Privacy Notice

Version:                  2018-04
Last Updated:       20 April 2018

Introduction

Airangel Limited understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Sites and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.

This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site and You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

This privacy policy is meant to help you understand what data we collect, why it is collected and what we do with it.

The GDPR comes into force on 25th May 2018. This legislation will replace current data privacy law, giving more rights to you as an individual and more obligations to organisations holding your personal data.

One of the rights is a right to be informed, which means we have to give you even more information than we do now about the way in which we use, share and store your personal information. This means that we will be publishing a new privacy notice, so you can access this information, along with information about the increased rights you have in relation to the information we hold on you and the legal basis on which we are using it.

This new privacy notice will be published on this website on 25 May 2018.

  1. Definitions and Interpretation

In these Terms and Conditions, unless the context otherwise requires, the following expressions have the following meanings:

  • “Account” means an account required to access and/or use certain areas and features of Our Site;
  • “Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;
  • “Our Site” means this website, airangelprod.wpengine.com;
  • “UK and EU Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and
  • “We/Us/Our” means Airangel Limited, a company registered in England and Wales under Company No: 494 8173, whose registered address is Unit A, The Beacons, Birchwood Park, Warrington, Cheshire, WA3 6GP, United Kingdom and whose main trading address is Unit A, The Beacons, Birchwood Park, Warrington, Cheshire, WA3 6GP, United Kingdom.
  1. Information About Us

2.1 Our Site, airangelprod.wpengine.com, is owned and operated by Airangel Limited, a limited company registered in England and Wales under Company No: 494 8173, whose registered address is Unit A, The Beacons, Birchwood Park, Warrington, Cheshire, WA3 6GP, United Kingdom and whose main trading address is Unit A, The Beacons, Birchwood Park, Warrington, Cheshire, WA3 6GP, United Kingdom. Our VAT number is GB 860 6694 96.

  1. Scope – What Does This Policy Cover?

3.1 This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

  1. How we use your information

This privacy notice tells you what to expect when Airangel Limited (Airangel) collects personal information. It applies to information we collect about:

When someone visits airangelprod.wpengine.com, or one of our affiliated sites we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

  • Use of cookies by Airangel

The Services may also require us to use cookies. A cookie is a text file, invoked by standard browser software, that we place on your hard drive to enable our systems to, among other things, recognize your browser, track transactions, and allow you to navigate the Service without having to re-enter information. The information gathered by cookies is not made available to organisations. We may also automatically receive and store certain other types of information, such as the type of web browser you use or the pages you browse to for statistical analysis and support purposes.

You can read more about our Cookie Policy here.

  • E-newsletter

We use a third-party provider, Hubspot, to deliver our e-newsletters. We gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our e-newsletter. For more information, please see Hubspot privacy notice.

  • Online reporting tool

We collect information volunteered by clients and members of the public about our products and services using an online reporting tool hosted by SurveyMonkey. This company is a data processor for Airangel and only processes personal information in line with our instructions. For more information, please see SurveyMonkeys privacy notice.

  • Security and performance

Airangel uses a third-party service to help maintain the security and performance of Airangel website. To deliver this service it processes the IP addresses of visitors to Airangel website.

  • Websites

We use a third-party service, WPEngine.com, to publish our website, blog, and some of our affiliated microsites. These sites are hosted at wpengine.com, which is run by WPEngine, Inc. We use a standard WordPress service to collect anonymous information about users’ activity on the site, for example the number of users viewing pages on the site, to monitor and report on the effectiveness of the site and help us improve it. WordPress requires visitors that want to post a comment to enter a name and email address. For more information about how WordPress processes data, please see the WPEngine, Inc privacy notice.

  • People who contact us via social media channels

We use third-party providers, such as Facebook, Twitter, Google and LinkedIn to deliver our social media interactions. If you send us a private or direct message via social media the message will be stored in line with the Social Media platforms own Privacy and Data Retention Policies.it is important to understand that Airangel do not have any control over those policies and you are encouraged to review those independently prior to any communication.

Any private or direct messages will not be shared with any other organisations.

  • People who call our helplines

When you call Airangel helplines, we collect Calling Line Identification (CLI) information. We use this information to help improve its efficiency and effectiveness. We may also record the call for the purposes of training, quality control or dispute resolution.

We may engage with third-party companies to assist in providing 24×7 and specialist technical support services. The companies that provide this service may also retain call records but we will ensure that they are contractually bound to the same privacy and data protection requirements as our own.

  • People who email us

We use Transport Layer Security (TLS) to encrypt and protect email traffic in line with best-practice recommendations. If your email service does not support TLS, you should be aware that any emails we send or receive may not be protected in transit.

We use DKIM (Domain Keys Identified Mail) signatures as an authentication process that can help protect both senders and recipients from forged and phishing emails.

We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.

  • People who make a complaint to us

When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.

We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We do compile and publish statistics showing information like the number of complaints we receive, but not in a form which identifies anyone.

We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.

We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.

Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.

When we take enforcement action against someone, we may publish the identity of the defendant in our Annual Report or elsewhere. Usually we do not, identify any complainants unless the details have already been made public.

  • People who use Airangel services

Airangel offers a variety of WiFi connectivity services to our customers, who then use our platforms to offer their customers and the public guest internet access services. As such, the majority of data we hold on individuals will only be as a requirement to process data on behalf of the Data Controller, which is typically the venue operator.

We have to hold and process the details of the people who have requested the service in order to provide it and for the purposes of meeting country-specific legislative and regulatory compliance. However, we only use these details to provide the service the person has requested and for other closely related purposes. Platform-specific privacy policies will be presented by the relevant Data Controller when a person chooses to connect using our platform.

For example, we might use information about people who have requested a publication to carry out a survey to find out if they are happy with the level of service they received. When people do subscribe to our services, they can cancel their subscription at any time and are given an easy way of doing this.

We may use a third-party to deal with some publication requests, but they are only allowed to use the information to send out the publications.

  • Job applicants, current and former Airangel employees

Airangel is the data controller for the information you provide during the process unless otherwise stated. If you have any queries about the process or how we handle your information please contact us at careers@aiarngel.com.

  • What will we do with the information you provide to us?

All of the information you provide during the process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary.

We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.

We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for.

  • What information do we ask for, and why?

We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary.

The information we ask for is used to assess your suitability for employment. You don’t have to provide what we ask for but it might affect your application if you don’t.

  • Application stage

If you use our online application system, this will be collected by a data processor on our behalf (please see below).

We ask you for your personal details including name and contact details. We will also ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for. Our recruitment team will have access to all of this information.

You may also be asked to provide equal opportunities information. This is not mandatory information – if you don’t provide it, it will not affect your application. This information will not be made available to any staff outside of our recruitment team, including hiring managers, in a way which can identify you. Any information you do provide, will be used only to produce and monitor equal opportunities statistics.

  • Shortlisting & Assessments

Our hiring managers shortlist applications for interview. They will be provided with your name, contact details, your previous experience, education, referees and for answers to questions relevant to the role you have applied for, and with your equal opportunities information if you have provided it.

We might ask you to participate in assessment days; complete tests or occupational personality profile questionnaires; and/or to attend an interview – or a combination of these. Information will be generated by you and by us. For example, you might complete a written test or we might take interview notes. This information is held by Airangel.

If you are unsuccessful following assessment for the position you have applied for, we will ask if you would like your details to be retained in our talent pool for a period of six months. If you say yes, we would proactively contact you should any further suitable vacancies arise.

  • Conditional offer

If we make a conditional offer of employment we will ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer. We are required to confirm the identity of our staff, their right to work in the United Kingdom and seek assurance as to their trustworthiness, integrity and reliability.

  • You will therefore be required to provide:

Proof of your identity – you will be asked to attend our office with original documents, we will take copies.

Proof of your qualifications – you will be asked to attend our office with original documents, we will take copies.

Dependent upon the role, you may be asked to complete a criminal records declaration to declare any unspent convictions.

We will contact your referees, using the details you provide in your application, directly to obtain references

We will also ask you to complete a questionnaire about your health. This is to establish your fitness to work and make provisions, should there be any pre-existing conditions that may affect you or your colleagues safety whilst at work.

If we make a final offer, we will also ask you for the following:

  • Bank details – to process salary payments
  • Emergency contact details – so we know who to contact in case you have an emergency at work
    • Post start date

Airangel have a separate Employee Privacy Policy that covers the storage, processing and protection of your personal data within your employment period and the period after employment terminates. This will be provided through the onboarding process and is available within the Quality & Security Management System.

  • Use of data processors

Data processors are third parties who provide elements of our recruitment and employment service for us. We have contracts in place with our Data Processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.

  • Cascade Go HR

If you use our online application system, you will provide the requested information via a web-based application, operated by who provide this online service for us. Once you click ‘apply now’ you will be taken to Vacancy Filler’s website and they will hold the information you submit but Airangel will have access to it.

If you accept a final offer from us, some of your personnel records will be held on Cascade Go which is an internally used HR records system.

  • How long is the information retained for?

If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus 7 years following the end of your employment. This includes your criminal records declaration, fitness to work, records of any security checks and references.

If you are unsuccessful at any stage of the process, the information you have provided until that point will be retained for 6 months from the closure of the campaign.

Information generated throughout the assessment process, for example interview notes, is retained by us for 6 months following the closure of the campaign.

Equal opportunities information is retained for 6 months following the closure of the campaign whether you are successful or not.

Cascade Go will provide us with management information about our recruitment campaigns. This is anonymised information which tells us about the effectiveness of campaigns, for example, from which source did we get the most candidates, equal opportunities information for monitoring purposes. This anonymised information will be retained for 6 years from the end of the campaign.

  • How we make decisions about recruitment?

Final recruitment decisions are made by hiring managers and members of our recruitment team. All of the information gathered during the application process is taken into account.

You are able to ask about decisions made about your application by speaking to your contact within our recruitment team or by emailing careers@airangel.com.

  1. Your rights

Under the Data Protection Act 1998, and in line with forthcoming GDPR requirements, you have rights as an individual which you can exercise in relation to the information we hold about you.

Under GDPR you have:

  • The right to be informed
  • The right of access
  • The right to rectification
  • The right to erasure
  • The right to restrict processing
  • The right to data portability
  • The right to object
  • Rights in relation to automated decision making and profiling.

More information about an individuals rights can be found here.

  1. Complaints or queries

Airangel tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of Airangels collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.

If you want to make a complaint about the way we have processed your personal information, you can contact us using the contact details below..

  1. Access to personal information

Airangel tries to be as open as it can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by making a ‘subject access request’ under the Data Protection Act 1998. If we do hold information about you we will:

  • give you a description of it;
  • tell you why we are holding it;
  • tell you who it could be disclosed to; and
  • let you have a copy of the information in an intelligible form.

To make a request to Airangel for any personal information we may hold you need to put the request in writing addressing it to support@airangel.com, or writing to the address provided below.

If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.

If we do hold information about you, you can ask us to correct any mistakes by, once again, contacting us using the details provided below.

  1. Disclosure of personal information

In many circumstances we will not disclose personal data without consent. However when we investigate a complaint or respond to a law enforcement agency, for example, we will need to share personal information with the organisation concerned and with other relevant bodies. Where allowed, we will inform you of the factors we shall consider when deciding whether information should be disclosed.

We may disclose your personal information when we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be violating our T&Cs or to protect the safety, property or other rights of our users or the public.

We also may disclose your personal information if we believe in good faith that we are required to do so in order to comply with applicable law or other legal process. We will only disclose this data when requested from a Law Enforcement Agency, and will do so responsibly, protecting the confidentiality, integrity and availability of that data during this process. Disclosure in this instance does not require your consent.

  • Data Transfer

As part of operating the website and providing the Services, we may transfer personal data to a third country where this is legally permissible, and we have appropriate adequacy conditions in place, such the EU-US Privacy Shield (or equivalent), approved ‘Model Contract’ clauses, Binding Corporate Rules and contractual confidentiality agreements.

If your personal information is transferred to a server located outside of the country in which you access the website or Services, we operate technical and organisational controls to ensure that you’re the confidentiality, integrity and availability of your data is maintained, through an internationally recognised certification mechanism (ISO/ICE 27001).

  1. Links to other websites

This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.

  1. Changes to this privacy notice

We keep our privacy notice under regular review. This privacy notice was last updated on 20 April 2018.

  1. How to contact us

If you want to request information about our privacy policy, you can email us at support@airangel.com or write to:

The Data Protection Team
Airangel Limited
Unit A, The Beacons,
Birchwood Park
Warrington
Cheshire
WA3 6GP

Contains public sector information licensed under the Open Government Licence v3.0