In this privacy policy, the following terms used with an initial capital letter have the following meaning, unless expressly stated otherwise or unless the context indicates otherwise:
Account: The account of the Quotation Requester on the Website;
GDPR: General Data Protection Regulation;
Data subject: The natural person whose Personal Data is processed;
Booking: The agreement between the Aircraft Operator and the Quotation Requester whereby the Quotation Requester books one or more Flights for one or more persons with the Aircraft Operator;
Flowings: The user of this privacy policy: Flowings B.V. established at Meent 106 in (3011 JR) Rotterdam, the Netherlands, registered with the Chamber of Commerce under KvK number 87054892;
Request for Quotation: The request for quotation submitted by the Quotation Requester via the Website or received by Flowings or any other means from the Quotation Requester for one or more Flights;
Quotation Requester: The legal person, organisation or natural person who has submitted or wishes to submit a Request for Quotation;
Passenger: The natural person for whom the Quotation Requester wishes to book a Flight or for whom the Flight has been booked. If the Quotation Requester has submitted a Request for Quotation or has booked a Flight for his own benefit, the Quotation Requester is then also the Passenger;
Personal data: Data relating to an identified or identifiable natural person;
Service: The service that Flowings provides, including the provision of the Website on which Flights can be viewed and where the Quotation Requester can submit a Request for Quotation and process it on behalf of an Aircraft Operator;
Aircraft Operator: The aircraft operator that offers flights with a private aircraft and with which Flowings cooperates;
Flight: The flight with a private aircraft that the Aircraft Operator offers or performs or is required to perform under the Booking;
Website: The website www.flowings.com and the associated application of Flowings.
Unless the context indicates otherwise, terms defined in the singular also refer to the plural and vice versa.
Where in this privacy policy “he” or “his” is mentioned, of course “she” or “her” can also be read.
General, controller and contact details
This privacy policy describes how Flowings processes Personal Data in connection with the Service and the Bookings.
The controller is:
Flowings B.V.
Meent 106
3011 JR Rotterdam
The Netherlands
KvK number: 87054892
email address: info@flowings.com
Telephone number: +31850805925
Careful handling of Personal Data is of great importance to Flowings. With regard to the processing of Personal Data, Flowings acts in accordance with the GDPR.
Collecting Personal Data
Flowings processes Personal Data from Quotation Requesters and Passengers.
Flowings collects Personal Data at the time that the Quotation Requester has provided the Personal Data to Flowings, for example when creating an Account, completing a contact form on the Website, sending a Request for Quotation or sending information to Flowings for the purpose of a Booking.
Flowings receives Passenger Personal Data from the Quotation Requester in connection with the Request for Quotation or the Booking.
Personal Data
Flowings processes the following Personal Data:
First name;
Surname;
Number and street name;
Postcode;
City;
Telephone number;
Email address;
Gender;
Travel documents, such as passport or identity card;
Date of birth;
Payment details;
Login details of the Account;
Medical information.
An Account must be created to submit a Request for Quotation. For the creation of an Account, the provision of the Personal Data of the Quotation Requester referred to in Article 4.1 sub. a. through g. is mandatory. Without these Personal Data, no Account can be created.
In order to make a Booking, it is necessary that:
The Personal Data of the Passengers referred to in Article 4.1 sub a. through j. are processed;
The payment details of the Quotation Requester will be processed.
Special Personal Data, such as medical data, of Passengers will only be processed if permission has been granted for this processing for one or more specific purposes. Special Personal Data of Passengers are processed, for example, because the Passenger has special wishes regarding the Flight due to his physical condition. By submitting a special request regarding the physical condition of a Passenger, the Quotation Requester grants permission for the processing of this special Personal Data for the processing of the request and the Quotation Requester guarantees that the Passenger has also granted his consent for this. Special Personal Data of Passengers will only be processed for the purpose of processing a special request and so that the Aircraft Operator can provide the necessary facilities and/or care.
Data Retention
Flowings will not retain the Personal Data for longer than is strictly necessary to achieve the purposes, described in Article 6.1, for which the Personal Data is processed, unless there is a legal obligation that requires longer retention.
Purposes and bases of the processing of the Personal Data
Flowings processes the Personal Data for the following purposes:
Providing the Service, such as:
Creating the Account;
Sending a confirmation that the Account has been created;
Handling the Request for Quotation;
Sending a quotation to the Quotation Requester on behalf of the Aircraft Operator;
Creating the Booking;
Forwarding the booking confirmation from the Aircraft Operator to the Quotation Requester.
Communication purposes, such as:
Corresponding with the Quotation Requester about the Request for Quotation and the Booking;
Handling a question, comment, request or complaint;
Informing about the progress of the handling of a question, comment, request or complaint;
Sending notification messages, for example if a Flight is available that falls within the preferences of the Quotation Requester;
Administrative purposes, such as:
Preparing the invoice;
Maintaining a customer file.
Sending newsletters.
The bases for the processing are:
Performance of the Service;
The processing is necessary for compliance with our legal obligations;
Consent.
Flowings only processes the Personal Data that are minimally necessary for the existing purposes. Flowings strives for minimal data processing.
Flowings will not process the Personal Data for purposes other than those described in this privacy policy.
When providing the Service, Flowings does not use automatic decision-making.
Notification messages and newsletters
The Quotation Requester will only receive notification messages via email if the Quotation Requester has enabled it through their Account. Receiving notification messages can be turned off at any time by the Quotation Requester through his Account.
Newsletters will only be sent to the Quotation Requester if the Quotation Requester has subscribed to a newsletter and the Quotation Requester has thus granted permission to send newsletters to the email address provided by the Quotation Requester. The Requester may unsubscribe from newsletters at any time.
The Requester may unsubscribe from newsletters in the following ways:
By clicking on the link in the e-mail in which the newsletter is included, the Quotation Requester can unsubscribe from such newsletters; An unsubscribe link is included in each newsletter;
By contacting Flowings, see Article 2.2 for contact details.
Security measures
In order to prevent access to Personal Data by unauthorised persons, loss, theft and unlawful use of Personal Data, Flowings has taken various security measures, including measures against unauthorised access, use, modification, unlawful and unintentional destruction and unintentional loss of the Personal Data.
Providing Personal Data to third parties
Flowings will provide the Personal Data to third parties if:
This is necessary for the provision of the Service. These are ICT service providers or payment providers who Flowings engages. The agreements with processors are laid down in a processor agreement or are agreed by means of another legal act, for example in the general terms and conditions of the processor;
The Data Subject has given permission for the provision;
This is necessary for the processing of the Request for Quotation and the establishment of the Booking, such as the provision of Passenger Personal Data to Aircraft Operators;
Flowings is obliged to provide the Personal Data on the basis of:
Laws and regulations;
A court order or verdict.
Deletion of Personal Data
Flowings will remove Personal Data from its systems without unreasonable delay if:
The Personal Data are no longer necessary for the purposes for which they were collected or otherwise processed;
The Data Subject objects to the processing of his Personal Data and this objection is justified.
Flowings is not obliged to delete Personal Data if one of the situations described in the law exists in which the “right to be forgotten” does not apply.
Right of inspection, right to portability, rectification and deletion
Upon request, Flowings grants the Data Subject free access to all Personal Data that Flowings maintains of the Data Subject, and Flowings provides the Data Subject with an electronic copy of these Personal Data free of charge.
Flowings offers the Data Subject the opportunity to have any incorrect Personal Data that Flowings keeps of the Data Subject corrected or deleted free of charge.
Objections
The Data Subject may object to the processing of his Personal Data by Flowings if the Data Subject has good reason to do so in view of his specific situation. After Flowings has received the objection from the Data Subject, Flowings will stop processing the Personal Data of the Data Subject, unless Flowings has legitimate interests in the processing of Personal Data that outweigh the interest of the Data Subject.
Right of limitation
If the Data Subject has submitted a request to amend, supplement or delete his Personal Data or an objection has been submitted to the processing of his Personal Data and the processing, processing and execution of this request or that objection takes some time, the Data Subject may request Flowings to restrict the processing of his Personal Data.
Consent
The Data Subject may revoke his consent to the processing of his Personal Data at any time. Withdrawal of consent shall not have retroactive effect.
Questions, requests and complaints
For:
Questions about how Flowings processes Personal Data; or
Withdrawing consent; or
Exercising any of the rights set out in Article 11, 12 or 13; or
Reporting (suspected) abuse of the Personal Data that Flowings processes of the Data Subject,
the Data Subject can contact Flowings: see Article 2.2 for the contact details.
If the Data Subject invokes one of the rights set out in Articles 11, 12 or 13:
Flowings may, if Flowings is unsure of whether it is dealing with the right person, ask for additional information;
Flowings shall inform the Data Subject within 1 month of receipt of the request of the response given to the request.
If Flowings corrects, supplements or deletes Personal Data of the Data Subject at the request of the Data Subject or terminates or restricts the processing of the Personal Data or has processed a revoked consent, Flowings shall inform the Data Subject accordingly.
If the Data Subject considers that the processing of Personal Data by Flowings is not in accordance with this privacy policy and/or with the applicable laws and regulations, the Data Subject may lodge a complaint with the Dutch Data Protection Authority.
Cookies
This website uses cookies. For more information about the use of cookies, please refer to the Flowings cookie policy, see [link to cookie policy].
Changes
Flowings reserves the right to make unilateral changes to this privacy policy, for example due to a change in the law.
Third-party privacy policy
This privacy policy does not apply to the processing of Personal Data by Aircraft Operators or by third-party websites that are linked to the Website. Flowings accepts no responsibility or liability whatsoever with regard to the way in which Aircraft Operators or third-party websites handle Personal Data. For more information about how Aircraft Operators and third-party websites handle Personal Data etc., please consult the privacy policy of the relevant Aircraft Operator or third-party website.
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