Version 4

This version was reviewed and updated on October 10th, 2018

In this Privacy Policy (this “policy”), “CTT Aviation”, “we”, “us” or “our” means CTT Aviation Limited (a company incorporated in Cyprus, with registration number HE 39193, and principal office at Panteli Katelari 14, CY-1097 Nicosia) and its trade name CTT Travel Services (TM) and affiliated business partners and associates collectively; “you” or “your” means you, the person who provides us with your personal data; “personal data” shall have the meaning assigned to it in Article 4 of Regulation (EU) 2016/679 of the European Parliament and of the Council.

A privacy policy is a statement or a legal document that discloses some or all of the ways a party gathers, uses, discloses and manages a customer's personal data. It fulfils a legal requirement to protect a customer's privacy.

Personal data, or personal information, means any information about an individual from which that person can be identified.

Personal data processing within CTT Aviation

All personal data is obtained, held, protected and processed by CTT Aviation in compliance with this policy, any and all data protection related laws and regulations that are applicable to CTT Aviation {including without limitation, Regulation (EU) 2016/679 of the European Parliament and of the Council (“GDPR”)} and any and all data protection related terms in any service agreement or contract in force between you and CTT Aviation.

CTT Aviation’s data protection and privacy measures are governed by:

(i) The General Data Protection Regulation (EU) 2016/679) (“GDPR”).
(ii) Any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the Republic of Cyprus.
(iii) Any successor legislation to the GDPR or the Data Protection Act 1998 (“Data Protection Legislation").

What personal data will CTT Aviation collect about me?

• When you use CTT Aviation to purchase a service or a product, we may collect a variety of information, including, but not limited to:

(a) your name,
(b) your job title,
(c) your mailing address,
(d) your telephone number,
(e) your email address,
(f) your passport and/or ID details,
(g) your credit/debit card or bank details.

• Where you use the websites www.cttaviation.aero, www.cttaviation.com, www.ctt-travel.com (“website”), we may collect technical data such as IP addresses and cookie ID.

You are not required to provide us with your personal data, but, if you choose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have.

For more information around how we use cookies please see our Cookie Settings at www.cttaviation.aero/cookie-settings (link at end of page).

How is my personal data collected?

You may directly provide your personal data to us, or we may collect your personal data from third parties, such as customers providing your passenger details for the purpose of arranging a travel service and/or product. We may also collect information from publicly available sources where necessary and in order to expedite our services to you.

What is the purpose of collecting personal data and how are they processed?

We have set out the below list describing why and how we process your personal data and on which legal basis we rely on to do so. This list identifies which information is to be asked and collected by us, as well as our legitimate interests for processing your personal data.

(1) To register you as a new customer and verify your identity, we would ask for:
(a) Your identity.
(b) Your contract details.

Basis on which we are processing your personal data for:
(a) To perform a service and/or contract agreement.
(b) Our legitimate interest.

Your consent is required.

(2) To process and deliver services to you for purposes of:
· contacting you and corresponding about services we provide to you;
· managing transfers and fees;
· managing payment arrangements,
we would ask for:
(a) Your identity.
(b) Your contract details.
(c) Means of communication you prefer to be contacted with.
(d) Your payment details.
(e) Your financial details.

Basis on which we are processing your personal data for:
(a) To perform a service and/or contract agreement.
(b) Our legitimate interest.

Your consent is required.

(3) To create, develop, offer, operate, deliver and improve our services to you, we would ask for:
(a) Your identity.
(b) Your contact details.
(c) Means of communication you prefer to be contact with.

Basis on which we are processing your personal data for:
(a) To perform a service and/or contract agreement.
(b) Our legitimate interest.

Your consent is required.

(4) For loss prevention and anti-fraud purposes, or national security matters, we would ask for:
(a) Your identity.
(b) Your contact details.
(c) Your payment details.
(d) Your financial details.

Basis of which we are processing your personal data for:
(a) To perform a service and/or contract agreement.
(b) Our legitimate interest.
(c) Legal requirements.

Your consent is required.

(5) To update you about our and our affiliated business partners’ and associates’ services, products, news, events and special offers, we would ask for:
(a) Your contact details.
(b) Means of communication you prefer to be contacted with.

Basis on which we are processing your personal data for:
(a) To perform a service.
(b) Our legitimate interest.

Your consent is required.

We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your personal data.

If you require details about the specific legal ground we are relying on to process your personal data, please contact us at data.protection@cttaviation.aero.

When will CTT Aviation contact me?

• In relation to any service, activity or online content you have signed up for in order to ensure that CTT Aviation can deliver its services to you, e.g. to confirm payment and ensure receipt of your air-ticket, and offer other travel related services or upgrades, or to ask whether you’re in need of any additional service.

• In relation to any correspondence we receive from you or any comment or complaint you make about CTT Aviation.

• To invite you to participate in voluntary surveys about CTT Aviation.

• To update you on any material changes to CTT Aviation’s policies and practices.

• To keep you informed periodically on relevant products and services that we think may be of interest to you. Types of communication may include sales calls and sales visits, newsletter updates by emails such as flights with empty legs availability, passenger/cargo charter aircraft availability, travel deals, airline and hotel updates and offers, industry news, company news.

If you wish to adjust what information we use or choose to opt out, you can do so at any time; please contact us at data.protection@cttaviation.aero.

For how long will CTT Aviation keep my personal data?

We retain your personal data as long as it is necessary and relevant to our operations. Generally, we keep personal data in accordance with our internal retention procedures, which are determined in accordance with our regulatory obligations and good practice. In addition, we may retain personal data relating to previous booking activity to comply with national laws, prevent fraud, collect any fees owed, resolve disputes and/or troubleshoot problems, assist with any investigation and take other actions permitted or required by applicable national laws. After it is no longer necessary for us to retain your personal data, we anonymise part of the data for analytical purposes and dispose of the rest in a secure manner.

If you have any questions in relation to our retention periods, please contact us at dara.protection@cttaviation.aero.

Will CTT Aviation share my personal data with anyone else?

At times CTT Aviation may make certain personal data available to:

• Strategic partners that work with CTT Aviation to provide products and services, such as when we share your personal data with an airline in order to book your flight.

• With third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this policy.

• With third party consultants selected by CTT Aviation.

• To protect the rights, property or safety of CTT Aviation's customers for the purpose of fraud prevention, law enforcement or national security.

• Within CTT Aviation Limited.

CTT Aviation will never sell your personal data; your personal data will only be shared by CTT Aviation to provide or improve our products, services and advertising; it will not be shared with third parties for their marketing purposes.

What rights do I have in relation to my personal data?

Under certain circumstances, you have the below rights under Data Protection Legislation in relation to your personal data.

These include the right to:

• Request access to your personal data;

• Request correction of your personal data;

• Request erasure of your personal data;

• Object to processing of your personal data;

• Request restriction of processing your personal data;

• Request transfer of your personal data;

• Right to withdraw consent.

You can help ensure that your contact information and preferences are accurate, complete, and up to date, or make a request to exercise your rights at data.protection@cttaviation.aero.

Can I delete my data?

Yes, in some cases you will be able to do so. To make a deletion request please contact us at data.protection@cttaviation.aero.

Will CTT Aviation employees have access to my personal data?

Yes, part or all of your personal data we collect from you is shared where appropriately between our employees. To make sure your personal data is secured, we communicate our privacy and security guidelines to all CTT Aviation employees and strictly enforce privacy safeguards within CTT Aviation Limited.

How do I contact CTT Aviation?

For any queries or comments about this policy, or complaints of how we use your personal data, or updates, amendments and corrections to your records we hold, or for any other personal data request, please contact us by email to data.protection@cttaviation.aero.

By post:

CTT Aviation Limited
c/o Data Protection Department
P.O.Box 21386, CY-1507 Nicosia
Cyprus

You may also choose to contact the local data protection authority for further general clarifications and/or assistance on data protection related laws and regulations.

CTT Aviation Privacy Policy updates:

We will occasionally update this policy. In such case, we will post a notice of any material changes on our website following implementation of such changes and where appropriate, notify you using the contact details we hold for you for this purpose. We encourage you to periodically review this policy to be informed of how we use your information.
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Version Control
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Date: 04/27/2017 / Version 1 / Effective date
Date: 05/15/2018 / Version 2 / Reviewed and Updated
Date: 10/07/2018 / Version 3 / Reviewed and Updated
Date: 10/10/2018 / Version 4 / Reviewed and Updated