Personal data and cookies

 

1.Introduction

In the context of the commercial activity as air transport and its derived commercial activities, the VallJet company is required to process data about you. For example, by browsing our websites as well as our numerical and mobile apps, by filling out a registration form to a newsletter and by clicking on an ad, you transmit pieces of information to us, some of which are used to identify you (called “personal data”). The following Cookie Policy gives details on how we collect and process your personal data. We invite you to read it carefully. Important We use your personal data only in the cases foreseen by the current regulations: To enforce a contract we have signed with you, and/or To respect a legal obligation, and/or We have your consent to use your data, and/or There is a legitimate interest to use your data. The legitimate interest is a set of commercial or business reasons which justify the usage of your data by VallJet. For all inquiries related to this document, you can contact the VallJet publication director (jvalli@valljet.com).  

2.Who is in charge of the processes mentioned in this document?

The supervisor of aforementioned processes is the VallJet company, simplified joint-stock company (sole partner company) with a capital that runs to 1,800,000 euros, registered on the Trade and Companies Registry of Nantes under the number 501 457 907 of which the head office is located 257 rue Georges Clemenceau 44150 Ancenis and represented by its CEO, Jean Valli. The VallJet website is an entity of the VallJet company.

3-What data do we collect on you and in which circumstances do we collect them?

3.1 Data you directly give us

On the occasion of different contacts we have with you, you can be required to communicated pieces of information that concerns you. They are notably collected when you subscribed to a newsletter, when you create an account on our websites and apps or to access any offer or service. They are generally your email address and any other information you want us to know.

3.2 Data we collect during a business relationship

Data we collect during our business relationship are the following: Your participation in promotional offers, contests or events; Requests to our sales representative or incidents you have signalled, for example concerning the non-execution of our services.

3.3 Data we automatically collect

During each of your visit on our websites and apps, we collect data concerning your connection and browsing. Different technologies can be used to collect data. The main one is the cookie. .Data collected via cookies A Cookie is a text file that’s left when you visit a website, an app or an online ad, it is then stocked in a specified space of your computer or phone’s hard drive. The cookies are handled by your web browser and only the cookie emitter can decided to read or modify the information contained in it. A cookie has a limited lifespan. Its submission and stockage on your terminal is done in compliance with the current legislation and with the choices you have expressed which you can modify at any moment, in the conditions defined in article 9 below. A cookie does not identify you personally. It allows its emitter to recognise your terminal an to collect a certain number of information concerning the browsing done from this terminal. Cookies have several functions, such as allowing you to efficiently browse a website or an app, remember your choices, goods and services you wish to purchase, to propose you pertinent ads depending on your interests. You will find more information on cookies on the following pages: www.cnil.fr www.allaboutcookies.org www.youronlinechoices.eu Depending on your choices, cookies left by the VallJet website give us access to the following information: Identifying the used equipment (IP address, Android user ID, Apple user ID, etc.), Type and version of your web browser (Microsoft Internet Explorer, Apple Safari, Mozilla Firefox, Google Chrome, etc.), Date and hour of your connection to our services, Address of the Internet page of origin (“refer”), Navigation data on our services, viewed contained. Data collected by standard Internet technologies We also are susceptible to use standard internet technologies, such as scripts, pixels and redirections. Scripts (sometimes called tags), written in javascript language, are programs which run in your browser and do various actions, for example, sending a piece of information to our servers. Scripts are also able to create pixels. Pixels (sometimes called transparent GIFs, clear GIFs or web-bugs) are lines of code which allow the display of a graphic image (generally invisible) on a web page or in an email. Redirections make a web page available with several URLs. When a browser open a redirection URL, a page with a different URL is opened. The purpose of these technologies is to enhance your experience on our site and applications, including providing you with content customized to your interests. For example, when a user clicks on the share button on an article, a script creates a pixel that counts the share. In this way, we can see the total number of times an article has been shared, and we can rank the most shared articles. These technologies give us access to the following data: Data concerning your usage of our websites and apps; Data concerning the presence of cookies on your terminal, about the date and hour you viewed our page, and a description of the page where the web tag is put; Data on whether you’ve read the emails we sent you and on which links you’ve clicked in those emails. Our sites and applications may also include third-party scripts, pixels and redirects. These technologies allow third party service providers to collect certain information such as your browser type, and the web page that redirected you to our websites. These third party service providers process the information they collect for the purposes of auditing, research, and to report information about our sites and applications and the advertisements viewed on them. We do not share your identifying information with these third parties in connection with their use of these technologies. Data provided by mobile devices Some mobile devices, depending on the functionalities activated during the download of our apps (by example “push” or “geo-tracking”), send data such as: phone model, the operating system version, name and version of the app used. These data, necessary to the good run of the mobile apps we edit, are automatically managed by our servers and those of some of our partners (notably AT Internet and SmartAdserver) so we can provide a service and ads adapted to the technical characteristics of your device and measure the audience of our app. Furthermore, if you accept this functionality when downloading our apps, we will be able to identify the physical location of your device (geo-tracking), especially to inform you of contents and offers we think will suit your expectations or your interests or to improve your experience on our mobile apps. In compliance with the current law, geo-tracking functions can be deactivated at any moment in the parameters of your device.

 

3.4 Data we may assume

We are likely to establish, by reconciling the data we have about you with general and anonymous statistical information, assumptions about the content and services that may meet your tastes or uses. Example: If, according to statistical data, a majority of people aged between 30 and 50, living in Paris and interested in flights to Nice, are also interested in a type of aircraft, and you are one of our Parisian customers, aged 42, who regularly consult reservation requests on our site, we will assume that you are also interested in flights to Marseille and we will be able to show you during navigation on our site an advertisement to go to this city.  

3.5 Data relative to minors

Generally, our products and services are for adults who can subscribe to contractual obligations. The underage user has to get the consent of their legal guardian before communicating their personal data. To subscribe on our websites and some of our online services (newsletter), you have to be at least 16. An internet user aged 18 at the moment of the publication or the creation of an online account benefits from a specific right to the deletion of data about them. For any information, please contact the website and app manager by email: charter@valljet.com  

3.6 Data related to other persons

Before offering a flight or any other product or service we offer to an outsider, you have to be sure that the person in question accepts to give their personal data, especially their home address.  

3.7 Exclusion of any sensitive information

VallJet does not collect sensitive data about you. Data considered as sensitive are: race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, health or sexual orientation. If such data were to be given to us in any way, they would be deleted. To what extent do we use your data? The following article indicates the main purposes for which we use the data mentioned in article 3.  

4.1 Operations necessary for the supply of products or services

Managing subscriptions to our newsletters, website, applications and/or email alerts; Customer relations: provision of a sales representative accessible by email for any question or complaint; Carrying out satisfaction surveys; Sending information on the modification or evolution of our services; Management of the exercise of your rights to your personal data, under the conditions set out in Article 9; Verification of compliance with applicable legislation, our contracts and general conditions of use.  

4.2 Operations of marketing or commercial prospection relating to publications, products and services of the Valljet.com website and the VallJet group.

Updating, enhancing and deduplicating our personal information in a dedicated database of the VallJet group; Sending information about our civil aviation group, its publications and its activity; Sending marketing, advertising and promotional offers relating to our products and services by post, email, mobile notifications, social media or any other means; Personalised loyalty or commercial prospecting actions; Collection of customer opinions; Preparation of commercial statistics.  

4.3 Operations linked to business partners

Sharing, exchanging or renting files with business partners in compliance with the regulations in force and security requirements; Sending marketing, advertising and promotional messages relating to the products and services of partners by post mail, email, mobile notifications, social media or any other medium; Setting up contests or other promotional or event operations with business partners.  

4.4 Purposes associated with the submission of cookies on your browser.

Operation and optimization of the navigation on our sites and applications. Adapting the presentation of our sites and applications to the display preferences of your terminal (language used, display resolution, operating system, etc.) during your visits, depending on the hardware and viewing or reading software that your terminal includes; Storage of information relating to a form that you have filled out on our site (registration or access to your account) or to products, services or information that you have chosen on our site (service subscribed to, content consulted, purchase made, etc.); Automatic connection to reserved or personal areas of our site, such as your account, thanks to identifiers or data that you have previously entrusted to us; Provision of sharing tools on social networks; Management of our platforms and internal technical operations for problem solving, data analysis, testing, research, analysis, studies and surveys; Implementation of security measures; Quality measures to ensure that the display of our content is suitable for your device. Attendance and audience measurement Establishment of statistics and volumes of frequentation and use of the various elements making up our site (sections and content visited, paths) in order to improve the interest and ergonomics of our services; Accounting of the total number of advertisements displayed by us on our advertising spaces, classification and statistics; Audience analysis based on the results of advertising campaigns; Determination of areas of interest and behaviour; Improving customer/user knowledge for personalization purposes. Personalization of the ads on our sites and applications; Adapt the advertising spaces to the display preferences of your terminal (identification of advertisements, establishment of statistics and volumes of frequentation and use of the various elements composing our site: sections and contents visited, paths) in order to improve the interest and ergonomics of our services; Adapt the advertisements displayed on your device when you browse our sites and applications to its technical characteristics (1), to your previous browsing choices (2), to your centres of interest and uses (3), to the data you have previously communicated to us (4), and, where applicable, to the geographical location data of your device (5); Recognize you to display personalized advertisements on social networks ; Measure the effectiveness of our advertising campaigns and service proposals.

 

5. How long do we keep your data?

Your personal data are kept for a duration conformable to the legal provisions or proportional to the purposes for which they have been saved. Some storage life answer the legitimate interest of the VallJet website such as specified in the introduction. The storage life vary depending on various thing: if we have an ongoing contractual relation (active client), if we have had a contractual relationship with you in the past (inactive client) or if we never had any relationship of this kind (potential client). Data linked to your browsing on our online services that were collected by authorized cookies have a specific storage life. The main storage lives of your data are the following: At all events, we constantly review the data we detain. When their storage is no longer justified by legal requirements, commercial or linked to the management of your client account, or if you have decided to use your right to modify or delete, we will delete the data in a secure way. Data related to a potential client Data categories: set of data Purposes: constitution and management of potential clients files Storage life: 3 years starting from the data collection or the last contact from the potential client.   Data relative to an active client Data categories: set of data Purposes: Management of the client account Storage life: For the whole duration of the commercial relationship   Data relative to an inactive client Data categories: Identification and contact data – Newsletter subscribers Purposes: Sending information on the evolution of our publications and our offers. Storage life: 3 years maximum from the date of unsubscription or the last contact from the customer.   Data generated by cookies Data categories: Data related to your navigation on our online services Purposes: Operation and optimization of services. Attendance measurement. Personalization of content and advertising. Storage life: 13 months maximum.   Assumed data Data categories: Data related to your assumed uses and interests. Purposes: Sending information and offers assumed to fit your uses and interests. Storage life: Yearly update.

 

6. Who is prone to have access to your data?

6.1 Access to data within the VallJet group.

Are prone to have access to some data: Employees in the administrative, accounting and controlling, IT, community management and marketing & sales departments. The VallJet Group’s advertising agency. Access to your data is based on individual and limited access authorization. Staff who can access personal data are subject to an obligation of confidentiality (through a nominal and personal commitment to confidentiality).  

6.2 Sharing of data

Are also prone to have access to some of your data:   Subcontractors They provide services on our behalf, in particular: Management of telephone calls, sending of postal or digital letters Personalization of mobile site and application content Carrying out maintenance operations and technical developments Collection of customer reviews Providing analytical solutions or statistics for audience measurement Our subcontractors have access to your data on the basis of signed contracts that specify their obligations to protect their security or confidentiality of the data.   Social media The usage of social media to interact with our sites and apps (especially the share button of Facebook, twitter and Google+) is in fact prone to trigger exchanges of data between the website or the VallJet app and its social media. For example, if you are connected on Facebook and you visit a page on www.valljet.com, Facebook may collect this information. Similarly, if you view an article on www.valljet.com and click on the “tweet” button, Twitter will collect this information. We therefore invite you to consult the personal data management policies of the various social media to find out about the collections and processing they carry out on your data.   Business partners They promote products or services on their own behalf or on behalf of advertisers. We draw your attention to the fact that if you decide to subscribe to the products or services of our business partners and you let them access some of your information, especially by logging on their sites or applications, their privacy policies and their cookie repositories are opposable to you. We have no control over the collection or processing of your data implemented by our business partners on their own platform.   Police, judicial or administrative authorities When we are legally obliged to do so or in order to guarantee the rights, property and safety of the VallJet Group.  

7. Is you data transferred outside of the European Union?

We store your personal data in the European Union. In all cases, we ensure that the processing is carried out in accordance with this privacy policy and that it is governed by the standard contractual clauses of the European Commission which ensure an adequate level of protection of privacy and fundamental rights of individuals.  

8. How is your data protected?

As data controller, we implement appropriate technical and organisational measures in accordance with the applicable legal provisions to protect your personal data against alteration, accidental or unlawful loss, unauthorised use, disclosure or access, and in particular : The appointment of a data protection officer; The establishment of a unit dedicated to information systems security; Raising awareness of the confidentiality requirements of our employees who need to access your personal data; Securing access to our premises and computer platforms; The implementation of a general company IT security policy: The high level of data protection requirements when selecting our subcontractors and partners.  

9. What are your rights? 9.1 Your rights in terms of personal data access

You have the right to access your personal data and to request that they be corrected, completed or updated. You may also request the deletion of your data or object to their processing, provided that you can justify a legitimate reason. You may request to exercise your right to portability of your data, for example, the right to receive the personal data you have provided us with in a structured, commonly used format and the right to pass this data on to another data controller. Finally, you can formulate guidelines for the storage, deletion and communication of your personal data after your death. You can exercise your rights by contacting the VallJet Group’s personal data protection officer at the following address: VallJet. Le Bourget Airport, rue de Prague 95500 Bonneuil en France, or by email: charter@valljet.com. Before responding to your request, we may verify your identity and/or ask you to provide us with further information to respond to your request. We will endeavour to respond to your request within a reasonable time and, in any event, within the time limits set by law. In the event of an unsatisfactory response, you may lodge a complaint with the Commission Nationale de l’Informatique et des Libertés (CNIL – France).  

9.2 Your rights to oppose commercial solicitations

We may use your contact information in connection with commercial solicitations in accordance with applicable law and the terms of this Privacy Policy. You may object to these solicitations at any time, in a manner that depends on the communication channel we use to send them to you.   Commercial solicitations by electronic means (email) : We comply with the rules of article L.34-5 of the French Postal and Electronic Communications Code, which provides for the prior and express collection of your consent for the sending of commercial prospecting by electronic means (e-mail, push notifications or SMS). However, your express prior consent is not required if you are already a VallJet customer and the purpose of our solicitation is to offer you products or services similar to those we already provide. In any case, you always have the possibility to object to the receipt of such solicitations by clicking on the unsubscribe link provided in each email.   Commercial solicitations on mobile applications The first time you open VallJet mobile applications on your smartphone or tablet, you can give authorization to receive mobile or “push” notifications. These notifications allow us to send you editorial content (info alert, new devices, empty flight), and may, from time to time, be used for commercial offers. You can deactivate these notifications at any time in the settings of your Smartphone.  

9.3 Your rights to accept cookie management

The saving of a cookie on your browser device is subject to your will. You can at any time modify your choices regarding the acceptance or refusal of cookies placed on your terminal, either on your browser or online with the various operators. In order to manage cookies as closely as possible to your wishes, we invite you to configure your browser taking into account the purpose of the cookies. How to apply your choice? A. Make your choice on your browser You can set your browser software either to offer you the possibility of accepting or refusing cookies from time to time, before a cookie is likely to be stored, or to systematically accept or refuse the storage of a cookie on your device. We would like to alert you to the fact that any setting on your browser software concerning the refusal of technical and functional cookies will be likely to alter your comfort of navigation on our websites, or even prevent the use of some of our services requiring the use of these same cookies. Where applicable, we decline all responsibility for the consequences linked to the impaired functioning of our websites and services resulting from the impossibility for us to record or consult the cookies necessary for their functioning and which you would have refused or deleted. For the management of cookies and your choices, the configuration of each browser is different. It is described in the help menu of your browser, which will enable you to find out how to change your wishes regarding cookies. Microsoft Internet Explorer http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies Microsoft Edge https://privacy.microsoft.com/fr-fr/windows-10-microsoft-edge-and-privacy Apple Safari http://docs.info.apple.com/article.htmi?path=Safari/3.0/fr/9277.html Google Chrome http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647 Mozilla Firefox http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies Opera http://help.opera.com/Windows/10.20/fr/cookies.html Cookies Flash of Adobe Flash Player Adobe Flash Player is a computer application that allows the rapid development of dynamic content using the Flash computer language. Flash (and similar applications) stores the parameters, preferences and use of these contents thanks to a technology similar to cookies. However, Adobe Flash Player manages this information and your choices through an interface different from that provided by your browser software. To the extent that your device is likely to view content developed using Flash, we invite you to access your Flash cookie management tools directly from the http://www.adobe.com/fr website. “Do not track” You can also parameterize your browser so that it will send a conde indicating to websites that you do not wish to be followed (“do not track” option). Microsoft Internet Explorer http://windows.microsoft.com/fr-fr/internet-explorer/use-tracking-protection#ie=ie-11 Microsoft Edge https://privacy.microsoft.com/fr-fr/windows-10-microsoft-edge-and-privacy Apple Safari http://support.apple.com/kb/PH11952 Google Chrome https://support.google.com/chrome/answer/114836? Mozilla Firefox https://support.mozilla.org/fr/kb/comment-activer-option-ne-pas-pister Opera http://help.opera.com/Windows/12.10/fr/notrack.htmil   B. Make your choice online For audience measurement cookies and analytics cookies Analytics cookies allow us to obtain anonymous statistics on the use of our site in order to optimise it and detect possible malfunctions. They are deposited on our sites and applications by the companies Google Analytics, ATInternet (XiTi), Parse.ly, Weborama. If you do not want our sites and services to store cookies in your browser for audience measurement purposes, you can click on the following links for further information: Cookies Google Analytics https://tools.google.com/dlpage/gaoptout Cookies ATInternet https://www.atinternet.com/societe/protection-des-donnees/mettre-a-jour-mes-preferences/ Cookies Parse.ly https://www.parse.ly/privacy-policy/ Cookie Weborama https://weborama.com/fr/respect-de-la-vie-privee For social media cookies We use the “share” buttons on Facebook, Twitter, Pinterest, Instagram, Google+ and Linkedin. To manage your data on Facebook: https://www.facebook.com/help/cookies To manage your data on Twitter: https://support.twitter.com/articles/20170518-utilisation-des-cookies-et-des-technologies-similaires-par-twitter To manage your data on Pinterest https://policy.pinterest.com/fr/cookies To manage your data on Google + https://policies.google.com/privacy?hl=fr#infochoices To manage your data on Linkedin https://www.linkedin.com/legal/cookie-policy To manage your data on Instagram (waiting for the link) Deactivating those cookies prevents all interactions with social media.   For advertising cookies We use platforms like Doubleclick and SmartAdverser to handle the displaying of ads on our websites. To manage the cookies of Doubleclick https://www.google.com/setting/u/0/ads/authenticated To manage the cookies of SmartAdverser https://www.smartadverser.fr/privacy-policy You also have the possibility to go on http://youronlinechoices.com, proposed by digital advertising professionals grouped within the European association EDAA (European Digital Advertising Alliance) and managed in France by the Interactive Advertising Bureau France. This European platform is shared by hundreds of Internet advertising professionals and provides a centralized interface allowing you to express your refusal or acceptance of the cookies used by these companies to adapt to your browsing information the advertisements likely to be displayed on your device: http://www.youronlinechoices.com/fr/controler-ses-cookies/ Finally, some cookies are deposited by third party service providers for the purpose of personalised advertising. You can also click on the following links to learn more about their practices and exercise your choices: Cookies Rubicon http://www.rubiconproject.com/privacy/consumer-online-profile-and-opt-out/ Cookies DoubleClick for Publisher https://www.google.com/setting/u/0/ads/authenticated Cookies AppNexus http://appnexus.com/en/company/platform-privacy-policy-fr Cookie weborama https://weborama.com/fr/respect-de-la-vie-privee/ Cookie Index Exchange https://www.indexexchange.com/