Privacy Policy

1. Introduction

Palmyra Aviation Advisors BV ("we," "our," or "us") is committed to protecting your privacy and ensuring compliance with the General Data Protection Regulation (GDPR). This Privacy Policy explains how we collect, use, process, and protect your personal data when you visit our website or use our services.

2. Legal Basis for Processing

We process your personal data under the following legal bases:

• Consent: When you provide explicit consent for specific processing activities
• Contract: When processing is necessary for contract performance
• Legitimate Interest: For business operations, security, and service improvement
• Legal Obligation: When required by applicable laws and regulations

3. Data We Collect

3.1 Information You Provide

• Contact information (name, email)
• Professional information (company, position, aviation experience)
• Inquiry details and service requirements
• Training and certification records (for our clients)
• Communication preferences and consent records

3.2 Information Automatically Collected

• IP address and geolocation data
• Browser type, version, and settings
• Device information and operating system
• Website usage patterns and analytics data
• Cookies and similar tracking technologies

4. How We Use Your Data

• Responding to your inquiries and providing requested services
• Processing and fulfilling service contracts
• Providing aviation consulting, training, and K9 certification services
• Maintaining client records and service history
• Sending relevant industry updates and service information (with consent)
• Improving our website and services
• Ensuring security and preventing fraud
• Complying with legal and regulatory requirements

5. Data Sharing and Disclosure

We may share your personal data with:

• Service Providers: Trusted third parties who assist in our operations
• Regulatory Bodies: When required for aviation compliance and certification
• Legal Authorities: When required by law or legal process
• Business Partners: For joint training programs or certification services (with consent)

We do not sell, rent, or trade your personal data to third parties for marketing purposes.

6. International Data Transfers

If we transfer your data outside the European Economic Area (EEA), we ensure adequate protection through approved mechanisms such as Standard Contractual Clauses or adequacy decisions by the European Commission.

7. Data Retention

We retain your personal data for the following periods:

• Contact inquiries: 3 years from last contact
• Client records: 7 years from contract completion (regulatory requirement)
• Training records: 10 years (aviation industry standard)
• Marketing consent: Until consent is withdrawn
• Website analytics: 26 months

8. Your Rights Under GDPR

You have the following rights regarding your personal data:

• Right of Access: Request copies of your personal data
• Right to Rectification: Request correction of inaccurate data
• Right to Erasure: Request deletion of your data (subject to legal obligations)
• Right to Restrict Processing: Limit how we use your data
• Right to Data Portability: Receive your data in a structured format
• Right to Object: Object to processing based on legitimate interest
• Right to Withdraw Consent: Withdraw consent at any time

To exercise these rights, please contact us using the information below. We will respond within one month.

9. Cookies and Tracking

We use cookies and similar technologies to enhance your browsing experience. For detailed information about our cookie usage, please see our Cookie Policy.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. This includes encryption, access controls, regular security assessments, and staff training.

11. Data Breach Notification

In the event of a data breach that poses a high risk to your rights and freedoms, we will notify you within 72 hours of becoming aware of the breach, as required by GDPR.

12. Children's Privacy

Our services are not directed to individuals under 16 years of age. We do not knowingly collect personal data from children under 16. If we become aware of such data collection, we will delete it promptly.

13. Updates to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will notify you of significant changes and post the updated policy on our website with a new effective date.

14. Contact Information

15. Supervisory Authority

If you believe we have not handled your personal data appropriately, you have the right to lodge a complaint with the Belgian Data Protection Authority (APD/GBA) at www.dataprotectionauthority.be.