Privacy Information Notice

Introduction 

NAVBLUE SAS (hereinafter “NAVBLUE” or “we” or “us”) appreciates your interest in its products, services and business lines, as well as your use of our website, portals and ”apps” and our digital platform Skywise (“Skywise”) together as (“Websites”). Your privacy is important to us and we want you to feel comfortable using our Websites and services. The protection of your privacy and Personal Data is an important concern to which we pay special attention throughout our business processes. Personal data collected during use of our Websites is processed by us according to the legal regulations valid for the countries in which the Websites are maintained. In addition, Airbus Binding Corporates Rules, to which NAVBLUE as a fully owned subsidiary completely adheres, protect customer and partner data throughout the entire organisation.

About Skywise and its Services

Skywise features a layer of data analytics and visualization tools that allow for the exploration and analysis of certain data, information, and material, including correlation between the elements of various data sets. Via Skywise, NAVBLUE provides online IT services, both standard and bespoke, to players in the aviation ecosystem—such as airlines, airline manufacturers, operators, lessors, MROs, and system/component suppliers (together: the “Customers”).

These services provide information for optimized decision-making regarding:

  • Maintenance, design, engineering, and safety.
  • Aircraft upgrades and flight operations.
  • Cost reductions and fleet planning.
  • Cabin, commercial operations, and support activities.

Access to Skywise is granted only to designated personnel of Customers (the “Users”) and to NAVBLUE’s employees, affiliates, subcontractors, representatives and business partners. In connection with the operation of Skywise, information originating from various sources, such as aircraft operations, configuration, and maintenance, is collected and processed by NAVBLUE, its affiliates, representatives and subcontractors (together “NAVBLUE”) as well as Customers, to the extent permitted by law.

Furthermore, a specific Skywise Support Portal is available to Users, enabling the creation of support tickets, escalation of inquiries, and access to the Skywise knowledge database.

Our Commitment to Data Protection

NAVBLUE is committed to protecting the rights of individuals in line with General Data Protection Regulation (reference EU2016/679) of the European Parliament (“GDPR”) as well as each applicable national personal data protection laws and regulations (collectively referred as “Data Protection Laws and Regulations”).

Note on External Links: Our Websites may include links to other websites or specific applications not necessarily covered by this Privacy Notice. In such events, we encourage you to carefully read the privacy policies of those specific platforms.

PRIVACY NOTICE INDEX

This Privacy Notice will inform you of the Personal Data we collect when you access and/or use the Websites, how we use and disclose your Personal Data, how you can control the use and disclosure of your Personal Data and how we protect your Personal Data.

  • What is Personal Data?
  • Which sources and what Personal Data do  we use?
  • What are the purposes of the processing of your Personal Data?
  • What is the basis for the processing of your Personal Data?
  • Who will receive your Personal Data?
  • Will your Personal Data be transferred to a third country outside the European Economic Area?
  • To which countries can NAVBLUE transfer Personal Data to?
  • For how long will your Personal Data be stored?
  • Security
  • What are your rights and how can you exercise them?
  • Are you  obliged to provide your Personal Data?
  • To what extent will decision-making be automated?
  • Will profiling take place?
  • How can I contact the responsible for processing my Personal Data?
  • Can I ask for assistance from the  competent authorities?
  • Additional Notice for Chinese Residents
  • What are cookies?
  • How can you disable or delete cookies?
  • Which cookies do we use on our Websites?
  • Which cookies do we use on Skywise?
  • Which cookies do we use on Skywise Support Portal?
  • Modification of the Privacy Notice

01. What is Personal Data ? 

Personal data is information that can be used to identify a person either directly or indirectly (“Personal Data”).. It includes information such as name, address, contact details,  address, financial data, identification number, location data or online identifier.

02. Which sources and what Personal Data do we use?

When you use the Websites, NAVBLUE will collect, use and process any Personal Data you provide to us (e.g. your name, date of birth, company name etc.) and any information generated as a result of using the Websites, such as IP address, the date, length of visit to the site, the pages you view etc.

The personal data we process in relation to Skywise services are as follows: 

  • directly from you by accessing to and using Skywise or that you include in your Skywise Support Portal profile:
    • Identification data : Name, Family Name, Nickname, professional email address, profile picture (optional),
    • Professional data : Job Title (optional), Department (optional), location (optional), Organisation, professional phone number (optional), tickets support number opened to support team, emails content and comments you shared with support.skywise@airbus.com, timezone (optional).
    • Account information: roles and permissions, settings and preferences, user name login, password, unique user nickname
    • IT data/ Digital activity: IP Address, MAC address, Unique ID, Application information, Application session data and logs (including access and activities)
  • indirectly for those personal data that we collect from other databases or data sources we have in NAVBLUE, such as Airbus OneLogin, profile or data provided to Airbus by your local administrator (UMC & UMS):
    • Identification data (first name, last name) 

 

03. What are the purposes of the processing of your Personal Data?

By accessing and using our Websites, NAVBLUE will collect and process Personal Data in accordance with this Privacy Notice and with the applicable Data Protection Laws and Regulations. Your Personal Data may be used for the following purposes:

  • Website Browsers/Platform Access and Administration: We use your Personal Data to provide access to products and services (including access to Skywise Support Portal, provide support service through ticketing solution and/or improve our Skywise products and services) and for administrative purposes, including to help us better understand how our customers access and use our Services ; to provide reports to prospective partners, service providers, regulators, and others; to implement and maintain security, anti-piracy, fraud prevention, and other services designed to protect our customers, partners and us; and to enforce our policies, directives and processes. .
  • Decision Making and Marketing: We can use your data to manage operational workflow and decision making. Additionally, to  the extent permitted by law or with your consent, we may use your Personal Data for marketing and promotional purposes, including communications through email or equivalent electronic means. For example, we use your Personal Data, such as your email address to send news and newsletters, special offers, promotions and competitions, or to otherwise contact you about the products and services or information we think will interest you.
  • Communication: We use your Personal Data to communicate with you, including responding to requests for assistance. We use your personal data to let you create support requests (tickets), assist you and follow their resolution. We can communicate with you in a variety of ways, including email and via your social media accounts if you have agreed, and/or text message.
  • Customer service: We use your Personal Data for customer service purposes, including to provide services to you, for technical support or other similar purposes and to establish and maintain customer accounts. We use your personal data to let you create support requests (tickets), assist you and follow their resolution
  • Research and development: We use your Personal Data for research and development purposes, including to improve our websites, applications, services, and customer experience and for other research and analytical purposes dedicated to improve our products, services, businesses, operations and processes.
  • Legal compliance: We use your Personal Data to comply with applicable legal obligations, including to respond to an authority or court order or discovery request.
  • Cybersecurity: To protect Information, Systems, and Networks. Skywise contains a restricted area of which access protection relies on your personal data
  • To protect us and others: Where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of policies, terms, and other policies.

We will use your personal data for the above purposes only. If we need to use your personal data for an unrelated purpose, we will notify you prior to further personal data processing and provide you with the relevant privacy information notice.

04. What is the basis for the processing of your Personal Data? 

As a responsible company, we need a lawful basis for collecting and/or processing your Personal Data. We generally rely on a number of grounds (reasons) for our business processing.

We process your Personal Data in accordance with the provisions set out in the GDPR and the relevant applicable Data Protection Laws and Regulations. The purposes for processing your Personal Data are:

  • To comply with contractual obligations: When you subscribe to specific products or services via our Websites, the primary purposes for processing your Personal Data are dictated by the nature of the requested service. NAVBLUE processes such data as necessary to fulfill our contractual obligations and deliver the specific features, functionality, and support associated with that service.
  • As a result of your consent: When you have consented to the processing of your Personal Data by us for certain services through the Websites, you can withdraw consent at any time by following the instructions provided in the application process or by contacting us at dataprotection@navblue.aero. For further information on the right of withdrawal, please see below Section “Am I obliged to provide my Personal Data?”
  • Within the scope of a legitimate interest: On occasion, NAVBLUE may process your Personal Data based on our legitimate interests, provided such interests are not overridden by your data protection rights. While such processing does not require your prior consent, we are committed to maintaining transparency by informing you of these activities and their underlying purposes.Examples of this are:
    • For the analysis and optimisation of our Websites and services;
    • For Skywise Users: for the performance of the Skywise Specific Terms of Use (“STU”) and related services agreement between NAVBLUE and your company, notably for providing you support on Skywise application and/or service that have been purchased by your company, when you have been designated as a User by your company.
    • For ensuring IT security (to detect security threats, frauds or other malicious or criminal activities)  and the IT operation of NAVBLUE;
    • For prevention and investigation of criminal acts.
    • For ensuring efficient communication and to keep you up-to-date on the latest information about our services, solution and/or business activities, participation in forums, events, marketing campaigns, market analysis or other promotional activities and for analysis and improving the quality of our services and communication with you.
    • For monitoring the compliance with our policies and standards.
  • On the basis of NAVBLUE legal obligations or in the public interest: NAVBLUE, as any other company, is subject to legal obligations and regulations. In some cases, the processing of your Personal Data will be necessary for NAVBLUE in order to fulfil these obligations.

05. Who will receive your Personal Data?

We may disclose your personal data to the following recipient(s) on a need to know basis and for the Purposes as outlined in this Privacy Notice:

  • NAVBLUE and its affiliates,
  • Authorised persons working for or on behalf of NAVBLUE and Airbus, including our agents, service providers and advisers (e.g., Third party service providers and advisers providing a variety of products and services we need such as IT maintenance and support, Personal Data storage analytics, procurement services and subcontractors of NAVBLUE, compliance and security services, etc.);
  • Other authorised third parties in connection with a reorganisation or sale of NAVBLUE businesses and/or assets;
  • Any Skywise Users accessing to Skywise Support Portal (limited to Nickname and profile picture if uploaded);
  • Law enforcement or government authorities where necessary to comply with applicable law or in response to any subpoenas, court orders, or to establish or exercise our legal rights or to defend against legal claims.

06. Will your Personal Data be transferred to a third country outside the European Economic Area (EEA)?

NAVBLUE processes your personal data mostly in the EEA. On occasion, Personal Data is transferred to relevant recipients as described in Section “Who will receive your Personal Data?”, on a need-to-know basis, including entities located outside  of the EEA. This transfer is subject to appropriate safeguards, and through the legal framework of our Binding Corporate Rules, that  can be found on our website www.airbus.com or through alternative contractual frameworks where a third party is engaged to help us provide web-services to you.

In addition, we may share some personal data to third parties as authorised recipient and engaged to help us notably for providing Support services to you and located outside the European Economic Area, subject to one of the following safeguards: (i) We will only transfer personal data to countries which are recognised as providing an adequate level of legal protection or where we are satisfied that arrangements are in place to protect your privacy rights, (ii) transfers to service providers and other third parties will be protected by contractual commitments (such as the European Commission-approved Standard Contractual Clauses) or other legally acceptable mechanisms that ensure an adequate level of protection, and (iii) any requests for personal data information we receive from law enforcement or regulators will be carefully checked before personal data is disclosed. If you have any questions regarding data transfers, please contact us (dataprotection@airbus.com) for further details. 

07. To which countries can NAVBLUE transfer Personal Data to?

Our Binding Corporate Rules allow us to transfer Personal Data within our international organisation, and they include a list of countries (below) which are structured to allow us to transfer personal information to the countries where we or our affiliates have a presence. For NAVBLUE, Canada, France and United Kingdom are where most of our processing of Personal Data takes place and below is a list of countries where Airbus, to which we may transfer your Personal Data according to this Privacy Policy, operates:

Algeria, Australia, Belgium, Brazil, Canada, Chile, China, Czech republic, Denmark, Egypt, Finland, France, French Guyana, Germany, Greece, Hong Kong, Hungary, India, Indonesia, Ireland, Italy, Japan, Kazakhstan, Libya, Malaysia, Mexico, Morocco, Netherlands, New Zealand, Norway, Oman, Philippines, Poland, Qatar, Romania, Russia, Saudi Arabia, Singapore, Slovakia, South Africa, South Korea, Spain, Sweden, Taiwan, Tanzania, Thailand, Tunisia, Turkey, United Kingdom, United States of America, Uruguay, United Arab Emirates, Vietnam.

08. For how long will your Personal Data be stored?

We process and store your Personal Data for as long as is required to meet our contractual and statutory obligations. If your Personal Data is no longer required for the performance of the contractual or statutory obligations, it will be erased on a regular basis unless further processing is necessary, for instance for preserving a particular evidence under the applicable Data Protection Laws and Regulations, or in the context of legal liabilities limitation.

For Skywise Services, we retain your personal data as long as reasonably necessary for the purposes for which it was collected:

  • For Skywise account management : twelve (12) months from the date of the last interaction with you or twelve (12) months after your company is notifying us about the request for account deactivation.
  • For Ticket Skywise Support portal: up to three (3) years after your last interaction with the Support team.
  • For Forum post: up to three (3) years without activity on the related post. 

In some circumstances, we may retain your personal data for a longer period of time than is needed for those purposes such as where we are required to do so in accordance with legal, regulatory, tax or accounting legal requirements. The retention conditions of your Personal Data is determined by applicable Laws and Regulation and/or by our procedures or processes adopted in accordance with applicable Laws and Regulation.

09. Security 

We use technical and organisational security measures in order to protect the Personal Data we have under our control against accidental or intentional manipulation, loss, destruction and against access by unauthorised persons. Our security procedures are continually enhanced as new technology becomes available.

What are your rights and how can you exercise them?

You may, at any time, exercise your personal data protection rights as listed below by contacting us by e-mail at the following address: dataprotection@navblue.aero or by writing to the following address: NAVBLUE SAS, 1 rond-point Maurice Bellonte, 31700 Blagnac Cedex, France :

  • Right to access/ obtain a report detailing the information held about you: You have the right to obtain NAVBLUE’s confirmation as to whether or not your Personal Data is being processed by NAVBLUE and if so, what specific data is being processed.
  • Right to correct Personal Data: You have the right to change any inaccurate Personal Data concerning you.
  • Right to be forgotten: In some cases, for instance, when the Personal Data is no longer necessary in relation to the purposes for which they were collected, you have the right for your Personal Data to be erased.
  • Right to stop the processing of your data: You have the right to restrict the processing of your Personal Data by NAVBLUE, for instance when the processing is unlawful and you oppose the erasure of your Personal Data. In such cases, your Personal Data will only be processed with your consent or for the exercise or defense of legal claims.
  • Right to data portability: Under some circumstances provided by law, you have the right to receive the Personal Data concerning you in a structured, commonly used and machine-readable format and/or transmit those Personal Data to another controller.
  • Right to object and to withdraw consent:  In some cases required by law, you may ask us to stop processing your Personal Data. Please  refer to the section below “Are you obliged to provide your  Personal Data?”

10. Are you obliged to provide your Personal Data?

You may at any time object to the processing of your Personal Data or where your consent is required, withdraw such consent by contacting us at dataprotection@navblue.aero. However, please note that if you withdraw your consent, you may not be able to access and use certain information, features or services of the Websites.

Your access in Skywise directly results from a commercial agreement signed between your company you worked with and NAVBLUE. Your personal data is therefore required to grant appropriate access right into Skywise. Any failure to provide the requested personal data may result in failure to fulfil our contractual/legal obligations agreed with your company and consequently you may not be able to access and use information, features or services of Skywise (including opening support tickets on Skywise products nor accessing to Skywise Support Portal)

To what extent will decision-making be automated?

As a matter of principle, we do not use fully automated decision-making processes. In the event that we should use such processes in individual cases, we will specifically inform you of this and of your associated rights if required by law.

Will profiling take place?

As a matter of principle, your Personal Data will not be processed automatically with the objective of evaluating certain personal aspects (profiling). In the event that we should process your Personal Data with the objective of conducting profiling we will inform you of this and of your associated rights if prescribed by law. 

How can I contact the responsible for processing my Personal Data?

If you are unhappy with the way in which your Personal Data has been processed or should you have questions regarding the processing of your Personal Data, you may refer in the first instance to our Group Data Protection Officer, who is available for enquiries, suggestions or complaints, at the following email address dataprotection@airbus.com or you can write to the addresses below : Airbus SA, Head of Data Protection, HAP, 1 rond-point Maurice Bellonte 31700 Blagnac Cedex, France.

Can I ask for assistance from the  competent authorities?

If you remain unsatisfied, then you have the right to apply directly to a Data Protection Supervisory Authority. Listed below are the main European countries where NAVBLUE operates and the relevant Supervisory Authority:

FRANCE : CNIL
UK : ICO

11. Additional Notice for Chinese Residents

By accessing and using Skywise, your personal information will be transferred to NAVBLUE located outside of China and will be processed in accordance with this privacy notice. We will comply with the applicable obligations and requirements under Chinese PIPL regulation in relation to sharing and cross-border transfers of personal information. 

WHAT ARE COOKIES?

Cookies are small files or amounts of information that may be downloaded on your device when you access and use our Websites. They allow the Website to recognise your device and store information about your preferences or past actions. We use cookies to record the preferences of our users, to enable us to optimize the design of our Websites. They ease navigation and increase the user-friendliness of websites and applications. Cookies also help us to identify the most popular sections of our Websites. This enables us to provide content that is more accurately suited to your needs, and, in doing so, improve our service. Cookies can be used to determine whether there has been any contact between us and your device in the past.

Personal details can be saved in cookies, provided that you have given your consent, for example, in order to facilitate a secured online access, without having  to enter your user ID and password again.

12. How can you disable or delete cookies? 

If you choose not to accept cookies, you can still visit our Websites. Most browsers automatically accept cookies. You can prevent cookies from being stored on your hard drive by setting your browser to not accept cookies. The exact instructions for this can be found in the manual for your browser. You can delete cookies already on your hard drive at any time. However, if you choose not to accept cookies it may result in a reduced availability of the services provided by our Websites.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

13. Which cookies do we use on our Websites?

Please find below a table with specific information for each cookie that we may use on our Website: