As an EU licensed Airline Operator, LIFE LINE AVIATION is regulated by the EU and Greek legislation (Greece being our home-base of operations), the generally acceptable and applicable aviation rules and the standard operating procedures (SOPs) of the airports we operate. At LIFE LINE AVIATION we are committed to conducting our business in accordance with all applicable Data Protection laws and regulations and in line with the highest standards of ethical conduct.
As of May 25th, 2018 we conform to the rules of the General Data Protection Regulation (GDPR EU 2016/681). We have adopted a Policy that sets forth what we are expected to do when we handle the personal data of our Passengers, Employees, Business Relations and Third Parties. We have additionally adopted appropriate technical and organisational measures to ensure compliance with the GDPR.
What we mean by Personal Data
Personal Data means any information relating to natural persons that is or can be identified, even indirectly, by reference to any other information including a personal identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
We hold Personal Data of sensitive nature only when necessary, including personal health and information on minors. Personal Data is subject to certain legal safeguards and other regulations, which impose restrictions on how organisations may process Personal Data. LIFE LINE AVIATION complies with specific rules related to the processing of special categories’ data, such as collecting specific informed consent from the natural person concerned and applying stricter safeguards.
When does our Policy apply to you
We will need a certain amount of personal data to ensure that we offer to you a flight or a service of your choice and then make sure that you are on board the flight you booked on our network and that you receive the requested services. You will always be informed on the details we request and the reason we collect and maintain your data. When you are not in direct contact with us for the purpose of flying in one of our flights, our www.lifelineaviation.com site will always be up-to-date on the applicable policy, or you can send us your question, request or comment by using our privacy e-mail pa@lifelineaviation.com.
When you decide to contact us and or make your travel arrangements with LIFE LINE AVIATION, you need to know that we take all measures to make sure that you are always in control of your personal details, so take some time to check out the rights you have under our Data Protection Policy.
Data Categories
We may collect, hold and process any of the following data categories:
Your name and surname and your contact details (email address, telephone number and postal address).
Information about your booking and your travel itinerary, if you require special assistance or if you have specific requirements. This information may include any changes to your bookings.
Information about your health, if you have a medical condition that may affect you when on board.
Information about other passengers in your booking, and the age range of any children traveling with you.
Information about children travelling unaccompanied and the personal details of their guardians.
Information about your transaction, including your payment card details.
Passenger Name Record. This might include information such as date of travel, travel itinerary, ticket information, full name, date of birth, your nationality (where required), your gender – the number and type of your travel document (e.g. passport or ID), its expiry date and country of issue.
Information related to your flight and our services in connection with your flight (e.g. boarding time, declaring lost luggage)
Information about your purchases of our partners’ travel related products and services.
Communications you exchange with us (for example, your emails, letters or calls)
Information about how you use our website such as your searches for flights
Your posts and messages on social media directed to LIFE LINE AVIATION
When you book a flight
When you make a hotel reservation
When you book or manage your flight or hotel booking
When you provide us with this information before you fly
When you make a booking on behalf of other passengers
When parents request a UM service
When you purchase products and services
Accordingly, when you you’re booking and after you board your flight
When you take a LIFE LINE AVIATION flight
When you use our services at the airport
When you purchase such products or services
When you contact LIFE LINE AVIATION or you are contacted by LIFE LINE AVIATION
When you navigate on our website
When you interact with us on social media
We process your data with care
LIFE LINE AVIATION will Process Personal Data in accordance with all applicable laws and applicable contractual obligations. More specifically, LIFE LINE AVIATION will not Process Personal Data unless at least one of the following requirements are met:
• The Data Subject has given Consent to the Processing of their Personal Data for one or more specific purposes.
• Processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract.
• Processing is necessary for compliance with a legal obligation to which the Data Controller is subject.
• Processing is necessary in order to protect the vital interests of the Data Subject or of another natural person.
• Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller (LIFE LINE AVIATION).
• Processing is necessary for the purposes of the legitimate interests pursued by the Data Controller (LIFE LINE AVIATION) or by a Third Party (except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Subject, in particular where the Data Subject is a child).
Personal Health Information is only collected as part of standard regulatory requirement under IATA rules and the respective airline SoPs, for the purpose of ensuring safety on board. Such information is granted with the consent of Data Subjects as part of their valid ticket and are maintained by LIFE LINE AVIATION for a period not to exceed three (3) months, in case of nondisrupted
flights. Special rules and retention rights may apply to other instances, as identified in the LIFE LINE AVIATION Data Retention Policy Chart.
Consent when relevant to Children is sought from the person who holds parental responsibility over the child. However, it should be noted that where Processing is lawful under other grounds, Consent need not be obtained from the child or the holder of parental responsibility.
According to IATA regulation, minors, accepted as unaccompanied travellers, require special documentation and file preparation, which is processed in accordance with the standard guidelines for the purpose, the files of which are transferred to the cabin crew of the airline and the airline itself for safe keeping. The consent of the legal guardians of such minors is always obtained, otherwise no Unescorted Minor can conclude an air trip. The strictest rules apply when processing a trip file that contains UM Personal Data.
Why will we use your personal data
We will use your information because we need:
• To get you on board the flight you booked
• To secure your boarding process
• To deliver to you any service requested
• To make sure we can get you on board your connecting flight
• To update you on our recent network and service expansion and share with you our current offers and news
• To communicate any flight disruptions or program cancellations timely
• To keep you safe when you fly with us
• To comply with our legal and regulatory requirements
• To run statistical analyses that will help us do better and more for you
• To improve our website, products and services.
We will respect your choice as to what communications you wish to receive and how these are sent.
We have principles
LIFE LINE AVIATION has adopted the following specific data protection principles to govern its collection, use, retention, transfer, disclosure and destruction of Personal Data for the Processing to be legitimate:
• Principle 1: Lawfulness, Fairness and Transparency through our implemented management practices
You will always know WHAT, HOW and WHY
• Principle 2: Purpose limitation
It’s always specific and legitimate
• Principle 3: Data minimization
Never held beyond what is strictly required or beyond the period for which it is absolutely required.
• Principle 4: Data Accuracy
Personal data shall be accurate, and, where necessary, kept up to date.
• Principle 5: Storage Limitation
Kept no longer than is necessary for the purpose
• Principle 6: Integrity & Confidentiality
Secure against loss.
• Principle 7: Accountability
You will provide you with information as requested and required.
If you have made a flight booking through a third party that party might be considered as a Data Controller, under European Union and Greek Data Protection Law. Make sure that you consent to provide your personal information to that third party for the purposes that this party provides. The data requested might not be relevant to our service.
ALWAYS make sure that you contact us for your personal data you provided to us. Booking your flight through our website www.lifelineaviation.com, you can always rely on our Personal Data Privacy Policy promise.
You Have Rights
The EU General Data Protection Regulation (effective as of 25 May 2018) requires that every data controller, including airlines, facilitate the exercise of the data subject’s rights and communicate the information requested in an intelligible and easy to access form.
We at LIFE LINE AVIATION have worked to establish a system to enable and facilitate the exercise of your right as Data Subjects. You may write to our Privacy Officer at pa@lifelineaviation.com for questions.
Be always alert that when it comes to your personal information the following rights apply:
• Your right to access information we may hold on you
• Your right to object to processing of any personal information
• Your right to object to automated decision-making and profiling
• Your right to restrict our right to processing
• Your right to request a Data portability
• Your right to request Data rectification
• Your right to request Data erasure
ALWAYS NOTE that we have a commitment to ensure that data requested by us are essential for concluding your flight, taking you to the desired destination and offering services ancillary to your flight coupon. We may be requested by authorities to process personal data for safety and security reasons.
We will respect your choice as to what you want us to do with your Personal Data.
How and why do we share your Personal Data
LIFE LINE AVIATION needs to rely on the services of third contracted parties to complete the services you requested.
Whenever a Third-Party Processes Personal Data on behalf of LIFE LINE AVIATION – that is, whenever LIFE LINE AVIATION delegates part of the Processing activities to an external business – LIFE LINE AVIATION enters into a written agreement. When entrusting Third-party with Processing activities, LIFE LINE AVIATION assess whether the service provider provides sufficient guarantees to ensure compliance with the GDPR, has implemented appropriate controls to meet data protection requirements defined by the agreement, instructions and/or legal requirements and to ensure the protection of the rights of Data Subjects.
Entities and individuals who process Personal Data under the authority of LIFE LINE AVIATION as Data Processors receive specific formal instructions. LIFE LINE AVIATION gives specific instructions, relating to the implementation of security measures and safeguards, to all of its Employees / Personnel in charge of Processing Personal Data.
Data breaches
Should a data breach occur, GDPR sets forth that LIFE LINE AVIATION/Controller has to notify such Breach to the Supervisory Authority providing specific information, without undue delay and in any case no later than 72 hours from the time of knowledge.
When the breach leads to significant risk of serious adverse effects on the data subject(s) or serious adverse consequences for the protection of Personal Data, those individuals shall also be informed without undue delay.
Any individual who suspects that a Personal Data Breach has occurred due to the theft or exposure of Personal Data must immediately notify the Privacy Office of LIFE LINE AVIATION and provide a description of what occurred. Notification of the incident can be made to the Privacy Office via email pa@lifelineaviation.com. All incidents are retained for training purposes, anonymised or pseudonimised.
The Privacy Office shall investigate all reported incidents to confirm whether or not a Personal Data Breach has occurred. If a Personal Data Breach is confirmed, the Privacy Office shall follow the relevant authorised procedure based on the criticality and quantity of the Personal Data involved.
For severe Personal Data Breaches, LIFE LINE AVIATION General Counsel with the support of the Data Protection Officer will initiate and chair an emergency response team to coordinate and manage the Personal Data Breach response.
The PNR Directive and our obligations
We may be obliged, at any time, to submit your data to an official authority in order to comply with legal obligations or requirements, such as PNR Directive obligations or other passenger specific legal obligations.
Requests in relation to your personal information
You may always contact our Data Protection Office at privacy@skyexpress.gr using the details of Your Right to Access.
YOUR RIGHT TO ACCESS
In order to request a copy of the personal data that LIFE LINE AVIATION holds about you, please email pa@lifelineaviation.com
When contacting our Data Protection Office use always an e-mail subject “Personal data request” clearly stating the following personal information:
Your full name
• a description of the data that you are requesting (such as flights booked/ flown with LIFE LINE AVIATION), including an approximate date of reservation and the date/number of flight
• all email addresses (past and present) used to book flights and
• attach to the email a copy of your current and valid photo ID (e.g. passport photo page).
• The name of the booking engine and /or travel agent you used for booking your flight if you have not directly accessed our web page for your purchase.
The above information is absolutely essential to allow us to track the details you request and will be used solely for the purpose of responding to your request..
From the date that we receive ALL of the Required Information, we have – under the relevant legislation – 40 days to process your request.
Whilst we will make all reasonable effort to process your request within this deadline, we cannot guarantee that this will be the case.
Please note that:
• any missing information will delay the processing of your request; and
• LIFE LINE AVIATION reserves the right to charge an administration fee of € 5 in processing your request, in accordance with the relevant legislation.
By successfully concluding our search your request will be held anonymized in our files for Data Processing Requests, as provided for by the GDPR rules.
Please email pa@lifelineaviation.com if you have any questions.