What personal information do we collect and hold?
The types of information that we collect and hold about you could include:
- ID information such as your name, postal or email address, telephone numbers, and date of birth;
- other contact details such as social media handles;
- aviation details such as your ARN;
- health and biometric information (e.g. fingerprints, voice patterns) where permitted;
- your location or activity including IP address, and whether you’ve accessed third party sites;
- other information we think is necessary.
Over the course of our relationship with you, we may collect and hold additional personal information about you, including transactional information, account or policy information, complaint or enquiries about your product or service.
If you have general enquiry type questions, you can choose to do this anonymously or use a pseudonym. We might not always be able to interact with you this way however as we are often governed by strict regulations that require us to know who we’re dealing with.
When the law authorises or requires us to collect information
We may collect information about you because we are required or authorised by law to collect it. There are laws that affect aviation orginisations, including company and aviation law, which require us to collect personal information. For example, we may require to collect details to be able to communicate with CASA, ATSB or other regulatory bodies as required.
What do we collect via your website activity?
When you use FlyFreely websites or mobile applications we may collect information about your location or activity including IP address, telephone number and whether you’ve accessed a third party site. This is done to ensure we can verify you and you can receive information from us, to identify ways we can improve our services for you and to understand you better. Some of this website or application information is collected using cookies.
If you start but don’t submit an online form we can contact you using any of the contact details you’ve supplied or other contact details we have for you to offer help (unless the use is anonymous).
We also know that some customers like to engage with us through social media channels. We may collect information about you when you interact with us through these channels. For all confidential matters, please interact with us via private messaging or secure channels.
How do we collect your personal information?
How we collect and hold your information
There are many ways we seek information from you. We might collect your information when you fill out a form with us, when you’ve given us a call, used our websites or dropped into one of our offices. In addition, when you use our website or mobile applications we may collect information about your IP address, location or activity. We also find using electronic means, such as email or SMS, a convenient way to communicate with you and to verify your details. However we’ll never ask you for your security details in this way – if you are ever unsure, just contact us. We will try to collect personal information directly from you unless it’s unreasonable or impracticable. For this reason, it’s important that you keep your contact details up-to-date.
How we collect your information from other sources
Sometimes we collect information about you from other sources. We may collect information about you that is publicly available (for example from public registers or social media) or made available by third parties. For instance, we do this where:
- we distribute or arrange products on behalf of others, including our business partners;
- we can’t get hold of you and need to update your contact details;
- we need information from third parties about an application you make through us;
- we need information for fraud prevention purposes;
- we are checking the security you are offering;
- you have consented to third parties sharing it with us, such as organisations we have loyalty programs with or we sponsor.
We may use or disclose information about you in order to combine the information that we hold with information collected from or held by external sources. We do this in order to enable the development of customer insights about you so that we can serve you better. This includes being able to better understand your preferences and interests, personalise your experience, enhance the products and services you receive, and to tell you about products and services that may be of interest to you. Where those insights are provided to others, such insights are based on aggregated information and do not contain any information that identifies you. We may also use service providers to undertake the process of creating these consumer insights.
What if you don’t want to provide us with your personal information?
If you don’t provide your personal information to us, we may not be able to:
- provide you with the product or service you want;
- manage or administer your product or service;
- personalise your experience with us;
- verify your identity or protect against fraud; or
- let you know about other products or services that might better meet your operational, RPAS or UAV needs.
How do we take care of your personal information?
We store information in different ways, including in paper and electronic form. The security of your personal information is important to us and we take reasonable steps to protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure. Some of the ways we do this are:
- confidentiality requirements and privacy training of our employees;
- document storage security policies;
- security measures to control access to our systems and premises;
- only giving access to personal information to a person who is verified to be able to receive that information;
- ensuring third parties meet FlyFreely’s privacy obligations; and
- electronic security systems, such as firewalls and data encryption on our websites.
We can store personal information physically or electronically with third party data storage providers. Where we do this, we use contractual arrangements to ensure those providers take appropriate measures to protect that information and restrict the uses to which they can put that information.
What happens when we no longer need your information?
We’ll only keep your information for as long as we require it for our purposes. We’re also required to keep some of your information for certain periods of time under law, such as the Corporations Act, Aviation regulations, and any other regulations that require us to maintain the records. When we no longer require your information, we’ll ensure that your information is destroyed or de-identified.
How we use your personal information
What are the main reasons we collect, hold and use your information?
Because we offer a range of services and products, collecting your personal information allows us to provide you with the products and services you’ve asked for. This means we can use your information to:
- provide you with information about products and services, including help guidance and advice;
- consider your request for products and services, including your eligibility;
- process your application and provide you with products and services; and
- administer products and services which includes answering your requests and complaints, varying products and services, conducting market research, taking any required legal action in relation to our accounts and managing our relevant product portfolios.
Can we use your information for marketing our products and services?
We may use or disclose your personal information to let you know about products and services that we believe may be of interest to you, including products and services from our related companies or from those we distribute products on their behalf, including MLC Limited. We will not do this if you tell us not to.
Such marketing activities may be via email, telephone, SMS, iM, mail, or any other electronic means, including targeted advertising through FlyFreely or other websites.
We may also market our products to you through third party channels (such as social networking sites), or via other companies who assist us to market our products and services. We may use de-identified data to disclose to online advertisers that allow us to place communications in the media most relevant to you.
Where we market to prospective customers, we are happy to let them know how we obtained their information and will provide easy to follow opt-outs.
With your consent, we may disclose your personal information to third parties such as brokers or agents, or for the purpose of connecting you with other businesses or customers. You can ask us not to do this at any time.
Yes, You Can Opt-Out
You can let us know at any time if you no longer wish to receive direct marketing offers (see ‘Contact Us’). We will process your request as soon as practicable.
Where you have subscribed to something specific (like to hear from one of our sponsored organisations) then these subscriptions will be managed separately. If you no longer wish to receive these emails click the unsubscribe link included in the footer of our emails.
We know that you may prefer to receive some types of messages over others, so where possible we will offer you a choice. For instance, if you’d like to keep receiving particular messages on operations and flight techniques but not data processing, then if we can, we will offer you a way to indicate that choice to us.
You can always update your preferences at any time.
What are the other ways we use your information?
We’ve just told you some of the main reasons why we collect your information, so here’s some more insight into the ways we use your personal information including:
- identifying you or verifying your authority to act on behalf of a customer;
- telling you about other products or services that may be of interest to you, or running competitions and other promotions (this can be via email, telephone, SMS, iM, mail, or any other electronic means including via social networking forums), unless you tell us not to;
- Identifying opportunities to improve our service to you and improving our service to you;
- assisting in arrangements with other organisations (such as loyalty program partners) in relation to a product or service we make available to you;
- allowing us to run our business and perform administrative and operational tasks (such as training staff, risk management; developing and marketing products and services, undertaking planning, research and statistical analysis; and systems development and testing);
- preventing or investigating any fraud or crime, or any suspected fraud or crime;
- as required by law, regulation or codes binding us; and
- for any purpose for which you have given your consent.
Who do we share your personal information with?
To make sure we can meet your specific needs and for the purposes described in ‘How we use your personal information’, we sometimes need to share your personal information with others. We may share your information with other organisations for any purposes for which we use your information.
Sharing outside of Australia
We run our business in Australia and overseas. We may need to share some of your information with organisations outside Australia. Sometimes, we may need to ask you before this happens.
We may store your information in cloud or other types of networked or electronic systems. As electronic or networked systems can be accessed from various countries via an internet connection, it’s not always practicable to know in which country your information may be held. If your information is stored in this way, disclosures may occur in countries other than those listed.
Overseas organisations may be required to disclose information we share with them under a foreign law. In those instances, we will not be responsible for that disclosure.
Cookies and web beacons
Cookies are text files containing small amounts of information which is downloaded to your hard disk or to your browser’s memory when you visit one of FlyFreely’s sites or apps. Cookies are useful because they help arrange the content and layout of our sites and allow us to recognize those computers or other devices that have been to our sites before. Cookies do many different jobs, such as allowing our websites to remember your preference settings and helping us to enhance the usability and performance of our sites and your experience using them.
Our sites also may contain electronic images known as web beacons – sometimes called single-pixel gifs – that allow us to count the number of users who have visited specific pages. We may include web beacons in promotional e-mail messages or newsletters in order to determine whether messages have been opened and acted upon.
The type of cookie that may be used on FlyFreely’s sites and apps can be put into 1 of 4 categories: Strictly Necessary, Performance, Functionality & Profile, and Advertising.
Strictly Necessary Cookies
These cookies are essential, as they enable you to move around our sites and apps and use their features, particularly in connection with information searches and order placement. Without these cookies, services you have asked for cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet. An example of a strictly necessary cookie is a “shopping basket cookie,” which is used to remember the products that you wish to purchase when you add products to your shopping basket or proceed to checkout.
These cookies collect information about how you use our sites and apps, for example which pages you go to most often and if you get any error messages from certain pages. These cookies collect only anonymous information that is used to improve how our sites and apps work.
These cookies are not used to target you with online advertising. Without these cookies, we cannot learn how our sites and apps are performing and make relevant improvements that could better your browsing experience. Examples of performance cookies that our sites and apps use include Google and Adobe Analytics (see further discussion below).
Functionality & Profile Cookies
These cookies allow our sites and apps to store information that you provide such as your site language preferences and to store technical information useful for your interactions with our sites and apps. For instance, they remember your user ID and elements of your user profile. They also ensure that your experience using the sites and apps and FlyFreely’s marketing efforts are relevant to you. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymous and they cannot track your browsing activity on other websites and apps.
Without these cookies, a website cannot remember choices you have previously made or personalize your browsing experience. For example, we use a cookie to store your language preferences, which allows us to present you with product search results in the correct language, and we use a cookie to store your choice about the appearance of the cookie information banner that we display on our sites and apps. This cookie will help us remember your choice about the appearance of the cookie information banner when you subsequently visit the same site where you made your choice about the banner and any other FlyFreely sites and apps with the same domain or the same top level domain.
These cookies may be used to deliver advertisements that are more relevant to you and your interests. They may also be used to limit the times you see an advertisement as well as help to measure the effectiveness of the advertising campaign. Although these cookies may track your visits to other websites and apps, they do not usually know who you are.
Without these cookies, online advertisements you encounter will be less relevant to you and your interests.
Setting your cookie preference
You have the ability to accept or decline cookies. Most internet browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies or to notify you when a cookie is being placed on your computer. If you choose to decline cookies, you may not be able to fully experience the features of FlyFreely’s sites and apps or other websites and apps that you visit.
Our use of web analytics
FlyFreely uses industry standard web analytics to track visits to our sites and apps. Google Analytics provides these analytics. The information generated by the cookie about your use of our sites and apps (including your IP address) will be transmitted to and stored by Google on servers in the United States or around the world. Google will use this information for the purpose of evaluating your use of our sites and apps, compiling reports on website activity for website operators, and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.
How do you access your personal information?
How you can generally access your information
We‘ll always give you access to your personal information unless there are certain legal reasons why we can’t. In some cases we may be able to deal with your request over the phone or in an office.
We will give you access to your information in the form you want it where it’s reasonable and practical (such as a copy of a emails we may have exchanged with us – we can put it on a disk for you). We may charge you a small fee to cover our costs when giving you access, but we’ll always check with you first. You can find the schedule of fees explained on the Access form.
How do you correct your personal information?
Contact us if you think there is something wrong with the information we hold about you.
If you are worried that we have given incorrect information to others, you can ask us to tell them about the correction. We’ll try and help where we can – if we can’t, then we’ll let you know in writing.
Whether we’re able to correct the information or not, we’ll let you know within five business days of deciding to do this. If we can’t we will provide reasons. We’ll also let the relevant third parties know as well as any others you tell us about. If there are any instances where we can’t do this, then we’ll let you know in writing. If you have any concerns, you can make a complaint to the Office of the Australian Information Commissioner.
How do you make a complaint?
If you have a complaint about how we handle your personal information, we want to hear from you. You are always welcome to contact us. We are committed to resolving your complaint and doing the right thing by our customers. Most complaints are resolved quickly, and you should hear from us within five business days (see ‘Contact Us’).
If you still feel your issue hasn’t been resolved to your satisfaction, then you can escalate your privacy concern (see ‘Contact details for escalating complaints’).
Last updated: 18/01/2018 1320 AEST +10GMT