Privacy Policy

1. INTRODUCTION

Gloucestershire Airport respects your privacy and is committed to protecting your personal data.

This Privacy Policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.

2. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy aims to give you information on how we collect and processes your personal data through your interaction with us, including any data you may provide through the website, using our services, or when you sign up to receive our marketing material.

We do not knowingly collect data relating to children.

It is important that you read this Privacy Policy together with any other privacy notice on our website from time to time so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

CONTROLLER

Gloucestershire Airport Limited is the ‘controller’ and therefore responsible for your personal data (collectively referred to as, “we”, “us” or “our” in this Privacy Policy).

We have appointed a Data Protection Lead (DPL) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us at briefing@gloucestershireairport.co.uk and state that your query is for the attention of the DPL. 

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact our DPL in the following ways:

Name of legal entity: Gloucestershire Airport Limited. Registration number 2774189.
Gloucestershire Airport is registered and operates in the United Kingdom.

Postal address: Gloucestershire Airport Limited, Staverton, Cheltenham, Gloucestershire GL51 6SR

Email address: briefing@gloucestershireairport.co.uk

You can also contact us through our ‘Contact Us’ page on our website.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (https://ico.org.uk). In the UK, please read: https://ico.org.uk/for-the-public/raising-concerns/ for details of how to do this. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We may need to update this Privacy Policy at any time and without notice and where we do this, we will notify you via our website and/or emailing our customers. This Privacy Policy was last updated on 24 February 2023.

It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

Our website includes links to third-party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy Policy of every website you visit.

3. THE DATA WE COLLECT ABOUT YOU

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).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, aircraft numbers, ICATO Codes and IATA numbers, and passport numbers.
• Contact Data means the data we use to contact you including your billing address, delivery address, email address and telephone number.
• Financial Data means the data we use to process your payments for the services we provide, including your bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of what you have purchased from us.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website and services
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, where you do not provide suitable and current contact details). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

4. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you, including through:

• Direct interactions. You may give us your Identity Data, Contact Data, Financial Data and Marketing and Communications Data by using our website, filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you
  • purchase a product or service;
  • open an account;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs]and other similar technologies. Please see our Cookie Policy for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  • analytics providers such as Google based outside the UK;
  • search information providers such as Google based outside the UK.
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.

5. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or social media messaging. You have the right to withdraw consent to marketing at any time by contacting us directly.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, a description of all the ways we may 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 data. Please contact us 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 below.

Purpose/Activity

To register you as a new customer
Type of data: (a) Identity; (b) Contact
Lawful basis for processing: Performance of a contract with you.

To process your order, including:
1. managing payments, fees and charges; and
2. managing your queries through our Customer Service team – this may include recording calls to our teams.
Type of data: (a) Identity; (b) Contact; (c) Financial; (d) Transaction; (e) Marketing and Communications
Lawful basis for processing including basis of legitimate interest: Performance of a contract with you. We may also use some of the data related to your queries for our legitimate interests of ensuring our customer service quality standards are met.

To collect and recover money owed to us in respect of purchases or using our services 
Type of data: (a) Identity; (b) Contact; (c) Financial
Lawful basis for processing including basis of legitimate interest:  Necessary for our legitimate interests (to recover debts due to us).

To manage our relationship with you which will include: notifying you about changes to our terms or privacy policy; and asking you to leave a review or take a survey.

Type of data: (a) Identity; (b) Contact; (c) Profile; (d) Marketing and Communications
Lawful basis for processing including basis of legitimate interest: Performance of a contracts with you. Necessary to comply with a legal obligation. Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services.

To carry out fraud assessments
Type of data: (a) Identity; (b) Contact; (c) Financial
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests of ensuring payments are not fraudulent.

To comply with our legal obligations as an airport.

Type of data: (a) Identity; (b) Contact
Lawful basis for processing: Necessary to comply with a legal obligation. Performance of a contract with you.

To help us improve our offering to our customers
Type of data: (a) Identity; (b) Contact; (c) Financial; (d) Marketing and Communications
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to study how customers use our products/services, to improve our offering to our customers, to develop them and grow our business).

To administer and protect our business (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data: (a) Identity; (b) Contact; (c) Technical
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud).

To deliver relevant marketing material to you and measure or understand the effectiveness of the advertising we serve to you
Type of data: (a) Identity; (b) Contact; (c) Profile); (d) Usage; (e) Marketing and Communications; (f) Technical
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business to inform our marketing strategy and to improve our offering to you).

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of data:  (a) Usage; (b) Technical
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).

To make suggestions and recommendations to you about goods or services that may be of interest to you
Type of data: (a) Identity; (b) Contact; (c) Profile); (d) Usage; (e) Marketing and Communications; (f) Technical
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our products/services and grow our business, and to improve our offering to you).

For any operational or safety related update or notification pertaining to airport operations
Type of data: (a) Identity (b) Contact
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests of ensuring our customers are updated on these changes.

AUTOMATED DECISION MAKING

We do not conduct any automated decision making.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We generally only send electronic marketing – such as email marketing – to people who have previously used our services, and this is in our legitimate interests. We will always offer a way out of receiving this marketing (see Opting out below).  We may on occasion send out postal marketing for the purpose of growing our sales which is in our legitimate interests and in this scenario, we will rely on you to let us know if you do not want to receive this by opting out of marketing (see Opting out below).

Where you have not previously bought from us but have registered your details with us (for example signing up for a newsletter), we will only send you marketing communications if you opted into receiving marketing at the time and so given us your express consent (which you may withdraw at any time – see Opting out below).

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). This is undertaken for our legitimate interests of ensuring our marketing is relevant to its audience. For example, we may classify an appropriate audience for a promotion by what services they have previously used or expressed an interest in. We do not conduct any online behavioural tracking.

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

THIRD PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

OPTING OUT

You can ask us to stop sending you marketing messages at any time by contacting us at any time.

If you opt out of receiving email marketing from us, we will no longer store your email address, unless we are required to continue processing your email address for another purpose.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, or related correspondence, and we will continue to process such data in accordance with this Privacy Policy and only ever as permitted by law.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy.

6. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal information with the parties set out below:

• providers of IT and system administration services to our business, including SAGE and ALDIS;
• our professional advisers (including solicitors, bankers, IT providers, auditors and insurers);
• HM Revenue & Customs, the Information Commissioner’s Office, Border Force, regulators and other authorities who require reporting of processing activities in certain circumstances,
• BACS (automated payment provider);
• analytics and search engine providers that assist us in the improvement and optimisation of our website;
• our security provider [RJA]; and
• 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 information in the same way as set out in this policy.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

7. INTERNATIONAL TRANSFERS

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

8. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, including:

• Building entry controls. We have security such as door locks and security codes at our premises.
• Secure lockable desks and cupboards. Desks and cupboards are kept locked when not in use if they hold confidential information of any kind.
• Methods of disposal. Paper documents are disposed of by shredding in a manner that ensures confidentiality.
• Firewalls.
• Encryption.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

You acknowledge that the Internet is not a completely secure medium for communication and, accordingly, we cannot guarantee the security of any information you send to us (or we send to you) via the Internet. We are not responsible for any damages which you, or others, may suffer as a result of the loss of confidentiality of such information.

9. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see ‘Your Legal Rights’ below for further information.

10. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under UK data protection laws in relation to your personal data.

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it, for example where you consider that we do not need it any longer for the purposes for which we originally collected it as explained to you in this Privacy Policy, where you have withdrawn your consent to our using it and we had relied on that consent according to this Policy, where you consider that we cannot show a ‘legitimate interest’ in continuing to process it and we have relied on that legitimate interest to process it as explained to you in this Policy . You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you wish to exercise any of these rights, please contact us, marking your query for the attention of the DPL.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and a safe and secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.