As an international Business-to -Business Flight Support Company, data and information is important in the SEAS activity.
We take the privacy and protection of data and information seriously, and are committed to handling the personal information of all those we engage with, whether customers, suppliers, colleagues or any other community, responsibly and in a way that meets the legal requirements of the countries in which we operate.
SEAS is one-stop aviation services entity aiming to serve Sri Lankan private aircraft owners and commercial operators. Based in the beautiful island of Sri Lanka, SEAS’ team of aviation experts provides efficient, reliable and cost eﬀective solutions dealing directly with local authorities and the best suppliers in the country. The excellent quality of our services as pre-ﬂight planning, inflight supervision, ground handling, fuelling and concierge services complement every customer journey with economic value.
What we collect
This section explains the personal information that may be collected when using our products and services, and the other personal data we may receive from other sources.
- Contact details, such as your full name, e-mail address, postal address and telephone number;
- Educational, nationality and professional background information;
- Usernames and passwords;
- Payment information, such as a credit or debit card number;
- Comments, feedback, posts and other content submitted;
- Interests and communication preferences including marketing permissions where appropriate; and
- Location information (e.g. through mobile apps).
We collect and use your personal information in the following main categories:
- As customer / consumer data, related to transactions, prospective sales or analytics;
- As contact data, which includes academic and corporate customer contact data such as details of account manager / key contact at corporate customers, and subscriber / user data;
- In connection to an event, for instance exhibition or conference visitors, exhibitors, speakers, and attendee data;
- Product / intelligence data, collected through customer and market research surveys;
Sensitive personal data
If collecting or storing sensitive personal data such as information relating to health, beliefs or political affiliation, we typically ask for your explicit consent. However, there are some situations, of an accidental nature, where it will not be possible to request consent. If this does occur, we will ensure your privacy rights are protected.
Children’s personal data
Our services and products are directed to academics and business professionals. They are not intended for children under the age of 13 and we do not knowingly collect personal data from this age group. If any information is collected from a child under the age of 13 without verification of parental consent, it will be deleted.
How and why personal information is used.
This section explains in detail how and why we use personal information.
LAWFUL PROCESSING IN EUROPE
SEAS collects and uses personal information. The lawful bases we use for this activity in Europe, as required under European data protection laws, are:
- Where it is necessary for entering into or performing a contract with you
- Where we have a legitimate interest to do so, provided your rights do not override these interests
- Where you have consented to its use
- Where our colleagues believe it is in your vital interests to share your personal details, for example with emergency services
- Where required to comply with our legal obligation
PRODUCT ENQUIRIES, SALES AND ADMINISTRATION
As part of a purchase, product enquiry, request for information and for account administration, we collect information such as your name, country, job title, company information or academic affiliation, postal address, e-mail address and telephone number.
If you have made an enquiry about us or our products or services, either online or over the phone, we will use your personal information to respond to the enquiry or to take other steps at your request, before you enter into a contract. For example, we collect the e-mail addresses and additional contact details of those who send e-mails to request information. Where a sales representative speaks to you over the phone or live chat, the calls and chats are recorded for training and monitoring purposes only.
If you have registered for or purchased a product or services, including on a trial basis, your personal information will be used to provide that product or service, communicate about it and handle payments, as is necessary for the performance of the contract entered into with us.
If your personal information is relevant to certain products and is freely available through public sources, such as on a website related to your work or profession, we may use this personal information for providing customers with our products, as is necessary for the purposes of our legitimate interests as a commercial organisation.
We will use your personal information to send you newsletters, offers or other marketing emails that keep you up to date with news, events, products and research opportunities, from SEAS that may be of interest. Depending on the nature of your interaction with us and the laws of the country where you live, you may have actively given us your consent for this, by opting in, or we may be entitled to rely on your implied consent or our legitimate interests. The opportunity to opt out of future marketing emails will always be provided, and information on how to do this given when your personal information is collected and on every marketing email sent.
CUSTOMER AND PROSPECTS MANAGEMENT INCLUDING ANALYTICS
We may use your personal information, combined with publicly available data and demographic data, to maintain our customer database and carry out internal analysis of the usage of our products and services. This is done to improve those services, develop new products and predict future customer behavior, as part of our legitimate interests as a commercial organisation. This may include automated profiling and campaign management techniques.
MOBILE APPLICATIONS AND WEBSITES ANALYTICS INCLUDING LOCATION DATA
We may combine visitor session information, or other information collected through tracking technologies, with personally identifiable information in order to understand and measure your online experience and determine what products, promotions and services are likely to be of interest.
Technical methods are also used in HTML e-mails sent to visitors, for purposes including: (i) to determine whether visitors have opened or forwarded e-mails and/or clicked on links in those e-mails, (ii) to customise the display of banner advertisements and other messages after closing an e-mail, and (iii) to determine whether a visitor has made an enquiry or a purchase in response to a particular e-mail.
In compliance with the California Online Privacy Protection Act (CalOPPA) (e.g.: Browsers Do Not Track Signals) while we strive to offer you choice when using our website and mobile applications, we do not promise that we will be able to receive or honor web browser Do Not Track signals.
AUTOMATED DECISION-MAKING, INCLUDING PROFILING
We use algorithm-based technologies to personalise dynamic web content based on your explicit and/or implicit interests. We carry out general profiling such as segmentation, non-automated and automated decision-making based on profiling for the purpose of providing you with a more relevant experience and for the purposes of our legitimate interests as a commercial organisation. Automated decision making is never used in any way that produces a legal or similarly significant effect.
Depending on the laws of the country where you live, you may have rights related to our decision. For example, if you live in the European Union, you may have the right not to be subject to our decision, or you may have the right to insist on human intervention in the process, express your point of view or contest the decision. To exercise any such right, please contact us via one of the methods set out in the “Contact Us” section below. In some cases, we may have the right to continue with our decision, in accordance with applicable laws. This will be explained if it is the case. Otherwise, we will respond to your request as promptly as reasonably possible.
COMPLIANCE WITH OUR LEGAL OBLIGATIONS
To ensure compliance with international trade sanction laws and regulations, we screen customers, vendors and suppliers against US, OFAC, BIS, UN, EU and UK sanctions lists. Should any screening check flag an issue where we cannot continue in a contract with a customer or supplier, they will always be informed.
How we protect personal information.
Any personal information given to us will be treated with the utmost care and security. This section sets out some of the security measures in place.
A variety of physical and technical measures is used to keep data safe and prevent unauthorised access to, or use or disclosure of personal information.
Electronic data and databases are stored on secure computer systems and we control who has access to information, using both physical and electronic means. Our colleagues receive data protection training, and we have detailed security and data protection policies that colleagues are required to follow when handling personal data.
All reasonable steps are taken to ensure that your personal information is kept secure from unauthorised access, but we cannot guarantee it will be secure during the transmission process to this website because this transmission is not controlled by us. We make use of HTTPS (HTTP Secure) whereby the communication protocol is encrypted via Transport Layer Security for secure communication over a computer network. The website is loaded via HTTPS, represented by the lock icon in your web browser, which ensures the transmission is secure and is demonstrated by a certificate issued by an official security certificate authority to us.
INTERNATIONAL TRANSFER OF PERSONAL INFORMATION (?)
As an international business and because of the technologies we use, personal information may be accessed by our colleagues and third-party service providers from locations outside of the European Economic Area, whose data protection laws may not be as extensive as those in Europe.
To ensure the same level of protection is in place when processing is conducted outside the European Economic Area, we use appropriate safeguards approved by the European Commission.
We apply appropriate protection to make sure your personal data remains adequately protected and is treated in line with this Policy. SEAS has put in place international data transfer agreements between its companies and with relevant third-party service providers based on standard contractual clauses approved by the European Commission.
THIRD PARTY LINKS
Who we share personal information with.
As an international company, to provide you with services and products we may share your information for specific reasons. This section explains how and why we share personal data with other companies, our suppliers, and other third parties.
Sharing with SEAS partner companies
We may share your personal information with certain other companies within SEAS partner network for specific purposes. For example, other companies may assist us in providing products and services to you, in carrying out internal analysis of the usage of products and services, or in offering products and services which may be of interest.
Sharing with Service Providers
We may share your personal information with the following types of third parties, to assist us in providing products and services to you:
- Fuel providers
- Ground Handling providers
- Overflying and landing permit providers
- Airport Authorities globally
- Hotels and Ground transportation providers
- Private Jet services and FBO providers
- Flight Crew management associations
- Food & beverage catering providers
We only share your personal information with such third parties, if and to the extent necessary for them to provide such assistance.
Sharing with other Organisations
We may share your personal information with trusted partner organisations for their marketing purposes, in accordance with local data laws and where appropriate your consent. If your personal information is subject to European data protection laws, we will not share it with third parties for their marketing purposes, unless you have actively given us your consent to do this.
We may also share your personal information with third parties in the event of a sale, merger, acquisition, partnership, joint venture, or negotiations related to the same with respect to all or part of our business.
In some circumstances, we may be legally required to disclose your personal information, because a court, the police, another judicial or law enforcement body, or government entity has asked us for it.
How long information is kept
We will only retain your personal information for as long as is necessary and as permitted by applicable laws.
We will retain your personal information while we are using it, as described in the section above, and may continue to retain it after these uses have ended where we have a legitimate business purpose. For example, if you have opted out of marketing communications from us, we will retain limited details about you to ensure we can honor your opt-out request. We may also continue to retain your personal information to meet our legal requirements or to defend or exercise our legal rights.
Personal information will only be retained for as long as is necessary and as permitted by applicable laws. The length of time for which we will retain your personal information will depend on the purposes for which we need to retain it. After we no longer need to retain your personal information, it will be deleted or securely destroyed.
How to update your information and marketing preferences
We want to ensure you remain in control of your personal information. We try to ensure that the personal information held about you is accurate and up-to-date, and will always give the opportunity to opt out of future marketing communications.
We will process your data to send marketing information that we believe is targeted and of interest to you. If you are a registered user, you can access your account information and make corrections or updates upon log-in. The accuracy of such information is solely your responsibility.
Information on how to opt out will be given when your personal information is collected and specified on every marketing email sent. You may opt-out of our email marketing lists by following the directions at the bottom of our emails. Please note that SEAS has a number of services and we allow you to opt-out selectively. To remove a specific email address from all of SEAS marketing communications, send a request to firstname.lastname@example.org. If you wish to remove your email address only from a specific brand, please use the opt-out mechanism provided in emails you receive from such brand, or contact the brand directly.
You may receive email marketing messages from us about company’ offerings as part of a business partner marketing program. To opt-out of a business partner marketing email program, follow the instructions at the bottom of any email sent as part of the program. Please note that opting-out of promotional mailings will not affect delivery of your subscription-based products.
SEAS operates in countries with data protection laws that may provide individuals the right to be able to access and control their information. We always will enable you to be able to exercise the rights provided by data protection laws.
EU data protection laws give individuals a number of rights, where their data and information is collected and used by companies that are active and operating in Europe. Under the General Data Protection Regulation, these are:
- The right to confirmation whether or not we have your personal data and, if we do, to obtain a copy of the personal information we hold. This is known as subject access request;
- The right to have inaccurate data rectified;
- The right to have your data erased. This does not however apply where it is necessary for us to continue to use the data for a lawful reason;
- The right to request the restriction or suppression of their personal data, such as, we will stop using the data but we may continue storing it.
- The right to obtain your personal data that you have provided to us, on the basis of consent or performance of a contract, and where technically feasible, transmitted in a common electronic format to you or directly to another company.
- The right to object to the use of your data. Specifically, you have the right to object to our use for marketing and in relation to automated decision making, including profiling where there may be legal or similarly significant effects.
There are exceptions to the rights above. Where you make a request to us as part of these rights, we will always try to respond to your satisfaction, although there may be situations where we are unable to do so.
Depending on the laws of the country where you live, you may have other rights in respect of your personal information. If you wish to exercise any legal right in respect of your personal information, please contact us via one of the methods set out in the Contact Us section below.
In some cases, we may be entitled to decline a request you have made regarding your personal information, in accordance with application laws. We will explain if that is the case. Otherwise, we will meet your request as promptly as we reasonably can. If you have requested that we stop sending you marketing messages, please note that you may still receive them for a short period while the request is processed.