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Privacy Policy

Last update: April 2023

1. Subject

This privacy policy (hereinafter the «Privacy Policy ») illustrates the commitment of HIGH PROFILE, a Private limited company with a share capital of 10 000 €, registered in the Trade and Companies Register of Pontoise under the Number 517 864 450, VAT number : FR 40517864450 and whose head office is located at 188 rue des Chardonnerets in Roissy-en-France (95700) (hereafter the « Company » to respect the privacy and protection of personal data of the following website : https://highprofile.aero/ (hereinafter the «Website »).

The Website allows you :

  • to discover the Company and its associated services ;
  • to send requests for ground handling assistance;
  • to obtain contact details about the Company.

2. Processing of your personal data

2.1 Description of the processing of your personal data

In accordance with applicable laws and regulations, the Company, acting as data controller, and collects certain personal data from you when you visit the Website.

In order to respond to your requests for ground handling assistance, the Company, acting as a data controller, collects the following personal data: 

  • Your name;
  • Your e-mail address; and
  • Your telephone number;
  • The flight number;
  • The city of departure;
  • The date of arrival;
  • The arrival time;
  • The city of arrival;
  • The date of departure*;
  • The departure time *;
  • Your comments*.

     

*The data marked with an asterisk are optional, you are not obliged to provide them to the Company.

When you connect to the Website, the Company, acting as data controller, also collects the following personal data:

  • Connection logs; 
  • Connection data; 
  • IP address.


The Company uses your personal data for the following purposes :

Purpose

Legal basis

Retention period

Receive and manage ground handling requests

The processing is based on your consent

Until the request for assistance is withdrawn or the assistance is provided by the Company

Management of requests for rights of access, portability, erasure, restriction of processing, rectification and opposition

The processing is necessary to respond to your requests to exercise your rights and is based on your consent

Personal data shall be retained for the duration of one year from the date of your request to exercise your right(s)

Management of requests for the right to object to commercial prospecting

The processing is necessary to respond to the request to exercise the right to object

Personal data shall be retained for the duration of three years from the time you exercise your right to object

2.2 Recipients / transfers of your personal data 

Access to your personal data is restricted to only those persons who need your personal data in order to fulfil the specific purpose of the processing.

Your personal data may also be disclosed by the Company to third parties :

  • if the law or a legal procedure requires the Company to share your personal data ;
  • in response to a request from a public or judicial authority (in particular in the event of a judicial requisition) ;
  • when the Company considers that the transmission of your personal data is necessary or appropriate to ensure the safety of individuals or to protect the public.

Your personal data is transferred to AGENCE DES MÉDIAS NUMÉRIQUES, operating under the trade name AMEN, a national scientific, cultural and professional public institution registered in the Trade and Companies Register of Paris under the number 421 527 797, and whose head office is located at 12 Rond-Point des Champs Elysées-Marcel Dassault in Paris (75008).

Your personal data is therefore not transferred outside the European Economic Area.

2.3 Security of Personal Data 

The Company ensures the security of your personal data by implementing appropriate technical and organizational measures in order to guarantee a proper level of security and to implement means to guarantee the confidentiality, integrity, constant availability and resilience of the processing systems and services, restore availability and access to your personal data, as well as a procedure to regularly test, analyze and evaluate the effectiveness of the technical and organizational measures put in place by the Company.

2.4 Retention of your personal data 

Your personal data should be retained only for the period required to fulfil the purpose for which the Company stores such data, to meet your needs, to fulfil its legal or regulatory obligations, to enable it to exercise its rights and/or for statistical or historical purposes.

At the end of the above-mentioned periods, your personal data will be deleted, or the Company will anonymize it.

2.5 Your rights regarding your personal data

You have the following rights regarding your personal data:

Right of access and rectification

You may request to access to your personal data. 

You may also request to modify the inaccurate personal data or incomplete data to be completed.

Furthermore, you have the right to know the origin of your personal data.

Right to erasure

You may request the erasure of your personal data if :

  1. The data is no longer necessary for the purposes it was collected and processed ;
  2. You have chosen to withdraw your consent (where consent has been collected as the legal basis for processing); this withdrawal does not impact the lawfulness of the processing before its implementation ;
  3. You have objected to the treatment of your personal data;
  4. The data have been processed unlawfully ;
  5. The data should be deleted to comply with a legal obligation ; or
  6. Such erasure is required to ensure the compliance with current legislation, in particular with regard to the retention periods applicable to the collected personal data.

Right to object 

You may object to the processing of your personal data in accordance with the legal obligations imposed on the Company.

Right to restriction of processing

You may also request a restriction of processing of your Personal Data if :

  1. You contest the accuracy of such data ;
  2. The Company no longer needs this data for processing purposes ; and
  3. You objected to the treatment of your personal data ;

Right not to be subjected to a decision exclusively based on the basis of an automated data processing

You shall not be the subject to the decision based exclusively on automated processing that produces legal effects concerning you or significantly affects you, particularly based on profiling.

Right to portability

You may request that the Company provide you with your personal data in a structured, commonly used, machine-readable format, or request to transmit those data directly to another data controller as long as:

  1. The processing is based on your consent ; and
  2. It is carried out by automated means.

Right to give directives on the processing of your personal data after your death

Pursuant to the Article 85 of French Data Protection Act of 6 January 1978 as amended, you can give directives on the exercise of your rights under this section after your death, (in particular on the duration of the retention of your personal data, its deletion and/or its communication) as well as designate a person responsible for the exercise of these rights.

In the absence of such directives, the Company will grant the requests to your heirs, as set out in article 85(II) of the French Data Protection Act.

Right to withdraw your consent

You can withdraw your consent for the processing of your personal data at any time.

The withdrawal of your consent only applies to the future processing and does not affect the lawfulness of any processing carried out by the Company based on your consent before your withdrawal or the lawfulness of any processing based on another legal basis, such as the execution of a contract between you and the Company.

Right to make a complaint to a supervisory authority

If you have any concerns or appeals regarding the protection of your personal data, you have the right to make a complaint to the Commission Nationale de l’Informatique et des Libertés via the following link : Plaintes en ligne | CNIL

The CNIL can also be contacted at the following address: 3 Place de Fontenoy, 75007 Paris – phone: 01 53 73 22 22.

You are invited to inform the Company in advance so that the Company can process the request and attempt to find an amicable solution.

You may exercise your above-mentioned rights and/or ask any questions concerning the processing of your personal data using the following email address: vip@highprofile.aero or by post at the following address: HIGH PROFILE, 188 rue des Chardonnerets, 95700, Roissy-en-France.

In order to process the request as quickly as possible, you may indicate in your request the purpose and the context in which your personal data was collected by the Company.

The Company may ask you to provide a copy of both sides valid identity document, if there is a reasonable doubt about your identity.

The latter will be deleted by the Company once your request has been granted.

The Company may retain a copy of your identification for the sole purpose of establishing proof in the event of a dispute with you.

2.6 Links to third party sites

In order to improve the quality of the Site, the Company may include on the Site links to third-party sites. These sites have a privacy policy that is different and independent from that of the Company. You are invited to consult the privacy policy of the third-party sites you visit.

2.7 Language

This Privacy Policy is written in English for informational purpose. Only the English version shall be deemed authentic in the event of a dispute.

2.8 Cookies

The provisions relating to the deposit of cookies on the Website are contained in the cookie policy available on the Website.

2.9 Modification of Privacy Policy

The Company reserves the right to make changes to this Privacy Policy at any time.

The Company recommends that you check this page regularly, referring to the date of the last modification.

In the event of a major change to the present Privacy Policy, the Company will notify you of such changes.