Last updated: 27 February 2019
1.1 The www.goshawk.aero website (the “Website”) is operated by Goshawk Management (Ireland) Limited (“Goshawk” “we” or “us”) of 32 Molesworth Street, Dublin 2, Ireland for and on behalf of Goshawk Aviation Limited, Goshawk Management Holdings (Cayman) Limited and our affiliated and group companies (together, the “Goshawk Group”). Goshawk respects your right to data protection and privacy. This Privacy Statement (“Statement”) sets out the basis on which we use, process, store or disclose any personal information about you (“Personal Data”), as detailed below, that we collect from you or that you provide to us through the Website. The Personal Data provided by you will be held by Goshawk as a controller. 1.2 This Statement, together with our website terms and conditions of use (the “Terms and Conditions of the Website”) and our Cookies Policy, applies to your use of the Website. We are not responsible for the content or privacy practices of other websites. Any external links to other websites are clearly identifiable as such.
2.1 We collect Personal Data from you when you use the Website and process this Personal Data for the purposes of providing you with access to the Website which we are entitled under the Terms and Conditions of the Website to do. You can also choose to provide your Personal Data to us via email which we will process for the purposes of responding to your queries. Responding to these queries is necessary for the purposes of our legitimate interests. We will only share your Personal Data outside Goshawk if Goshawk (or most of our assets) is purchased by a third party. We will also share your Personal Data with law enforcement agencies or public bodies if we are required by European Union or European Union Member State law to do so.
3.1 We will collect and process the following Personal Data from you:
When using the Website or availing of services related to the Website, Personal Data will be collected from you by Google Analytics and by Goshawk. This includes information about:
3.2 You can choose to provide us with the following Personal Data:
You may choose to give us your Personal Data, such as your first name, last name, e-mail address, address, telephone number and other details when contacting us or submitting enquiries through the Website by e-mailing firstname.lastname@example.org. If you choose to provide us with this information, we will keep a record of this correspondence for as long as is necessary to deal with this query (please see our section on How Long We Keep Your Data for further information).
CV or Job Application
You may choose to send your CV or submit a job application to Goshawk via the Website (or other link on the Website) which will contain your Personal Data, such as your name, contact details, job experience, references, etc. If you choose to do this, Goshawk will process your Personal Data in accordance with the Goshawk Recruitment and Job Application Data Protection Notice (which will be provided to you on Goshawk receiving your CV or job application).
4.1 The following table details the legal basis for (the “Legal Basis”) and the reasons why (“Purposes”) we process your Personal Data:
It is necessary to process your Personal Data to enter into and perform our contract with you regarding your use of the Website.
|Access to the Website
To provide you with access to the Website and to allow you to use the Website.
It is necessary for the purpose of our legitimate interests to collect and process your Personal Data for the purposes of improving and monitoring website efficiency and enhancing your use of the Website. It is also necessary for the purposes of our legitimate interests to process your Personal Data to respond to any queries or requests submitted by you regarding the Website to Goshawk. This includes any job application or CV that you submit to Goshawk via the Website (or other link on the Website).
|Improving Website Functionality & Efficiency
To provide, improve, test and monitor the effectiveness of the Website * To monitor metrics such as total number of visitors, traffic data and demographic patterns * To ensure the content on the Website is presented in the most effective manner for you and your device.
Responding to Queries
To process and respond to any enquiries or requests you submit to us by emailing email@example.com.
Notification and Information
To notify you about changes to the Website and/or our business;
Job Application or CV
Please refer to the Goshawk Job Application and Recruitment Data Protection Notice (which will be provided to you on Goshawk receiving your CV or job application) for more information.
|Compliance with a Legal Obligation
We may process your Personal Data where it is necessary to comply with legal obligations to which we are subject. *
|To comply with our obligations under European Union and/or European Union Member State laws, including but not limited to safeguarding and complying with law enforcement requests.|
|To Defend, Establish or be a Party to legal Claims
We may process your Personal Data as necessary in order for us to establish, investigate, exercise or defend a legal claim to which you are a party.
5.1 We will disclose your Personal Data to other entities within the Goshawk Group.
5.2 We will only disclose your Personal Data to third parties outside the Goshawk Group in the following circumstances:
6.1 We may transfer your Personal Data outside the European Economic Area (“EEA”) to other recipients. Some recipients (e.g. our third party service providers) who process your Personal Data on our behalf may transfer your Personal Data outside the EEA to a country that does not provide an adequate level of protection to your Personal Data. Where such transfers occur, we ensure that: a) they do not occur without our prior written authority; and b) that an appropriate transfer agreement is put in place to protect your Personal Data.
6.2 If you would like to find out more about any such transfers, please e-mail firstname.lastname@example.org.
7.1 The Website contains links to other websites (“Linked Websites”). Goshawk is not responsible for the privacy/data protection notices or practices on the Linked Websites. This Statement governs only information collected on the Website. When accessing Linked Websites, you should read the privacy/data protection notice published on the relevant Linked Website. The terms of our Statement do not apply to Linked Websites. Please check these notices before you submit any Personal Data to Linked Websites.
7.2 The Website contains links to other sites and resources provided by third parties for your convenience and information only. We accept no liability in connection with any Linked Website, or any contract entered into or through a Linked Website. We have no control over the contents of those sites or resources, and accept no responsibility for them or for any loss or damage that may arise from your use of Linked Websites.
8.1 In general, we expect to keep your Personal Data for the following periods:
|Personal Data||Retention Period|
|Device Information||Two years after your last session on the Website.|
|Query Information||The length of time it takes to address/conclude your query and, in some cases, a reasonable period of time after that to allow for follow-up actions or queries.|
|Job Application or CV||Please refer to the Goshawk Recruitment and Job Applications Data Protection Notice.|
Please note that in certain circumstances, we may hold your Personal Data for a longer period, for example, if we are processing an ongoing claim or believe in good faith that the law or a relevant regulator may reasonably in our view expect or require us to preserve your data.
9.1 The table below sets out the rights which you have to address any concerns or queries with us about our processing of your Personal Data:
|Right of Access||You have the right to request a copy of the Personal Data held by us about you and to access the information which we hold about you. We will charge you for making such an access request where we feel your request is unjustified or excessive.|
|Right to Rectification||You have the right to have any inaccurate Personal Data which we hold about you updated or corrected.|
|Right to Erasure||In certain circumstances, you may also have your Personal Data deleted, for example if you exercise your right to object (see below) and we do not have an overriding reason to process your Personal Data or if we no longer require your Personal Data for the purposes as set out in this Statement.|
|Right to Restriction of Processing||You have the right to ask us to restrict processing your Personal Data in certain cases, including if you believe that the Personal Data we hold about you is inaccurate or our use of your information is unlawful. If you validly exercise this right, we will only store your Personal Data and will not carry out any other processing until the issue is resolved.|
|Right to Data Portability||You may request us to provide you with your Personal Data which you have given us in a structured, commonly used and machine-readable format and you may request us to transmit your Personal Data directly to another controller where this is technically feasible. This right only arises where:
|Right to Object||You have a right to object at any time to the processing of your Personal Data where we process your Personal Data on the legal basis of pursuing our legitimate interests. When we process your Personal Data based on our legitimate interests, we make sure to consider and balance any potential impact on you and your data protection rights. We will not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by European Union or European Union Member State law).|
9.2 You can exercise any of these rights by submitting a request to email@example.com.
9.3 We will provide you with information on any action taken upon your request in relation to any of these rights without undue delay and at the latest within one month of receiving your request. We may extend this up to two months if necessary however we will inform you if this arises.
9.4 You have the right to lodge a complaint with the Data Protection Commission with regard to our processing of your Personal Data.
10.1 If we amend this Statement, in whole or part, any changes will be posted on this page. The new statement may be displayed on-screen and you may be required to read and acknowledge it to continue your use of the Website.
Questions, comments and requests regarding this Statement are welcomed and should be addressed to firstname.lastname@example.org.