This privacy policy will explain how our organisation, 2Excel Group Ltd and all of its subsidiaries (collectively 2Excel), uses the personal data we collect through the course of our activities.  This includes the personal data we collect from you when you use our website(s).

2Excel understand that your privacy is important to you and that you care about how your personal data is used.  We respect and value the privacy of all our customers, passengers, job applicants and website visitors/users and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

The websites referred to in this privacy policy are https://www.2Excelaviation.com and https://www.2excelengineering.com and any other 2Excel website that may exist from time to time.

As we handle the personal information of people in the UK and in the EU, we comply with both the EU General Data Protection Regulation (GDPR) and the UK Data Protection Act 2018 (collectively, “the Data Protection Legislation”).

What is personal data?

Personal data is defined by Data Protection Legislation as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.  The Personal data that we use is set out in this Privacy Policy.

Your Rights

As a data subject, you have the following rights under the Data Protection Legislation, which this Policy and our use of personal data have been designed to uphold:

  • The right to be informed about our collection and use of personal data;
  • The right of access to the personal data we hold about you
  • The right to rectification if any personal data we hold about you is inaccurate or incomplete
  • The right to be forgotten – i.e. the right to ask us to delete any personal data we hold about you
  • The right to restrict (i.e. prevent) the processing of your personal data;
  • The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
  • The right to object to us using your personal data for particular purposes; and
  • Rights with respect to automated decision making and profiling.

If you would like to talk to us about any of your right and/or exercise your rights under the Data Protection Legislation, please contact us: info@2excel.uk

If you have any cause for complaint about our use of your personal data, please contact us and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office or the relevant authority in the EU country where your data is being processed – we can help you identify who this is.

Types of Personal Data we Process and Why

2Excel collect and process personal data only for legitimate business purposes.  The types of personal data we process depends on the nature of your relationship with 2Excel.  We process personal data primarily for the following reasons:

  • To respond to enquiries
  • To verify the identity of visitors
  • To process job applicants
  • To produce manifests and flight plans for the safe operation of our aircraft
  • To meet the requirements of our customer contracts

As required by GDPR, 2Excel has a lawful basis for processing personal data as described above.  This lawful basis includes one or more of the following:

  • Consent – consent from you to process personal information.
  • Contract – processing is required in order for 2Excel to carry out its contractual obligations or exercise its contractual rights.
  • Legal obligations – processing is necessary in order to comply with 2Excel’s legal and regulatory obligations.
  • Legitimate interests – processing is necessary for the pursuit of 2Excel’s legitimate business interests.

Where 2Excel has a legitimate interest in processing personal data, we have carefully balanced our need to process this data with the subjects’ rights and freedoms and have determined that the processing is reasonable, proportionate, and has minimal privacy impact.  The types of processing 2Excel does based on its legitimate interest include:

  • Monitoring and investigating compliance with company policies and procedures
  • Physical and system security, including the use of on-premises CCTV
  • Execution and fulfilment of customer contracts
  • Management of disputes and legal proceedings
  • Support for safety and aircraft operations
  • Day-to-day business operations, including customer relations
  • Maintaining appropriate business records

Contact & Communication

If you make contact with us, you do so at your own discretion and the details you provide us are provided at your own risk.  You may contact us by telephone, email, through social media, visiting our sites, completing an online form submission or writing us a letter.

2Excel use any information submitted to provide you with further information about the products / services they offer or to assist you in answering any questions or queries you may have submitted.

We may sometimes contract with third parties to supply products and services to you on our behalf. These may include payment processing and delivery of goods.  In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.

Customers/Passengers

If you have or are due to fly with 2Excel, are purchasing a flight on behalf of somebody else or you buy any other service from us, you are known as a customer and/or passenger.  We may collect some or all of the following personal data about you which may vary according to your relationship with us:

Name, Date of Birth, Gender, Address, Email Address, Telephone Number, Health Information, Weight, Height, Payment Information, Next of Kin Details, photographs and video footage.

This data will be used for some or all of the following:

  • Supplying our products and services to you
  • Processing regulatory and safety passenger information about you
  • Personalising and tailoring our products and services for you
  • Communicating with you. This may include responding to enquiries, emails or calls from you.

If you are travelling within the UK, your data will only be stored in the UK in a way that is fully compliant under the Data Protection Legislation.

If you are travelling outside of the UK, we may have to transfer some or all of your personal data outside of the UK in order to process regulatory and safety passenger information about you.  These are known as “third countries”.  If this is within the EEA, your data will be fully protected under the EU General Data Protection Regulations (GDPR) or to equivalent standards by law.  For any other country, they may not have data protection laws that are as strong as those in the UK and/or the EEA.  Information is transferred via our Flight Operations software which will send information encrypted in order to additionally safeguard your data.

Job Applicants

If you use our website to apply for a job, submit a CV, or send an application or CV to us directly by email, you are known as a job applicant.  Applications will be processed through our Applicant Tracking System, third party software, and automatically deleted after 12 months, unless you choose to keep your application live.   Applications may be fed into our ATS through other third party websites, such as job boards.  Job applicants should familiarise themselves with the privacy policy for the website they are using to apply for a job with 2Excel.

When you apply for a job with us, we may collect and process some or all of the following personal data about you which may vary according to your relationship with us:

Name, Date of Birth, Gender, Address, Email Address, Telephone Number, Health Information, Next of Kin Details, photographs.

This data will be used for some or all of the following:

  • Processing your application
  • Providing statistical analysis of job applicants – all data will be anonymised
  • Communicating with you. This may include responding to enquiries, emails or calls from you.

We do not use automated decision making or profiling through during our recruitment processes.  Job applicants can choose to withdraw their consent for 2Excel to process their data at any time by emailing recruitment@2excel.uk

What else will we do with your data?

Other than processes declared above we will not share any of your personal data with any third parties for any purposes unless in some limited circumstances where we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

Your personal information will be kept private and stored securely until a time it is no longer required or has no use, as detailed in the Data Protection Legislation. We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.

If you want to access your personal data or know what personal data we have about you, you can request a copy of it via a “subject access request” in writing to info@2excel.uk and we will respond in line with the requirements of the Data Protection Legislation.  There is not normally any charge for a subject access request unless your request is manifestly unfounded or excessive where a fee may be charged to cover our administrative costs in responding.

The Website

Our websites and its owners take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of its users throughout their visiting experience. This website complies to all EU and UK laws and requirements for user privacy.

Cookie Policy

Our websites may use cookies to better the users experience while visiting. Where applicable our websites use a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer / device. This complies with legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer / device.

These cookies contain no personally identifiable information but they will use your computer’s IP address to know from where in the world you are accessing the Internet.

Google stores the information collected by these cookies on servers in the United States. Google may transfer this information to third-parties where required to do so by law, or where such third-parties process the information on Google’s behalf.

Opt Out

In order to provide website visitors with more choice on how data is collected by Google Analytics, Google has developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to stop data being sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not affect usage of the website in any other way. A link to further information on the Google Analytics Opt-out Browser Add-on is provided below for your convenience.

http://tools.google.com/dlpage/gaoptout?hl=None

For more information on the usage of cookies by Google Analytics please see the Google website. A link to the privacy advice for this product is provided below for your convenience.

http://www.google.com/analytics/learn/privacy.html

Disabling Cookies

If you would like to restrict the use of cookies you can control this in your Internet browser. Advice on how to do this will be available for the Internet browser of your choice either online or via the software help (normally available via key F1).

External Links

Although we aim to only include quality, safe and relevant external links on our website(s), users are advised adopt a policy of caution before clicking any external web links mentioned throughout this website. (External links are clickable text / banner / image links to other websites.)

We cannot guarantee or verify the contents of any externally linked website despite our best efforts. Users should therefore note they click on external links at their own risk and our website(s) and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.

Social Media Platforms

Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.

Users are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to their own privacy and personal details. This website nor its owners will ever ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.

This website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.

Shortened Links in Social Media

This website and its owners through their social media platform accounts may share web links to relevant web pages. By default some social media platforms shorten lengthy urls [web addresses] (this is an example: http://bit.ly/zyVUBo).

Users are advised to take caution and good judgement before clicking any shortened urls published on social media platforms by this website and its owners. Despite the best efforts to ensure only genuine urls are published many social media platforms are prone to spam and hacking and therefore this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.

Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

Resources & Further Information

  • UK Data Protection Act 2018
  • EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”)
  • Privacy and Electronic Communications Regulations 2003 – The Guide

This policy can be made available orally upon request to info@2excel.uk

29th August 2024

Edited & customised by: 2Excel Group Ltd. Company Registration Number 15499159 (England and Wales).

Registered office address: 72 Fielding Road, London, England, W4 1DB