Flyby, whose registered offices Flyby S.r.l., Via Aurelio Lampredi 45, 57121, Livorno, Italy (“Flyby”, “we”, “us”, or “our”) knows that you care how information about you (“your data”) is used and shared, and we appreciate your trust in us to do that carefully, securely and sensibly. We respect your privacy and are committed to protecting your data.
At Flyby S.r.l. we are committed to safeguarding and preserving the privacy of our visitors.
We do update this Policy from time to time, so please do review this Policy regularly.
Important information about who we are
Flyby is a controller and responsible for all personal data it receives and holds. We have appointed a data protection leader (“DPL”) who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the DPL using the details set out below:
Full name of legal entity:
Via Aurelio, Lampredi 45, 57121, Livorno (LI), Italy.
Information we collect
Personal data or personal information means any information about an individual from which that person can be identified. It does not include data where a person’s identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of data about you which we have categorised as follows:
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- We also collect and use Aggregated Data (as defined in this paragraph) such as statistical or demographic data for internal purposes. Aggregated Data may be derived from Your Data but is not personal data as it does not directly or indirectly reveal your identity. For example, we may aggregate information about how you use our website and services to calculate the percentage of users accessing a specific website feature, but this is anonymised. However, if we combine or connect Aggregated Data with Your Data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.
How is Your Data collected?
We use different methods to collect data from and about you, including through:
Automated technologies or interactions: If you interact with our website, we may automatically collect data about your equipment, browsing actions and patterns. When you visit our website, we automatically collect information about your use of our site including details of your visits such as pages viewed and the resources that you access. Such information may include Aggregated Data, traffic data, location data and other communication data.
Direct interactions: You may give us your Identity, and Contact Data by filling in forms, or by corresponding with us by post, phone, email or otherwise. This includes the personal data you provide when you:
- make an online enquiry;
- completing forms on our website. This includes information provided at the time of registering to use our site, subscribing to our service, posting material or requesting further services;
- request marketing material to be sent to you;
- provide us with feedback.
Use of Your Information
We will only use the information that we collect from you as follows:
- To enable us to comply with regulatory requirements;
- To communicate with you in the event that there is a query or problem with your order;
- To inform you of any changes to our website, services or goods and products;
- For record keeping purposes;
- For internal training and creation of internal training materials (with your explicit consent);
- To improve our services to you through machine learning and artificial intelligence software (with your explicit consent); and
- To track and analyse activity on our website.
We will only contact you for marketing purposes where you have given us your express consent to contact you for this purpose. Once you have given us your permission to contact you for marketing purposes, we may use Your Data for one or more of the following:
- To provide information to you that you request from us relating to our products or services.
- To provide information to you relating to other products that may be of interest to you.
- To allow selected third parties to use Your Data to enable them to provide you with information regarding unrelated goods and services, which we believe may interest you.
You may change your mind and withdraw your permission for us to contact you for marketing purposes at any time by emailing us at email@example.com. This will not affect your use of our services.
Storing Your Personal Data
We have put in place appropriate security measures to prevent Your Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to Your Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process Your Data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Please note that sending information via the internet is not totally secure and on occasion, such information can be intercepted. We cannot guarantee the security of personal information that you choose to send us electronically and sending such information is entirely at your own risk.
We will only retain Your Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for Your Data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of Your Data, the purposes for which we process Your Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
During the provision of our services to you, we will retain Your Data to provide our goods or services to you.
Please note that we may keep Your Data for longer than the periods stated above if it is necessary. However, this will be assessed on a case by case basis. If we determine that it is necessary to keep Your Data for longer than the periods listed above, we will confirm this to you in writing when we have finished providing our goods and services to you and explain why it is necessary.
Disclosing Your Data
As set out above, we may disclose Your Data to third parties, in accordance with this Policy, in the following circumstances:
We may share your Identity, Contact and Financial Data with our External Third Parties (as set out below) to enable us to provide our services (for example, we may provide your postal address to a courier, or we may share your name, address and age with a third-party service provider in order to verify your age and identity).
We may share Marketing and Communications Data where you have provided your express consent for us to share such with third parties for marketing purposes.
We may also share Your Data:
- with our internal third parties including the business entities within the Flyby Group.
- where we are legally required or permitted by law to disclose Your Data.
- In the event of a joint venture, collaboration, financing, sale, merger or reorganisation of the company. If a change happens to our business, then the new owners may use Your Data in the same way as set out in this Policy.
- To further fraud protection and reduce the risk of fraud (for example, to comply with anti-money laundering regulations).
In addition to the disclosures set out in “Disclosing Your Data” above, some of our third parties are based outside the European Union so their processing of Your Data will involve a transfer of data outside the European Union. Whenever we transfer Your Data out of the European Union, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer Your Data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the EU-US Privacy Shield Framework which requires them to provide similar protection to personal data shared between Europe and the US.
Please email firstname.lastname@example.org if you want further information on the specific mechanism used by us when transferring Your Data outside the European Union.
Third Party Links
Your legal rights
In certain circumstances, you have the following rights under data protection laws in relation to Your Data. You have the right to:
Request access to Your Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Your Data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of Your Data. This enables you to ask us to delete or remove Your Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove Your Data where you have successfully exercised your right to object to processing (see below), where we may have processed Your Data unlawfully or where we are required to erase Your Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of Your Data where we are relying on a legitimate interest (or those of a third party), and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing Your Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process Your Data which override your rights and freedoms.
Request restriction of processing of Your Data. This enables you to ask us to suspend the processing of Your Data in the following scenarios:
- if you want us to establish the data’s accuracy;
- where our use of Your Data is unlawful, but you do not want us to erase it;
- where you need us to hold Your Data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of Your Data, but we need to verify whether we have overriding legitimate and/or legal grounds to use it.
Request the transfer of Your Data to you or to a third party. We will provide to you, or a third party you have chosen, Your Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process Your Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. Please note that we may not be able to comply with this request where we have a legal obligation to keep Your Data.
If you wish to exercise any of the rights set out above, please email email@example.com.
Data subject access request
You will not have to pay a fee to access Your Data (or to exercise any of the other rights set out above). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access Your Data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
Please do not hesitate to contact us regarding any matter relating to this Policy at firstname.lastname@example.org.