Principles
How we collect your Information
To the extent permissible under applicable law, we collect information (including, without limitation, your name, organisation, email address and telephone number) about you and any other party whose details you provide to us when you:
- register to use our websites, applications or services
- update your contact details on our websites, applications or services
- place an order using our websites, applications or services
- complete online forms, sign up for our newsletter, take part in surveys, post in our community forums, comment on our blog posts, post any blogs, enter any competitions or prize draws, download information, or otherwise interact with our websites, applications or services
- interact with us using social media
- contact us offline, for example, by telephone, SMS, email or post
We will also collect your information when you only partially complete and/or abandon any information you have input into our website and/or other online forms. We may use this information to contact you to remind you to complete any outstanding information and/or for marketing purposes.
We also collect information from your devices (including mobile devices) and applications you or your users use to access and use any of our websites, applications and services (for example, the referral URL and your IP address). We may do this using cookies or similar technologies (as described in our Cookie Usage Policy below).
We may enhance personal information we collect from you with information we obtain from third parties that are entitled to share that information (for example, information from credit agencies, search information providers or public sources), but in each case only as permitted by applicable laws.
Providing us with information about others
If you provide us with personal information about someone else, you are responsible for ensuring that you comply with any obligations under applicable data protection laws, for example, by providing them with the required notices and obtaining their explicit consent. You must explain to them how we collect, use, disclose and retain their personal information, or direct them to read this Privacy Policy.
How we use your information
To the extent permissible under applicable law, we use your information to:
- provide any information and services that you have requested
- provide any applications and services that you have ordered
- check information for accuracy, including verifying it with third parties
- provide, maintain, protect and improve any applications, services and information that you have requested from us
- manage and administer your use of the applications and services you have asked us to provide
- manage our relationship with you (for example, customer services and support activities)
- monitor, measure, improve and protect our content, website, applications and services
- undertake internal testing of our websites, applications, systems and services to improve their security, provision and performance, in which case, we would pseudonymise your personal data
- provide you with any information that we are required to send you to comply with our regulatory or legal obligations
- detect, prevent, investigate or remediate crime, illegal or prohibited activities, or to otherwise protect our legal rights (including liaising with regulators and law enforcement agencies)
- contact you to see if you would like to take part in customer research
- to monitor and to carry out statistical analysis and benchmarking on an aggregated basis, which will not be linked back to you
- deliver targeted advertising, marketing (including in-product messaging) or information to you which may be useful to you, based on your use of our applications and services
- deliver joint content and services with third parties with whom you have a separate relationship
- provide you with location-based services, where we collect geo-location data
To the extent permitted by applicable law, we retain information about you after the termination of your Artifax agreement or if you decide not to proceed with our applications or services. This information will be held and used for as long as permitted for legal, regulatory, fraud prevention and legitimate business purposes.
Our websites, applications (including mobile applications) and services may use technology that enables us to:
- check specific information from your device or systems directly relevant to your use of our websites, applications and services against our records to make sure that our websites, applications and services are being used in accordance with our terms and conditions
- obtain information relating to any technical errors or other issues with our websites, applications and services for troubleshooting purposes
- collect information about how you and other users use the functions of the features of our websites, applications and services
- gather statistical information about the operating system and environment from which you access our applications and services
You can manage your privacy settings within your browser or our applications and services, where applicable.
We may monitor and record our communications with you, including support tickets, emails and telephone conversations. Information we collect may be used for training purposes, quality assurance, to record details about our websites, applications and services you order from us or ask us about. This information is also used in order to enable us to meet our legal and regulatory obligations generally.
Mobile data
We may obtain information through mobile applications that you install on your mobile devices to access and use our websites, applications and services, or which you use to provide other services related to that mobile application. These mobile applications may be our own mobile applications or those belonging to third parties. Where the mobile application belongs to a third party, you must read that third party’s own privacy policy as it will apply to your use of that third party mobile application. We are not responsible for such third party mobile applications and their use of your personal information.
Mobile applications may provide us with information related to your use of that mobile application and the use of our applications and services accessed using that mobile application. We may use such information to provide and improve the mobile application or our own applications and services.
Data analytics and benchmarking
We may use information generated and stored during your use of our services for our legitimate business interests to give you the best applications and services.
This enables us to:
- deliver advertising, marketing (including in-product messaging) or information to you which may be useful to you, based on your use of our applications and services
- carry out research and development to improve our applications and services
- develop new and existing applications and services (including statistical analysis, benchmarking and forecasting services)
- provide you with location-based services where we collect geo-location data to provide a relevant experience
Whenever we use your information for our legitimate interests, we will ensure that your information is processed on a pseudonymised basis and displayed at aggregated levels, which will not be linked back to you.
You have the right to object to processing based on our legitimate interests, and if you wish to do so, please contact us at
[email protected] to discuss this further. If you object, this may affect our ability to provide certain applications and services for your benefit.
Sharing your information
We may share your information with:
- any company within the Volaris Group, for the purposes set out in this Privacy Policy
- our service providers, distributors and agents (including their sub-contractors) or third parties who process information on our behalf (for example, internet service and hosting providers, payment processing providers and those organisations we engage to help us send communications to you)
- partners, distributors, agents, independent software vendors and developers that may help us to provide you with the applications, services and information you have requested or which we believe is of interest to you
- third parties used to facilitate payment transactions, for example clearing houses, clearing systems, financial institutions and transaction beneficiaries
- third parties where you have a relationship with that third party and you have consented to us sending information
- third parties for marketing purposes (for example, our partners, distributors, agents and other third parties with whom we work and whose products or services we think will interest you in the operation of your business activities
- credit reference and fraud prevention agencies
- regulators to meet Artifax’s legal and regulatory obligations
- law enforcement agencies so that they may detect or prevent crime or prosecute offenders
- any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully
- any third party in order to meet our legal and regulatory obligations, including statutory or regulatory reporting or the detection or prevention of unlawful acts
- Artifax’s professional advisors and auditors
- another organisation if we sell or buy (or negotiate to sell or buy) any business or assets
- another organisation to whom we may transfer our agreement with you
- Government departments where reporting is mandatory
We may share non-personally identifiable information about the use of our websites, applications and services publicly or with third parties, but this will not include information that can be used to identify you.
Marketing
We may use your information to contact you with details about our applications and services, which we feel may be of interest to you. We will not share your information with third parties. You have the right at any time to stop us from contacting you for marketing purposes. If you wish to exercise these rights, you can do so by sending us an email to
[email protected]. You can also unsubscribe from any email marketing using the links provided in the emails we send to you.
Third party platform advertising
When you respond to communications we post on third-party platforms (such as Facebook, Google and Twitter), we may also share your information with those third parties to serve targeted advertising/content to you via the relevant third-party platform based on your profile/interests. Your information is used by the third-party platform provider to identify your account and serve advertisements to you. You can control what advertisements you receive via the privacy settings on the relevant provider’s platform and you should consult the third party’s help/support centre for more information.
Your rights
We are required to provide you with the following information:
- the purposes of the processing for which the personal data is intended as well as the legal basis for the processing
- where the processing is necessary for the legitimate interests pursued by Artifax or a third party, what those legitimate interests are
- if applicable, the fact that Artifax intends to transfer personal data to a third country or international organisation and of any safeguards in place (Excluding the UK as this is where Artifax’s headquarters are based)
- the period for which the personal data will be stored or, if that is not possible, the criteria used to determine the period
- you have the right to request access to and rectification of personal data or restriction of processing or to object to processing as well as the right to data portability
- where the processing is based on consent, the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal
- you have the right to lodge a complaint with our supervisory authority, the Information Commissioner’s Office (ICO)
- from 1 Jauary 2021 customers within the European Union may address privacy-related inquiries to our EU data representative pursuant to Article 27 EU GDPR:
EU-REP.Global GmbH
Hopfenstr. 1d, 24114 Kiel,
Germany
[email protected]Responsibilities
All members of Artifax’s staff (including permanent, temporary, casual, agency and apprentices) and sub-contractors, consultants, processors, sub-processors, distributors, agents, suppliers and other third parties working for, or on behalf of, or with Artifax are responsible for actions to meet the requirements of this policy.
Key Outcomes
If the objectives of this policy are met, Artifax will have ensured that your personal data will be:
- processed lawfully, fairly and in a transparent manner
- collected for specified, explicit and legitimate purposes
- adequate, relevant and limited to what is necessary
- accurate and, where necessary, kept up to date
- kept in a form which permits your identification for no longer than is necessary
- processed in a manner that ensures appropriate security
