GDPR Policy

Privacy Policy

This is the Redhill Aerodrome Limited’s Privacy Policy.

Redhill Aerodrome Limited respects your privacy and is committed to protecting your personal data. This Privacy Policy gives information on how we look after your personal data when you visit our website (regardless of where you visit it from) or book services with us and tells you about your privacy rights and how the law protects you.

A glossary of terms is provided at the end of this privacy policy so that you can understand the meaning of the various terms that are used in it.

1.IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

The purpose of this privacy policy is to give you information on how Redhill Aerodrome Limited collects and processes your personal data, including the contact details that you provide through the website, by email or over the telephone when you book services or make enquiries about our services.

Redhill Aerodrome Limited is the controller and responsible for your personal data (collectively referred to as "Company", "we", "us" or "our" in this privacy policy).

CONTACT DETAILS

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We will keep our privacy policy under regular review. This policy was last reviewed on 9 Jan 2020. Historical versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. W

2.DATA WE COLLECT ABOUT YOU

Personal Data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Redhill Aerodrome Limited may collect, use, store and transfer the following different kinds of personal data about you:

• Technical Data includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology any devices used to access this website.
• Usage Data includes information on use of our website and products and services.
• Identity Data includes first name, last name, username or similar identifier, title, data of birth and gender, and also includes CCTV images.
• Financial Data includes bank account and payment card details
• Transaction Data includes details about payments to and from you and other details of services you have purchased or may be interested in purchasing from us.
• Contact Data includes billing address, email address and telephone numbers, and any contact details you provide on any specific enquiry or bookings forms either on the website or at the Aerodrome.
• Communications Data includes all communications we have with you whether by email, post, phone or otherwise, including any consultation form information, as well as any feedback given directly or indirectly to our staff or consultants.

We may also collect and use Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal 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 privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform an existing contract or enter into a new contract with you. In such a case, we may have to cancel a product or service you have with us but will notify you at the time if this is the case.

METHODS OF COLLECTING YOUR PERSONAL DATA

We use different methods to collect data from and about you including through:

• Direct Interactions. You may give us your Identity, Contact and Financial Data by filling in forms, contacting us through our website or communicating with us by post, phone, email or otherwise. This includes personal details you provide when you:
  • visit our premises
  • enquire about and/or pay for our services;
  • apply for an account or enter details on our website, or
  • engage with any consultation process or provide us with feedback.

In addition, your image may be recorded by our CCTV cameras at the Aerodrome and, to the extent that you are identifiable from those images or in combination with any other person, this may also amount to Personal Data.

• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources:
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

3.HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to, to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

See the Glossary, and the definition of Lawful Basis to find out more about the types of lawful basis that we will rely on to process your personal data.

We do not rely on consent as a legal basis for processing your personal data. If at any time this changes, and we ask for your consent to process personal data, you will have the right to withdraw consent at any time by contacting us although by doing so we may not be able to continue to provide certain services to you. We will advise you at the time if that is the case.

PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

MARKETING

At present, we do not carry out, or intend to carry out, any marketing or advertising activities that would involve processing your personal data.

Similarly, we do not share your personal data with any third party for the purpose of marketing.

4.DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table in section 3 above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5.TRANSFERRING YOUR PERSONAL DATA ABROAD

We do not transfer your personal data outside the European Economic Area (EEA).

SAFETY AND SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal 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.

DURATION OF DATA RETENTION

We will only retain your personal data for as long as we need it to meet the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirement. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data, are available by contacting us.

In some circumstances you can ask us to delete your data: see “Your Legal Rights” in section 6 below.

We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in these cases we may use this information indefinitely without further notice to you.

6.YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws as follows:

• The right to request access to your personal data;
• The right to request correction of your personal data;
• The right to request erasure of your personal data;
• The right to request a restriction of the processing of your personal data;
• The right to object to processing of your personal data;
• The right to withdraw your consent;
• The right to request the transfer of your personal data.

Further details of these legal rights are set out in the Glossary under “Your Legal Rights”.

Please contact us if you wish to exercise any of the rights set out above.

FEES

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). 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 personal 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.

RESPONSE TIMES

We try to respond to all legitimate requests within one month. Occasionally, it could take longer if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated.

COMPLAINTS

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

LIST OF WEBSITES COVERED BY THIS POLICY

www.redhillaerodrome.com

GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the Group acting as joint controllers or processors and who are based in England and provide administration services.

External Third Parties

• Service providers acting as processors based in the UK and who provide billing and IT services including Nevalee Business Solutions Limited.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK and who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, The Civil Aviation Authority, regulators and other authorities acting as processors or joint controllers based in the United Kingdom.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal 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 personal data. This enables you to ask us to delete or remove personal 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 personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal 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 personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular 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 personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal 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 personal 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.