Osprey Flight Solutions Platform Privacy Policy

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

Sora Risk Solutions Limited, trading as Osprey Flight Solutions (“Osprey”, “we”, “us” or “our”) is the controller and responsible for your personal data. This privacy policy aims to give you information on how Osprey collects and processes your personal data through your use of this website including signing up for our newsletter and registering to participate in training.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy so that you are fully aware of how and why we are using and protecting your personal data.

We have appointed a data privacy manager 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 the data privacy manager using the details set out below.

CONTACTING US  

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

Email address: privacy@ospreyfs.com

By post: Data Privacy Manager, Manor Court, Basingstoke RG25 2PH, UK.

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 (www.ico.org.uk). 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 review our privacy policy regularly. Where the policy has been updated, this will be clearly identified by reference to the date of the policy above. We encourage you to check our privacy policy regularly to ensure you have read the most recent version.

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

THIRD-PARTY LINKS  

This website (and where relevant our system) 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.

2.  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 your personal data which we have grouped together as follows:

  • • Identity Data includes first name, last name, username (email address) or similar identifier, company and job title.
  • • Contact Data includes where customer billing address, email address and telephone numbers.
  • • Technical Data includes internet protocol (IP) address, your login data, 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 your services platform username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • • Usage Data includes information about how you use our products and services.
  • • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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IF YOU FAIL TO PROVIDE PERSONAL DATA  

Where we need to collect personal data by law, or under the terms of a contract (in this context including registration for a free service) 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. 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.

3. 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 and Contact details by filling in web forms or corresponding with us by phone, email or otherwise. This includes personal data you provide when you:

  • apply for our products or services;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
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Please see our cookie policy for further details.

4. 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 which includes fulfilling your request to receive our services alerts, usually signed up via our website and participate in our on-line training.
  • 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 obligation.
  • Where we are required to obtain your consent as required by law.
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Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before placing non-essential cookies on your device or sending direct marketing communications to you via email or text message where required by local law where you live. You have the right to withdraw consent to marketing at any time by contacting us.

5. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA  

We have set out below, in a table format, a description of all the ways we plan to 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 in the table below. 

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To process and deliver your order including where relevant: (a) Manage payments, fees and charges (b) Collect and recover money owed to us

(a) Identity (b) Contact (c) Transaction (d) Marketing and Communications

(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)  

To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey

(a) Identity (b) Contact (c) Profile (d) Marketing and Communications  

(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers interact with us)  

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications

(a) Necessary for our legitimate interests (to study how customers interact with us, to develop them and grow our business)  

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, improvement, support, reporting and hosting of data)

(a) Identity (b) Contact (c) Technical  

(a) Necessary for our legitimate interests (for running our business, network security, and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation to prevent fraud

To deliver relevant website content to you

(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical

(a) Necessary for our legitimate interests (to study how customers use our website, to develop them, to grow our business and to inform our marketing strategy)  (b) where required by law, with your consent

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

(a) Technical for website improvement and marketing relationships only (b) Usage  for website improvements

(a) 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) (b) where required by law, with your consent

To make suggestions and recommendations to you about goods or services that may be of interest to you, including via our appointed digital marketing agents

(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications

(a) Necessary for our legitimate interests (to develop our products/services and grow our business)  (b) where required by law, with your consent

To provide the Osprey.learnworlds training platform to you

(a) Identity (b) Contact (c) Marketing and Communications

(a) Performance of a contract with you b) where required by law, with your consent

6.  MARKETING  

We comply with data protection laws applicable to your location of work or residence in respect direct marketing messages sent by email, SMS or other electronic means.

You can ask us to stop sending you marketing messages at any time by following the unsubscribe links included in all marketing message sent to you. These include the messages sent where you sign up for free alerts.

Please note, that alerts sent to you as a customer, are not classified as marketing messages under data protection laws and cannot be unsubscribed from as a result.

7.  COOKIES  

We use a variety of cookies on our website. Please see our cookie policy for further details.

Our training platform is hosted by our partner, LearnWorlds (CY) Ltd. For information about the cookies placed by LearnWorlds, please read their cookie policy for further details.

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 non-essential cookies, please note that some parts of this website may become inaccessible or not function properly.

8.  DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with other companies within the Sora group of companies and with third the parties as set out below:

  • Service providers acting as processors based in the UK and abroad including Amazon Web Services, Microsoft Corporation who provide our cloud hosting, Salesforce, Planhat and Helpscout who provide our client relationship management systems, Salesforce, Pardot and MailChimp who provide our email marketing systems, and  LearnWorlds (CY) Ltd who provide our Osprey.learnworlds training platform.
  • Service providers acting as controllers including Prospect Global Ltd., our digital marketing partner. We recommend that you read their privacy policy available here to understand how the personal data we share with them is protected and used.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom, and the United States, Singapore and the EEA who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom to the extent they require reporting of processing activities in certain circumstances.
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We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

9. INTERNATIONAL TRANSFERS

Sora Risk Solutions Limited is part of an international group of companies. Where we share your personal data with other group companies and third parties, this may involve a transfer of data outside of Europe.

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

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission, UK Government and/or the Federal Council of Switzerland.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission, UK Government and/or Federal Council of Switzerland which give personal data the same protection it has in Europe.
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Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

10. 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. 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 personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11. DATA RETENTION

We categorise personal data according to how we use it and then retain it in accordance with our data retention policy and applicable law. Each use has a different retention period associated with it, and incorporates any legal obligations to retain that data category. After that time, we permanently delete your personal data.

12. YOUR LEGAL RIGHTS

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

The law entitles you:

  • to receive a copy of any of your personal data which we have collected;
  • to request that we correct or complete personal data we have collected;
  • to request that we delete or stop using or storing any of your personal data when we no longer need it;
  • to object to the processing of your personal data where we are processing it other than where we need to continue processing it to fulfil your request in relation to a role you would like to be considered for;
  • to withdraw your consent where we are using consent as our legal ground of processing; and
  • in some circumstances, have your personal data transferred to another organisation.
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If you wish to exercise any of the rights, please contact privacy@ospreyfs.com

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 could 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.