Skylink Services Ltd (“Skylink”, also referred to as “we”, “us”, “our”) are providing this privacy policy to inform you (“you” refers to any entity or person who is not a Skylink employee) regarding our collection, use, disclosure, and storage of data about you that we collect via our websites, telephone, facsimile, or otherwise. Our primary goals in collecting data are to provide superior products and services to our clients and to contact companies and individuals who have indicated an interest in Skylink. Skylink follows all relevant laws and regulations regarding Data Protection, including GDPR.

 [General Data Protection Regulation (EU) 2016/679 (GDPR) is a regulation in EU law on data protection and privacy for all individual citizens of the European Union (EU) and the European Economic Area (EEA). It also addresses the transfer of personal data outside the EU and EEA areas.]

DATA WE COLLECT

We collect personal data from you directly and from third parties. We collect personal data directly from you when you fill out any online or hard-copy forms or provide information to us by any means of communication. Your submission of personal data is voluntary, but we may be unable to provide you requested information, products, and services if you choose not to provide the necessary personal data, explicitly with your consent.

In some cases, we may also collect certain personal data from third parties such as brokerage and charter agencies, airlines and travel agencies, government departments and our other business customers.

We also collect non-personal data when you visit or use our websites or access our services. This non-personal data may include information about your device and usage such as your operating system, browser, geographical location, IP address, and page views and clicks.

USE OF YOUR DATA

We use your data:

• for the purposes for which you provided it to us
• to respond to your inquiries and communications to us;
• to improve, maintain, and operate our websites and our services;
• to fulfil our obligations under our customer contracts (e.g., to provide ground handling services, flight planning services, trip support services, in-flight catering services, or any other logistics services pursuant to our customer contracts or requests);
• to screen you against lists of people, organizations and vessels with which  certain countries are prohibited from doing business; and
• to comply with statutory and regulatory requirements, including responding to lawful requests for information by governmental authorities.

You may revoke your consent to the use of your data for certain other purposes by contacting us directly via email.

DISCLOSURE OF YOUR DATA

We do not sell your personal data to any third parties. We may share your personal data as needed to fulfil the purposes described in the “USE OF YOUR DATA” section above, including:

• with our suppliers and vendors to provide goods and services you have requested;
• with global trip support providers to provide additional services to you;
• with our service providers, such as technical or customer support providers, who use the data on our behalf; and
• as necessary in response to lawful requests by public, governmental authorities, including to meet national security or law enforcement requirements.

We require such third parties to take reasonable security measures to protect your personal data, and we prohibit such third parties from using your personal data for their own purposes, or any purposes other than pursuant to our instructions and contractual obligations. 

DATA CONTROLLER

We are typically the data controller, as that term is used in applicable privacy laws, for any personal data that we collect from you. However, when we collect data from or on behalf of our customers (e.g., charter aircraft operators, corporate aviation departments), those customers may be the data controller for such data and we may be the data processor. If we are acting as the data processor, we will only process the relevant data in accordance with the applicable customer contract requirements.

DATA RETENTION, ACCESS, AND CORRECTION

We may retain your data so long as we can reasonably foresee the data may be required in connection with our business relationship with you. In some cases, we will retain the data for a longer period as necessary to comply with our legal obligations, follow records retention policies, resolve disputes, and enforce our agreements.

You may request  access and correct your personal data that we process, except where the burden of providing you such access would be disproportionate to the risks to your privacy, or where the rights of other persons would be violated. You may also request erasure of your personal data in certain circumstances. To request access to, correction of, or erasure of your personal data, please contact us via email. In cases where we are not the data controller (such as when the personal data was collected from or on behalf of a charter aircraft operator, corporate aviation department or other customer), we may need to refer you or your request to the applicable data controller.

SECURITY

Skyink is very concerned with safeguarding your personal data. The integrity and availability of your personal data are critical to the provision of superior products and services to you. We employ administrative, physical, procedural, and technological measures designed to protect your data from unauthorized access or alteration and loss or misuse. We have implemented a multi-layered approach to protect electronic information through an Information Technology (IT) Security program. Our IT Security program is designed to safeguard electronic information by proactively providing leadership and support for areas related to network security, system security, risk assessment, remediation tracking, and adherence to security compliance mandates. Skylink employees work as a team to ensure that information is protected against unintentional disclosure and are guided by compliance objectives, standard operating procedures, and acceptable usage policies.

PRIVACY POLICY CHANGES

We reserve the right to and may revise this privacy policy from time to time. If we make a material change to this policy, we will post the updated privacy policy (with the date of change(s) noted in the policy) on our homepage and other places we may deem appropriate, so that you are aware of what data we collect, how we use it, and under what circumstances, if any, we disclose it.