Introduction

Your privacy is very important to us at Speur. This privacy statement explains what information we receive from you, how it is used and how it is protected by Speur. This privacy statement and the procedures outlined herein comply with EU General Data Protection Regulation 2016/679 of April 27, 2016 (“GDPR”) and the relevant national legislation of the EU Member States implementing the GDPR (together the “Regulations”). For the purposes of this privacy statement “Speur” refers to Speur Aviation Ltd. Speur is considered a data controller under the Regulations.

Personal data

Speur collects and uses certain personal data that we have received either directly from you or indirectly e.g. via authorities or social security agencies. Typically, the personal data that Speur processes about you is your name, address/contact details (including telephone number and email address), banking and tax information, family status, nationality, date of birth, identity card or passport details, health information, psychometric tests, flying licenses and records, photos and information for any security checks. Within the sense of the Regulations, some of this data is regarded as special categories of personal data (e.g., health information).

Processing and purpose of use

Speur uses the personal data collected in order to properly provide requested recruitment, employment and placement services. Speur therefore collects, uses, administers, records, transfers and stores (“Processes”) personal data in order to efficiently perform the agreed services. Among other things, Speur processes personal data:

• To provide recruitment and/or related intermediary services to or for you and to facilitate the recruitment process;
• To allow you to apply for specific jobs or to subscribe to Speur ‘s job alerts so that Speur can notify you when relevant job vacancies arise. Note that Speur will not put you forward for any positions without your prior consent;
• To determine whether candidates meet the relevant skills and requirements to fulfil roles;
• To send you relevant updates and keep you informed where you have requested this;
• To improve website offerings to you including via the use of cookies;
• To perform, manage and/or maintain your employment or assignment relationship where applicable;
• For accounting and payment processing;
• To manage communication and transactions;
• To answer queries or complaints;
• To carry out analyses and research.

Speur also processes data to comply with applicable laws, e.g. export regulations, and generally for any other purpose that is necessary or related to the relationship between you and Speur.

These are collectively identified as “Purposes”.

All of this is considered necessary to protect the legitimate interests of Speur in accordance with the applicable legislation and to give proper consideration to your interests.

Speur processes your personal data only in accordance with the Regulations as applicable. Speur reserves the right to update and amend this privacy statement from time to time to the extent necessary in relation to our legitimate business interests such as amendments to the Regulations or updates to the services provided by Speur.

Disclosure of personal data

Speur may disclose your personal data to relevant members of the Speur group, prospective employers or airline clients and relevant third parties who perform related functions on Speur’s behalf. Any such disclosure will be only to the extent required for the Purposes and in accordance with the Regulations. Speur may disclose personal data in order to comply with legal requirements (e.g. in relation to legal claims, audits, investigations or consultations with competent authorities and social security agencies), to respond to demands or to protect the interests of individuals. Disclosures shall be made in accordance with the Regulations.

Speur may disclose your personal data to associated companies (e.g. affiliates), business and joint venture partners, as well as subcontractors at home and abroad. We will only disclose your personal data once it has been ensured that there is an adequate level of data protection and/or when we have signed a personal data processing agreement in accordance with the Regulations.

International data transfers

Speur operates in multiple jurisdictions some which are located outside the European Economic Area (EEA). Countries located outside the EEA may have data protection laws which do not provide the same level of protection for personal data as within the EEA. Speur transfers personal data outside the EEA only to the extent required for legitimate business purposes. Speur utilizes standard means under the Regulations to legitimize data transfers outside the EEA.

Protection of personal data

Speur regards your personal data as an asset that must be protected. We are committed to ensuring that your personal data is stored securely, only accessible by authorized persons and only transferred in accordance with this Privacy Statement and after the implementation of appropriate technical, security and organizational measures in compliance with the Regulations. Nonetheless there are third parties that may unlawfully try to access systems or intercept transmissions or communications containing personal data. Speur continuously uses its reasonable efforts in line with industry standards to protect personal data of customers but cannot absolutely guarantee that such unlawful actions will not occur. Speur has in place a data breach response plan.

Rights of data subjects

As a data subject whose personal data is processed by Speur for the purposes mentioned above, in applicable circumstances you have the right to access your personal data, request a copy of (e.g. for transfer to another IT environment), and request to update or correct, your personal data held by Speur. To the extent that the processing of personal data by Speur occurs on the basis of your consent you have the right to withdraw such consent. Such withdrawal will however not restrict Speur in continuing to process personal data if the justification therefore does not rely on your consent and is still necessary for any of the mentioned Purposes.  You also have the right to object to the processing of your personal data by Speur, to request that Speur restrict the processing of your personal data or request that Speur erase your personal data, all on the grounds mentioned in the Regulations.  Speur will respond to all such requests in accordance with the Regulations.

You have the right to lodge a complaint with the competent personal data protection authority if you believe that the processing of your personal data is not in compliance with Regulations, or if Speur does not respond to your requests in timely and/or appropriate manner, or if they are not answered at all.

Speur will only store your personal data for the duration necessary and in a manner permitted by the Regulations or other applicable laws.

Contact details and further information

If you have any questions in connection with this notification or the processing of personal data by Speur in general, or if you have questions or requests for information, you can contact Speur’s Data Protection Officer as follows:

Data Protection Officer

Address: Speur Aviation Ltd, IDS & Co, 38 Beanbsurn, Kilmarnock KA3 1RL, United Kingdom

Email: info@speuraviation.com

Consent

The Regulations may require that Speur ask for your specific consent if certain elements of the personal data that Speur processes qualify as special categories, namely medical data and criminal records. That consent needs to be given freely by way of an explicit, affirmative action and after you have been properly informed. In this respect, Speur provides this privacy statement to its candidates.

If you submit your personal data to Speur (irrespective of the manner or form), you agree to the terms of this privacy statement and to its processing in accordance with the Regulations.