Privacy and Cookie Policy.
Focus.Aero ApS ("we", "us", or "our") is committed to protecting your privacy and ensuring the security of your personal data. This Privacy Policy outlines how we collect, use, and process your personal information in various situations. By using our services or providing your personal data to us, you consent to the practices described in this Privacy Policy.
Website usage data
When you visit the website, we may automatically (i.e. not by registration) collect and store the following information about you:
Details of your visits to this website, and/or any Focus.Aero Group extranet or customer portal that you access via this website.
Through your use of telecommunications services to access our website, your communications data or utilization data are technically generated and could conceivably relate to personal data.
No attempt is made to identify individual users or to associate the technical details listed above with any individual.
Cookies and Privacy
Our websites use cookies. If the cookie is not necessary for the functioning of our website, it will not be stored on your device unless you consent to it. Read about the cookies we use and how we manage them at the bottom of the website.
Privacy Statement:
Data Controller
This Privacy Statement explains how we collect and process personal data in our business. Focus.Aero ApS, through its Chief Pilot, is the data controller for the processing.
NB! Copying any text from this privacy statement is not permitted, according to copyright law (retsinformation.dk).
Our contact information is:
Focus.Aero ApS
Business Address: Hørrelundvej 4, 8653 Them, Denmark
Org. number: CVR DK43224137
Email: jc@focus. aero
We take your privacy seriously and have implemented several measures to ensure that we provide clear information about how we process your data and the rights you have. If you find anything unclear or missing, please do not hesitate to contact us.
Your Rights
Contact us if you have questions about or wish to exercise any of your rights. You are entitled to a response within 30 days. Learn more on the Danish Data Protection Authority's website (datatilsynet.dk).
Access and Correction of Your Data: You can request a copy of all information we process about you and ask us to correct any inaccurate information.
Deletion or Restriction: In some situations, you can ask us to delete and/or restrict the processing of your information, but we cannot delete data that we are legally obliged to process.
Objection to Processing: If we process your information based on legitimate interests, you have the right to object to it.
Data Portability: If we process your information based on consent or a contract, you can ask us to transfer your information to you or another data controller.
You also have the right to withdraw your consent at any time.
If you are not satisfied with how your data is handled, you can lodge a complaint with the Danish Data Protection Authority (datatilsynet.dk), but we hope you will notify us directly first, so that we can try to resolve the matter for you in a satisfactory manner.
Whom We Process Personal Data About
We process personal data about:
Customers
Former Customers
Potential customers
Visitors to our website
Job applicants
Employees
Freelance Employees
Former employees
How we collect Personal Data
Providing personal data to us is voluntary, but to register as a partner, customer or Freelance Employee, we require certain information from you. We neither lease, buy, nor sell personal data to/from others. We do not use automated decision-making or profiling in the processing of your personal data.
For certain employees, we process data in special categories based on voluntary written consent.
We process personal data when you:
Purchase our services.
Contact us via phone, SMS, our website, email, or social media.
Use our website.
Purpose, Legal Basis, and Storage
According to the General Data Protection Regulation (GDPR) Article 6 no. 1 and Article 9.2 a) and h), we process personal data based on:
Your consent
An agreement we have entered into
A legal obligation we have
A legitimate interest we believe we have
As a general rule, personal data should not be processed and retained longer than necessary to fulfil the purpose of processing.
We keep data for as long as we are legally obligated to do so under current legal requirements, such as related to accounting, tax, or employment legislation, and/or other relevant rules and regulations. You can contact us at any time if you wish us to stop processing or delete your personal data, but please note that we cannot delete data that we are legally obligated to process.
How We Process Personal Data
Here, we describe in detail when and how we process your personal data, for what purposes, on what legal basis, and for how long.
We process personal data when:
You communicate with us
When you give us your business card or contact us via the website (contact form, comment section, chat, or similar), email, phone (calls, text messages), or social media, we process personal data. Depending on where and how you send us messages, this may include name, contact information, E-mail address, and other information you choose to send us.
The purpose is to respond to your inquiries, for historical records, and for documentation in case we receive complaints, claims, or legal demands. The legal basis is Article 6 f), where the legitimate interests are to respond to your inquiries, for historical records, and for documentation in case we receive complaints, claims, or legal demands. The legal basis is Article 9 - 2 a) and b) in cases where the personal data is of a special category. We review, archive, and delete inquiries as needed, but no less frequently than every 3 years. Accounting material is kept for up to five years, according to the rules of the Danish Accounting Act.
You purchase our services
When you purchase services from us, we process personal data such as name, contact information, order, and payment information, and purchase history.
You are interested in becoming a Freelance or Permanent Employee with us
When you express interest in employment, freelance or permanent, with us, we process personal data such as name, address, contact information, date of birth and passport, licence, and medical details.
If you decide not to join the Company as a freelancer, we delete the personal data immediately after you have declined the Freelance contract (pilot agreement) or permanent employment with Focus Aero.
In addition, based on written consent, we process special personal data necessary for your employment status.
Throughout your “employment” period, we process personal data such as Licence Proficiency Checks, minutes of meetings, flight schedules and content on shared platforms (WhatsApp groups).
The purpose is to deliver work schedules in the best possible way, to have a history of delivery and completion of the flights and deliveries, and to manage and follow up on our customer relationship. The legal basis is a) agreement and b) legal obligation according to the Accounting and Tax Acts. Accounting material is kept for up to five years, according to the rules of the Danish Accounting Act, and other personal data is deleted after 3 years.
Marketing to Existing Customers
When you become a customer with Focus.Aero ApS, we process personal data as mentioned above. If you have an existing customer relationship with us, we may send you marketing material via email and SMS, in accordance with the Marketing Act § 15.
The purpose is to provide good customer service. The legal basis is f), where the legitimate interest is to offer you relevant products and services. The legal basis can also be a), where you have given us your consent. You can unsubscribe from marketing emails and SMS at any time. Information on how to unsubscribe is provided in all marketing-related emails and SMS sent by us. Information is retained as long as the customer relationship exists, until you unsubscribe, or until you request us to delete your information.
Job Applicants
When you apply for a job with us, we process personal data such as your name, contact information, CV, and other necessary details to assess your application. The legal basis for processing this data is typically a contractual relationship (b), but it may also include other legal grounds (e.g., your consent for processing special categories of data under Article 9). Your data will be retained until another candidate is chosen for the position unless you provide consent for us to keep your information for future job opportunities. In such cases, your consent will be renewed annually.
Employees
For our employees, we process personal data as mentioned above, along with information required for payroll and employment administration. The legal basis for this processing includes the employment contract (b), legal obligations (c), and, if applicable, your consent for special categories of data under Article 9. As a general rule, employee data is deleted when the employment relationship ends, unless specific circumstances (such as disputes or legal requirements) necessitate a longer retention period. Information related to payroll administration will be retained for up to five years, in accordance with the rules of the Bookkeeping Act.
Survey Respondents
We always inform you of the purpose of any surveys we conduct and whether they are anonymous or not. For non-anonymous surveys, we process your personal data based on your consent (a). Your data will be deleted upon your request or within 3 months after you have responded to the survey.
Suppliers and Partners
When you enter into an agreement with us as a supplier, partner, or data processor, we process personal data such as your name, contact information, and correspondence. The purpose is to establish and manage the contractual relationship, and the legal basis for this processing is the contract (b). Your data will be retained for up to five years in accordance with the Bookkeeping Act. We also process personal data related to general correspondence and communication as described above.
Website Visitors
When you use our website, we process personal data in accordance with our Cookie Statement. The purpose is to administer our website, promote our business, and respond to inquiries from visitors. The legal basis for processing cookies that store, or process information covered by the Electronic Communications Act § 2-7b is your consent, provided through the browser settings, in accordance with the Danish Communications Authority's recommendations as described here (Danishbusinessauthority.dk).
Who We Share Personal Data With
In order to run our business efficiently and securely, we may sometimes need to share your personal data with third parties, including:
Data Processors: Providers of various services who process your personal data on our behalf (Flightplanning, handling companies etc.).
Professional Advisors: Advisors from industries such as law, finance, CAAs, accounting, auditing, and insurance.
IT and Administrative System Support: Support providers for IT and administration systems.
Public Authorities: Authorities we are obliged to report to by law.
We require all third parties with whom we share your personal data to ensure the security of your data in accordance with good information security practices and the requirements of the General Data Protection Regulation (GDPR). We enter into data processing agreements with all third parties processing data on our behalf and provide confidentiality agreements as needed.
We use data processors for:
Email, calendar, and digital meetings
Bookkeeping, accounting, and invoicing
Cloud storage
Electronic signatures
Due to security reasons, we have not specified these by name, but please feel free to contact us if you want to know more.
Transfer of Personal Data Outside the EU/EEA
In some cases, your personal data may be transferred outside the European Union (EU) or the European Economic Area (EEA). For example, this may occur when we use service providers located outside the EU/EEA to handle tasks such as overflight permits, aircraft handling, visas, providing services through our website, ensuring website security, and operating our business effectively and securely. Transfer of personal data to countries outside the EU/EEA is only permitted to countries approved by the European Commission or under the necessary safeguards provided by the GDPR. This may include the use of EU standard contractual clauses.
For security reasons, we have not specified these third parties by name. Please feel free to contact us if you would like to know more about the third parties we use, the necessary safeguards for such transfers, and the additional security measures we have implemented.
Security
We take information security seriously and make every effort to protect your personal data. Among other measures, we use strong passwords, data encryption, access control, and backups to secure our data and prevent unauthorized access, alteration, deletion, or any other form of unauthorized data processing of the data we store, including your personal data.
We only permit others to access and/or process your personal data based on our instructions and only when strictly necessary (e.g., for IT support). We have established procedures for handling data breaches, and we will report any breaches to the Danish Data Protection Authority within 72 hours of discovering the breach. If the breach poses a high risk to your privacy, we will also inform affected individuals.
This Privacy Policy was last updated on: March 15, 2023.
Please note that it is not permissible to copy any text from this Privacy Policy, in accordance with copyright law.
For any inquiries related to this Privacy Policy, please contact:
Focus.Aero ApS