APM技术SA (我们) are committed to protecting your personal data and respecting your privacy and we have systems in place to ensure that we comply with all relevant data protection legislation.

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in our Privacy Policy and it is important that you read that information. Please note that in some circumstances the manner in which we process your personal data may be governed by the terms of your contract with your employer (Airline) which we will need to comply.

The APM CrewConnect App and the APM OpsConnect App are provided free of charge for your convenience only. The APM CrewConnect App is designed to assist crew in managing your rostering schedule and crew records with the Airline. The APM OpsConnect App is designed to assist your flight schedulers in managing your ground operations, flight schedules and flight records with your employer (Airline). Please note that any personal information which you enter via an App may be visible to other crew members, crew supervisors, flight schedulers and the Airline. In this Privacy Policy a reference to App is a reference to APM CrewConnect App and / or the APM OpsConnect App as appropriate.

 

How you can withdraw consent

Once you provide consent by downloading the App you may change your mind and withdraw consent at any time by contacting us by email to our HelpDesk, helpdesk@apmtechnologies.com but that will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent you will no longer be able to access and update / 修改 / view your rostering information or flight information via the App. Any personal information which you have entered via an App before withdrawing your consent will remain visible to others who have access to the App.

 

 

INTRODUCTION

This policy (together with our terms of use as set out at APM APPS END USER LICENCE TERMS AGREEMENT (最终用户许可协议) together our Terms of Use) applies to your use of:

• The APM CrewConnect and / or the APM OpsConnect mobile application software (App) available from the Apple Store or Google Play Store’s or once you have downloaded a copy of the App onto your mobile telephone or handheld device (Device).
• Any of the APM services accessible through the App (服务).
• This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

 

IMPORTANT INFORMATION AND WHO WE ARE

APM技术SA (collectively referred to as, “我们”, “us” or “our” in this policy) and your Airline are joint controllers of the personal information which we receive from you and we will only process your personal date in accordance with the requirements of your Airline and the terms of this policy.

 

联系方式

Our full details are:

• Full name of legal entity: APM技术SA
• Email address: helpdesk@apmtechnologies.com
• Postal address: Traz的方式 20, 邮政信箱 1100, 1211 日内瓦 5, 瑞士
• Telephone number: 00 41 22 717 8499

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 or any other competent supervisory authority of an EU member state if the App is downloaded outside the UK.

 

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on 9th May 2024. It may change and if it does, these changes will be posted on this page. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

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 our relationship with you.

 

Third party links

The App or any Service may contain links to other independent websites which are not provided by us. Such independent sites are not under our control, and we are not responsible for and have not checked and approved their content or their privacy policies (if any).

You will need to make your own independent judgement about whether to use any such independent sites, including whether to buy any products or services offered by them.

 

THE DATA WE COLLECT ABOUT YOU

We may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data.
• Contact Data.
• Financial Data.
• Transaction Data.
• Device Data.
• Content Data.
• Profile Data.
• Usage Data.
• Marketing and Communications Data.
• Location Data. Please note the CrewConnect APP has a ‘geolocalisation’ feature that will track your position when near your crew reporting location for crew check in purposes.

We explain these categories of data below.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. 例如, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health except for medical certificate records as required for the compliance of flight qualifications for the safe crewing of an aircraft as defined by your Airline, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

 

HOW IS YOUR PERSONAL DATA COLLECTED?

We will collect and process the following data about you:

• Information you give us. This is information (including Identity, 联系, Crew Qualifications data, Financial, and Marketing and Communications Data) you consent to giving us for specific purposes via the App or by corresponding with us (例如, by email). It includes information you provide when you download or register an App, subscribe to any of our Services, share data via an App, and when you report a problem with an App or our Services. If you contact us, we will keep a record of that correspondence.
• Information we receive from other sources. We may receive personal data about you from your Airline to enable us to confirm that you are entitled to download and use the App and to enable us to populate the rostering database with necessary information about you to enable the App to function correctly.
• Information we collect about you and your device. Each time you use one of our Apps we will automatically collect personal data including Device, Content and Usage Data.
• Location Data. Certain Services may require access to your location and in such circumstances we will wish to make use of location data sent from your devices. In such circumstances we will advise you of our proposed use within the App with an alert before we start collecting location data. You will be able to turn off this functionality at any time by turning off the location services settings for the App on the device. If you use these Services, you consent to our transmission, collection, retention, maintenance, processing and use of your location data and queries to provide and improve location-based functionality relating to the Services. You may stop us collecting such data at any time by turning off the location services settings on, however in this event certain functions may be not available.
• Photographic Images. We will hold a photographic image of you if you view or add a photograph to your personal crew profile on the App.

We will only collect the minimum amount of personal data needed to enable us to carry out our legitimate activities.

 

COOKIES

We do not use cookies but we do use JSON Web Token (JWT) tracking and identification technologies within the App in order to validate a user’s identity. The JWT is sent as a bearer token in the authorization header.

 

HOW WE USE YOUR PERSONAL DATA

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:

• Where you have consented before the processing by accepting the (最终用户许可协议) terms and conditions of downloading the Apps.
• Where we need to use your personal date to enable the App to function correctly. In particular, we will use any personal data which you, other users of the App and your Airline give us to update and maintain the Airline rostering schedules and authority reporting.
• 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 or regulatory obligation.
• In order to contact you about the Services.

We will not share your personal data with any third party for marketing purposes

 

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

To install the App and register you as a new App user.

To manage our relationship with you including notifying you of changes to the App or any Services.

To deliver the Services to you and other users of the Service.

To administer and protect our business and this App including troubleshooting, data analysis and system testing.

 

DISCLOSURES OF YOUR PERSONAL DATA

When you consent to providing us with your personal data, you consent to our disclosing that data in the following ways:

• To Internal Third Parties as necessary to maintain the App and the Services.
• To the Airline and other crew members and crew supervisors to enable us to provide the Services.
• To airport, other third party service providers and other authorities who require crew information for compliance purposes. Any such disclosures will be in accordance with the terms of your employment with the Airline.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacypolicy.

 

INTERNATIONAL TRANSFERS

Some third parties to whom we transfer your data may be based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we put safeguards in place to ensure a similar degree of protection is afforded to it as if it were held within the EEA.

 

DATA SECURITY

All information you provide to us is stored on our secure servers or your Airline’s servers. Where we have given you (or where you have chosen) a password that enables you to access the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone and not to share your mobile device with anyone. You are responsible for logging off the services at the end of a transaction and we remind you not to leave your device accessible to anyone when you are logged on to the services, for in the event you do so and your data is accessed this will be your sole responsibility.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way or improperly altered or disclosed. 此外, we only authorise 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 suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

DATA RETENTION

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us with a copy to your Airline’s authorised person.

In some circumstances you can ask your Airline to delete your details from their servers hosting the information, subject to any legal compliance they are obligated to adhere to by government or crewing compliance organisations. See Your legal rights below for further information. You will need to send us a copy of your deletion request as well as the Airline to ensure that all copies of the data are removed from the relevant App(小号).

Where any personal data about you is deleted from our records we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

 

YOUR LEGAL RIGHTS

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

You have the right to:

1. Request access to the personal information that we hold about you. This enables you to receive a copy of the personal data we hold about you and to check that we are processing it lawfully.
2. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us with your Airline. It is important that the personal information we hold about you is accurate and current. Please keep us and / or your Airline informed if your personal information changes.
3. Request erasure of your personal information where there is no good reason for us continuing to process it.
4. Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may be able to demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. Please note if we stop processing such data at any time certain functions of the App may be not available and your Airline may object to this. In this eventuality APM will simply follow the instructions of the Airline and it will be your responsibility to resolve the situation with your Airline.
5. Request in writing the transfer of your personal information to you or to a third party.
6. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
   • if you want us to establish the data's accuracy;
   • where our use of the data is unlawful but you do not want us to erase it;
   • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; 要么
   • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

You can exercise any of these rights at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

 

DESCRIPTION OF CATEGORIES OF PERSONAL DATA

• Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, place of birth gender, passport and visa information, identity photograph, next of kin, contract type, airline crew qualification and attribute records, airline crew training records, personal flight preferences.
• Contact Data: personal address, email address and telephone numbers.
• Financial Data: bank account and payment card details.
• Transaction Data: includes details about payments to and from you and details of in-App purchases.
• Device Data: includes the type of mobile device you use, a unique device identifier (例如, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device),mobile network information, your mobile operating system, the type of mobile browser you use and time zone settings.
• Content Data: includes information stored on your Device, including friends’ lists, login information, photos, videos or other digital content, check-ins,.
• Profile Data: includes your username and password, feedback and survey responses.
• Usage Data: includes details of your use of any of our Apps including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
• Location Data: includes your current location disclosed by GPS technology or other similar technology.