For your convenience our Policy is divided into the following sections:
Table of Contents
DIFES (Digital In-Flight Entertainment Services) is committed to protecting your privacy and ensuring you have a positive experience when using the services, we provide, which we generally refer to as DIFES (Digital In-Flight Entertainment Services) or DIFES (Digital In-Flight Entertainment Services) services.
Who are we and how to contact us?
The words “we”, “our”, “us” refer to DIFES (Digital In-Flight Entertainment Services).
Our Data Protection Officer is ______ you may contact him via _________
If you have questions, please contact the support team at _________
What data, for what purposes, how long, and based on what grounds do we process as a Controller?
|Purpose of Processing||Data Subjects: Categories of Data||Storage Period||Legal Basis|
|To collect your feedback||Our customers: full name, email address, seat number||2 months from the date of the last request or until you object to such processing whichever happened first||Our legitimate interests to improve the quality of our service|
|To create an account for you||Our customers: full name, phone numbers, email address, seat number.||6 months from the date of the last flight date||Your consent to register with the media service. You may withdraw your consent at any time by contacting us at email@example.com|
|To better understand your preferences, to help you navigate our website, to personalize and provide a more convenient experience to you, to analyze which pages you visit, and to measure advertising and promotional effectiveness||Our website visitors: type of device, browser language, last time login.||60 days or until you withdraw your consent whichever happened earlier||Your consent to store cookies in your browser. You may withdraw your consent at any time by changing the settings of your web browser.|
What data do we process as a Processor of our Customers (Controllers)?
As described more below, under the EU’s GDPR, DIFES (Digital In-Flight Entertainment Services) is a “Processor” of personal data that our customers (airlines) may put into our systems when they use DIFES (Digital In-Flight Entertainment Services).
Our customers are the “Controllers”. We follow their directions regarding this data, and may store it, delete it, or disclose it at their direction.
The data processing practices related to cases when we act as a processor and process on behalf of our customers are described in our Data Processing Agreement together with the EU Standard Contractual Clauses incorporated into our License Agreement with our customers.
Specific categories of data which we process on our customers’ behalf include:
With regard to customers (Passengers): booking code; seat number; full name; gender; service class; SSR codes; incoming transfer indication; outgoing transfer indication; indication of “with a child”; indication of “frequent flyer; loyalty card type and number; VIP passenger indication; age indication for children from 2 to 12 years old; number of CHD passengers aged 2-3, 3-6, 6-12; CHD sign; NF attribute; RFISC for 5* flights; RFISC congratulations for flights 5*.
With regard to crew members: full name; photo; position; languages; personnel number.
We also process various information concerning flight such as: flight number; airline company code; date of the flight / scheduled section, LT / UTC; Type (operational or marketing); date / time of scheduled departure, LT / UTC; date / time of scheduled arrival, LT / UTC; departure airport, IATA; departure airport terminal; arrival airport, IATA; arrival airport terminal; aircraft configuration; type of aircraft; tail number.
We process the data provided by our customers until the termination of our License Agreement with them and within the terms specified by applicable law.
Who do we share your data with ?
We use third-party service providers to help us provide portions of the DIFES (Digital In-Flight Entertainment Services) services and give support. Examples of these third parties include our payment processor and hosting provider.
They only receive data needed to provide their services to us. We have agreements with our service providers under which they cannot use any of this data for their own purposes or for the purposes of another third party.
We prohibit our service providers from selling data they receive from us or receive on our behalf.
We require service providers to use data only in order to perform the services we have hired them to do (unless otherwise required by law). For example, we may use a company to help us provide client support. The information they may receive as part of providing that support cannot be used by them for anything else.
Acting as a Controller we share your data with the following processors:
|Aerogroup, LLC (Russia)||Administration of information systems, content updates, software sub-licensing||We use Standard Contractual Clauses to ensure that your data is properly protected|
|Mail.Ru, LLC (Russia)||Hosting Service Provider||We use Standard Contractual Clauses to ensure that your data is properly protected|
|DIFES, LLC (Ireland)||Administration of information systems, publishing, device management||We use Standard Contractual Clauses to ensure that your data is properly protected|
We do not make any automated decisions about you that would result in legal or other similarly significant effects on you.
What is a cookie?
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
- to better understand your preferences,
- to help you navigate our website,
- to personalize and provide a more convenient experience to you,
- to analyze which pages you visit, and
- to measure advertising and promotional effectiveness.
Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies. Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously. Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers.
Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.
Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.
More specifically we use the following cookies and tracking technologies, including cookies from our partners and service providers:
|user||ife.one||Persistent||Necessary||Registers whether the user is logged in. This allows the website owner to make parts of the website in accessible, based on the user's log-in status.|
|userId||ife.one||Persistent||Preferences||Identifies the visitor across devices and visits, in order to optimize the chat-box function on the website|
|lastTimeLogin||ife.one||Persistent||Unclassified||Registers information about the last user logon.|
|selectedLanguage||ife.one||Persistent||Unclassified||Registers information about the selected user's language|
|settings||ife.one||Persistent||Unclassified||Registers information about user settings choice on portal|
What can you do if you do not want storing cookies to be set or want them to be removed?
You are able to withdraw the consent to store cookies by changing the settings of your web browser.
You have the following rights under the GDPR concerning personal data: the right to information, right to access, right to rectification, right to withdraw consent, right to object against processing for specific purposes (such as direct marketing), right to object to automated processing, right to be forgotten and right for data portability (copy of personal data in a commonly used machine–readable format).
You may also exercise the mentioned rights by contacting us via email at ____________
You also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or where an alleged infringement of the GDPR has taken place.
Changes to this Policy
We regularly update this Policy in case there are significant changes in the way we process your personal data.
You will receive a notification prior to such significant changes become effective by pop–up notice on our website.