PERSONAL DATA PROTECTION POLICY
(PRIVACY POLICY)

(“FLIGHTHUNTER” LLC, Effective from 17, 07 2017)

Introduction

This Personal Data Protection Policy (hereinafter referred to as the “POLICY”) sets out the policy which is intended to describe the procedure and conditions for processing information relating to a natural person, which allows or may allow for direct or indirect identification of a person's identity (hereinafter referred to as the “Personal Data”) received from individuals in connection with the activities of this website (hereinafter referred to as the “Website”) and software (hereinafter referred to as the “Software”) created, owned and developed by “FLIGHTHUNTER” LLC (hereinafter referred to as the “Company”).

This POLICY is based on principles such as: respect for individuals’ basic rights; lawfulness, fairness and transparency; data minimization; ensuring adequate level of protection; accuracy; storage limitation; integrity and confidentiality.

Under this POLICY "Personal Data" or “data” is defined as any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly.

Under this POLICY “processing” covers any operation or group of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

For the Website and/or Software your Personal Data is collected, inputted, storage, used, altered, restored, transferred, rectificated, blocked and / or destructed in accordance with the applicable legislation and with your consent.

The Company, unless otherwise is specified under this POLICY, does not aim to collect, or process biometric; special category; publicly available data; and/or data on personal life (“Sensitive Personal Data”) like information on your:

Data We Process

For the purposes of Website and/or Software only the Personal Data you provide is used. That information must be complete, accurate, kept up to date. Thus, the Company is not responsible for the integrity of the data seen in your personal account.

Under the operation of Website and/or Software the Company processes the following Personal Data of the registered person;

If you are an authorized representative of any company then you may be asked to provide information on that company (name, registration number and date, TIN) and your position therein.

Grounds for Data Processing

Your Personal Data can be processed following consent by you. The declaration of consent must be obtained in writing or electronically for the purposes of documentation. In some circumstances, such as telephone conversations, consent can be given verbally. The granting of consent must be documented.

Personal Data can be processed to register you in the Website and/or Software and ensure error free and uninterrupted access thereto, and, if it is necessary, to protect legitimate interests of the Company. Personal Data may not be processed for the purposes of a legitimate interest if, in individual cases, there is evidence that the interests of the data subject merit protection, and that this takes precedence.

The data being processed on the basis of consent will be stored for the period objectively necessary for implementing the purposes of processing data or for the period prescribed by the consent.

Your Rights

You have the following main rights:

1. RIGHT TO BE INFORMED

You shall have the right to information on your Personal Data, processing of data, grounds and purposes for processing, processor of data, the registered office thereof, as well as the scope of persons to whom your Personal Data may be transferred, including on:

2. RIGHT OF ACCESS

You shall have the right to access your Personal Data and supplementary information. The right of access allows you to be aware of and verify the lawfulness of the processing.

For email subject access valid requests should be addressed to [info@flighthunter.com]. For this issue the information should be provided in a commonly used electronic format validated by an electronic digital signature. Postal requests should be sent to: [12 Proshyan Street, Yerevan, Armenia, 0019].

To get an official respond your valid request will have the following requisites: a description in writing of the Personal Data you wish to receive, including the relevant dates, a copy of identification material such as a passport, and if you are an authorized person a document confirming your appropriate right to receive that particular information.

Information must be provided within five working days upon receipt of the written request. A copy of the information will be provided free of charge and in an accessible manner. However, the Company may charge a “reasonable fee” based on the administrative cost of providing the information, or refuse to respond when a request is manifestly unfounded with a written reasoned decision by making a reference to the provisions of the applicable law which served as a ground for delivering a decision.

3. RIGHTS TO RECTIFICATION AND TO BE FORGOTTEN

You shall have the right to require from the processor to rectify, block or destruct your Personal Data, where the Personal Data are not complete or accurate or are outdated or have been obtained unlawfully or are not necessary for achieving the purposes of the processing.

You shall have the right to require from the processor to erase your Personal Data (“right to be forgotten”) and to prevent processing in specific circumstances:

In case of doubts with regard to the rectification, blocking or destruction of Personal Data by the Company, you shall have the right to apply to the authorised body to make clear the fact of your Personal Data being rectified, blocked or destructed and by the request to be provided with information.

In such circumstances we will be obliged to immediately or, where there is no such an opportunity, within three working days, carry out necessary operations for completing, updating, rectifying, blocking or destructing tour Personal Data.

4. RIGHTS TO DECLINE

You shall have the right to withdraw your valid consent when you consider that:

You should withdraw your valid consent in writing, validated by signature, or electronically, validated by electronic digital signature. In case we accept your withdrawal, you will be informed on the destruction of Personal Data within three working days upon destruction.

5. RIGHT TO APPEAL ACTIONS OR INACTION OF PROCESSOR

Where you consider that the processing of your Personal Data is carried out in violation of the requirements of the applicable legislation or otherwise violates your rights and freedoms, you shall have the right to appeal our actions or inaction before an authorised state body for the protection of Personal Data or through judicial procedure.

If the authorised or judicial body considers the grounds for rejecting the provision, rectification, blocking or destruction of Personal Data unjustified, we will be obliged to immediately provide, rectify, block or destruct your Personal Data.

Our Obligations

Our principal obligations under the applicable legislation include:

Transfer of Your Personal Data to the Third Parties

The Company may use trusted third parties, who assist us in operating our Website or Software, conducting our business, or servicing our customers, so long as those parties agree to keep the information on your Personal Data confidential. We may also disclose such information when we believe disclosure is appropriate to comply with the applicable legislation, enforce our policies, or protect ours or others’ rights and freedoms, property, and/or safety.

In some cases, the Company can transfer your Personal Data to the third countries which ensure an adequate level of protection and provide for such safeguards with regard to the preservation of that information with your valid consent.

We may transfer Personal Data to the certain scope of persons without your valid consent, where the transfer of data stems from the purposes of processing Personal Data and/or is necessary for the implementation of these purposes or it is provided for by the applicable legislation and has an adequate level of protection.

Personal Data Breaches

A Personal Data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, your Personal Data transmitted, stored or otherwise processed.

Your Personal Data breach is a security incident and can concern a breach of confidentiality, integrity or availability of Personal Data, as well as any combination of these.

In the case of a Personal Data breach, the Company shall without undue delay and, where feasible, not later than within three working days after having become aware of it, notify you on the Personal Data breach via e-mail or phone call and with your valid consent1 take the following steps:

Protection of Personal Data

We follow legal and technical rules determined by the RA laws, EU regulations, GDPR recommendations and other highly recommended sources to provide efficient and necessary protection for your Personal Data.

For this purpose, we

We use a set of standards and technologies that protect data from intentional and/or accidental destruction, modification and / or disclosure. Data security is applied using a range of techniques and technologies, including administrative controls, physical security, logical controls, organizational standards, and other safeguarding techniques that limit access to unauthorized or malicious users or processes.

Our steps of securing Personal Data include:

Sensitive Personal Data

The Company will only process Sensitive Personal Data where the data subject expressly consents to such processing or where one of the following conditions apply:

Where special categories of data are being processed, Company will adopt additional protection measures if the latter at its sole and absolute discretion deems appropriate.

Cookies and Web Beacons

In order to help enhance the performance and functionality of Website and/or Software, we utilize session, persistent and third-party “cookies” that store a small piece of data on a users’ computers and collect certain information about the users’ visit to our Website and/or Software. Our Website and/or Software also uses web beacons (either directly or from our partners), along with cookies, to determine if a user has visited a Websit or used a Software, but provide no personally identifiable information.

The cookies and web beacons we apply collect non-personally identifiable information about users of the Website and/or Software, including: browser used to access the site, date and time, the URL of the page being loaded, users who have visited a particular Website(s) and/or Software, any previously assigned cookie identification (a unique identifier assigned to a user to identify repeat visitors), browser window size, the geographic location of the user, device and operating system used to access the Website and/or Software. The information we collect from these cookies and web beacons is used to determine information about a user’s visit to our Website and/or Software, including the number of visits, average time spent, pages viewed, navigation history through the Website and/or Software, and other statistics. This information is used to enhance the users experience while visiting our Website and/or Software and to improve its performance by, among other things, allowing us to monitor Website’s and/or Software’s performance, making it easier to use, measuring the effectiveness of promotional placements, and tailoring the Website and/or Software to better match a user’s interests and preferences.

External Links

The Company’s Website and/or Software provide links to other third-party websites. Even if the third party is affiliated with the Company through a business partnership or otherwise, the Company is not responsible for the privacy policies or practices or the content of such external links. These links are provided to you for convenience purposes only and you access them at your own risk.

Notification

We will notify you (electronically, by calling or in other reasonable and adequate way) on the following changes to get your valid consent if at any time the Company will need to:

Additionally, we will promptly notify you (electronically, by calling or in other reasonable and adequate way) about:

These notifications will be sent from [info@flighthunter.com] or via post by [Edmond Khachatryan The CEO of Flight Hunter LLC] on behalf of the Company.


  1. Please not if it is not possible to get in touch with you within a day, we will take the necessary action without your valid consent.