Privacy policy

Skytra Privacy Policy and Disclaimer

Introduction

Welcome to SKYTRA LTD (an Airbus Company) Privacy Notice.

SKYTRA respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you are visiting our website) and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW WE COLLECT YOUR PERSONAL DATA

4. HOW WE USE YOUR PERSONAL DATA

5. WHO WE WILL DISCLOSE OR SHARE YOUR PERSONAL DATA WITH.

6.PERSONAL DATA INTERNATIONAL TRANSFERS

7. WHAT SECURITY DO WE USE TO SAFEGUARD YOUR PERSONAL DATA

8. DATA RETENTION

9. YOUR LEGAL RIGHT AS DATA SUBJECT

10. GLOSSARY

11. DISCLAIMER

12. INTELLECTUAL PROPERTY

13. ACCURACY

14. COOKIES POLICY

15. WHO YOU CAN CONTACT

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Skytra Limited collects and processes your personal data when you apply to open an account with us in other to use one of our services or whenever you visit or use this website, including any data you may provide through this website when you sign up to our services or contact us to request for information.

This website is not intended for children and we would not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing your personal data so that you are fully aware of how we are collecting and processing your data. This privacy notice supplements the other notices and is not intended to override such other notices.

  1. Controller

This privacy notice is issued on behalf of Skytra Limited so when we mention “Skytra”, “we”, “us” or “our” in this privacy notice, we are referring to the company responsible for processing your data - .i.e. Skytra Limited.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us (information@skytra.com)

You have the right to make a complaint at any time to us about how you feel regarding your personal data with us. We would appreciate the chance to deal with your concerns. If after contacting us you feel the need to contact the UK Data Protection regulatory authority, please do so, however, we would appreciate it before you approach the ICO to contact us in the first instance. To contact the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues please visit the ICO’s website at www.ico.org.uk.

  1. Changes to the privacy notice and your duty to inform us of changes

This version was first updated on the 20th of January 2020 and subject to periodic review.

This privacy notice sets out your rights under the UK Data Protection Act 2018 and the EU GDPR 2016.

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.

  1. 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. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The Data we collect about you

Personal data, or personal information, means any information related to an individual from which that person can be identified. It does not include data where the identity has been removed or modified.

We may collect, process, store or transfer different kinds of personal data about you from you, these which we have grouped as follows:

Identity Data includes first name, last name, username, job title, or similar identifier

Contact Data includes company email address, company address and telephone numbers.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us including invoices.

Technical Data includes internet protocol (IP) address, your login data, browser type, and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data includes information about how you use our website, products, and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Aggregated Data We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 notice.

Special Categories of Personal Data We do not collect any Special Categories of Personal Data about you (such as 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 offenses related to you, such as driving offense.

If you refused to provide us your Personal Data

Reasons, why we may collect your personal data, includes, to engage a service with you, under the terms of a contract we have with you, by regulation means, should you refuse to provide such data when requested, we may not be able to perform the service or contract we have or are trying to enter into with you (for example, to provide you with services you want from us). In this case, we may have to cancel such service you have with us but we will notify you if this is the case before we do so.

3. How is your Personal Data collected?

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

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in an application on our website or by corresponding with us by post, phone, email or otherwise. This includes the personal data you provide when you:

• apply for our products or services;

• create an account on our website;

• subscribe to our service or publications;

• request marketing to be sent to you;

• enter a competition, promotion or survey; or

• give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. (please click here to read about our cookies policy).

Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:

• Technical Data from the following parties:

a. analytics providers such as Google based outside the UK/ROI and the EU;

• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK/ROI and the EU.

4.0 How we use Your Personal Data

We will only use your personal data when the law allows us to do so, known as Lawful bases of the processing of personal data. Hence we will use your personal data in the following circumstances:

• Where we need 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 or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw your consent to marketing at any time by contacting us at (information@skytra.com)

Purposes for which we will use your Personal Data

The number one Principle of Both the UK DPA and the EU GDPR is Accountability and Transparency, as such, we have set out below, in a tabular format, a description of all the ways we plan to use your personal data, with established legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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 (information@skytra.com) 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 below.

Purpose When you register as a new customer

Type of data

a) Identity

b) Contact

Lawful bases for processing including legitimate interest, contract, consent and legal obligation

Performance of a contract and Services with/for you

Purpose

To manage our relationship with you/contact you which will include:

a) Notifying you about changes to our terms or privacy policy

b) Asking you to leave a review or take a survey

c) Updates you about new services or marketing-related

Type of data

a) Identity

b) Contact

c) Profile

d) Marketing and Communications

Lawful bases for processing including legitimate interest, contract, consent and legal obligation

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) Consent

Purpose

To enable you to partake in a prize draw, competition or complete a survey

Type of data

a) Identity

b) Contact

c) Profile

d) Usage

e) Marketing and Communications

Lawful bases for processing including legitimate interest, contract, consent and legal obligation

a) Performance of a contract with you

b) Necessary for our legitimate interests (to study how customers use our products/services to develop them and grow our business) Consent

Purpose

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data

a) Identity

b) Contact

c) Technical

Lawful bases for processing including legitimate interest, contract, consent and legal obligation

a) Necessary for business legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

b) Necessary to comply with a legal obligation and to comply with regulations such as the UK DPA and the EU GDPR

Purpose

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Type of data

a) Identity

b) Contact

c) Profile

d) Usage

e) Marketing and Communications

f) Technical

Lawful bases for processing including legitimate interest, contract, consent and legal obligation

Purpose

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy and to help you enjoy the use of our website, such as fast browsing, and navigation)

Purpose

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of data

a) Technical

b) Usage

Lawful bases for processing including legitimate interest, contract, consent and legal obligation

Purpose

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Purpose

To make suggestions and recommendations to you about goods or services that may be of interest to you

Type of data

a) Identity

b) Contact

c) Technical

d) Usage

e) Profile

Lawful bases for processing including legitimate interest, contract, consent and legal obligation

Necessary for our legitimate interests (to develop our products/services and grow our business in other to offer you an improved service)

4.1 Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

4.2 Promotional offers from us

We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think may be of interest to you. This is how we decide which products, services, and offers may be relevant for you hence we refer to this as marketing.

You will receive marketing communications from us if you have consented information from us regarding our services and, in each case, you have initially opted in. however, you can always opt-out from receiving marketing or promotional offers from us even after initial acceptance.

4.3 Third-party marketing We will get your express opt-in consent before we share your personal data with any company outside of Skytra Limited for marketing purposes.

4.4 Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at information@skytra.com at any time.

Where you have decided to opt-out from receiving these marketing messages, this will not apply to personal data provided to us for product and service purchase, warranty registration, product/service experience or other transactions. If however, you require further information or clarification please contact us.

4.5 Cookies

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies popups. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please read our cookies policy

4.6 Change of purpose

We will only use your personal data for the purposes for which we have collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us (information@skytra.com)

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of Your Personal Data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties as set out in the [Glossary link]. • External Third Parties as set out in the [Glossary link]. • 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 notice.

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 agreed with them to only process your personal data for original and specified purposes and in accordance with the purpose for which we have collected.

6. International Transfers

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

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, disclosed, altered or accessed in an unauthorised way. In addition, we limit access to your personal data to our employees, agents, contractors, and other third parties only for the purpose of business need to know bases only. They have been well trained, they will only access or 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 (Supervisory Authority) of a breach when and where we are legally required to do so.

8. Data Retention

How long are we keeping or processing your personal data?

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for which in most cases is to provide you the services you agreed with us, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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.

By law and regulation standards, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see [Request erasure] below for further information.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated or identified with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your Legal Rights as a Data Subject Under certain circumstances, you have rights under data protection laws and regulations of the UK Data Protection Act 2018 and the EU GDPR 2016 in relation to your personal data.

Such rights include your right to:

Access Request to your personal data (commonly known as a “Data Subject Access Request”). This enables you to receive a copy of your personal data we hold about you and to check that we are lawfully processing your personal data.

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 in some cases.

Request erasure of your personal data. This enables you to ask us to delete or remove your personal data where there is no good reason for us to continue with the process of your personal data. 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 (as shown 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 complete erasure for specific legal reasons which will be explained 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 overrides 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds.

Request the transfer of your personal data to you or to a third party. We will provide 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 chose to withdraw your consent.

If you wish to exercise any of the sets out rights above, please contact us at information@skytra.com

No fee usually required

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 for more information about applicable fee relating to Data Subject Access Request please visit the ICO website www.ico.org.uk

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 the wrong person who has no right to receive personal information. 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 will try to respond to all legitimate requests within one month as requested by law. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated particularly should we need more time.

10. Glossary

A- 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 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 (information@skytra.com)

Performance of Contract means the processing of 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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. Such law and regulations include the UK DPA 2018 and the EU GDPR.

B- THIRD PARTIES

Internal Third Parties

Other companies in the Skytra Group acting as joint controllers or processors

External Third Parties

• Service providers acting as processors based in the United Kingdom and within the European Union jurisdiction and are EU GDPR compliant who provide IT and system administration services.

• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom and within the European Union jurisdiction and are EU GDPR compliant who provide consultancy, banking, legal, insurance, and accounting services.

• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

11. Disclaimer

This Website www (the “site”) is operated by Skytra Limited (“Skytra”). These conditions of use are governed by the laws of England and Wales of the United Kingdom and you agree that the English courts shall have exclusive jurisdiction in any dispute.

12. Intellectual property

Your use of this website and any materials downloaded, viewed, copied or printed does not authorise you to use any names or trademarks of Skytra Limited.

The copyright notice which is displayed in this site indicates that all materials within the site are the intellectual property of Skytra Limited. Such materials may not be copied save to the extent necessary to view them online. However, you may print complete pages of the site as hard copies for your own personal use.

13. Accuracy of information

Whilst Skytra Limited uses reasonable endeavours to ensure that the contents of this site are accurate and up to date, it does not accept any liability for any information which may not be accurate. Skytra Limited is reliant upon third parties for much of the information provided (see below) and reserves the right to change data, references and product specifications at any time or from time to time.

The contents of this site are for general information and public relations purposes only and do not purport to provide advice, make any offer or otherwise create or lead to the creation of any legally enforceable relationship between Skytra Limited and you. No reliance should be placed on any statements made on the site, whether for investment purposes or otherwise. Skytra Limited excludes to the fullest extent permitted by law all liability resulting from your access to the site including (without limitation) any loss (financial or otherwise) or damage resulting directly or indirectly from any such reliance.

Certain hypertext links contained in this site will direct you to websites that are not under the control of Skytra Limited. Such links are included for your convenience and do not constitute an endorsement by Skytra Limited of third party products or services. The selection of a link will take you out of this site to other websites that Skytra Limited has no control over. Skytra Limited accepts no liability or responsibility whatsoever for any other websites which may be accessed through the Skytra Limited site, nor does Skytra Limited endorse or make representations in respect of such websites. All links are used at your own risk. In evoking links to other websites, you agree to accept these conditions of use.

You may not create a link to this website from another website or document without Skytra Limited’s prior written consent. Persons providing access to this website via links from another website are solely responsible for the content, accuracy, opinions expressed, privacy policies, products or services of, or available through, the source website and for any representations made or impressions created concerning Skytra Limited.

14. How to Contact us

If you have submitted personal data through the site and would like that information deleted from our records, please contact us at (information@skytra.com)

Latest update: January 20th, 2020

Request a call back

For more information on accessing our indices, or for any other enquires please request a call back from us.

Or call us on the number below:

Phone: +44 (0) 20 8059 7700


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Skytra Limited is currently applying to the UK FCA for registration to act as a benchmark administrator. Skytra Limited is a wholly-owned subsidiary of Airbus, and is a company incorporated in England and Wales under registered number 11984828. VAT number: 335130145 and LEI 254900Y389SLBTPDX711. This presentation is for information purposes only. None of the information concerning the services or products described in this presentation constitutes advice or a recommendation of any product or service. To the extent that the information provided in this presentation constitutes a financial promotion as defined by section 21 of the Financial Services and Markets Act 2000, it is only directed at persons who qualify as Professional clients as classified by MiFID II. © Copyright Skytra Limited.
Skytra is an Airbus company facilitating financial risk transfer for the air travel industry