Privacy statement

Your privacy is important to us. This privacy statement explains the personal data Touchdown Aviation B.V. (henceforth be known as TDA) processes, how TDA processes it, and for what purposes.

Scope of this statement

This statement governs the manner in which TDA collects and processes personal data. We encourage you to read this statement carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this statement.

TDA may collect personal data from you

TDA may collect personal data from you in the following circumstances:

TDA may collect or obtain personal data when you visit any TDA website or use any features or resources available on or through a site. When you visit a site, your device and browser will automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a site and other technical communications information) some or all of which may constitute personal data.  
TDA may collect or obtain personal data when you register to use any service provided by TDA via a site, or log into a site, including the following: registration details, login name, email address, and password.
TDA may collect or obtain personal data when you contact TDA (whether in person, by mail, by phone, online, via electronic communication or by any other means).
TDA may collect or obtain personal data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).

TDA may receive personal data about you from others

TDA may receive personal data about you from third parties. For example:

If you interact with third party content or advertising on a site or in an app, TDA may receive personal data about you from the relevant third party, in accordance with that third party’s applicable privacy statement.
If you choose to make payment directly to TDA, or through a site or an app, or through a dealer, TDA may receive personal data about you from third parties such as payment services providers, for the purposes of that payment, including the following: purchase details, payment data, credit card data.
To the extent that any credit reference checks are carried out by TDA or on its behalf, in connection with an application for credit, in accordance with applicable laws, TDA may receive personal data about you from credit reference agencies and other third parties, for the purposes of that credit check, including the following: confirmation of whether the reference agency was able to verify your details; and the results of the reference check including your credit rating.

In complying with its obligations under applicable laws, TDA may receive personal data about you from law enforcement agencies and public authorities.
TDA may receive personal data about you from public sources (such as telephone directories, land ownership records, lien records, etc.).
If you interact with any third party content or advertising on a site or in an app (including third party plugins and cookies), TDA receives personal data about you from the relevant third party provider of that content or advertising.

Categories of personal data processed by TDA

The categories of personal data that may be processed by TDA under this statement include:

personal details: name; gender; profession; business or employer; sector;
contact details: email address; postal address; telephone number; fax number; customer ID;
data relating to sites: technical data (as outlined above, including device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a Site, and other technical communications information necessary for the operation of the relevant site); username; password; security login details; aggregate statistical information; marketing data: advertising interests; cookie data; clickstream data; browsing history; responses to direct marketing; and opt-outs from direct marketing.

Lawful basis for processing personal data

In processing your personal data in connection with the purposes set out in this statement, TDA may, depending on the circumstances, rely on any of the following legal bases:

we have obtained your prior express consent to the processing;
we have a legitimate interest in carrying out the processing (including our legitimate interests in

operating our business, providing goods and services to you, alerting you to other products or services that may be of interest to you, and maintaining or improving our products or services), and there is no undue risk to your rights, freedoms or interests;
the processing is necessary in connection with a contract entered into with you, or for your benefit;
the processing is required by applicable laws;
the processing is necessary to protect the vital interests of any individual; or any other lawful basis available under applicable laws.

Processing your sensitive personal data

TDA does not seek to collect or otherwise process your sensitive personal data

Purposes for which TDA may process your personal data

TDA may process your personal data for the following purposes:

to display the content of a site;
to monitor, adapt, update, secure and improve our products and services to you;
to respond to your service requests and support needs;
to understand how individuals collectively use the features of a site;
to administer content, promotions, surveys or other features of a site;
to send you information relevant to your past purchases and interests, subject to compliance

with applicable laws regarding direct marketing;
to send you communications regarding administration of your accounts and the features of a site;
to notify you about changes to a site;
to perform data analyses and other processing (including trend analysis);
to give effect to your legal rights and your rights under this statement;
to protect against fraud, identity theft, and other unlawful activity;
to establish or exercise TDA’s legal rights or defend legal claims; to establish, exercise or defend legal claims; and to comply with applicable laws and our other applicable policies.

International transfers of personal data

We may make use of processing facilities controlled or operated by our third party service providers, located in jurisdictions other than the jurisdiction in which your personal data were originally collected. In particular, the content and features of a site may be provided by means of servers located outside your jurisdiction (including, but not limited to, servers located in the United States). Your personal data may be transferred to, and processed using, those servers or other processing facilities, as part of the operation of a site, or in connection with any of the processing purposes set out in this statement, subject always to compliance with the provisions of applicable laws. These transfers are necessary in order to provide our products and services to you in an efficient and effective manner. Where we transfer your Personal Data to other countries, we do so only with third party service providers who comply with EU-VS Privacy Shield certification.

Protection of your personal data

TDA is committed to processing your personal data securely. We adopt appropriate data processing practices, and appropriate technical and organizational security measures, to protect against unauthorized access, alteration, disclosure or destruction of personal data.

You are responsible for keeping your access credentials for each site safe and confidential. You should frequently change your access credentials and you must notify TDA promptly if you become aware of any misuse of your access credentials, and immediately change your access credentials.

Disclosure of your personal data

We will not sell, trade, or rent your personal data to others without your consent. We may, however, share or disclose your personal data to third parties in the following circumstances:

We may disclose your personal data to employees and agents of TDA, to the extent necessary to provide the services.
We may share your personal data with recipients within TDA, for the purposes of operating our business, operating sites, providing you with products or services you have selected, or otherwise for the purposes set out in this statement.
We may share your personal data with recipients outside TDA for the purposes of operating our business, operating sites, providing you with products or services you have selected, or otherwise for the purposes set out in this statement.
We may use third party service providers to help us operate our business, operate sites, provide you with products or services you have selected, or to administer activities on our behalf, such as sending out newsletters or surveys. We may share your personal data with such third parties for the purposes set out in this statement.
Subject to obtaining your consent, we may share your personal data with our third party marketing partners, for direct marketing purposes. You may withdraw your consent at any time, or object at any time to the processing of your personal data for direct marketing purposes.
If you make a payment via a site, or directly to TDA, your personal data may need to be provided to third parties (e.g., payment services providers) for the purposes of facilitating those payments.
If we sell, merge or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, liquidation or other restructuring), we may disclose your personal data to the prospective seller or buyer, or their representatives, provided that we have first taken reasonable steps to ensure the security and confidentiality of your personal data.
We also may disclose your personal data:
- to the extent necessary to establish, exercise or defend legal claims;
- if required by applicable laws or regulations;
- in response to requests from government agencies and law enforcement authorities; o when disclosure is necessary or appropriate to prevent physical harm or material financial loss;
- for the purposes of investigating unlawful activity.

Third party services

You may encounter other content on any site that may link to websites or services of TDA’s partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these third party websites or services, and we are not responsible for the practices employed by third party websites or services linked to or from any site. These websites and services may be subject to their own privacy policies and terms of use.

Direct Marketing

As set out in this statement, we, may contact you via email, text message, or other electronic means, from time to time, to provide you with information relating to products or services that may be of interest to you. If you wish to unsubscribe from these communications, we include detailed unsubscribe instructions in each such communication.

Please note that, in the event that you unsubscribe from receiving communications relating to marketing or advertising, we may nevertheless continue to contact you for the purposes of carrying out your instructions, enabling you to make any purchases you request, administration of your account, or as required or permitted by applicable laws.

Cookies

A cookie is a small file that is placed on your device when you visit a website. It records information about your device, your browser and, in some cases, your preferences and browsing habits. We may process your personal data through cookie technology, in accordance with our Cookie Policy.

Data retention

We will only retain your personal data for as long as we require those personal data in connection with the purposes set out in this Privacy Statement. We may also be required to retain your personal data for additional periods of time, for example, where required to do so by applicable laws.

Your rights

It is your responsibility to ensure that your personal data held by TDA is complete, accurate and up-to- date. Subject to the GDPR, you have the following rights:

the right to request access to, or copies of, your personal data that we process;
the right to request correction of any inaccuracies in your personal data;
the right to object, on legitimate grounds, to the processing of your personal data;
the right to request, on legitimate grounds:
- erasure of your personal data that we process;
- restriction of processing of your personal data that we process;

the right to have your personal data transferred to another controller, to the extent applicable;
where we process your personal data on the basis of your consent, the right to withdraw that consent; the right to lodge complaints regarding the processing of your personal data with the Data.

Protection Authority.

This does not affect your statutory rights. You may exercise any of these rights by using the contact details provided below.

Contact details

If you have any questions about this Privacy Statement, our processing of your personal data, or your dealings with a site, please contact us at:

TDA (Touchdown Aviation)
Att. Brigitte van der Drift
Tokyostraat 29 – 33
1175 RB LIJNDEN

Phone: +31 20 659 99 00
Email: brigitte@tda.aero

If you contact us, we will endeavor to investigate and attempt to resolve each query or complaint within 4 weeks.

Amendments to this Policy

TDA may amend, revise or update this Privacy Statement at any time, without providing you with any specific notice. You are encouraged to frequently check this Policy Statement for any changes, and to stay informed about how we are helping to protect your personal data. Your continued use of any site is deemed to be acceptance of any amendments to this Policy.

Last updated: 12 July 2018