Privacy Policy

Privacy Policy

Your Privacy, Our Priority: Navigating Your Trust in Aviation Excellence.

Allestro is dedicated to safeguarding individual privacy and adhering to relevant data protection laws and regulations. Our goal is to ensure your comfort with our methods of collecting, processing, securing, and sharing your personal information. This Privacy Notice elaborates on the personal data we gather, our usage practices, our sharing protocols, and how you can manage the use of your information.

This Privacy Notice governs the primary processing of personal data by Allestro. For specific processing activities or tools, detailed information may be provided in a separate privacy notice.

What is personal data?
Personal data encompasses any information capable of identifying an individual, whether directly or indirectly. This category includes details like names, contact information, identification numbers, financial records, geographic locations, or online identifiers.

What personal data do we use?

Depending on the nature of your relationship with Allestro, we collect, use, and process the following categories of personal data:

  • Identification Information includes full name, contact information (mailing address, email address, phone number), signature, nationality, age, gender, birth date and place, identification and passport numbers, social security number, photographs, voice clips, videos, CCTV footage, audio recordings, and details of vehicle registration and driver’s license.
  • Professional Information – This includes your resume, employment status with Allestro or its subsidiaries, and shareholder details.
  • Financial Information – Details such as banking and credit card information.
  • Technology-Related Information – Includes IP addresses, user accounts, personal or corporate identifiers, security passcodes, smartcard info, cookie IDs, and other tracking technologies, radio frequency identification (RFID) tags, activity records (from applications, security access controls, etc.), and passwords for IT systems or website access.

We may collect this personal data:

  • directly from you when you fill out a form and willingly supply us with this information, or
  • indirectly via your employer if necessary for a purpose outlined below or based on information that has been made public.

What are the purposes of the processing of your personal data?

Allestro may process your personal data for the purposes outlined below:

  1. Website Browsers / Administration Your personal data helps us enhance our understanding of how our various stakeholders interact with our websites. It supports our administrative tasks, including security and fraud prevention measures, policy enforcement, and generating reports for partners and regulators.
  2. Marketing Within legal boundaries and when relevant, we use your personal data for marketing efforts, such as sending emails or other electronic communications to keep you informed about Allestro’s products and news that might interest you.
  3. Communication We utilize your personal data to engage with you, addressing any requests for assistance. Communication methods include email, social media interactions (with your consent), and text messaging. Additionally, your information supports our internal and external communication channels, event management, and updates on Allestro’s financial results and product news.
  4. Recruitment We leverage personal data to recruit and select suitable candidates for positions within Allestro, ensuring a competent and effective workforce.
  5. Performance of Allestro Business Activities and Customer Services Your personal data aids in our sales and customer service activities, from managing customer relationships and technical support to maintaining customer accounts and managing supplier relations and procurement activities.
  6. Research and Development We engage in research and development to enhance our websites, applications, services, and overall customer experience. This also includes efforts to improve our products, services, and operational processes.
  7. Security and Health & Safety Personal data is crucial for managing access rights to Allestro’s digital spaces, IT security, physical access controls, and health and safety procedures, ensuring a secure and safe environment for all stakeholders.
  8. Compliance with Legal Obligations We process personal data to fulfill legal requirements, respond to legal processes, and adhere to export controls and sanctions laws.
  9. Protection of Allestro and Others In scenarios where it’s necessary to address illegal activities, fraud, or safety threats, we will process personal data to protect the interests of our stakeholders and comply with our policies.

We will utilize your personal data strictly for the stated purposes, unless a need arises to use it differently, in which case the new purpose will be compatible with the original. Should an unrelated need for processing your data emerge, we will inform you beforehand and provide the relevant privacy details.

What is the legal basis for the processing of your personal data?

Subject to applicable laws, we process your personal data on the following legal grounds:

  1. To Fulfill Contractual Obligations. Your subscription to any of our services through a website sets the primary purpose for processing your personal data. We process your information to ensure the provision of the subscribed service.
  2. Based on Your Consent. If you’ve given us consent to process your personal data for specific services, you have the freedom to withdraw this consent at any time. Withdrawal instructions are provided during the subscription process or can be followed by contacting us at dataprotection@Allestro.com. For details on how to withdraw consent and exercise your rights regarding your personal data, please refer to the section “How to exercise your rights and/or contact Allestro regarding your personal data?”
  3. For Legitimate Interests. Sometimes, to minimally impact your privacy, it becomes necessary to process your personal data:
    • To manage and perform our business operations, including accounting, auditing, and fulfilling contracts.
    • To analyze and improve our websites.
    • To ensure IT and facility security, including the detection of security threats, fraud, or other harmful activities, and the protection of Allestro facilities and individuals.
    • To prevent and investigate criminal activities.
    • For communication purposes, such as updating you on our latest services, solutions, business activities, events, marketing campaigns, market analysis, or other promotional activities, and to enhance the quality of our services and our communication with you.
    • To monitor compliance with our policies and standards.
  4. According to Allestro’s Legal Obligations or Public Interest. Like any other company, Allestro is bound by legal obligations and regulations. Processing your personal data may be necessary for Allestro to meet these legal requirements.

Who will receive your personal data?

In accordance with applicable laws, we may share your personal data with certain recipients on a strictly need-to-know basis, including:

  • Allestro and its affiliated companies;
  • Authorized individuals acting for or on behalf of Allestro, such as our agents, service providers, and advisors, offering a range of essential products and services (this includes IT, procurement, communications, compliance, security, and training services);
  • Business partners of Allestro engaged in activities related to Allestro’s operations (this encompasses educational institutions for recruitment purposes, law firms, auditors, consultants, insurance companies, and flight schools);
  • Customers of Allestro;
  • Other authorized third parties, in the event of a merger, organizational restructure, sale of Allestro assets, or if our business undergoes financing or acquisition by another company;
  • Law enforcement or regulatory authorities, when required to adhere to legal obligations.

Is any of your personal data transferred overseas?

Except for Allestro Affiliates operating outside the European Economic Area or the UK, we generally process your personal data within these regions. Occasionally, we may transfer personal data to countries outside of these areas.

Within Allestro, we may share your personal data for our daily business operations and internal organization, governed by an intra-group agreement outlined in our Binding Corporate Rules (Binding Corporate Rules). These rules include contractual safeguards to ensure that your personal data is protected adequately across all Allestro entities.

Furthermore, we may disclose some personal data to external parties located beyond the European Economic Area and the UK, adhering to strict protocols to safeguard your privacy rights:

  • We ensure personal data is only transferred to countries recognized for adequate legal data protection standards or where adequate privacy safeguards are confirmed.
  • Transfers to service providers and third parties are secured by contractual agreements (e.g., European Commission-approved Standard Contractual Clauses) or other legally recognized mechanisms ensuring adequate protection.
  • We rigorously evaluate any law enforcement or regulatory requests for personal data to ensure compliance before any disclosure.

We also process personal data in third countries, aligning with local data protection laws and regulations, as detailed in our specific privacy notices.

For inquiries about data transfers, please reach out to us at dataprotection@Allestro.com for more information.

How long will your personal data be retained?

We hold your personal data for as long as necessary to fulfill the purposes for which it was gathered. However, there may be situations where we need to keep your personal information for an extended period, beyond those purposes, to comply with legal, regulatory, tax, or accounting obligations.

Regarding newsletters, we will manage your personal data until you choose to unsubscribe.

What about the security of your personal data?

We implement comprehensive technical and organizational security measures to safeguard the personal data under our control from accidental or intentional manipulation, loss, destruction, or unauthorized access. Our security protocols are consistently updated to incorporate advancements in technology, ensuring the highest level of protection.

What are your rights?

You can exercise your personal data protection rights at any time by reaching out to us at dataprotection@Allestro.com, as outlined below:

  • Access/Obtain Information: You’re entitled to confirm if Allestro is processing your personal data and, if so, to obtain a detailed report of the specific data being handled.
  • Correction of Personal Data: If any personal data concerning you is inaccurate, you have the right to request its correction.
  • Right to be Forgotten: Under certain conditions, such as when your personal data is no longer needed for the purposes it was collected, you can request its deletion.
  • Restriction of Processing: You have the authority to limit the processing of your personal data by Allestro, especially in cases where the processing is unauthorized, and you oppose the deletion of your personal data. In these instances, your data will be processed solely with your consent or for legal claim purposes.
  • Data Portability: In specific legal scenarios, you are entitled to receive your personal data in a structured, widely used, and machine-readable format and/or transfer that data to a different controller.
  • Objection to Processing: Under certain legal conditions, you have the right to request that we cease processing your personal data.
  • Withdrawal of Consent: Where your consent is the basis of the processing, you can withdraw it at any time. However, be aware that withdrawing consent may render you unable to access certain information, features, or services.

How to exercise your rights?

Should you wish to exercise your rights, express dissatisfaction with the handling of your personal data, or have any inquiries about how your information is processed, kindly reach out to the Allestro Personal Data Protection Officer via email at: dataprotection@Allestro.com.

Should there be any uncertainty regarding your identity, we may request that you provide verification by submitting a copy of a valid identification document.

In the Preference Centre, you have the flexibility to update your personal data at any time for the newsletters you’re subscribed to.

Do we use automated decision-making?

Guided by our principles, we abstain from employing fully automated decision-making processes, including profiling. Should our approach evolve, we will ensure you are promptly notified.

How to ask for assistance from the competent authorities?

Should you continue to feel unsatisfied, you are entitled to reach out directly to a Data Protection Supervisory Authority. Below, you’ll find a list of the primary countries where Allestro operates, alongside the corresponding Supervisory Authority for each.

FRANCE: CNIL: Supervisory Authority France

GERMANY: Each federal state has its own Data Protection Authority that can be found under the following link: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html

SPAIN: AEPD: Supervisory Authority Spain

UK: ICO: Supervisory Authority UK

Additional Notice

for California residents

In accordance with the California Consumer Privacy Act of 2018 (CCPA), we uphold the principle of not selling your personal information to third parties. Our commitment remains steadfast unless a specific privacy notice indicates otherwise. We adhere to a strict non-discrimination policy towards California residents choosing to exercise their CCPA privacy rights. For instructions on how to exercise your California privacy rights, please see the section titled “How to exercise your rights”.

for Chinese residents

In accordance with this privacy notice or for other legitimate purposes, we may share and transfer your personal information to entities both within and outside China. We are committed to adhering to the relevant obligations and requirements under the Personal Information Protection Law (PIPL) regarding the sharing and cross-border transfer of personal information.

Cookies and similar technologies

Allestro utilizes Cookies and additional tracking technologies on its websites, as outlined in our Cookies Policy.

Modification of the Privacy Notice

Allestro is committed to regularly updating this Privacy Notice to ensure it accurately reflects our practices and services changes. Should there be any significant alterations in the way we manage your personal data, we will notify you promptly. The last update to this Privacy Information Notice was in November 2022.

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