At Global Wings Ltd we are committed to maintaining the accuracy, confidentiality and security of your personal information. This Privacy Policy describes the personal information that Global Wings Ltd collects from or about you, and how we use and to whom we disclose that information.
Global Wings Ltd is a family member of Komodromos Group with operations globally. This Privacy Policy applies to the personal information of all individuals who seek to be, are, or were employed by Global Wings Ltd.
It is Global Wings Ltd policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and / or an individual’s right to privacy are different from one jurisdiction to another. This Privacy Policy shall guide the activities of Global Wings Ltd. In addition, specific privacy practices may be adopted to address the specific privacy requirements of particular jurisdictions. This Privacy Policy has a limited scope and application and the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions.
For the purposes of this Privacy Policy, personal information is any information about an identifiable individual. Personal information does not include anonymous or non-personal information (i.e., information that cannot be associated with or tracked back to a specific individual).
We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:
We collect and maintain different types of personal information in respect of those individuals who seek to be, are, or were employed by us, including the personal information contained in:
As a general rule, Global Wings Ltd collects personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources. We may utilize the services of third parties in our business and may also receive personal information collected by those third parties during the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us. Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.
We use your contact details to contact you about news, job opportunities, and information which we think may be of interest to you. However, we will not contact you with marketing material unless you have consented to our doing so. You have the right to unsubscribe at any time.
The personal information collected is used and disclosed for our business purposes, including establishing, managing or terminating your employment relationship with Global Wings Ltd. Such uses include:
The legal basis for processing personal information of our employees and potential employees is that it is either necessary for taking steps prior to entering into an employment contract and for performing an agreement with the employee (cf. GDPR article 6 no. 1 b), that we are under a legal obligation to process personal information (such as in relation to applicable tax, social security and social protection law and labor law legislation, cf. GDPR article 6 no. 1 a) and sometimes we process personal information in order to achieve our legitimate interest in ensuring the purposes mentioned above (cf. GDPR article 6 no. 1 f).
Further, we process personal information based on consent (cf. GDPR article 6 no. 1 a). This is for instance the case for recruitment, where the potential employee may consent to Global Wings Ltd retaining information regarding the applicant for a period of time after the application.
The legal basis for processing information relating to union membership and health data is that the processing is necessary for the purposes of carrying out our obligations as an employer towards our employees and for exercising our or the employee’s specific rights in the field of employment and social security and social protection law insofar as authorized by applicable law or a collective agreement pursuant to local law.
We will not share your personal information with third parties except for in circumstances where such sharing is necessary to provide our services or achieve our business objectives as further described in this Policy.
We may share your personal information within the Global Wings Ltd and with our clients when necessary to fulfil a request from you or for entering into an employment contract with you or in other circumstances where sharing is necessary.
We use external third-party service providers for delivering services on our behalf and on our instructions as set out in a data processing agreement with the relevant service provider. In such instances, we may share your personal information with such parties to the extent necessary to perform such services or to fulfil terms within an employment contract with you.
In addition to using cookies and related technologies, we also may permit certain third party companies to help us tailor advertising that we think may be of interest to our registered users.
In addition, personal information may be disclosed or transferred to another party (including to another member of the Global Wings Ltd outside of your home jurisdiction) in the event of a change in ownership of, or a grant of a security interest in, all or a part of Global Wings Ltd through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.
Further, your personal information may be disclosed:
When sharing personal information to other parties as described above, we sometimes need to transfer personal data to a country outside the EEA in order to be able to fulfil one of the purposes set out in this Policy. As an example, we may need to transfer personal information to Global Wings Ltd business units outside the EEA in order to provide you employment or international assignments located outside the EEA.
We will not transfer personal information to a third country outside the EEA that does not provide adequate protection of personal information unless appropriate safeguards are adduced or the transfer otherwise takes place in accordance with applicable data protection legislation. Examples of such safeguards are Binding Corporate Rules, EU Standard Contractual Clauses or if the receiving party is certified under the EU-US Privacy Shield.
Global Wings Ltd endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to protect your personal information from loss and unauthorized access, copying, use, modification, destruction or disclosure and all other unlawful forms of processing.
We follow strict security procedures in the storage and disclosure of your personal data, and to protect it against accidental loss, destruction or damage. The data you provide to us via our website or associated services is protected using SSL (Secure Socket Layer) technology. SSL is the industry standard method of encrypting personal information and credit card details so that they can be securely transferred over the Internet.
We may disclose your information to trusted third parties for the purposes set out in this Privacy Policy. We require all third parties to have appropriate technical and operational security measures in place to protect your personal data, in line with EU law on data protection.
Except as otherwise permitted or required by applicable law or regulatory requirements, Global Wings Ltd endeavors to retain your personal information only for as long as it believes is necessary to fulfill the purposes for which the personal information was collected (including, for the purpose of meeting any legal, accounting or other reporting requirements or obligations).
When we no longer need your personal data, we will securely delete or destroy it. We will also consider if and how we can minimize over time the personal data that we use, and if we can anonymize your personal data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.
You have the right to request access to and rectification of any information we have collected about you. To help us keep your personal information updated, we advise you to inform us of any changes or discrepancies. In some circumstances, we may not agree with your request to rectify your personal information and will instead append an alternative text to the record in question. You will be notified both when information is rectified and when not, and if so what the reason is for not obeying to your request.
You also have the right to erasure and restriction of processing in some instances. You may have a right to receive personal data concerning you in a machine-readable format and to forward the data to another party (data portability), provided that certain conditions are met.
You also have the right to object to the processing, including if the processing is for marketing purposes. In order to object to processing, please contact Global Wings Ltd.
Where your consent was required for our collection, use or disclosure of your personal information, you may, at any time, withdraw your consent. All communications with respect to such withdrawal or variation of consent should be in writing.
Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.
To exercise your rights as a data subject, or if you wish to make a complaint regarding our compliance with this Policy, please contact Global Wings Ltd. Prior to fulfilling your request, we may request specific information from you to enable to confirm your identity and right to access as well as to search for and provide you with the personal information we hold about you.
You have a right to complain to Global Wings Ltd regarding violations of your rights under applicable data protection law. Further, you have a right to complain to the supervisory authority competent to resolve such concerns according to applicable law, but we encourage you to first contact us before filing such complaint.
Address: 9 Ioannou Gladstonos Street, 6023 Larnaca Cyprus.
E-mail: info@global-wings.co
Global Wings Ltd may from time to time make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the way we deal with your personal information.
We will communicate any revised version of this Privacy Policy. Any changes to this Privacy Policy will be effective from the time they are communicated, provided that any change that relates to why we collect, use or disclose your personal information will not apply to you, where your consent is required to such collection, use or disclosure, until we have obtained your consent to such change.
This Privacy Policy was last reviewed Jun 10, 2019.
This Privacy Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word ‘including’ is used, it shall mean ‘including without limitation’. This Privacy Policy does not create or confer upon any individual any rights, or impose upon Global Wings Ltd any rights or obligations outside of, or in addition to, any rights or obligations imposed by the privacy laws applicable to such individual’s personal information. Should there be, in a specific case, any inconsistency between this Privacy Policy and such privacy laws, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.
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