privacy policy

What is personal data?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

You are not required to provide the personal data that we have requested, 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.

EFE AIR’s data protection and privacy measures are governed by the (i) the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the GDPR or the Data Protection Act 1998 (“Data Protection Legislation”).

For the purposes of Data Protection Legislation, we EFE AIR collects personal data for customers such as contact details for the purpose of providing services or sending marketing communications, EFE AIR will be data controller. Where EFE AIR are provided with information from a third party or a customer relating to a passenger that we are arranging a charter for we are data processors and will only process such data in accordance with the customer’s instructions.

What personal data will EFE AIR collect about me?

  • When you use EFE AIR to purchase a service, purchase a product, contact us or complete an online form, we may collect a variety of information, including, but not limited to; your name, job title, mailing address, telephone number, email address, passport details, credit/debit card or bank details.
  • Where you use the website www.efeair.com (“Website”), we may collect technical data such as IP addresses and cookie ID. For more information around how we use cookies please see our Cookie Policy.

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 charter. We may also collect information from publically available sources.

How data used and what is EFE AIR’s basis for processing?

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that 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. Please contact EFE AIR if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer and verify your identity

(a) Identity
(b) Contact

Performance of a contract
Required by law

To process and deliver the services including:
(a) Manage payments, fees and charges
(c) contacting you and corresponding about the services we provide to you

(a) Identity
(b) Contact
(c) Financial
(d) Transaction

Performance of a contract
Necessary for our legitimate interests

To create, develop, offer, operate, deliver, and improve our products, services, content and personalised advertising.

(a) Identity
(b) Contact
(c) Transaction

Legitimate interests

For loss prevention and anti-fraud purposes, or national security matters

(a) Identity
(b) Contact
(c) Financial
(d) Transaction

Required by law

To respond to queries and enquiries

(a) Identity
(b) Contact

Legitimate interests

To keep you informed and may include communication by post, telephone, SMS or email, about us and our business partners’ content, products and services, events and special offers.

(a) Identity
(b) Contact

Consent
Legitimate Interests

When will EFE AIR contact me?

  • In relation to any service, activity or online content you have signed up for in order to ensure that EFE AIR can deliver, e.g. to ensure payment of your charter, offer other charter related services or upgrades, or to enquire whether you’re in need of our services.
  • In relation to any correspondence we receive from you or any comment or complaint you make about EFE AIR.
  • To invite you to participate in voluntary surveys about EFE AIR. To update you on any material changes to EFE AIR’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 include quarterly newsletter updates, Cloud magazine, EFE AIR Flyer or emails such as empty legs and passenger/cargo charter availabilities.

If you wish to adjust what information we use or choose to opt out, you can do so at any time by contacting us at [email protected]

How long will EFE AIR keep my personal data?

We retain your personal data as long as it is necessary and relevant for 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, 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 [email protected]

Will EFE AIR share my personal data with anyone else?

At times EFE AIR may make certain personal data available to:

  • strategic partners that work with EFE AIR 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 privacy policy.
  • with third party consultants selected by EFE AIR.
  • to protect the rights, property or safety of EFE AIR’s customers of for the purpose of fraud prevention, law enforcement or national security.
  • within EFE AIR.

EFE AIR will never sell your personal data and it will only be shared by EFE AIR 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 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 by contacting at [email protected]

Can I delete my data?

Yes in some cases you will be able to. To make a deletion request please contact at [email protected]

Will EFE AIR employees have access to my personal data?

To make sure your personal data is secure we communicate our privacy and security guidelines to all EFE AIR’s employees and strictly enforce privacy safeguards within EFE AIR. 

How do I contact EFE AIR?

For any queries or comments about this privacy policy or updates, amendments and corrections to your records, or for personal data requests, please contact [email protected] or by post to: Efe Havacılık Isl. A.S., Adalet Mah. Manas Bulv. No:39/0 K:31 35530 Bayraklı, Izmir, Turkey

If you wish to make a complaint about how we use your information, please contact [email protected]. You can also contact the local data protection authority.

Changes

We will occasionally update this privacy policy. We will post a notice of any material changes on our website prior to implementing the 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.