Privacy Policy

Report and agreement for the use of personal data
Legislative Decree No.196, Article 13, of 30 June 2003

Air One S.p.A considers the privacy of its customers to be of fundamental importance and guarantees that the use of personal data by its website will be carried out in full respect of the fundamental rights, freedom and dignity of the person concerned, with particular reference to confidentiality, personal identity and the right to protection of personal details. To this end, Air One has adopted and implemented a Privacy Policy for all that concerns the method of management of the website in reference to the use of the customer's personal details. This is a report that is also covered by Article 13 of  "The Code on the Subject of Personal Data Protection", (Legislative Decree 196/2003)

We urge you to look at the following Privacy Policy and to check it well regularly, for eventual updates or revisions should they become necessary.

Definition of "Personal Details"
For the purpose of the present Policy, as specified more fully in Article 4 of the Code, by "Personal Details" we mean - "any information regarding any one individual person, board, corporation or association, identified or identifiable, even indirectly, by means of reference to any other information, including a personal identification number".

The present Privacy Policy applies to the personal details collected on Air One ’s website and/or through the Company’s e-mail inbox. It does not apply to personal details collected in "off-line" mode, except where these are combined with others collected by Air One on-line. Furthermore, it does not apply to other websites belonging to third parties that may be accessed by means of Hyperlinks, for the reason that Air One does not manage or control the content of these sites.

The following personal details may be collected by Air One through their website: given name, surname, address, e-mail address, information classified merely for statistical reasons during site navigation, other information furnished voluntarily by the user through the on-line registration procedure or the compiling of requisite fields, modules etc. This information is aimed at facilitating site navigation.

Process Method
Users may access various sections of the website without having to give any personal information. Air One collects and processes personal details on-line through its own website or other of its Company e-mail addresses. This processing is mostly automated in the following ways:

1.Details given voluntarily by the user
Air One collects personal details and other data that is inserted into registration forms or module fields on the website, as well as details and data sent to the Company by e-mail. These details may be necessary to provide the services required to the interested party (e.g. Newsletters) and/or for contacting them: - name, postal address, e-mail address, telephone number, UserID and Password – or even date of birth, professional credentials, hobbies and interests of the user.

2.Navigation data collected by means of electronic tools
The IT systems and software procedures used in Air One’s website acquire, in the course of normal use, an amount of personal information, the transmission of which is implicit in the use of Internet Communication Protocol. For example, the user’s IP address or the domain name of the computer used to access the website, the URLof the requested sources, the time of the request or the session time, the method used for making the query to the server, the size of the files received in reply to the request, the code number concerning the status of the server’s reply and other types of information regarding the user’s operating system and technological environment. Air One’s website does not use cookies or similar technology with the aim of collecting and/or transmitting users’ personal details. Air One uses such technology with the sole aim of finding out statistical information on the use of the website – for example, total number of site visitors, visitors per single page and domain name of users’ Internet service providers. In particular, the use of session cookies (those that are removed from the user’s computer when the browser is closed) is strictly limited to the transmission of information relating to the user’s session, which is of fundamental importance for safe and efficient navigation of the website. The use of such session cookies, furthermore, absolutely excludes the resorting to other information techniques, potentially detrimental to the confidentiality of the user’s navigation, and does not allow them to acquire identifying personal data.
Air One does not make use of any type of persistent cookies.

Collection Aims
Air One collects the personal details of its clients necessary for putting in place the authorization, qualification and personalization of operations for access to the various areas and relative content of the Company’s website. Furthermore, Air One acquires the necessary data for carrying out its contractual obligations with its clients, deriving from reservation operations and ticket buying by passengers. The performing of these obligations necessarily entails that the data must be available to Air One’s booking and commercial clerks as well as third party service-supply firms.

Air One uses the personal details collected on-line with the aim of offering products and services, controlling the system of authorized access for monitoring the safety of data and evaluating work proposals sent in by candidates (CVs). Only on specific request, via the on-line registration form, does Air One send commercial offers or marketing promotions by means of its own Newsletter.
Air One, as the proprietor of these relevant procedures, states that the data in question will be processed and utilized exclusively for the ends set out in this Privacy Policy.

Communication and/or Dissemination of Personal Details
Personal details will be accessible to the employees of Air One, formally named Process Representatives or Agents. The use and transmission of personal details on the part of external individuals and organizations that are working for Air One are regulated by contracts that provide for adequate protection for the data. Users’ personal data will be used by and released exclusively to individuals and organizations that work for them, in conformity with this Privacy Policy and according to the specific provisions of the current regulations.
Air One, moreover, manages the information contained in its own website in collaboration with other service providers and web agencies, from which it may receive personal details relative to the users of this data. These on-line collaborations are regulated by special contracts that presuppose an adequate protection level of the processed personal data.
Air One is obliged, in ever-greater measure, to communicate to the various local authorities in all countries in the world, particularly to the Customs and Immigration Authorities, the personal and traveling details of its clients, acquired by the Company during its normal contractual dealings. This communication is necessary for carrying out the transport contract and comes about, above all, for security reasons. In some cases, Air One may also be required to release its website users’ personal details, in carrying out contractual obligations, conforming to current regulations, or satisfying a service request on the part of the user. The release of data may come about in the following cases:

1. When on-line users have authorized the data release;
2. When Air One needs to communicate information on users in order to offer services and satisfy an on-line user’s request;
3. When Air One needs to communicate information to its partners, so that they can carry out services for on-line users;
4. When Air One is obliged, by order of the judicial authorities, to release information regarding clients or conforming to a local or international law, regulation or warrant.
Furthermore, circumstances may arise whereby, for example, Air One decides for commercial reasons to effect buying, selling or merger of capital. In the scope of such reorganization, the personal data may be shared with present or future buyers. In such circumstances, Air One will obtain written guarantees that personal data will be treated with an adequate level of protection in accordance with existing regulations. Except in cases explicitly allowed by law, or covered by this Privacy Policy, personal details will not be communicated or shared without the agreement of the interested party.

Air One will not sell or give away its website users’ personal details to unauthorized third parties.

Care of Personal Details
In conformity with the principle of necessity allowed by Art. 3 of Legislative Decree 196/03 Air One guarantees that processing by electronic tools is carried out, limiting the use of personal details and identification data to a minimum of the cases where it is strictly necessary, in order to achieve the aims for which they were collected. Air One also guarantees the adoption and observing of specific security measures to avoid loss of data, any unlawful or incorrect use of data, and unauthorized access.
Users’ data will be stored by Air One until the eventual cancellation order by the user, including data which does not need to be stored in relation to the aims for which it was collected, in observance of the rights set out in Art. 7 of Legislative Decree 196/03 and to be carried out according to the succeeding paragraph "Your Rights".
It is the responsibility of each user to guarantee and verify the ownership and custody of their personal password and relative access codes to the web resources.

Agreement to Personal Data Processing
Air One carries out their user/clients’ data processing exclusively with the consent of the same. However, should a user not agree to his/her details being processed or request their cancellation, it will not be possible to access the reserved areas of the Company’s website.

The Processing Owner
The processing owner of your details is Air One S.p.A., whose registered office is at Viale Abruzzo, 410, 66013 Chieti, Italy.

Processing Manager
The processing manager of your data is our Personnel and Organization Manager. Processing connected with Air One’s website services is carried out at the Rome Fiumicino offices and is solely looked after by technical personnel of the processing office responsible (e.g. Internet Area), or by eventual outsourcers who carry out occasional or periodic technical operations (e.g. database maintenance).

Options for Data Contribution
Apart from what has been specified as regards navigation data, the user has the option to contribute - or not - personal details asked for in the request module and/or registration to the Air One website.

Not contributing them may make it impossible to obtain what the user requires.

Finally, it must be remembered that in some cases - not the object of this site’s usual management - the Authorities may ask for news and information as allowed by Legislative Decree 196/03 Art. 15, so as to verify personal data processing. In these cases, the reply is obligatory under pain of a fine.

Your Rights
Air One’s website users may always appeal to the Owner and/or Processing Manager (see above) to assert their rights as set out in Art. 7 of Legislative Decree 196/03, which states the following:

1.   The interested party has the right to obtain confirmation of the existence, or not, of personal details that regard him/her, even if not yet registered, and the communication thereof in an intelligible form. 2.   The interested party has the right to obtain evidence of:
a. the origin of the personal details;
b. the purpose and manner of processing;
c. the logic applied in case of processing effected with the aid of electronic tools;
d. the identity details of the owner, manager and agent designate as set out in Art. 5 clause 2;
e.the subjects and categories to which the data may be communicated or who might come to know of it in the role of designated national representative, manager or person in charge.
3.   The interested party has the right to obtain:
a. the update, correction or, when necessary, completion of data;
b. the cancellation, transformation to anonymity or blocking of data processed in violation of the law, including that whose conservation is unnecessary in relation to the purpose for which the data was, or will be, subsequently processed;
c. the declaration that the operations set out in letters a) and b) above, also as regards their content, have been brought to the notice of those to whom the data was communicated or disseminated, excepting those cases in which this is impossible or would require a manifestly disproportionate use of resources with respect to the right being protected.
4.   The interested party has the right to object, in whole or in part, to:
a. the processing of personal data that regards him/her, for legitimate motives, even though pertinent to the purpose of their collection;
b. the processing of personal data that regards him/her for the purpose of sending publicity material or direct selling, for carrying out market research or sending commercial messages.

In conformity with the present regulations and in addition to the other rights here specified, Air One offers its website users the following options:
1. Non-collection of personal details:
The user can choose not to furnish personal details on-line to Air One, deciding not to insert or release personal information in the registration forms or web module fields, or, in this case, not using any of the personalized services available on the Company’s site. Some of the contents and/or services on Air One’s website are offered exclusively to users who release personal information or use personalized services.
2. Limitations of use and personal data communication for various purposes:
Access to certain content sections and/or services on Air One’s website may require the user’s consent to the use and release of personal details with the aim of implementing a contact list and/or to identify and offer supplementary services and promotions considered interesting to the user. Users can limit further processing that may be done using this information by verifying or choosing their options when inserting the data.

Furthermore, the information given after the first registration may be modified or cancelled by changing the preceding options inserted in the Air One registration form, accessing the section from the Home Page. Alternatively, the information may be modified by sending an e-mail to: privacy@flyairone.it, with "cancellation/modification according to Art. 7, of L. D. 196/2003" as its subject. Where allowed, it is also possible to update and alter personal data on line.

Modification of the Privacy Policy
Air One ’s Privacy Policy may be updated and/or modified in order to implement and/or conform to National, EU or International laws, or to come into line with technological innovation. The updates and/or variations that may be made to this Privacy Policy will be reported on this web page and will always be available via a Hyperlink with the Company’s site, so that those interested can be fully informed about the use that is made of their personal details furnished to Air One’s website.

We recommend you examine this Policy every time you visit an Air One website.
Effective from: May 2004

Contacts
For further information regarding this Privacy Policy please contact Air One S.p.A.:
Air One S.p.A.
Via Cesare Giulio Viola, 27 00148 Rome
Telephone: +39 06 656811 Fax: +39 06 65681401