Last updated: 25 May 2021
We, Gen2 Systems Ltd (flydocs), The Lewis Building, Bull Street, Birmingham, B4 6AF, UK (hereinafter also “we”, “us”), wish to inform you of how your personal data is processed when you use our website www.flydocs.aero.
If you have any further queries regarding data protection in connection with our website or the services offered, please contact our Data Protection Officer: [email protected]
2. Scope, purpose and legal basis of processing personal data
We collect and use personal data directly from our users and other sources (mentioned below) in the following situations:
2.1. Provision of the website and log file creation
Whenever users visit our website, our system automatically records data and information about the user’s computer system. The following data (“technical information”) may be collected:
• Information on the browser type and version
• The user’s operating system
• The user’s Internet service provider
• The user’s IP address
• Date and time of access
• Websites from which the user’s system accesses our website
• Websites accessed by the user’s system via our website
The data is also saved in our system’s log files. This data is not stored together with other personal data of the user.
We collect and use this technical information for the purposes of network security (e.g. to ward off cyber-attacks), marketing and to better understand our users’ needs as well as to continuously improve our website and enable us to deliver the website to users’ computers systems.
The data is saved to log files to ensure optimised website functionality and to ensure the security of our IT systems. The data is not analysed for marketing purposes in this context.
Art. 6(1)(f) GDPR forms the legal basis for the temporary storage of the data and log files.
2.1.2. Cookies and other tracking technologies
When you access our website, we may use industry-wide monitoring and tracking technologies such as “cookies” or “pixel tags” (or similar technologies), which store certain information on your computer (“Local Storage”) and which will allow us to enable automatic activation of certain features, and make your service experience much more convenient and effortless.
For example, these technologies enable us to: (i) provide you with the information, (ii) keep track of our users’ preferences and authenticated sessions, (iii) secure our website by detecting abnormal behaviors, (iv) identify technical issues and improve the overall performance of the flydocs website, and (vi) deliver you targeted advertisements that are more tailored to you based on your browsing activities and inferred interests and track ad performance
We also use Google Analytics, Facebook, Twitter and LinkedIn’s functionality of re-marketing tracking cookies and pixel-based retargeting. This means that if you provided your consent to [Google, Facebook, Twitter or LinkedIn] (the “Social Ad Platforms”) to be provided with personalised commercial offers, you may be served with ads based on your use of the website, outside of the website and across the internet. In such event the Social Ad Platforms, will place cookies on your web browser and use such cookies to serve you ads based on past visits to our website.
1. Google Adwords: https://policies.google.com/technologies/ads
2. Facebook: https://www.facebook.com/about/privacy/
3. Twitter: https://business.twitter.com/en/help/ads-policies/other-policy-requirements/policies-for-conversion-tracking-and-tailored-audiences.html
4. LinkedIn: https://www.linkedin.com/legal/cookie-polic y
If you wish to opt-out of such re-targeting and tracking functionality of the Social Ad Platforms, you may do so at the following links:
1. Google Adwords: https://adssettings.google.co.il/authenticated
2. Facebook: https://www.facebook.com/settings/?tab=ads
3. Twitter: https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads
4. LinkedIn: https://www.linkedin.com/help/linkedin/answer/34318?query=opt-out%20pixel
Learn more about your choices and how to opt-out of tracking technologies:
Our legitimate interest pursuant to Art. 6(1)(f) GDPR for the purposes of increasing the efficiency of our website and (direct) marketing is the legal basis for the use of the tools listed.
2.2. Email Marketing
You have the option of consenting to receiving free email updates on our website when you contact us via the forms on our website. When you consent, the following data from the input screen is sent to us and processed:
b) First name
c) Last name
d) Email address
f) Job title
g) Telephone number
The following data may also be collected:
h) IP address of the computer accessing the website
i) Date and time of registration
No data is disclosed to third parties in connection with data processing for the distribution of marketing emails. The data is used exclusively to distribute the emails.
We process your data in connection with the marketing emails in order to send news about topics from flydocs that we think are interesting.
Art. 6(1)(a) GDPR forms the legal basis for data processing following the user’s subscription to the marketing emails if the user has given consent.
2.2.1. Statistical analysis
There is a possibility that your data may be analysed in a data warehouse to evaluate the preferences of our registered customers (“statistical analysis”) for the purposes of interest-led marketing, individual approaches and continuous optimisation of our business processes. We undertake this processing in order to acquire a better understanding of what our customers expect from us and to allow us to offer you communication that is tailored to you personally. This analysis also helps us with fraud detection, auditing and safeguarding security, which is why we perform this processing to protect our legitimate interests, Art. 6(1)(f) GDPR.
2.3. Our legitimate interest in processing personal data
If Art. 6(1)(f) GDPR forms the legal basis for the processing, our legitimate interests are, in addition to the purposes listed above:
• To protect the company against material and immaterial damage
• Professionalism (of our products and services)
• Cost optimisation (control and minimisation)
2.4. Other processing commitments
If obliged to do so by law, we process personal data in order to meet duties of retention under commercial or tax law or to meet legal security requirements.
2.5. Obligation to provide personal data
The input fields which are mandatory to be filled out for performing the requested service are marked accordingly on the website. The input is either mandatory because of legal or contractual requirements.
3. Duration of the data processing
Your personal data is deleted as soon as it is no longer needed for the specified purposes. In certain circumstances, personal data is kept for the period of time during which claims against Gen2 Systems Ltd may be enforced (statutory limitation period of three to thirty years). Personal data is also saved to the extent that and for so long as Gen2 Systems Ltd is legally obliged to do so. Corresponding burdens of proof and duties of retention arise from, among others, the Commercial Code, Tax Code and Money Laundering Act. These prescribe retention periods up to ten years.
4. Right to object pursuant to Art. 21 GDPR
You have the right to object, on reasons relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions.
The controller shall no longer process your personal data unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or processing is necessary for the establishment, exercise or defence of legal claims.
Where your personal data are processed for direct marketing purposes, you have the right to object at any time to processing of personal data, which includes profiling to the extent that it is related to such direct marketing.
Where you object to processing for direct marketing purposes, the personal data concerning you shall no longer be processed for such purposes.
In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications.
5. Disclosure of personal data to third parties
In order to offer you our products and services, based on our contractual obligations or in accordance with our legitimate interests, we may have to disclose your personal data to third parties internal or external to the Lufthansa Group.
Personal data may be transmitted to third countries or international organisations as part of this. For your protection and the protection of your personal data, appropriate safeguards are provided for such data transmissions as per and in accordance with legal requirements (particularly, the use of EU standard contractual clauses) or an adequacy decision has been issued by the EU Commission (Art. 45 GDPR).
We are also legally obliged to provide personal data to UK, German and international authorities, Art. 6(1)(c) GDPR together with local and international regulations and agreements.
6. Rights of the data subject
Gen2 Systems Ltd is committed to ensuring fair and transparent processing. That is why it is important to us that data subjects can not only exercise their right to object but also the following rights where the respective legal requirements are satisfied:
• Right of access, Art. 15 GDPR
• Right to rectification, Art. 16 GDPR
• Right to erasure (“right to be forgotten”), Art. 17 GDPR
• Right to restriction of processing, Art. 18 GDPR
• Right to data portability, Art. 20 GDPR
To exercise your rights, please email [email protected] Please note that we will process your personal data in accordance with Art. 6(1)(c) GDPR.
You also have the right to lodge a complaint with a supervisory authority. The relevant supervisory authority for Gen2 Systems Ltd is:
Information Commissioner’s Office
Phone: +44 (0) 303 123 1113
Fax: +44 (0) 1625 524 510
If you give your consent to us for processing your personal data, please note that you may withdraw this consent at any time by contacting [email protected]
Please note that your consent can only be withdrawn with future effect and such a withdrawal does not have any influence on the lawfulness of past processing. In some cases, we may be entitled in spite of your withdrawal to continue to process your personal data on a different legal basis – e.g. to perform a contract.
8. Disclaimer and limitations of these data protection notices
This policy only applies to processing for the website www.flydocs.aero. Other websites are not covered by these data protection notices and provide their own specific data protection notices.