Cookies and privacy
What is a cookie?
A cookie is a small piece of information in a text file that is placed on your computer or mobile device when you visit a website. It allows the website owner to learn things about your behaviour on the website. Cookies can make websites easier and quicker to use by storing information about your preferences.
A cookie enables AviationJobs.Me to ‘remember’ you, either for the duration of your visit using a ‘session cookie’ or, for repeat visits using a ‘persistent cookie’. Cookies do lots of different jobs, like letting you navigate between pages efficiently, storing your preferences and generally improving your experience. Some of these things can make the interaction between you and the website faster and easier.
For more information about cookies and their use visit: www.cookiecentral.com
What information do we collect and how do we use it?
On AviationJobs.Me we only collect information about anonymous behavior. Nothing that will personally identify you. The majority of our cookies are ‘first party cookies’ which means we set them ourselves.
The cookies we use are harmless and not stored by third parties, or used to target advertising. They include:
- Behavior targeting cookies – these include Google analytics cookies to collect information about visitors behavior and gain insight into how you use our website, so that we can continually enhance the user experience.
- Geo-location cookies – so we know approximately, where people sharing information are located.
- Essential cookies – these are important to make the website function properly and aren’t involved in tracking.
The information may remain on your computer after the Internet session finishes and you leave the website. Most Internet browsers are pre-set to accept cookies.What if I don’t want cookies stored?
Some people find the idea of a website storing information on their computer or mobile device a bit intrusive. If preferred, it is possible to block some or all cookies or even to delete cookies but, you need to be aware that it may have a negative affect on the user experience of the website.
If you choose not to accept or to disable cookies that are set by AviationJobs.Me you may lose some features and functionality.
For a more comprehensive description of how to change cookie settings in different browsers visit: www.aboutcookies.org
This sets out the policies and practices of AVIATIONJOBS.ME in relation to the handling of personal data.
Statement of Notice
We respect privacy. AVIATIONJOBS.ME is committed to complying with all applicable personal data privacy laws and regulations.
When we collect and process personal data, we will ensure that there is legal basis for us to do so – including but not limited to issuing a Privacy Notice and/or fulfilling any other requirements as provided under all applicable laws.Kinds of Personal Data Collected
Statement of Practice
We collect personal data in five broad categories below (“Categories of Personal Data”):
Subscription Records which include records containing the personal information of the subscribers of our publications, job alert services and any other subscription based products or services.
Personnel Records which include job applicants and our employees’ personal information.
Other Operational Records which include the personal data of such data subjects involved in news gathering, security checks, cleaning, maintenance services, consultancy, technology, auditing, supplier, service provider, licensor, and other data subjects providing services in relation to all aspects of our operations.
Records collected on/from Web Servers which include but not limited to the email addresses, location data and other online identifiers such as IP addresses of such data subjects who visit our websites and platforms.
Main Purposes of Processing Collected Personal Data
Subscription Records are processed for the purposes of: (i) provision of subscription, job alert orders and any other subscription based products or services; (ii) billing and payment (if applicable); and (iii) conducting market research for statistical purposes.
Personnel Records are processed for the purposes of: (i) recruitment; and (ii) human resources management and employment related activities such as employment benefits, termination, performance appraisal and discipline.
Other Operational Records are processed for the purposes of facilitating the effective operation of our business such as news gathering, security, maintenance, consultancy, technology, auditing, supplier, service provider, licensor, and other data subjects providing services in relation to all aspects of our operations.
Records collected from Web Servers are kept for the purposes of: (i) providing and/or improving on the news, information and related services to you; and (ii) keeping abreast of and analysing the latest trends in the global media landscape.
Data Protection Principles
All processing of personal data shall be conducted according to the data protection principles as follows:
· Personal data must be processed lawfully, fairly and transparently.
· Personal data can only be collected for specific, explicit and legitimate purposes.
· Personal data must be relevant and limited to what is necessary for processing.
· Personal data must be accurate and kept up to date with every effort to erase or correct.
· Personal data must be kept in a form such that the data subject can only be identified if it is necessary for processing.
· Personal data must be processed in a manner that ensures the appropriate security.
We have also kept a data inventory and data flow process to determine various aspects of our data processing including:
· Business processes that use personal data.
· Purposes for collecting and/or using the personal data.
· Source of personal data.
· Processing activities.
· Any data transfer, and to whom.
· Any data access, correction or opt-out request.
Such data inventory would facilitate AVIATIONJOBS.ME in tracking its data and the related processing activities, and put us in a better position to comply with the relevant privacy and other laws and regulations.
Legal Basis of Data Processing
We ensure that there is legal basis for our processing of personal data.
Such legal basis includes: (i) legitimate business interests of AVIATIONJOBS.ME in processing personal data; (ii) if required by applicable laws or regulations, seeking your specific consent to process such personal data; and/or (iii) any other relevant basis under applicable laws and regulations.
AVIATIONJOBS.ME processes personal data under the “legitimate interests” legal basis which means that the processing of the personal data is necessary for the legitimate interest pursued by AVIATIONJOBS.ME except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which requires the protection of personal data.
Legitimate Interests Assessment
In each relevant situation, we assess: (i) what these legitimate interests are; (ii) whether it is necessary to process such data to attain the objective; and (iii) the relevant rights of the data subjects; and balance such rights against our interests in achieving such objective, and ensure that such rights do not override AVIATIONJOBS.ME’s legitimate interests before we conclude that AVIATIONJOBS.ME can process the personal data on the basis of legitimate interests.
Data Security Mechanisms
We have also implemented appropriate mechanisms, policies and procedures to protect the confidentiality and security of the personal data that we collect and process, as we respect the privacy and related rights of the data subjects relating to such personal data by reducing the risks or potential negative impact of processing including but not limited to data minimisation, de-identification, encryption, restricted access and all other technical security methods and efforts to protect personal data. Such protection of the privacy and related rights of the data subjects would enable AVIATIONJOBS.ME in processing personal data under the legitimate interest legal basis.
Having conducted the above assessment thoroughly, AVIATIONJOBS.ME concludes that it is collecting and processing personal data under legitimate interest as follows:
a. Serving Customer and Operational Needs
The main purposes for processing the Categories of Personal Data have been set out above. There are legitimate interests for AVIATIONJOBS.ME to process the same because all such purposes are essential to AVIATIONJOBS.ME serving its customers and its operational needs as a corporation and a media organisation.
A corporation like AVIATIONJOBS.ME needs employees to work for its business (and hence Personnel Records) and service providers to keep it running (and therefore Other Operational Records).
A media organisation such as AVIATIONJOBS.ME needs the personal data of its newspaper subscribers, event attendees and website visitors so as to be able to have relevant and timely provision of information and/or other services (and thereby subscription and event attendee records together with records collected on web servers).
b. Market Analysis
We analyse the Public View Data to: (i) gain insightful knowledge of the reading habits, preferences or tastes of the public; and (ii) conduct market segmentation and related studies.
Such analysis is necessary because it enhances AVIATIONJOBS.ME’s capability to carry out its duty to inform and contribute to the welfare of our international community as a global digital news organisation. The knowledge and study results from such analysis would enable AVIATIONJOBS.ME to fulfil its duty to inform more effectively by providing more relevant and timely information, products, and services to the public.
This would benefit not just AVIATIONJOBS.ME – but also the international society as a whole. Our world is becoming more globalised and inter-connected. What is happening in one part of the world could have instant, far-reaching ramifications on others.
c. Direct Marketing
AVIATIONJOBS.ME also uses personal data for direct marketing purposes as part of its legitimate interests unless the data subject explicitly objects or such is otherwise specifically prohibited under applicable laws.
How you interact with AVIATIONJOBS.ME’s products or services (such as news, media, advertising, events, etc.) may indicate your consumption preferences or inclinations. Based on such preferences or inclinations, we use such personal data to conduct direct marketing in respect of various goods and/or services offered by AVIATIONJOBS.ME, its affiliates or business partners including but not limited to:
· Insurance, banking and financial products and services;
· Products and services relating to airlines, hotel, health club, travel and hospitality;
· Beauty, skin care, health, medical devices, biotechnology, pharmacy and wellness;
· Eyewear and optical, fashion, sports, sports events, sports clubs, watches and jewellery, flower shop, stationery, toys, department stores and shopping malls;
· IT, electronic goods and electrical appliances, mobile phones and accessories, telecommunications and media products and services;
· Food and beverages and restaurants;
· Design, automotive, education, antique and auction, arts and gallery, boat and accessories, services for children, real property, construction, furniture and household items, interior design, consular services, trade or industry associations, non-governmental organisations, government services, energy, events and exhibitions, personal announcements, pets and accessories, post and courier services, public utilities, professional services, career, security services, shopping, transportation and logistics.
We note that given the global spread of our businesses, there may be cases where our use of personal data for direct marketing is governed by the laws of certain jurisdictions (such as Hong Kong) which require the consent of the data subject(s) in this regard. Please refer to the “Consent” section immediately below for more information.Consent
Where applicable legal requirement demands specific consent must be obtained before we can process personal data including conducting direct marketing, we will ensure that such specific consent will be obtained as follows:Rights of the Data subjects
A. the consent has to be clear, explicit and specific;
B. data subject is fully aware of the types of the personal data that we intend to use; and the purposes of such usage (such as improving our services to the data subject or direct marketing); and
C. the name/identity of the transferee (if we ever intend to transfer your data) and how the transferee shall use your personal data.
AVIATIONJOBS.ME respects that data subjects have the following rights about the data processing, and the data which is recorded about them:Outsourcing Arrangements
1. To request for access regarding the nature of information held and to whom it has been disclosed.
2. To prevent processing likely to cause damage or distress.
3. To prevent processing for purposes of direct marketing.
4. To be informed about the mechanics of automated decision-making process which will significantly affect them.
5. Not to have significant decisions that will affect them taken solely by automated process.
6. To take action to rectify, block and erase including the right to be forgotten or destroy inaccurate data.
7. To request the supervisory authority (eg. a privacy commissioner or a data protection officer) to assess whether any provision of the relevant privacy and other laws has been violated.
8. To have personal data provided to them in a structured, commonly used and machine-readable format, and the right to have such data transmitted to another data controller.
9. To object to any automated profiling which is occurring.
AVIATIONJOBS.ME has been using internal resources to develop and maintain its IT systems. Occasionally AVIATIONJOBS.ME engages third-party vendors to provide certain services relating to its IT systems. Such vendor does not have access to the personal data stored under usual circumstances.
In the exceptional case where such vendor has such access, AVIATIONJOBS.ME uses reasonable measures to ensure that: (i) such vendor is contractually bound to keep such personal data confidential and adopt appropriate means to prevent any unauthorised access, use, loss, retention, modification, transfer or otherwise.Data Retention
We implement data retention policies and records to ensure that personal data will not be kept longer than is necessary in relation to the purpose for which they were collected.
Different retention periods apply to various types of personal data that we hold, depending on the respective data collection/usage purpose and relevant legal requirements.Data Protection Officer
We have appointed a Data Protection Officer whose responsibilities include the following:Data Access / Correction and Other Inquiries
1. To inform and advise AVIATIONJOBS.ME and its employees of their obligations pursuant to the applicable privacy and other laws and regulations (collectively “Privacy Laws”);
2. To monitor AVIATIONJOBS.ME’s compliance with such Privacy Laws;
3. To co-operate with the supervisory authority (eg. privacy commissioner or equivalent bodies); and
4. To act as the point of contact for the supervisory authority on issues regarding the data processing and related matters.
You have the right to know whether AVIATIONJOBS.ME holds your personal data, access the data and/or correct any inaccuracies of such data. You also have the right to make reasonable inquiries about AVIATIONJOBS.ME’s personal data policies and procedures. You have the right to object to the processing of your personal data or withdraw your consent (if applicable) at any time. Please note however that if you object to the processing of your personal data, it may affect AVIATIONJOBS.ME’s ability to provide the services that you required to you or may affect the quality of such services. If you withdraw your consent (if applicable), AviationJobs.Me will stop providing such services to you which applicable laws require specific consent.
All of the above requests should be made in writing to our Data Protection Officer at email@example.com