), an invitation to participate in a survey, etc.).
If you wish to object to the receipt of a communication when it is based on a legitimate interest (for more information, see Section 8), you may send an objection to [email protected] from the e-mail address to which you wish to address the objection, specifying the processing to which the objection concerns.
In such a case, we will exercise your rights and respond as soon as possible to the email address from which we received the request.
c) Information about the profile you have registered with our website and the request to delete it.
If you want to know what information is registered in your profile registered with our website or you want to delete such profile, then you have the opportunity to access the profile by logging in to such profile. You may delete your profile by choosing in the settings of the profile “delete profile”. If you have forgotten your password to access your profile, you can easily update it by sending a reset link to the email address you have registered in your profile.
However, in any case, you can also address your request to [email protected] from the e-mail address used to register the profile with our website. In this case, we can ask you additional questions for autentification purposes (to make sure that you are a holder of the profile) and only after successful autentification we provide you with information or delete your profile.
However, in this case, the e-mail would be considered sufficient to ensure mutual communication.
d) Other information related to service and its performance (for example, to obtain flight information, flight rescheduling, change of contact details, status of complaint handling and other activities related to day-to-day services and ancillary services, as well as other requests).
In order to provide passengers with opportunity to obtain general flight information, to purchase ancillaries services, to change of flight time or contact information, as well as to obtain other information related to the reservation and fulfillment of contractual relationships via e-mail correspondence or phone call, airBaltic may ask you to provide additional information to verify that you are the person who made reservation. If you have provided the required information, airBaltic can further proceed your request related to daily services.
Please note that we may disclose passenger information to the passenger, his/her legal representative or a duly authorized representative. In case of authorization, the power of attorney should specify the right to receive information and to make requests on behalf of the data subject concerning the processing of personal data.
We work thoroughly to protect your personal data and ensure transparency of personal data processing activities. However, if any issues appear or you have questions about your data processing, please contact our Data Protection Officer. We will answer your questions regarding the use of your information at airBaltic. You can reach the Data Protection Officer by sending an e-mail to [email protected].
Our activities in the field of personal data protection are monitored by State Data Inspectorate of the Republic of Latvia (Datu Valsts Inspekcija). Before you turn to them for advice or with a complaint, we encourage you to contact our Data protection Officer to solve any misunderstandings as quickly as possible.
Data Protection Officer
AS Air Baltic Corporation
Marupe parish, Riga International Airport
Tehnikas 3, Latvia