Privacy Notice

Version: 2018-05
Last Updated:25 May 2018

General Information

This privacy notice is meant to help you understand what data we collect, why it is collected and what we do with it.

To make this easier to understand, we've added the following quick links, to help you find out the reasons why we process your personal data and to see what we do with it.

  1. Introduction
  2. Airangel as a Data Controller - Our Details
  3. Data Protection Officers Details
  4. Airangel as a Data Processor
  5. Scope – What Does This Policy Cover?
  6. Your Data Protection Rights
  7. How Do We Get Information?
  8. How We Use Your Information
    1. Visitors to our websites;
    2. People who subscribe to our newsletter or request a publication from us;
    3. People who complete surveys or questionnaires on the Airangel blog;
    4. People who contact us via social media;
    5. People who call our helplines;
    6. People who email us;
    7. People Who Make a Complaint to Us;
    8. People who use our products and services;
    9. People who visit Our Offices;
    10. Job applicants and our current and former employees.
  9. Complaints or Queries
  10. Access to Personal Information
  11. Disclosure of Personal Information to Law Enforcement Agencies
  12. Data Transfer
  13. Data Retention
  14. Changes to this Privacy Notice
  15. How to Contact Us
  16. Definitions and Interpretation
  17. Attributions

Introduction

Airangel Limited understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Sites or use Our Services, and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.

The new GDPR legislation that came into force on 25 May 2018 replaced current data privacy law, giving more rights to you as an individual and more obligations to organisations like ours that hold your personal data.

One of the most important rights is a right to be informed about the way in which we use, share and store your personal information. Our privacy notice has been updated, so you can access this information, along with information about the increased rights you have in relation to the information we hold on you and the legal basis on which we are using it.

This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site. Within this policy we’ll tell you:

  • why we are able to process your information
  • what purpose we are processing it for
  • whether you have to provide it to us
  • how long we store it for
  • whether there are other recipients of your personal information
  • whether we intend to transfer it to another country, and
  • whether we do automated decision-making or profiling.

The first part of the notice is information we need to tell everybody, so please read this Privacy Policy carefully and ensure that you understand it.

Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site or Services and You will be required to read and accept this Privacy Noticewhen signing up for an Account. If you do not accept and agree with this Privacy Notice, you must stop using Our Site or Services immediately.

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Airangel as a Data Controller - Our Details

Unless otherwise stated, the controller for the pesonal information we process is Airangel Limited, a limited company registered in England and Wales under Company No: 494 8173. Our VAT number is GB 860 6694 96.

Our registered address and main trading address is:

Airangel Limited
Unit A, The Beacons, Birchwood Park,
Warrington,
Cheshire,
WA3 6GP,
United Kingdom

There are many ways you can contact us, including by phone, email, social media, and post. More details can be seen here.

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Data Protection Officers Details

Although Airangel Limited are not required to formally appoint a Data Protection Officer, our Chief Compliance Officer, (CCO) voluntarily takes on this role for Airangel.

You can contact the CCO by emailing compliance@airangel.com or via the postal address above. Please mark the envelope ‘Data Protection Officer’.

You can find more information about the role of the DPO on the Information Commissioners Office (ICO) website.

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Airangel as a Data Processor

Airangel are a Business-to-Business organisation. Because of the type of services we provide, we also process personal information on behalf of our Customers, typically venue opeartors or Partners who are offering WiFi services to their own end Customers.

In this capacity we are the Data Processor, and the Data Controller will be Our Customer. We have no control over the Privacy policies or Notices for our Customers. When you use a Customers WiFi you will be presented with their own terms and conditions of use and a Privacy Notice, which will be different to our own when we are the Data Controller.

Any Subject Access Requests (SAR) or enquiries regarding your rights must be directed to the Data Controller.

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Scope – What Does This Policy Cover?

This Privacy Policy applies only to your use of Airangel sites and Services.

It does not extend to any websites or services that are linked to from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

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Your Data Protection Rights

Under the recent GDPR requirements, you have rights as an individual which you can exercise in relation to the information we hold about you. The rights available to you depend on our reason for processing your information.

Under GDPR you have:

The right to be informedYou have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process.
The right of accessYou have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process.
The right to rectificationYou have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies.
The right to erasureYou have the right to ask us to erase your personal information in certain circumstances
The right to restrict processingYou have the right to ask us to restrict the processing of your information in certain circumstances.
The right to data portabilityYou have the right to object to processing if we are able to process your information because the process forms part of our public tasks, or is in our legitimate interests.
The right to object to processingThis only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated.
Rights in relation to automated decision making and profiling.You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning or affecting you.

 

General Considerations

If we are processing your information for criminal law enforcement purposes, your rights are slightly different. Please see the relevant section of the notice.

You are not required to pay any charge for exercising your rights. We have one month to respond to you.

Please contact us at support@airangel.com if you wish to make a request, 

More information about an individuals rights can be found on the ICO website.

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How Do We Get Information?

Most of the personal information we process is provided to us directly by you for one of the following reasons:

  • You are representing your organisation.
  • You have made an information request to us.
  • You wish to attend, or have attended, an event.
  • You subscribe to our e-newsletter.
  • You have made a complaint or enquiry to us.
  • You have applied for a job or secondment with us.

We also receive personal information indirectly, in the following scenarios:

  • Your Organisation has provided us with your details in order to provide you with access to our Products and Services or in relation to an opportunity or project
  • You have used the WiFi services at one of our Customers or Partners venues (where we act as a Data Processor on their behalf)
  • We have contacted an organisation about a complaint you have made and it gives us your personal information in its response.
  • A complainant refers to you in their complaint correspondence.
  • We have requested personal information as part of an investigation.
  • From law enforcement bodies.
  • An employee of ours gives your contact details as an emergency contact or a referee.

If it is not disproportionate or prejudical, we’ll contact you to let you know we are processing your personal information.

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How We Use Your Information

This privacy notice tells you what to expect when Airangel Limited (Airangel) collects and processes personal information. It applies to information we collect about:

Visitors to our websites

We use a third-party service, WPEngine.com, to publish our website, blog, and some of our affiliated microsites. These sites are hosted at wpengine.com, which is run by WPEngine, Inc. We use a standard WordPress service to collect anonymous information about users’ activity on the site, for example the number of users viewing pages on the site, to monitor and report on the effectiveness of the site and help us improve it. WordPress requires visitors that want to post a comment to enter a name and email address. For more information about how WordPress processes data, please see the WPEngine, Inc privacy notice

When someone visits www.airangel.com, or one of our affiliated sites we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

Links to Other Websites

This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.

Use of Cookies by Airangel

The Services may also require us to use cookies. A cookie is a text file, invoked by standard browser software, that we place on your hard drive to enable our systems to, among other things, recognize your browser, track transactions, and allow you to navigate the Service without having to re-enter information. The information gathered by cookies is not made available to organisations. We may also automatically receive and store certain other types of information, such as the type of web browser you use or the pages you browse to for statistical analysis and support purposes.

You can read more about our Cookie Policy here

Security and Performance

Airangel uses a third-party service to help maintain the security and performance of Airangel website. To deliver this service it processes the IP addresses of visitors to Airangel website.

Purpose & Legal Basis

The purpose for implementing all of the above is to maintain and monitor the performance of our website and to constantly look to improve the site and the services it offers to our users.

The legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests.

Your Rights

Although we rely on legitimate interest to process the personal data you provide to us, you have the right to access, to rectification, to be forgotten or to object to the processing of your personal data for this purpose at any time. If you do that, we’ll update our records immediately to reflect your wishes.

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E-newsletter or Subscribed Publications

We use a third-party provider, Hubspot, to deliver our e-newsletters. We gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our e-newsletter. For more information, please see Hubspot privacy notice.

We will need you to provide your name and your email address to enable us to send you the requested content.

We may ask you for additional information in order to tailor our communications with you with the aim of making them as relevant as we can. 

Purpose & Legal Basis

Our purpose for collecting the information is so we can provide you with a service that you requested and let you know about related upcoming events, or products and services changes.

The legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests.

Your Rights

Although we rely on legitimate interest to process the personal data you provide to us, you have the right to access, to rectification, to be forgotten or to object to the processing of your personal data for this purpose at any time. If you do that, we’ll update our records immediately to reflect your wishes.

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Online Reporting Tool

We collect information volunteered by clients and members of the public about our products and services using an online reporting tool hosted by SurveyMonkey. This company is a data processor for Airangel and only processes personal information in line with our instructions. For more information, please see SurveyMonkeys privacy notice.

Purpose & Legal Basis

Our purpose for collecting the information is so that we can understand the marketplaces within which we operate, and to improve our products and services.

The legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests.

Your Rights

Although we rely on legitimate interest to process the personal data you provide to us, you have the right to access, to rectification, to be forgotten or to object to the processing of your personal data for this purpose at any time. If you do that, we’ll update our records immediately to reflect your wishes.

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People Who Contact Us Via Social Media Channels

We use third-party providers, such as Facebook, Twitter, Google and LinkedIn to deliver our social media interactions. If you send us a private or direct message via social media the message will be stored in line with the Social Media platforms own Privacy and Data Retention Policies.it is important to understand that Airangel do not have any control over those policies and you are encouraged to review those independently prior to any communication.

Any private or direct messages will not be shared with any other organisations.

Purpose & Legal Basis

Our purpose for processing the information is so that we can communicate with you and respond to requests for information regarding our products and services or to provide support.

The legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests.

Your Rights

Although we rely on legitimate interest to process the personal data you provide to us, you have the right to access, to rectification, to be forgotten or to object to the processing of your personal data for this purpose at any time. If you do that, we’ll update our records immediately to reflect your wishes.

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People Who Call Our Helplines

When you call Airangel helplines, we collect Calling Line Identification (CLI) information. We use this information to help improve its efficiency and effectiveness. We may also record the call for the purposes of training, quality control or dispute resolution.

We may engage with third-party companies to assist in providing 24×7 and specialist technical support services. The companies that provide this service may also retain call records but we will ensure that they are contractually bound to the same privacy and data protection requirements as our own.

Purpose & Legal Basis

Our purpose for processing the information is so that we can communicate with you and respond to requests for information regarding our products and services or to provide support.

The legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests.

Your Rights

Although we rely on legitimate interest to process the personal data you provide to us, you have the right to access, to rectification, to be forgotten or to object to the processing of your personal data for this purpose at any time. If you do that, we’ll update our records immediately to reflect your wishes.

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People Who Email Us

We use Transport Layer Security (TLS) to encrypt and protect email traffic in line with best-practice recommendations. If your email service does not support TLS, you should be aware that any emails we send or receive may not be protected in transit.

We use DKIM (Domain Keys Identified Mail) signatures as an authentication process that can help protect both senders and recipients from forged and phishing emails.

We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.

Purpose & Legal Basis

Our purpose for processing the information is so that we can communicate with you and respond to requests for information regarding our products and services or to provide support.

The legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests.

Your Rights

Although we rely on legitimate interest to process the personal data you provide to us, you have the right to access, to rectification, to be forgotten or to object to the processing of your personal data for this purpose at any time. If you do that, we’ll update our records immediately to reflect your wishes.

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People Who Make a Complaint to Us

When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.

We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We do compile and publish statistics showing information like the number of complaints we receive, but not in a form which identifies anyone.

We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.

We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.

Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.

When we take enforcement action against someone, we may publish the identity of the defendant in our Annual Report or elsewhere. Usually we do not, identify any complainants unless the details have already been made public.

Purpose & Legal Basis

Our purpose for processing the information is so that we can investigate your complaint and check on our level of service.

The legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests.

Your Rights

We are acting in our official capacity to investigate your complaint, so you have the right to object to our processing of your personal data. There are legitimate reasons why we may refuse your objection, which depend on why we are processing it.

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People who use Airangel Products & Services

Airangel offers a variety of WiFi connectivity services to Our Customers, who then use our platforms to offer their customers and the public guest internet access services. As such, the majority of data we hold on individuals will only be as a requirement to process data on behalf of the Data Controller, which is typically Our Customer, the venue operator.

We hold the names and contact details of individuals acting in their capacity as representatives of their organisations, across the business.

Airangel Customers & Their Representatives

Where technically possible, if you are a representative of Our Customer and/or The Data Controller and accessing the admistrative portal for our product or service, you will be presented with a Platform Specific set of Terms and Conditions of Use and Privacy Notice.

In the event of any conflict or inconsistency between this Notice and the platform-specific Notice, the terms of this Notice  shall prevail.

Our Customers Clients

If you are a member of the public who has accessed a Guest WiFi service operated by one of Our Customers or Partners

 

Purpose & Legal Basis

We have to hold and process the details of the people who have requested the service in order to provide it, and for the purposes of meeting country-specific legislative and regulatory compliance. However, we only use these details to provide the service the person has requested and for other closely related purposes.

Where the data or interactions relate to suppliers, contracts, buildings management, IT services etc., the legal basis is article 6(1)(b) of the GDPR, which allows us to process personal data when its necessary for the performance of a contract, unless there is a country-specific legislative or regulatory compliance requirement, which would take precedence, and as such the legal basis we rely on to process your personal data is article 6(1)(c) of the GDPR.

Where the data does not relate to the above, the legal basis is article 6(1)(f) because the processing is within our legitimate interests as a business.

Your Rights

Where we rely on legitimate interest to process the personal data you provide to us, you have the right to access, to rectification, to be forgotten or to object to the processing of your personal data for this purpose at any time. If you do that, we’ll update our records immediately to reflect your wishes, or we will provide contact details for the relevant Data Controller, where we are the Data Processor.

If the processing is carried out to comply with legislative or regulatory compliance requirements, or where processing is neccessary for the performance of a contract, then your rights may vary from the above. Please contact us, if you have any query and we will povide clarification on a case by case basis, where neccessary.

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People who visit Our Offices

We meet people at our offices for a variety of purposes, including but not limited to:

  • hosting meetings with existing or prospective customers and suppliers;
  • to either receive or deliver training;
  • to interview job applicants;
  • for suppliers and tradespeople to carry out work; and
  • to hold company meetings with stakeholders.

We may require you to complete a visitor book or sign in, for fire and safety records. These records will be securely destroyed at the end of the day of each visit period.

Closed-circuit television (CCTV) operates within the building for security purposes. The information is recorded and stored for 30 days, before being overwritten. Theere is a specific and separate policy that covers our use of, and access to the CCTV recordings and management interface.

We offer guest internet access within our offices. A separate Terms and Conditions of Use and Privacy Notice will be presented to the Guest at the time of sign-up.

Purpose & Legal Basis

The purpose for processing this information is for security and safety reasons.

The legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests.

Your Rights

Although we rely on legitimate interest to process the personal data you provide to us, you have the right to access, to rectification, to be forgotten or to object to the processing of your personal data for this purpose at any time. If you do that, we’ll update our records immediately to reflect your wishes, with the exception of CCTV recordings, where some rights may be restricted.

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Job Applicants, Current and Former Airangel Employees

Airangel is the data controller for the information you provide during the process unless otherwise stated. If you have any queries about the process or how we handle your information please contact us at Careers@airangel.com.

What will we do with the information you provide to us?

All of the information you provide during the process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary.

We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.

We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for.

What information do we ask for, and why?

We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary.

The information we ask for is used to assess your suitability for employment. You don’t have to provide what we ask for but it might affect your application if you don’t.

Application stage

If you use our online application system, this will be collected by a data processor on our behalf (please see below).

We ask you for your personal details including name and contact details. We will also ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for. Our recruitment team will have access to all of this information.

You may also be asked to provide equal opportunities information. This is not mandatory information – if you don’t provide it, it will not affect your application. This information will not be made available to any staff outside of our recruitment team, including hiring managers, in a way which can identify you. Any information you do provide, will be used only to produce and monitor equal opportunities statistics.

Shortlisting & Assessments

Our hiring managers shortlist applications for interview. They will be provided with your name, contact details, your previous experience, education, referees and for answers to questions relevant to the role you have applied for, and with your equal opportunities information if you have provided it.

We might ask you to participate in assessment days; complete tests or occupational personality profile questionnaires; and/or to attend an interview – or a combination of these. Information will be generated by you and by us. For example, you might complete a written test or we might take interview notes. This information is held by Airangel.

If you are unsuccessful following assessment for the position you have applied for, we will ask if you would like your details to be retained in our talent pool for a period of six months. If you say yes, we would proactively contact you should any further suitable vacancies arise.

Conditional offer

If we make a conditional offer of employment we will ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer. We are required to confirm the identity of our staff, their right to work in the United Kingdom and seek assurance as to their trustworthiness, integrity and reliability.

You will therefore be required to provide:

  • Proof of your identity – you will be asked to attend our office with original documents, we will take copies.
  • Proof of your qualifications – you will be asked to attend our office with original documents, we will take copies.
  • Dependent upon the role, you may be asked to complete a criminal records declaration to declare any unspent convictions.
  • We will contact your referees, using the details you provide in your application, directly to obtain references
  • We will also ask you to complete a questionnaire about your health. This is to establish your fitness to work and make provisions, should there be any pre-existing conditions that may affect you or your colleagues safety whilst at work.

If we make a final offer, we will also ask you for the following:

  • Bank details – to process salary payments
  • Emergency contact details – so we know who to contact in case you have an emergency at work

Post start date

Airangel have a separate Employee Privacy Policy that covers the storage, processing and protection of your personal data within your employment period and the period after employment terminates. This will be provided through the onboarding process and is available within the Quality & Security Management System.

Use of data processors

Data processors are third parties who provide elements of our recruitment and employment service for us. We have contracts in place with our Data Processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.

  • CascadeGo HR

If you use our online application system, you will provide the requested information via a web-based application, operated by who provide this online service for us. Once you click ‘apply now’ you will be taken to Vacancy Filler’s website and they will hold the information you submit but Airangel will have access to it.

If you accept a final offer from us, some of your personnel records will be held on Cascade Go which is an internally used HR records system.

How long is the information retained for?

If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus 7 years following the end of your employment. This includes your criminal records declaration, fitness to work, records of any security checks and references.

If you are unsuccessful at any stage of the process, the information you have provided until that point will be retained for 6 months from the closure of the campaign.

Information generated throughout the assessment process, for example interview notes, is retained by us for 6 months following the closure of the campaign.

Equal opportunities information is retained for 6 months following the closure of the campaign whether you are successful or not.

Cascade Go will provide us with management information about our recruitment campaigns. This is anonymised information which tells us about the effectiveness of campaigns, for example, from which source did we get the most candidates, equal opportunities information for monitoring purposes. This anonymised information will be retained for 6 years from the end of the campaign.

How we make decisions about recruitment?

Final recruitment decisions are made by hiring managers and members of our recruitment team. All of the information gathered during the application process is taken into account.

You are able to ask about decisions made about your application by speaking to your contact within our recruitment team or by emailing Careers@airangel.com.

Purpose & Legal Basis

Our purpose for processing this information is to assess your suitability for a role you have applied for.

The legal basis we rely on for processing your personal data is article 6(1)(b) of the GDPR, which relates to processing necessary to perform a contract or to take steps at your request, before entering a contract. The legal basis we rely on to process any information you provide as part of your application which is special category data, such as health, religious or ethnic information is article 9(2)(b) of the GDPR, which also relates to our obligations in employment and the safeguarding of your fundamental rights and article 9(2)(h) for assessing your work capacity as an employee. And Schedule 1 part 1(1) and (2)(a) and (b) of the DPA2018 which relates to processing for employment, the assessment of your working capacity and preventative or occupational medicine.

Your Rights

As an individual, you have certain rights regarding your own personal data. For more information on your rights, please see Your Data Protection Rights.

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Complaints or Queries

Airangel tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of Airangels collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.

If you want to make a complaint about the way we have processed your personal information, you can contact us using the contact details below.

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Access to Personal Information

Airangel tries to be as open as it can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by making a ‘subject access request’. If we do hold information about you we will:

  • give you a description of it;
  • tell you why we are holding it;
  • tell you who it could be disclosed to; and
  • let you have a copy of the information in an intelligible form.

To make a request to Airangel for any personal information we may hold you need to put the request in writing addressing it to support@airangel.com, or writing to the address provided below.

Airangel have a seprate and specific policy for the handling of Subject Access Requests, which provides for differing processes based on wether we are the Data Controller or the Data Processor.

If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.

If we do hold information about you, you can ask us to correct any mistakes by, once again, contacting us using the details provided below.

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Disclosure of Personal Information to Law Enforcement Agencies

In many circumstances we will not disclose personal data without consent. However when we investigate a complaint or respond to a law enforcement agency, for example, we will need to share personal information with the organisation concerned and with other relevant bodies. Where allowed, we will inform you of the factors we shall consider when deciding whether information should be disclosed.

We may disclose your personal information when we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be violating our T&Cs or to protect the safety, property or other rights of our users or the public.

We also may disclose your personal information if we believe in good faith that we are required to do so in order to comply with applicable law or other legal process. We will only disclose this data when requested from a Law Enforcement Agency, and will do so responsibly, protecting the confidentiality, integrity and availability of that data during this process.

Purpose & Legal Basis

Our purpose is to investigate alleged criminal offences, and to bring legal action against the individual where required, to protect the dafety and rights of other users or the public, and to comply with relevant laws such as but not limited to the Regulation of Investigatory Powers Act 2000 (RIPA).

We rely on Schedule 8 1(a)and (b) of the Data Protection Act 2018 to process your personal data. This relates to processing ‘necessary for the exercise of a function conferred on a person by an enactment or rule of law, and is necessary for reasons of substantial public interest’.

Your Rights

Disclosure in this instance does not require your consent.

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Data Transfer

As part of operating the website and providing the Services, we may transfer personal data to a third country where this is legally permissible, and we have appropriate adequacy conditions in place, such the EU-US Privacy Shield (or equivalent), approved ‘Model Contract’ clauses, Binding Corporate Rules and contractual confidentiality agreements.

If your personal information is transferred to a server located outside of the country in which you access the website or use Our Services, we operate technical and organisational controls to ensure that you’re the confidentiality, integrity and availability of your data is maintained, through an internationally recognised certification mechanism (ISO/ICE 27001).

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Data Retention

As part of operating the website and providing the Services, we may transfer personal data to a third country where this is legally permissible, and we have appropriate adequacy conditions in place, such the EU-US Privacy Shield (or equivalent), approved ‘Model Contract’ clauses, Binding Corporate Rules and contractual confidentiality agreements.

If your personal information is transferred to a server located outside of the country in which you access the website or use Our Services, we operate technical and organisational controls to ensure that you’re the confidentiality, integrity and availability of your data is maintained, through an internationally recognised certification mechanism (ISO/ICE 27001).

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Changes to this Privacy Notice

We keep our privacy notice under regular review. This privacy notice was last updated on 25 May 2018. Earlier versions can be found by following this link.

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How to Contact Us

If you want to request information about our privacy notice, you can email us at support@airangel.com or write to:

The Data Protection Officer
Airangel Limited
Unit A, The Beacons,
Birchwood Park
Warrington
Cheshire
WA3 6GP

Our Telephone Number for the UK Office is: +44 (0) 1925 611061

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Definitions and Interpretation

In these Terms and Conditions, unless the context otherwise requires, the following expressions have the following meanings:

  • Account” means an account required to access and/or use certain areas and features of Our Site or Services;
  • Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;
  • Our Site” means this website, www.airangel.com and any other website or web-based service operated by Airangel;
  • "Our Products and Services" means and product or service provided by Airangel either directly, or via an approved Airangel Partner or contracted Customer of Airangel
  • UK and EU Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and
  • We/Us/Our” means Airangel Limited, a company registered in England and Wales under Company No: 494 8173, whose registered address is Unit A, The Beacons, Birchwood Park, Warrington, Cheshire, WA3 6GP, United Kingdom and whose main trading address is Unit A, The Beacons, Birchwood Park, Warrington, Cheshire, WA3 6GP, United Kingdom.

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Attributions

Contains public sector information licensed under the Open Government Licence v3.0

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