Privacy Statement

Aviareto Privacy Policy

Please read this policy in connection with our Cookies Policy, which is available on our website.

Aviareto Limited (“Aviareto, “we”, “us”)  Suite 5, Plaza 255, Corporate Park 2, Blanchardstown, Dublin 15, Ireland, is committed to protecting and respecting your privacy and personal data. This policy applies to visitors of the Aviareto website (“the Site”).

Aviareto operates the International Registry of Mobile Assets under a contract with the International Civil Aviation Organisation (ICAO).  You can connect to the International Registry website, and other websites, from links provided on our Site. Please note that all other sites have their own privacy policies and such policies should be reviewed on those sites directly.

Please review this policy carefully as it describes the way in which we will Process Personal Data in connection with the Site and the procedures we have in place to safeguard your privacy.

As we are located in the European Union, any Personal Data which is Processed by us in connection with your use of the International Registry will be treated in accordance with the provisions of the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and Council of 27 April 2016) and any consequential national data protection legislation in Ireland (together, the “Data Protection Laws”).  Aviareto is the data controller.

Definition of Terms

“Personal Data” means data relating to a visitor which can be used to identify, directly or indirectly, the visitor, for example by reference to an identifier such as a name, identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the User.

“Controller” means any persons who determine the purpose for which and the manner in which any Personal Data is Processed.

“Processor” means any persons who Process Personal Data on behalf of a Controller.

“Processing” is any activity that involves the use of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

 

What information do we collect and how do we use it?

General

The information we may collect and Process about you includes information that you enter on the Site such as your name, address, telephone number, email address, your company name, work address and telephone number together.  We may also collect technical data and online identifiers via cookies, as detailed in our Cookie Policy which is available on the Site.

 

Electronic Messages

We may also Process other information which you provide to us from time to time by email.

We may monitor or keep a record of the communications made to us to establish facts, ensure compliance with applicable regulatory practices and our internal policies, demonstrate standards that should be achieved (for example relating to quality control and training), prevent crime, investigate the unauthorised use of the Site and/or our telecommunications systems, secure effective operation of the Site and any related systems, and to establish the nature of communications made on the Site.

 

Purpose and Lawful Basis for Processing your Personal Data

For Personal Data to be Processed lawfully, it must be Processed on the basis of one of the lawful bases set out in the Data Protection Laws. These include, among other things, your consent to the Processing; for compliance with a legal obligation to which we are subject; or for the legitimate interest of Aviareto or a third party (provided in the case of the latter that your rights are not unduly prejudiced by the Processing).

The primary purpose for which your Personal Data will be Processed is to facilitate responding to queries you submit through the Site.  We will also Process your Personal Data for the legitimate interest of ensuring the Site operates efficiently.  In addition to the above, we may also Process your Personal Data to comply with our legal obligations under our contract for the operation of the International Registry and legal obligations under the Cape Town Convention.

 

Disclosure and Sharing of Your Personal Data

General

We will only share your Personal Data with selected third parties in limited circumstances including those described below. Specifically, we may share a copy of your Personal Data with (i) our service providers; and (ii) ICAO (only if required).

Other Recipients

We may provide Personal Data which we hold relating to you if we are required to do so by law or a court order. We may also disclose the Personal Data we have collected about you to our service providers and professional advisers.

International Data Transfers

Aviareto website data is on a server currently located in secure premises in Ireland. Your Personal Data will be processed by us (or any other third party to whom we may outsource the hosting of the Site to) in accordance with Data Protection Laws.  The server will not be relocated to a country which does not provide a similar level of legal protection for Personal Data without your being notified first.

We may also occasionally transfer your Personal Data to ICAO in connection with our obligations under the Cape Town Convention and our contract with ICAO. These transfers are required in order for us to perform our contractual obligations to you in accordance with applicable law.

 

Retaining your Personal Data

We will retain and Process your Personal Data for the period which we are required to do so under applicable law. If you require further information please contact us using the details below.

How We Protect Your Personal Data

General

We will take appropriate measures including IT security and operational measures to protect the information on the Aviareto website. We also take appropriate measures to keep your information confidential. Aviareto’s internal procedures cover the storage, access and disclosure of your information.

Your Rights

We will Process all Personal Data in accordance with your rights, in particular your right to:

(i)           access and obtain a copy of the Personal Data we hold about you (your access right);

(ii)           have any inaccurate Personal Data we hold about you corrected;

(iii)         to the extent permitted by applicable law, request that any of the Personal Data we hold about you be erased;

(iv)          require in certain circumstances that we restricts the Processing of your Personal Data;

(v)          object to us Processing your Personal Data;

(vi)         obtain your Personal Data as held by us to provide to a third party yourself or you can require us to transfer your Personal Data directly to a third-party nominee (the right to data portability); and

(vii)        not to be subjected to Processing which is wholly automated, and to object to any decision making based solely on automated Processing.

The rights set out above are not absolute – certain conditions may apply (e.g. there are statutory exemptions to your right to access or erase your Personal Data held by us). However, we will do our best to vindicate your data protection rights to the greatest extent practically possible. If you wish to exercise any of the rights outlined above, you can contact us using the details outlined below.

Making a Complaint

If you have any queries in relation to your Personal Data rights, you should contact us using the details outlined below. You also have the right to lodge a complaint with the Irish Data Protection Commission (its details are here).

Changes to this Privacy Policy

We reserve the right to change this policy as necessary, for example, to comply with changes in laws,  regulations, practices, procedures and organizational structure or requirements imposed by the Irish Data Protection Commission and other authorities.

Changes to the policy shall be applicable on the effective date of implementation. The revised policy will be posted to this page so that you are aware of the information we collect, how we use it and under what circumstances we may disclose it.

How to Contact Us

If you would like to contact us with any queries or comments in relation to data privacy or otherwise, please use the Contact Us section on the Site or write to Aviareto Limited, Suite 5, Plaza 255, Corporate Park 2, Blanchardstown, Dublin 15, Ireland.