Privacy Policy

1. Wha is the Privacy Notice about ?

The Sparfell group (“Sparfell” or “we”) is committed to protecting and respecting your privacy. 

The Sparfell group means Sparfell Group SA, Chemin des Papillons 18, 1215 Geneva, Switzerland and its affiliated companies listed here https://www.sparfell.aero/contact/. 

In this Privacy Notice, we describe what we do with your personal data (“data” or “personal data”) when you obtain services or products from us, interact with us in relation to a contract, communicate with us or otherwise deal with us or when you use the website sparfell.aero (the “website”). When appropriate we will provide a just-in-time notice to cover any additional processing activities not mentioned in this Privacy Notice. In addition, we may inform you about the processing of your data separately, for example in consent forms, terms and conditions, additional privacy notices, forms and other notices.

If you disclose data to us or share data with us about other individuals, such as for instance family members or coworkers, we assume that you are authorised to do so and that the relevant data is accurate. 

This Privacy Notice is aligned with the Swiss Data Protection Act entered into force on 1^st September 2023 (“DPA”) and with the EU General Data Protection Regulation (“GDPR”), it being specified that the application of these regulations depends on each individual case.

2. Who is the controller for processing your data?

You may contact us for data protection concerns and to exercise your rights under Section 9 as follows:

Sparfell Group SA
Chemin des Papillons 18
CH-1215 Genève
HR@sparfell.aero

We have appointed the following data protection representative in the EU: 

Sparfell Luftfahrt GmbH
General Aviation Terminal 
Niki Lauda Allee 1

A-1300 Vienna Airport
HR@sparfell.aero

3. Which data do we process and for which purpose?

We may obtain the following categories of personal data about individuals through direct interactions with us or indirectly from a variety of sources, including public sources, social network sites, business clients, suppliers or visitors to our website or to our events.

In some situations, the provision of personal data is required to provide certain services. In such cases, this will be indicated on our website or pointed out in the disclaimers or contractual agreements. We may also be required to collect certain personal data by law. If you fail to provide such data, we may not be able to provide the services, or we may have to cancel a product or service you have ordered from us.

a.          Clients and individuals associated with our clients

In connection with the provision of our contracted services to our clients, we process personal data that we need to provide the services and to protect our interests, and that we require by law or other binding regulations.

In this context, we commonly process the following personal data: 

• for certain services, such as for instance immigration services, or with the data subject’s consent, we may also process special categories of personal data such as information about religious beliefs, physical or mental health, biometric data, sexual orientation, excerpts from the debt register or criminal records.
• : although our services are not intentionally designed for or directed at children, we may occasionally receive details about children as part of our services to clients travelling with children. 

We process personal data for the following purposes:

We do not perform profiling or undertake any automated decision-making when processing personal data provided by our clients.

b.          Suppliers and individuals associated with our suppliers

We collect and process personal data about our suppliers, including subcontractors and individuals associated with our suppliers and subcontractors, to manage the relationship, to receive services from our suppliers and, where relevant, to provide professional services to our clients. 

We commonly process contact details, such as name, job title, work and private telephone numbers, work and personal e-mail addresses and other contact details.

We process personal data for the following purposes:

c.          Sparfell event attendees

When you attend a Sparfell event, we commonly process the following personal data: 

We process personal data for the following purposes:

d.          Website visitors

When you visit our website or contact us through our website, we commonly process the following personal data:

We process personal data for the following purposes:

For the use of cookies, please refer to Section 10 below. 

e.          Other persons in contact with Sparfell 

We may process personal data of employees of public authorities or other persons who are in contact with Sparfell. 

This may include contacting journalists regarding market insights, corporate news, invitations to press conferences or events or highlighting messages that may be of interest on specific industry topics. 

The type of personal data may vary depending on the context of your contact with us. 

4.      On which basis do we process your data?

We may rely on the following reasons when we collect and use data to operate our business and provide our products and services:

• contract: we may process personal data to fulfil our contractual obligations.
• consent: we may rely on your freely given consent at the time you provided us with your personal data.
• legitimate interests: we may rely on legitimate interests based on our assessment that the data processing is fair, reasonable and balanced. These interests may include to deliver the services and products our clients have engaged us to provide or to deliver timely industry insights and professional knowledge, offerings and invitations we believe are welcomed by our business clients, prospects, subscribers and other individuals.
• legal and regulatory obligations and litigation: we may process personal data to meet legal and regulatory obligations or in the event of a dispute for the enforcement or defense of legal claims. 

5.      Do we share your data?

In relation to our contracts, the website, our services and products, our legal obligations or otherwise with protecting our legitimate interests and the other purposes set out in Section 3, we may disclose your personal data to third parties, in particular to the following categories of recipients: 

• group companies: we may share personal data with other companies of our group where necessary for administrative, quality control or risk management purposes and to provide professional services to our clients. The list of our group companies is available in Section 1. 
• external service providers: we may disclose your personal data to our external service providers so that they can provide these services. This may include IT services, marketing, sales, communication or printing services, facility management or security agencies. 

• authorities: we may disclose personal data to agencies, customs, courts and other authorities in Switzerland and abroad if we are legally obliged or entitled to make such disclosures or if it appears necessary to protect our interests. 
• other persons: this means other cases where interactions with third parties follows from the purposes set out in Section 3.

All these categories of recipients may involve third parties, so that your data may also be disclosed to them. We can restrict the processing by certain third parties, such as IT providers, but not by others, such as authorities, courts or banks. 

6.      Is your data disclosed abroad?

To provide our services and/or to operate the website, we may be required to transfer your data to third parties not only in Switzerland but also abroad (in particular, service providers with which we cooperate and to whom we provide data, such as airport handling companies, customs or authorities). 

Not all countries may have laws that protect your personal data to the same extent as in Switzerland or the European Union. If we transfer your personal data to such a country, we will ensure the protection of your personal data in an appropriate manner, generally by signing recognised data protection agreements. Please note that such contractual arrangements can partially compensate for weaker or missing statutory protection but cannot rule out all risks completely (such as government access abroad). Data may also be transferred to countries without adequate protection in exceptional cases, for example if consent is granted, in connection with legal proceedings abroad, or if transfer is necessary for the processing of an agreement.

7.      How long do we process your data?

We seek to ensure that we only keep your personal data for the longest of:

• the period necessary for the relevant activity or services;
• any retention period that is required by law; or
• the period in which litigation or investigations might arise in respect of the services.

8.      How do we protect your data?

We use a range of measures to ensure we keep your personal data secure, accurate and up to date. These include:

• education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal data;
• administrative and technical controls to restrict access to personal data to a ‘need to know’ basis;
• technological security measures, including fire walls and anti- virus software; and
• physical security measures, such as security passes to access our premises.

When connecting to the website or with any electronic communication with Sparfell, your data go through a public network accessible to all. It may also occur that data cross borders, even if the sender and recipient live in the same country. It is possible that third parties have access to such information.

Although we make every effort to protect all data, we are not responsible for the security of data that are transmitted on the internet, since it is not possible to guarantee total safety transmissions over the internet. They are communicated at the client’s own risk. However, we make every effort to ensure their privacy, from when they are introduced in our system and to prevent such data to be transmitted to third parties other than those possibly involved for providing the services agreed upon between you and any entity of Sparfell.

We are not responsible for any damage or loss suffered, of any nature whatsoever, due to an error, technical or otherwise, a transfer failure, an overload situation, difficulty of use, interruption of services, a delay in the transmission of information, an incompatibility between the website and files or the client’s software (including his “browser” and/or computer), malfunction, interference, transmission of a virus or a worm to his computer, illegal access (for example due to hackers), the intentional blocking tools and telecommunications networks (e.g. after sending a mass e-mails or denial of service attacks) or any other inappropriate telecommunications service providers or networks is excluded.

9.      What are your rights?

You have the following rights in relation to our data processing, depending on the applicable data protection law: 

• to request information from us as to whether and what data we process from you;
• to have us correct data if it is inaccurate;
• to request erasure of data;
• to request that we provide certain personal data in a commonly used electronic format or transfer it to another controller;
• to withdraw consent, where our processing is based on your consent;
• to receive, upon request, further information that is helpful for the exercise of these rights;

If you wish to exercise the above-mentioned rights, please contact us as specified in Section 2 above.  

To report concerns you may have about our data processing practices, you can contact the data protection supervisory authority in Switzerland:

Federal Data Protection and Information Commissioner

Feldeggweg 1

CH – 3003 Bern, Switzerland 

www.edoeb.admin.ch 

Based on your residence, you may have the possibility to file a complaint with the appropriate data protection authority of your place of residence, such as, for EU residents, the EU data protection authority in your jurisdiction: https://edpb.europa.eu/about-edpb/about-edpb/members_en

10.      Do we use cookies ?

When you access our website, our system automatically records technical information about your computer. Our system collects information about the browser type and the version used, the operating system, the internet provider and the IP address of the user, the date and time of access, the websites from which the user’s system obtains access to our website, and the websites accessed by the user’s system via our website. 

Cookies are small text files that store information about your interactions with a particular website, either temporarily or more permanently on the hard drive of your computer. Cookies can make it easier to use a website by allowing servers to access certain information quickly. Sparfell also uses performance cookies to obtain information about visitors’ use of our website in order to improve the content of our website and make it more user-friendly. 

When you visit our website for the first time, we will show you a pop-up with an explanation about cookies. As soon as you click on “Save preferences”, you consent to us using the categories of cookies and plug-ins you selected in the pop-up. 

You can refuse the installation of cookies via your browser settings. You can also remove cookies already installed on your computer or mobile device at any time. If you decline cookies on the website, some functions on the website may be limited or unavailable. 

Sparfell may use “web beacon” technology to gather metrics from anonymous web users and email recipients for the purpose of operating and improving websites and e-mail communications. A web beacon is an electronic image that is imbedded in a web page or email which allows to track web page views/hits or the opening of an e-mail containing a beacon. Sparfell may use web beacons in conjunction with cookies to track website activity on sparfell.aero and associated websites. Web beacon tracking by Sparfell does not identify the name or email address of the web user or mail recipient.

10.      Can we update this Privacy Notice ?

This Privacy Notice does not form part of any contract with you and we may amend it at any time. The version published on our website is the version that currently applies.

Last update: 07/03/2024