Privacy Notice

Effective Date: 14 May 2018

Introduction

Avinode Group and its affiliates, including Avinode, SchedAero and PayNode, (collectively, the “Company”, “we” or “us”), are committed to safeguarding the privacy and personal information of our customers and business partners. This Privacy Notice explains how we may collect, use, process, share, and store personal information about you, including through designated third-party service providers, and the choices that are available to you regarding this information. Please read this Privacy Notice carefully to understand our views and practices regarding your personal information and how we will treat it.

In addition to information kept in hardcopy, this Privacy Notice also applies to our company websites, online applications that run on smart phones, tablets, mobile devices (“apps”), and other online services that we offer which link to this Privacy Notice. Also note that our websites may contain links to other websites; if you follow a link to any of these websites, you should read their own privacy notices.

 

What information do we collect about you?

Information you give us

We collect information about you when you open an account with us, purchase our products and services and/or remit payment for services. We also collect information about you using cookies, and if you interact with us via phone, websites, or apps.

The types of information that you may give us vary depending on the specific entity with which you are doing business, and/or the particular services requested. For example, you may be purchasing aviation, land or marine fuel products and/or related services, engaging with us to provide energy management services, using our trip planning services and/or related products, utilizing our software offerings, or using our payment solutions technology. The information you may give us could include categories such as, but not limited to, your name, work or personal address, e-mail address, phone number, date of birth, gender, financial and/or credit card information, passport or driving license information, national ID number, personal description and/or photograph, as well as customer data, payment data, employee data and/or website user data.

 

Cookies and website usage

Our websites may use cookies to distinguish you from other users of our websites. This helps us to improve the functionality and content of the websites, including keeping our websites and records safe and secure, and to facilitate usage by you. For more information regarding our use of cookies, please review the Avinode Group Cookie Policy, as well as the information contained in the banners of our various websites.

Please note that our websites are not intended for children under 13 years of age, and we do not knowingly solicit data online from, or market online to, children under 13 years of age.

Where we have given you (or where you have chosen) a password to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to/from our websites — any transmission is at your own risk.

 

Information we receive from other sources

We may receive information about you if you use any of the other websites we operate or the other services we provide. We also work closely with third parties (including, for example, business partners, sub-contractors, payment and delivery services, advertising networks, analytics providers, search information providers, and credit reference agencies) and may receive information about you from them.

 

How do we use the information about you?

We use your information to provide you with information, process orders for products and services that you request from us, and administer or otherwise carry out our obligations in relation to any agreement you have with us. We retain your information for the period necessary to serve a legitimate purpose or as required by law.

We may also use this information to provide you with information about goods or services we feel may interest you.

If at any time you wish us to stop using your information for any the above purposes, please contact us using the methods explained below. We will stop the use of your information for such purposes as soon as it is reasonably possible to do so.

 

How do we share your information?

We may share your personal information with other members of our group of companies and with selected third parties for the performance of any contract we enter into with them or you. These third parties will not use your personal information for any other purposes than what we have agreed to with them, and we request those third parties to implement adequate levels of protection in order to safeguard your personal information.

Since we operate globally, the data that we collect from you may be transferred to, and stored at, destinations inside and outside the European Economic Area (“EEA”). For example, it may be processed by our staff operating inside and outside the EEA, our subsidiaries, or our suppliers to provide you with our services. While the information is under our control, we seek to ensure that your personal information receives the level of protection as required by the EEA, including seeking to ensure that it is kept secure and used only in accordance with our instructions and for legitimate purposes.

In the event we go through a business transition, such as a merger, acquisition of another company, or sale of part or all of our assets, we may disclose your personal information to third parties and your personal data held may be among one of the assets transferred.

We may also automatically collect non-personal information about you such as the type of internet browsers you use or the website from which you linked to our website. We may also aggregate details which you have submitted to us. You cannot be identified from this information and it is only used to assist us in providing effective services, including in connection with this website.

Finally, we may be under a duty to disclose or share your personal information for various other reasons, such as to comply with a legal obligation; to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of the Company, our customers, or others. This could include, for example, exchanging information with a law enforcement agency or regulator; or with companies and organizations for the purposes of fraud protection and credit risk reduction.

 

Potential rights under the GDPR

Under the EU General Data Protection Regulation (“GDPR”), if you are a citizen or resident of an EEA country or Switzerland, you may have certain rights regarding your personal information:

  • Right to access information maintained about you;
  • Right to ensure your data is accurate and complete;
  • Right to erasure, or the right to be forgotten;
  • Right to restriction or suppression of personal data;
  • Right to data portability;
  • Right to withdraw consent if consent was previously provided; and
  • Right to raise a complaint to the Information Commissioner’s Office.

If you are eligible to invoke one of the rights listed above and wish to do so, you may contact us as part of a subject access request using the details found below. Please note that we may not always be able to fulfill your request as there may be legitimate purposes, such as certain legal or statutory obligations, that require us to retain your information as stored or if we believe the change would cause the information to be incorrect.

 

Updates to our Privacy Notice

As appropriate, we may make changes to this Privacy Notice that will be posted online and, where appropriate, be sent to you by e-mail. Please check back frequently to remain aware of any updates or changes to this Privacy Notice.

 

How to contact us

We encourage you to first read our Privacy Principles, which contain additional information regarding our policies and procedures. If you have additional questions, or believe you are eligible to submit a subject access request, you can reach us by email at privacy@avinode.com or by post at:

Avinode Group

Attn: Privacy Administrator, Legal Department

Odinsgatan 10

411 03 Gothenburg

Sweden

Please be aware that when we receive a formal written complaint regarding the processing of personal data, we try to resolve it directly with the person who has made the complaint, or with the data controller when we are acting as a data processor. However, as necessary, we will work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding our processing of personal data that we cannot resolve with a complainant directly.

Privacy Principles

Data Protection and Privacy Principles

Avinode Group and its subsidiaries and affiliates, including Avinode, SchedAero and PayNode, (collectively, “Avinode Group”) are committed to safeguarding the personal information of our customers, business partners, and employees. The following Data Protection and Privacy Principles (the “Privacy Principles”) outline how Avinode Group may collect, use, share, transmit, maintain, and store (collectively, “process”) information that relates to an identified or identifiable individual (“personal information”), and the choices that may be available to you regarding your personal information. Under these Privacy Principles, “you” and “your” means any individual customer, business partner, or employee of Avinode Group and any other individual whose personal information we process, and “we”, “us”, and “our” refer to Avinode Group.

Please read the following carefully to understand our views and practices regarding your personal information and how we may treat it. For more information, or if you have any questions and/or are eligible to submit a subject access request, please reach out to us using the contact details found below, or visit our Privacy Notice.

 

Collection, Notice, and Processing of Personal Information

We will only collect personal information as appropriate and using only fair and lawful methods. We will process your personal information fairly and for purposes permitted by you and/or as permitted by applicable law. If requested, and/or where it is not clear from the Avinode Group product or service that you utilize or from your relationship with us, we may inform you about how your personal information is processed and the rights and remedies you have under our Privacy Principles. In addition, where permitted under applicable law, you may object to certain types of processing. The Avinode Group business(es) with which you transact provide notifications regarding the collection and processing of personal data and such notices may be found in the Privacy Notice.

 

Data Security and Confidentiality

We will keep your personal information confidential and limit access to your personal information to those who specifically need it to conduct their business activities, except as otherwise permitted by applicable law. We have implemented industry standard measures to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. We require industry standard data security measures from those third parties who are authorized by us to process your personal information on our behalf.

 

Choices Regarding How We May Use and/or Disclose Personal Information

We strive to provide you with choices regarding the personal information you provide to us, including giving you the option of having your personal information included or removed from lists used by Avinode Group for marketing purposes, as may be required by applicable law. Each of our businesses may continue to send its customers information about the products or services that they receive from that business.

 

Accessing and Maintaining Personal Information

Depending on your country or residence and/or citizenship, under applicable laws such as the EU General Data Protection Regulation (“GDPR”), you may also have the right to demand access to, review and change, and request deletion of the personal information that you have provided to us. Please note, however, that we may not always be able to accommodate your request to change or delete information if we believe doing so would cause the information to be incorrect, if we have a legitimate business purpose to retain that information, and/or if doing so might violate other legal obligations.

 

Transferring Personal Information

As a global group of companies, we may transfer the Personal Information we collect about you to countries other than the country in which the information was originally collected. When we transfer your information to other countries, we will take appropriate steps to protect that information. Where it is not clear from the Avinode Group product or service or from your relationship with us, we will tell you if your personal information may be transferred outside of your country. We will ensure any transfers are conducted in accordance with applicable law.

If you are located in a country subject to the GDPR, please note that we will comply with applicable legal requirements and have adequate measures in place to provide protection for the international transfer of Personal Information. These measures include, among others, contractual obligations for recipients to handle and protect the personal information in accordance with standard contractual clauses developed by the European Commission.

 

Accountability

Avinode Group takes its data privacy obligations very seriously, and its employees may only process your personal information in accordance with these Privacy Principles, for which we conduct training and review compliance. Employees who violate these Privacy Principles may be subject to disciplinary action, up to and including termination.

 

Additional Information and Contact Details

For more detailed information regarding the collection and/or processing of your personal information, please visit our Privacy Notice.

If you have specific questions, and/or are eligible to exercise certain rights as described above, please email privacy@avinode.com or write to us at:

Avinode Group

Attn: Privacy Administrator, Legal Department

Odinsgatan 10

411 03 Gothenburg

Sweden