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Spaero
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PRIVACY POLICY

Policy version: 06-June-2023

1. INTRODUCTION

This Privacy Policy is provided by Spaero Limited, a company registered in England and Wales under company number: 15482090 with registered office 1 Sopwith Crescent, Wickford, Essex, England, SS11 8YU (‘we’, ‘our’ or ‘us’) for use of our products and services including Spaero, our online trading platform designed for registered users to buy and sell for new or used aircraft components or services, which is available on our website here: www.spaero.co.uk/documents/privacy-policy.pdf (Services).

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data).

It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).

We are the controller of personal data obtained via the Services, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

2. WHAT THIS POLICY APPLIES TO

This privacy policy relates to your use of the Services only.

The Services may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.

3. PERSONAL DATA WE COLLECT ABOUT YOU

The personal data we collect about you depends on the particular activities carried out through the Services. We will collect and use the following personal data about you:

If you do not provide personal data we ask for where it is required, including the geo-localisation services, it may prevent us from providing services and/or the Services to you.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

4. SENSITIVE DATA

Sensitive personal data (also known as special category data) means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person’s sex life; and data concerning a person’s sexual orientation.

Please note that we do not knowingly or intentionally collect sensitive personal data or information about criminal convictions from individuals and that you should not submit sensitive data to us.

If, however you do submit sensitive data to us, such as if you make this sensitive data available to other users of the Services (such as by publishing it through any forum feature we may make available from time to time) we will assume that you have purposefully made any such sensitive data manifestly public.

5. LOCATION SERVICES/DATA

The Services will request your consent to use location services to precisely identify your location each session (i.e. each time the Services is opened or has been placed in the background for more than 30 seconds).

This location data is in the form of IP addresses, and is collected as part of google analytics. To withdraw your consent at any time you can turn off the localisation permissions for our app on your device.

The location services in the Services will not operate unless location services/data are generally enabled on your device. You may disable such functionality at any time by turning your device’s location on “off” using the device’s settings app. When you allow your device to use location services/data, data will also be collected by Google in accordance with their Privacy Policy, as this is the map service we integrate to our app.

We exert no control over Google’s Privacy Policy and we therefore recommend that you consult their privacy policy for further information on how Google protect personal data please visit their site – https://policies.google.com/privacy?hl=en-US. For more information see the section ‘Who we share your personal data with’ below.

6. HOW YOUR PERSONAL DATA IS COLLECTED

We collect personal data from you directly when you sign up to the Services, contact us directly or reach out to us via social media, make submissions via the Services when a forum element is available, or indirectly, such as your activity while using the Services.

We also collect personal data about you using cookies and similar technologies in accordance with your device settings. Detailed information regarding our use of cookies is set out in our Cookies Policy, which is available here: https://xsaviation.com/documents/cookie-policy.pdf.

7. HOW AND WHY WE USE YOUR PERSONAL DATA

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

  1. where you have given consent
  2. to comply with our legal and regulatory obligations
  3. for the performance of a contract with you or to take steps at your request before entering into a contract, or
  4. for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your personal data for and why.

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

8. MARKETING

We intended to email marketing to inform you of our services such as promotions.

We will always ask you for your consent before doing sending you marketing communications, except where you have explicitly opted-in to receiving email marketing from us in the past or except where you were given the option to opt-out of email marketing when you initially signed up for your account with us and you did not do so.

You will have the right to opt out of receiving marketing communications at any time by:

  • contacting us at www.spaero.co.uk/contact
  • using the ‘unsubscribe’ link included in all marketing emails you may received from us

We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

9. WHO WE SHARE YOUR PERSONAL DATA WITH

We routinely share personal data with service providers we use to help us run our business or provide the services or functionalities in the Services, including repair providers and distributors, developers and cloud storage providers. We use Think One to run our Services, and we therefore recommend that you consult their privacy policy for further information on how it protect personal data – https://www.thinkone.group/privacy-policy/.

We only allow service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.

We or the third parties mentioned above may occasionally also need to share your personal data with:

  • external auditors, e.g. in relation to the audit of our accounts and our company —the recipient of the information will be bound by confidentiality obligations
  • professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations
  • law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
  • other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

We will not share your personal data with any other third party.

10. HOW LONG YOUR PERSONAL DATA WILL BE KEPT

We will keep your personal data for as long as you have an active account with us and for a period of up to 6 years thereafter to comply with any accounting or legal obligations including in the event of the pursuit or defence of legal claims. Once you have closed your account with us, we will move your personal data to a separate database so that only key stakeholders in our business on a ‘need to know basis’ have access to such data.

Following the end of the of the aforementioned retention period, we will delete or anonymise your personal data.

11. TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK

At this point in time, we do not transfer your personal data outside of the UK. If this changes, we would comply with applicable UK laws designed to ensure the continued protection and privacy of your personal data. Any updated destinations to which we send your personal data, would be indicated in the present section and notified to you in accordance with the section on ‘Change to this privacy policy’ below.

Furthermore, under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law. Accordingly, if we were to start transferring your personal data from the UK to:

  • The EEA: we would rely on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement to do; for any transfers from the EU to the UK, we would rely on the adequacy regulation granted to the UK under the Adequacy Decision.
  • Any country located outside the UK/EEA: we would rely an appropriate safeguards under the UK GDPR, such as by including the relevant Standard Contractual Clauses in our data processing agreements

In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.

12. YOUR RIGHTS

You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please complete a request form—available on our website at https://xsaviation.com/contact or email, call or write to us—see below: ‘How to contact us’. When contacting us please:

  • provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you, and
  • let us know which right(s) you want to exercise and the information to which your request relates
13. KEEPING YOUR PERSONAL DATA SECURE

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

14. HOW TO COMPLAIN

Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner.

The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

15. CHANGES TO THIS PRIVACY POLICY

We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example via the Services or by other means, such as email.

16. HOW TO CONTACT US

You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

  • Address: 1 Sopwith Crescent, Wickford, Essex, England, SS11 8YU
  • Email Address: concerns@spaero.co.uk.
  • Phone Number: +44-1733-347000