PRIVACY POLICY

Last revised October 17, 2020

Sirio S.p.A. recognises the importance of our customers’ privacy. Privacy is more than an issue of compliance – it is one of trust. With that in mind, our Privacy Policy is based on our basic belief of respect for the individual. This Privacy Policy describes:

  • The types of personal information we collect and how we collect it.
  • How we use the personal information we collect.
  • With whom we share your personal information.
  • The choices you can make about how we use your personal information.
  • How we protect your personal information.

We may update this Privacy Policy from time to time. When we change the policy in a material way, a notice will be posted on our website along with the updated Privacy Policy.

WHAT TYPES OF PERSONAL INFORMATION DOES SIRIO S.p.A. COLLECT?

Information You Give Us: We receive and store any information you enter on our website, enter into our mobile apps, or give us in any other way. You provide information to us when you buy a jet card, request a quote or book a flight, create or update your account, communicate with us by phone, e-mail, or otherwise, or complete a questionnaire or a contest entry form. Depending upon which actions you take, we may collect such information as your name, address, phone numbers and email addresses; credit card information; travel plans and flight participants; and financial information, among other things.

Technical Information: We receive and store certain types of technical information whenever you interact with us online or over the phone. Like many websites, we use “cookies,” and we obtain certain types of information when your web browser accesses Sirio S.p.A. This information may include your IP address, website login information, e-mail address, computer operating system and browser information, purchase history, clickstream to, though, and from our website, and the phone number you used to call us.

Please note that we never collect or maintain information at our websites from persons we know to be under age 18, and no part of our website is designed to attract anyone under age 18. Please do not communicate with or contact us if you are under age 18.

HOW DOES SIRIO S.p.A. USE COOKIES?

What Are Cookies?

A “cookie” is a small file of letters and numbers that is placed on your computer or mobile device and that that allows us to record certain pieces of information whenever you visit or interact with our websites, services, applications, messaging, and tools. Cookies can be in the form of session cookies or persistent cookies. Session cookies are deleted from your device when you close your browser. Persistent cookies will remain stored on your device until deleted or until they reach their expiration date.

How Does Sirio S.p.A. Use Cookies?

We use cookies to distinguish you from other users of our website and to provide a secure browsing experience that is unique to you. We also use cookies so that our website can remember what you have done while browsing it, for instance, your log-in details, how far you have progressed with a flight reservation, and so on. Where applicable, we protect our cookies to help ensure that only we and/or our authorized service providers can interpret them by assigning them a unique identifier that is designed for interpretation only by us. We don't store any of your personal information on any of our cookies or other similar technologies.

What Cookies Does Sirio S.p.A. Use?

  • Analytical/performance cookies. These cookies allow us to recognise and count the number of visitors to our website and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example by ensuring that users are finding what they are looking for easily.
    - Google Analytics

  • Functionality cookies. These cookies are used to recognise you when you return to our website. This enables us to personalise our content for you and remember your preferences.
    - No functional cookies currently being tracked.

  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
    - No targeting cookies currently being tracked.

What Kinds of Information Does Sirio S.p.A. Collect by Using Cookies?

We may use cookies to collect any of the information described in the section above entitled “WHAT TYPES OF PERSONAL INFORMATION DOES SIRIO S.P.A. COLLECT?”. We may collect this information whether or not you create an account or make a purchase with us.

Your Consent to Our Use of Cookies

Visiting our website with your browser settings adjusted to accept cookies or using our mobile app tells us that you want to use our products and services and that you consent to our use of cookies to provide them to you as described in this Privacy Policy. See below for information on how to modify the settings in your device to notify you when you receive a new cookie and disable cookies altogether.

HOW DOES SIRIO S.p.A. USE MY PERSONAL INFORMATION?

We use your information to support our core business functions. These functions generally include communicating with you, delivering and improving our services, and preventing fraud and other losses. Some examples are:

  • To fulfil your requests for services and communicate with you about those requests.
  • To register and service your account.
  • To administer surveys and promotions.
  • To help us improve and customise our service offerings, websites, and advertising.
  • To send you information about our products, services, and promotions, and to provide related customer service.
  • To protect the security and integrity of our website, all data collected by us, and our business.

To accomplish these purposes, we may combine personal and non-personal information we collect with offline information, including information from third parties. We may transfer or disclose your information within our corporate family of companies for these purposes.

We have also implemented Google Analytics features based on Display Advertising, including Remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting. With these services, we and third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) together to inform, optimise and serve ads based on past visits to our website. To opt out of Google Analytics services, please see “Google Analytics” under the heading “How can I change the way Sirio S.p.A. collects and uses my information?” below.

For Our European Customers: Sirio S.p.A. is [owned by a company] with primary operations located in the United States. In order for us to provide you with the services we offer, it is necessary for us to transmit the information that you provide to us or that we collect from you to the United States. The United States may have different and/or less stringent privacy/data protection and data security rules than those of your own country. As a result, your personal information may be subject to access requests from governments, courts, or law enforcement in the United States according to its laws. We have complied with the EU Data Protection Directive 95/46/EC framework as set forth by the European Union regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. We have also certified that we adhere to the requirements of notice, choice, onward transfer, security, data integrity, access and enforcement.

By proceeding to use our website or any of our mobile apps, you consent to the transmission of your personal information to the United States. If you do not want us to transmit your personal information to the United States, please do not use our website.

HOW DOES SIRIO S.p.A. SHARE MY PERSONAL INFORMATION?

Information about our customers is an important part of our business, and we are not in the business of selling it to others. We share customer information only as described in this policy and with our affiliated companies (some of which are located outside the European Economic Area) that follow practices at least as protective as those described in this Privacy Policy. Except as set forth in this Privacy Policy, we do not sell, rent, share, or otherwise disclose your personal information to third parties.

Third Party Services. Other companies and individuals perform services for us on a regular basis, and we may provide them with your personal information so that they may perform those services. Examples of these services include conducting flight operations, analysing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit card payments, and providing customer service. These companies will have access to your personal information needed to perform their designated functions, but they may not use it for other purposes. For more information on the specific third parties that provide these services, please contact the Data Protection Officer using the contact information below.

Legal Requirements. We release account and other personal information when we believe release is appropriate to comply with the law, to enforce or apply our terms and conditions and other agreements, or to protect the rights, property, or safety of Sirio S.p.A., our users, or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction. This does not include selling, renting, sharing, or otherwise disclosing personal information from customers for commercial purposes in violation of the commitments set forth in this Privacy Policy.

Business Transfers. We may transfer any information we have about you to a third party in connection with a merger or sale involving all or part of our business or as part of a corporate reorganisation or stock sale or other change in corporate control.

HOW DOES SIRIO S.p.A. PROTECT MY PERSONAL INFORMATION?

We maintain a security program intended to keep the personal information stored in our systems protected from unauthorized access and misuse. Our systems are configured with data encryption, or scrambling technologies and firewalls constructed to industry standards. We also use Secure Socket Layer (SSL) technology that protects the data you send over the Internet. Personal information may only be accessed by persons within our organizations or our third parties to carry out the uses indicated in this Privacy Policy.

HOW DOES SIRIO S.p.A. STORE MY PERSONAL INFORMATION?

The personal information that we collect from you may be stored and processed in the United States, Europe, or any other country in which we or our affiliates or services providers maintain facilities. We may transfer information that we collect about you, including personal information, across borders from your country to other countries around the world. If you are located in a country with laws governing the collection and use of data that differ from those of the United States, please note that we will not transfer your personal information to a country or jurisdiction that does not have data protection laws that are a least as protective of those in your country or jurisdiction.

To make a subject access request, please click HERE or email us at privacy@sirio.aero

HOW DO I ACCESS AND CORRECT THE INFORMATION SIRIO HAS RECEIVED FROM ME?

You can contact the Data Protection Officer using the contact information below to determine if we are keeping personal information about you. If we do have personal information about you, we will provide you with a readable copy of that information at no charge. You may correct factual errors in your personal information by sending us a request that sufficiently details how your personal information should be corrected. We encourage you to promptly update your personal information if it changes.

To make a subject access request, please click HERE or email us at privacy@sirio.aero

HOW CAN I CHANGE THE WAY SIRIO COLLECTS AND USES MY INFORMATION?

Our business provides highly personalized services, and access to our customers’ personal information is essential to our ability to provide those services. You can always choose not to provide us with your personal information or to alter our ability to collect information about you, but you may be unable to take advantage of our products and services as a result.

Cookies. The “Help” feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Most mobile devices allow you to turn off location-based services as well. Because cookies and location-based services allow you to take advantage of some of the essential features of Sirio S.p.A. com and our mobile apps, we recommend that you leave them turned on.

Click here to manage your cookie settings.

Google Analytics. If you would like to opt-out of Google Analytics for display advertising, you may do so by using the Google Ads Preferences Manager. You may also download a Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout/

Direct Contact Opt-Out If you prefer not to receive information from us (either through email or regular mail), or if you would like us to delete your personal information from our systems for any reason, please contact The Data Protection officer via email using the information below. Please note that such requests may take up to 30 days to take effect.

Objections and Deletion Requests. You have the right to object to our processing of your information, to withdraw your previously provided consent to our processing your information, and to the deletion of your personal information from our databases. To do any of these things, please contact The Data Protection officer using the contact information below.

To make a subject access request, please click HERE or email us at privacy@sirio.aero

Complaints?

CONTACT INFORMATION

You can email your complaints or request to:

privacy@sirio.aero

or write to us at:

Viale dell'Aviazione,65,

20138 Milano MI,

 Italy