Privacy Policy
Dear Clients, Ladies and Gentlemen,
Let me inform you in the name of Menzies Aviation (Czech), s.r.o. (hereinafter “we“ or “our company“) about how we process and protect your personal data in connection with our business activity performance.
The purpose of this communication is to provide you information, especially about what personal data we collect, what we do with it, what sources we obtain it from, for what purpose we use it, whom we can provide it to, where you can obtain information about your personal data processed by us and what your individual rights are in the field of personal data protection. We process personal data in compliance with the applicable generally binding legislation and our internal Rules of Personal Data Use. We only process personal data in the minimum scope required for the particular service being provided or by the particular purpose of processing.
Please kindly familiarize yourselves with the content of this communication; should you have any questions we will be happy to answer them in our registered offices at K Letišti 1049/57, 161 00 Prague 6, or on our company e-mail address prg.dpo@menziesaviation.com.
I. General Information
I.1. Personal Data Processing Policy
When processing your personal data, we respect and observe the highest possible data protection standards, including but not limited to the following principles:
- We always process your personal data for a clearly and comprehensibly defined purpose, by specified means, in the designated manner and for the minimum time necessary for the given processing purpose; We only process accurate client data with assured compliance of the processing with the defined purposes and strict necessity for the purpose fulfillment;
- We process your personal data in a way assuring the highest possible security of the data and preventing any unauthorized or random access to the personal data, its alteration, destruction or loss, unauthorized transmissions, other unauthorized processing or misuse;
- We always clearly inform you about your personal data processing, about your right to accurate and complete information about the circumstances of processing, as well as about your other related rights, all through our web site;
- Our company has set and observes adequate technical and organizational measures assuring the level of security addressing all predictable risks; all persons that come in contact with personal data are bound by non-disclosure agreements relating to information obtained in connection with personal data processing.
II. Information about Personal Data Processing
II.1. Information about Data Controller
The controller of your personal data is our company, Menzies Aviation (Czech), s.r.o., with registered offices at K Letišti 1049/57, 161 00 Prague 6, company ID 169 48 904, with entry in the Commercial Register maintained by the City Court in Prague, in Section C, under File number 2195.
Our company has appointed a personal data protection officer, who is Mr. Michal Miškovský. You can contact him on the following e-mail address: prg.dpo@menziesaviation.com.
II.2. Purposes and Legal Basis of Processing
II.2.1. Your Personal Data Processing Without Your Consent
Personal data of natural persons is processed by our company for the following reasons:
- Contractual obligation fulfillment – in the context of our business activity, our company is liable to process certain personal data, especially for the purpose of compliance with its legal ad contractual liabilities and because We could not provide our products/services to you without your providing us with certain personal data
- Legal duty (for example under the Accounting Act, the Value Added Tax Act, the Archiving and Filing Service Act, Regulation of the European Parliament and of the Council on common rules in the field of civil aviation security (no 300/2008, as amended by Commission Regulation no 18/2010), Act no 49/1997 Coll., on Civil Aviation, as amended)
- Direct marketing (service information distribution) towards customers and other interested parties
- Legitimate interest of the Controller (collection of evidence in case of the necessity to defend the rights of our company, camera system records for the purpose of asset protection, personal health protection and securing civil aviation against illegal acts)
With regard to these purposes, our company only processes personal data provided in the contract or obtained from the client – natural person – in the course of the contract implementation. Natural person´s data processing for the purpose of contract implementation is a necessary prerequisite for the contract execution itself and for the contractual supply provision from our side.
Our company processes personal data pursuant to this article exclusively in the modes in which the natural person´s – data subject´s – consent is not required.
II.2.2. Your Personal Data Processing With Your Consent
This mainly concerns situations when you voluntarily agree with your personal data processing by us. On the basis of your consent, our company processes your personal data to offer you a job or to contact you for this purpose. Your consent is valid for 2 years.
II.3. Personal Data Processing Scope
Personal data is processed in the scope in which it is provided by the data subjects (clients, in-house employees, job seekers, parties interested in service offer, natural persons – suppliers – self employed, legal entity suppliers´ representatives) to our company in connection with contract execution or another legal relationship establishment with our company or otherwise collected and processed by us in compliance with the law or to fulfill our legal obligations.
II.4. Personal data sources:
- The data subject – natural person – directly in the context of contract execution, order placement and demand for service, negotiation etc.
- The legal entity data subject or its representative in the context of contractual relationship establishment
- Company web
- Legal duty
- Camera recording
II.5. Processed personal data categories:
- Address and identification data used for unique and unmistakable identification of a natural person (such as the first name, surname, date of birth, address of permanent residence etc.)
- Data enabling contact with a natural person (contact data – such as a contact street address, phone number, e-mail address and similar information)
- Economic data (such as bankers – account number)
- Other data necessary for contract implementation
- Personal data required by law
- Camera recordings used for the purpose of in-house property, customers´ property/goods, personal health and civil aviation securing against illegal acts
II.6. Personal Data Processing Method
The method used by our company to process your personal data includes manual and automated processing in our company´s information systems and in the physical form.
Your personal data is primarily processed by our employees and also by third parties in the needed scope. Before forwarding your personal data to any third person we always execute a written contract with that person containing the same guarantees for personal data processing as our company itself observes in compliance with its legal obligations.
II.7. Personal Data Recipients
Our clients´ personal data, that is your personal data, is primarily made accessible to employees of our company in connection with fulfillment of their work duties where they need to deal with clients´ personal data, but only on the need-to-know basis and with observance of all available security measures.
In addition, your personal data is forwarded to third parties who work for us on the processing of personal data of our clients, or this personal data may be made accessible to them for other reasons in compliance with the law.
Personal data is provided in the first place to:
- Our attorney office;
- Our accounting service providers;
- Our providers of consultancy, training and advisory service; and
- Processors who provide server, web, cloud and IT services to us.
Before forwarding your personal data to any third person we always execute a written contract with that person where personal data processing and protection are defined in a way containing the same guarantees for personal data processing as our company itself observes in compliance with its legal obligations.
II.8. Personal Data Forwarding Abroad
If your personal data cross the frontier when forwarded to third parties by us or on our behalf, we apply appropriate security measures to protect your personal data in compliance with this data protection policy and the applicable legislation. These security measures include consent with the standard contractual clauses or contract templates dealing with personal data sharing among associated entities of Menzies Aviation and between us and our suppliers and business partners. These clauses or contracts require from our associated entities, suppliers and partners to protect personal data in compliance with the applicable data protection legislation.
II.9. Personal Data Processing Period
Clients´ personal data is processed by our company for the minimum period necessary for the purpose of its processing. We keep assessing whether the need to process certain personal data for a particular purpose still exists. If we find out that some data is no longer necessary for the purpose for which it was processed we delete it. However, we have internally assessed a usual usability period of personal data in relation to certain processing purposes, after elapse of which we assess further need to process the data for the given purpose especially carefully. In this connection there is the rule concerning the length of personal data processing depending on the purpose for which the data is processed:
- Data processed for the purpose of a contract fulfillment is processed throughout the period for which the contractual relationship with the respective client lasts; this personal data is usually usable for the period of ten years except for cases of longer processing periods required by generally binding legislation;
- Data processed for the purpose of providing a job offer is processed for the period of maximum 2 years from the new employee recruitment process completion, i.e. throughout the period of validity of the job seeker´s consent with his/her data processing;
- In the case of protection of rights and legitimate interests concerning data taken as camera recordings the data is usually usable for a period of maximum thirty days;
- In the case of record keeping in connection with employment on the basis of consent with personal data processing the processing period equals the period of the respective employment.
II.10. Right to Withdraw Consent
This communication clarifies the reasons why we need your personal data and that for certain purposes we are only allowed to process your personal data with your consent. You are not obliged to grant our company your consent with your personal data processing and you can always withdraw your consent granted at any time. We remind here that most of the personal data we process can be processed for certain purposes without your consent. If in such case you withdraw your consent we will terminate your data processing for the purposes requiring your consent but we may be allowed or even obliged to continue processing this data for other purposes.
If you wish to withdraw your consent with your data processing please address us in our registered offices on our street address K Letišti 1049/57, 161 00 Prague 6, or via our e‑mail prg.osobniudaje@menziesaviation.com.
II.11. Your Rights in Connection with Your Personal Data Processing
All your rights as data subject can be applied in our registered offices on K Letišti 1049/57, 161 00 Prague 6, or by e‑mail prg.osobniudaje@menziesaviation.com; at the same time, you may file a complaint with the respective supervisory office, which is the Personal Data Protection Office (www.uoou.cz).
II.11.1. Right to access means that any time you can ask for our confirmation whether personal data concerning you is or is not processed, and if yes then for what purposes, in what scope, who your data is made accessible to, for how long your data will be processed, whether you are entitled to ask its correction, erasure, or processing restriction or raise a complaint, where we obtained your personal data from and whether your processed personal data is used for automated decision-making, including potential profiling. You also have the right to obtain a copy of your personal data; while the first copy is free, in the case of further copies we may charge the related administrative expenses.
II.11.2. Right to correction means that you can ask us any time to correct or add your personal data if it is inaccurate or incomplete.
II.11.3. Right to erasure means that we have to erase your personal data if (i) it is no longer needed for the purpose for which it was collected or otherwise processed, (ii) its processing is illegal, (iii) you raise an objection against the processing and there are no prevailing legitimate purposes for the processing, or (iv) it is our legal responsibility.
II.11.4. Right to restriction of processing means that before any disputes concerning your personal data processing are successfully resolved we have to restrict your personal data processing to their storage and exclusive use for specification, execution or defense of our legal claims.
II.11.5. Right to raise an objection means that you can raise an objection against our processing of your personal data which we process for the purpose of direct marketing or for the reason of a legitimate interest. If you raise an objection against your personal data processing for the purpose of direct marketing your personal data will no longer be processed for that purpose.
III. Final Provisions
III.1. This communication is issued for an unlimited period of time with effect as of 1 June 2018. This communication was updated in January 2024.
III.2. This communication may be amended by issue of its complete new wording; the valid version is available on our company web site and in the paper format in our registered offices.
III.3. Unless explicitly specified otherwise, all information provided herein also applies to processing of personal data of our potential clients, i.e.persons with whom we have not yet established a contractual relationship but with whom we are already in contact. Information provided herein is also reasonably applicable to the processing of personal data of other persons our company is in direct contact with outside any contractual relationship (for example representatives of legal entities).