Last updated on 16-Feb-2017

Teorema Épico Privacy Policy

Introduction

The purpose of this document is to provide a concise policy statement regarding the Data Protection obligations of Teorema Épico. This includes obligations in dealing with personal data, in order to ensure that the organization complies with the requirements of the relevant legislation.

Rationale

Teorema Épico is committed to protecting our customers and website visitors privacy

Teorema Épico must comply with the Data Protection principles set out in the relevant legislation. This Policy applies to all Personal Data collected, processed and stored by Teorema Épico in relation to its staff, service providers and clients in the course of its activities.

Scope

The policy covers both personal and sensitive personal data held in relation to data subjects by Teorema Épico. The policy applies equally to personal data held in manual and automated form.

All Personal and Sensitive Personal Data will be treated with equal care by Teorema Épico. Both categories will be equally referred-to as Personal Data in this policy, unless specifically stated otherwise.

What information do we collect from you

During the process of selection and booking the charter flight we collect the following Personal Information from you:

  • Full name of the contact person
  • Contact Phone number
  • Email

In accordance with the legislation as soon as flight is confirmed and scheduled we collect the following data about each passenger of the flight on behalf of the Air Carrier:

  • First name
  • Last Name
  • Date of Birth
  • Passport/National ID document
  • VISA/Residence Permission data, if required

Who processes your data

In the course of its daily organizational activities, Teorema Épico might acquire, process and store personal data.

In accordance with the Portuguese Data Protection legislation, this data must be acquired and managed fairly.

Teorema Épico is committed to ensuring that its staff have sufficient awareness of the legislation in order to be able to anticipate and identify a Data Protection issue, should one arise. In such circumstances, staff must ensure that the Data Protection Officer is informed, and in order that appropriate corrective action is taken.

Due to the nature of the services provided by Teorema Épico, there is regular and active exchange of personal data between Teorema Épico and its Data Subjects. In addition, Teorema Épico exchanges personal data with Data Processors on the Data Subjects’ behalf.

This is consistent with Teorema Épico’s obligations under the terms of its contract with its Data Processors.

Third-Party processors

In the course of its role as Data Controller, Teorema Épico engages a number of Data Processors to process Personal Data on its behalf. In each case, a formal, written contract is in place with the Processor, outlining their obligations in relation to the Personal Data, the specific purpose or purposes for which they are engaged, and the understanding that they will process the data in compliance with the Portuguese Data Protection legislation.

Teorema Épico may share aggregated information that includes non-identifying information and log data with third parties for industry analysis, demographic profiling and to deliver targeted advertising about other products and services or gaining feedback in order improve our services.

Teorema Épico may share your information with selected third parties including

  • Air Carriers
  • Fixed Based Operators
  • Airport Handling companies
  • Security and Border Authorities
  • Suppliers, sub-contractors or other business partners for the performance of any contract we enter into with them or you

We may also disclose your personal information to third parties in the following instances:

  • To provide services, products and/or information requested by you;
  • To maintain and/or host our website;
  • Where we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply the terms of a legal agreement;
  • To protect the safety, property or rights of Teorema Épico and it's customers and partners; this includes exchanging information with other parties for the purposes of fraud protection and credit risk reduction.

Information we receive from other sources: We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).

When you visit our website we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behavior patterns. We do this to find out things such as the number of visitors to the various parts of our website. This information is only processed in a way, which does not identify anyone. We do not make any attempt to find out the identities of those visiting our website. If we do want to collect personal information through our website, this privacy notice will detail this.

Please note that we do not control the privacy or security practices of third parties.

What we do with your data

In its capacity as Data Controller, Teorema Épico ensures that all data is:

  • Obtained for purposes, which are specific, lawful and clearly stated. A Data Subject will have the right to question the purpose(s) for which Teorema Épico holds their data, and Teorema Épico will be able to clearly state that purpose or purposes.
  • Compatible with the purposes for which the data was acquired.
  • Kept with appropriate security measures to protect against unauthorized access to, or alteration, destruction or disclosure of any personal data held by Teorema Épico in its capacity as Data Controller.
  • Kept accurate, complete and up-to-date where necessary.
  • Not excessive and held only as long as necessary.

Accordingly Teorema Épico has implemented a Subject Access Request procedure by which to manage such requests in an efficient and timely manner, within the timelines stipulated in the legislation.

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