Privacy_and_Data_Protection_Policy

1.- WEB PRIVACY POLICY

PRIVACY POLICY

This Privacy Policy is designed to provide you with all the information you need to understand the scope and purpose of data processing. It applies when you visit or contact us through the website, as well as to any other document that may refer to or link to this privacy policy, in compliance with the obligation of information set forth in the applicable data protection regulations at any given time. Currently, these regulations include Regulation (EU) 2016/679 of the European Parliament and Council of April 27, 2016, concerning the protection of natural persons (hereinafter, GDPR) and Organic Law 3/2018 of December 5, on Personal Data Protection and the guarantee of digital rights (hereinafter, LOPDGDD).

Who is responsible for data processing?

The entity responsible for processing personal data is AD AIR CARGO BUSINESS SA, located at Calle José Echegaray, nº 8, 1st Floor, Office 7 – Building III, 28232, Las Rozas de Madrid.

The company’s primary activity is the commercialization of air cargo within aircraft holds, meaning that the processing of personal data in this activity carries a low and residual risk. Given this, the company aims to provide transparent information about the data processing it performs, the purposes for which it processes data, its legal basis, and the rights of individuals regarding the processing of their personal data.

AD AIR CARGO BUSINESS SA shall not be responsible, and it is therefore the user’s obligation to provide truthful data and keep it updated. As a result, the company reserves the right to exclude users from its services and cancel the service for any user who has provided false data, without prejudice to any other legal actions that may apply.

The personal information we receive, collect, or process from or on behalf of third parties, including our clients, is governed by the privacy policies of those third parties. We are not responsible for the policies or actions of our clients, business partners, or other third parties regarding personal information.

What type of data do we process, its origin, and categories?

The personal data we process comes from the information you provide when requesting information or establishing any type of relationship with us, directly through contact details. The category of data we will process is general in nature, including your identifying information: full name, email/postal address, phone number, and DNI/passport when necessary to provide the contracted service; financial data once the contract is formalized

At AD AIR CARGO BUSINESS SA, we process the data provided through the completion of the contact form enabled for this purpose on the website, personal data derived from the provision or contracting of our services or products, and personal data resulting from the commercial relationship you maintain with us.

Additionally, we process data related to website navigation.

For what purpose do we process your personal data?

AD AIR CARGO BUSINESS SA processes the personal data received with the aim of achieving the following objectives:

• To develop, execute, and fulfill the contracted service.

• Personal data collected through the user registration form will be processed for the control and management of the relationship with registered users, as well as for the administration, management, and monitoring of the website and its restricted access areas.

• Managing inquiries submitted via the contact email or requests for quotes. If the individual has only contacted AD AIR CARGO BUSINESS SA, the company will process their data solely to address inquiries or requests for information about the services offered, using electronic or telephone means. Only the personal data strictly necessary to manage or resolve the inquiry or request will be processed.

• Managing user data collected through cookies, including IP addresses. These will be processed to ensure that the website content is tailored to users’ needs and their devices, as well as for continuous improvement of the user experience.

• No profiling is carried out.

Additionally, whenever the individual has given consent, personal data will be processed for the purpose of sending commercial, advertising, and/or promotional communications.

What is the legal basis for processing your data?

The legal basis for processing your data is:

• Management of pre-contractual and, where applicable, contractual measures based on Article 6.1(b) of the GDPR, as we collect and process your personal data primarily to execute contracts according to the terms and conditions set forth in those agreements.

• Managing inquiries submitted via the contact email. This processing is based on Article 6.1(f) of the GDPR, reflecting the legitimate interest in responding to information requests through the website.

• Unequivocal consent based on Article 6.1(a) of the GDPR, in the case of non-customers, for the sending of commercial communications and updates.

• We may obtain and process your personal data for our legitimate interests, based on Article 6.1(f) of the GDPR (or those of any third party). Such legitimate interests include: The offering of products and services is justified by the legitimate interest of the data controller, and the customer may express opposition to this type of processing at any time, without this right affecting the execution of the contract in any way.

• Managing user data collected through cookies, which is legitimized by the unequivocal consent given by users.

• Regarding international data transfers, it is noted that their legitimacy is covered under Article 49.1(b) of Regulation (EU) 2016/679, as these transfers are necessary for the execution of a contract between the data subject and the data controller, or for the execution of pre-contractual measures requested by the data subject. Failure to accept this processing results in the impossibility of providing the service and fulfilling the contract.

• For compliance with legal obligations.

Additionally, please note that failure to provide the required information will make it impossible to subscribe and fulfill the contract.

How long do we retain your personal data?

AD AIR CARGO BUSINESS SA processes your personal data for the period necessary to fulfill the purposes established in this Privacy Policy, as well as to retain your personal information in compliance with the provisions of relevant laws and regulations.

Specifically, the data will be retained for the entire duration of the contract and will be blocked upon its expiration. In this way, the data will be blocked and retained for 5 years, which is the statute of limitations for actions that may arise from the contractual relationship entered into. Likewise, the data that the user has consented to for the sending of commercial information will be retained until they request its cancellation, at which point it will be deleted.

To whom will your data be communicated?

Only the necessary data will be communicated to third-party providers related to the Data Controller, such as external service providers including airlines and handling operators, billing services, administrative management, auditors, lawyers, and other external professional advisors, IT developers, marketing and/or advertising companies, data storage services, and similar entities whose involvement is necessary to fulfill the purposes described herein.

It is possible that, due to legal obligations, data must be provided to official and/or public authorities, including courts, law enforcement agencies, tax authorities, and fraud prevention authorities, as well as to comply with air security regulations.

For service needs, it may be necessary to provide data to companies located outside the European Economic Area that do not offer a level of data protection comparable to that of the European Union. In such cases, if personal data must be provided, we inform you that we transfer your data with adequate safeguards and always ensure its security. Failure to accept this processing implies the impossibility of providing the service and fulfilling the contract.

Apart from the cases described herein, no data will be communicated unless legally required.

Social Media

AD AIR CARGO BUSINESS SA has a presence on internet social media, for which it acts as the data controller in relation to the data published by AD AIR CARGO BUSINESS SA. Its presence is through LinkedIn.

The use of social media is intended to provide information about the services offered and any events organized to promote them. However, no personal data is collected from users interacting on these platforms unless they have given explicit authorization according to the settings they have saved in the respective social network.

Social media users can configure the privacy and security options provided by the platform itself. AD AIR CARGO BUSINESS SA is not responsible for the processing of users’ data on the social network.

What are your rights when you provide us with your data?

Any individual has the right to obtain confirmation on whether AD AIR CARGO BUSINESS SA is processing personal data concerning them.

The data subject has the right to withdraw their consent at any time, provided that the processing is not necessary for the fulfillment of the contract. Withdrawal of consent will not affect the legality of the processing based on prior consent before its withdrawal.

You may exercise your rights as a data subject, including access, rectification, erasure, restriction, portability, and objection to the processing of personal data, at any time and free of charge by sending an email to info@aircargob.com or by writing to AD AIR CARGO BUSINESS SA at the address indicated in the section concerning the data controller in this same privacy policy indicating the right you wish to exercise and your identifying data.

Additionally, the data subject has the right to file a complaint with the Spanish Data Protection Agency (AEPD) as the supervisory and control authority in matters of data protection within Spanish territory.

Privacy Policy Update. –

At AD AIR CARGO BUSINESS SA, we reserve the right to update our privacy policy at any time due to strategic corporate decisions, as well as to comply with any legislative or judicial changes.

Whenever the policy is significantly modified, all reasonable efforts will be made to inform affected users. In any case, when consent is required under current legislation, the appropriate protocols will be established for its collection.