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ASL Airlines France’s privacy policy is intended to inform, in a transparent manner, private individuals of the conditions under which their personal data is processed and of their rights in terms of protection under the European Regulation (EU) 2016/679 on the protection of personal data as well as Law No. 78-17 of January 6, 1978 relating to data processing, files and freedoms as amended.
The individuals concerned are those who come into contact with ASL Airlines France through the purchase, on-line or otherwise, of tickets directly from the company or through a third party (travel agency, tour operator, etc.); as well as any person who comes into contact with the company through any means made available by the company (website, mobile services and applications, social networks).
ASL Airlines France is committed :
– to comply with applicable law;
– restrict access to personal data to authorized persons who are aware of their obligations and responsibilities;
– to minimize treatments ;
– to limit data retention to that which is strictly necessary for contractual obligations, operational requirements, regulatory obligations and compliance with applicable law;
– to update personal data and consent to use such data;
– respect the rules governing commercial communications;
– not to communicate or sell personal data to third parties for commercial or marketing purposes;
– raise awareness and train employees in data protection and confidentiality obligations;
– to supervise and control partners and subcontractors who have access to personal data or who process personal data on behalf of the company, so that they comply with the company’s legal obligations and commitments;
– to take all measures to prevent the transfer of data to countries outside the European Union or which do not have equivalent legislation deemed adequate by the European Union;
– secure processing and information ;
– to respond promptly to any request for information.
ASL Airlines France, in its capacity as data controller within the meaning of European Regulation 2016/679 of April 27, 2016 (the “RGPD”), uses your individual data collected on the occasion of the following purposes, the legal bases of which are as follows:
| Purpose | Legal basis |
| Booking and purchasing tickets and other services | Necessity of processing for the performance of pre-contractual measures taken at the request of the data subject |
| Transportation or other services | Necessity of processing for the performance of a contract to which the data subject is a party |
| Sending of commercial information relating to our services and promotional offers and dissemination of targeted advertising | The processing is necessary for the purposes of the legitimate interests of ASL Airlines and its partners to promote their services or, where required by articles L.34-1 or L.34-5 of the French Post and Electronic Communications Code or any French or European provision that may replace it, the consent of the data subject. |
| Statistical studies | The processing is necessary for the purposes of ASL Airlines’ legitimate interests in improving its services and offering. |
| Compliance with our legal and regulatory obligations and with any judicial order or rule of procedure | Processing is necessary to comply with a legal obligation to which the data controller is subject |
The provision of the information requested for the booking of a ticket is a precondition for the conclusion of the contract. Although most personal data is collected directly from the persons concerned, the following data may be supplied by third parties such as travel agencies and other partners: surname, first names, title, email address, telephone number, gender, nationality, date and place of birth, passport number and place of issue, visa and/or other travel document, date of issue and expiry of travel document, flight date, flight number, departure and arrival route, PNR number.
Your personal data may be transmitted to third-party partners and service providers for reservation management, satisfaction analyses, newsletter and promotional offer mailings and, more generally, to any competent administration within the scope of our legal and regulatory obligations.
ASL Airlines undertakes to keep your personal data for no longer than is necessary for the purposes for which it is processed, in particular:
| Data type | Retention period |
| Data relating to orders and account use | 5 years from last account activity, then archived until expiration of longest applicable statute of limitations (6 years for misdemeanors) |
| Accounting documents as well as invoices, orders and other supporting documents | 10 years |
| Written record of a consumer contract concluded electronically for an amount of at least 120 euros | 10 years from delivery |
| Contact details of former and prospective customers for prospecting purposes | Up to 5 years after the collection of a prospect’s contact details or the end of the relationship with a former customer or, if later, after the last contact with that person or their request to unsubscribe. |
| Information for sending promotional offers to subscribers and information concerning their consent. | Up to 5 years after unsubscribe request |
| Identity card used to exercise access, rectification or other rights | Until expiry of applicable limitation period |
| Identity card used to exercise right of opposition | Until expiry of applicable limitation period |
| Credit card details | If you have consented to the storage of your credit card details (excluding cryptogram) to facilitate future purchases, as long as you have an account with us or, if earlier, on the expiry date of the card. Otherwise, as soon as the transaction is completed. From 13 months for immediate debit cards or 15 months for deferred payment cards to 25 months. |
| Website log data | 13 months |
If a dispute is in progress at the end of the retention period and personal data relates to it, the data will be retained for the purposes of the dispute until it is finally settled. The data will be deleted within one year of the end of the applicable retention period.
The communication of data to third-party partners or subcontractors is necessary for the provision of transport and related services, such as transport service intermediaries, airport authorities and public authorities.
In accordance with Article L.232-7 of the French Internal Security Code, we inform you that air carriers may be required to transmit their passengers’ reservation, check-in and boarding data ( API/PNR) to the French authorities, according to the processing methods and for the purposes set out in Decree No. 2014-1095 of 26/09/2014, amended by Decree No. 2018/714 of 3/08/18.
If we transfer personal data outside the European Union, we ensure that the country of destination is considered, at least for the relevant sector, to ensure an adequate level of protection of personal data by the European Commission in accordance with Article 45 of the GDPR, or that appropriate safeguards exist to protect your personal data in accordance with Article 46 of the GDPR – including standard contractual clauses approved by the European Commission.
You can unsubscribe from commercial information at any time by clicking on the unsubscribe link and sending an e-mail to rgpd_aslf@aslairlines.com, clearly stating that you do not wish to receive such information.
ASL Airlines has implemented a consent management solution. Any unsubscriptions or withdrawals of consent are stored to prevent any further communication.
ASL Airlines France ensures the security of information, in particular personal information, and implements appropriate technical measures against loss, alteration, disclosure, theft or unauthorized access to such data.
In accordance with the applicable regulations on the protection of personal data, you may, at any time, exercise your rights of access, rectification, deletion of your personal data and your rights to limit and object to their processing and portability. You also have the legal right to define instructions concerning the fate of your personal data after death.
In addition, any person who was under age at the time their personal data was collected may have it deleted as soon as possible. You also have the right to appeal to the French Data Protection Authority (Commission Nationale de l’Informatique et des Libertés).
This policy is subject to change. The current version is the one appearing on the company’s website. This version is dated November 2019.
Any request concerning the privacy policy and its application must be made exclusively to the ASL Airlines France Privacy Officer at the following e-mail address rgpd_aslf@aslairlines.com