Politique de Confidentialité

Chapter 2 – Personal Data Processing Related to the Websites of GuyaneFly by VanAir Europe

2.1 – Personal Data Subject to Collection and Processing by Us

We distinguish two main types of personal data processed:

• Data collected and recorded automatically by our website, guyanefly.com.
• Personal data that you enter via various forms on our site.

2.1.1 Automatically Collected and Recorded Personal Data

During your visit to guyanefly.com, we collect and record non-nominative data about you. The details of the treatments applied to these data will be explained later.

2.1.2 Personal Data Collected and Recorded via Forms

During your visit to guyanefly.com, we collect and record data that you enter by filling out a form. These data may be related to a contract (purchase of an airline ticket) or in a non-contractual framework (subscription to our newsletter or any other action not engaging the terms defining a contract).

As of the date of writing this document, our site allows you to enter data in the following cases:

• Creation of an internet account (non-contractual framework)
• Subscription to the loyalty program (contractual framework)
• Purchase of an airline ticket (contractual framework)
• Car rental (contractual framework)
• Online check-in (contractual framework)
• Reservation management (contractual framework)
• Disputes and claims (contractual framework)
• Internet assistance (non-contractual framework)
• Request for information (non-contractual framework)

These points will be detailed later in the document (paragraph 2.3).

2.2 – Collection of Your Consent for Recording Personal Data

For the recording of data in a contractual framework, we collect your consent when accepting the general terms of sale or use. These consents remain valid until the end of the concerned contract, except for regulatory obligations to retain data.

For the recording of data in a non-contractual framework, your explicit consent is collected. These consents remain valid until a predetermined date, unless you wish to withdraw them. The withdrawal procedure will be indicated later.

2.3 – Data Processing

2.3.1 Processing of Automatically Collected and Recorded Personal Data

We process the data mentioned in paragraph 2.1.1 to obtain information such as:

• Date and time of your visit to guyanefly.com
• Address of the referring website
• Pages visited on our site
• IP address of your device
• Characteristics of your device
• Services used on our site
• Searches made during your visit

These pieces of information help us improve our site and services. We use Google Analytics to analyze these data, with enhanced privacy measures, including the anonymization of your IP address.

You can refuse the deposit of cookies by modifying the settings of your browser. An extension to block Google Analytics is also available.

2.3.2 Processing of Personal Data Collected and Recorded via Forms

2.3.2.1 Creation of an Internet Account: Creating an account on guyanefly.com facilitates your future interactions with our site. The collected data include your name, email address, postal address, telephone, and other personal information. These data are stored securely and used to pre-fill forms on our site.

2.3.2.2 Subscription to the Newsletter: Subscribing to our newsletter requires entering your email address and other relevant information. These data are used to send you regular information about our offers and news.

2.3.2.3 Membership in the Loyalty Program: Our loyalty program rewards our regular customers. The data collected during membership are used exclusively within the framework of this program.

2.3.2.4 Traitement des données personnelles liées au statut de l’accréditation « Résident » GuyaneFly by VanAir Europe and VanAir Europe, as joint data controllers, collect and process your personal data to issue a personal accreditation number, known as the “Guyanese resident.” This processing is carried out to offer a tailored customer journey when purchasing round-trip airline tickets from Guyana. Personal data is collected directly via information entry forms on the website.

The processed data includes identification (name, first name, email address, etc.) and supporting documents (National Identity Card, income tax notice, health insurance certificate, etc.). Providing certain personal data is mandatory for your request to be considered.

The purpose of the processing is to issue a personal accreditation number, known as the “resident of Guyana,” upon verification of the supporting documents. Tessi, acting as a service provider, reconciles the data to generate this number.

Personal data concerning minors under 15 years old: Air France and GuyaneFly by VanAir Europe do not process personal data of children under 15 years old without prior consent from parents or legal guardians. In cases where consent is required for a child under 15, parents or legal guardians will be contacted.

Recipients of personal data: The personal data collected is intended for the use of GuyaneFly by VanAir Europe and is processed by Tessi, acting as a subcontractor. his data may be disclosed to competent authorities in the context of combating criminally reprehensible activities.

Processing, storage, and destruction of documents: Documents uploaded for the “Guyanese resident” accreditation are temporarily stored and destroyed within 24 hours after the acceptance or refusal of the request. Some data is securely retained by us for the duration of the contract.

Exercising rights: You have the right to access, rectify, erase, oppose, withdraw consent, limit, and port your personal data. You can submit your requests to GuyaneFly by VanAir Europe.

2.3.2.6 Purchase of airline tickets: When booking one or more airline tickets and associated services, GuyaneFly by VanAir Europe collects the following data: Title, Name, First Name, Email, Phone, and Date of Birth for certain categories of passengers This data is recorded in the AeroCRS reservation system and is kept until the end of the trip. It is also used for ground operations such as check-in and boarding control. Online payment operations are handled by EMERCHANTPAY. GuyaneFly by VanAir Europe also retains this data for regulatory obligations related to national security.

2.3.2.7 Online check-in: GuyaneFly by VanAir Europe offers the option of online check-in. The data entered for check-in integrates into the overall AeroCRS process, and the same personal data protection provisions apply.

2.3.2.8 Manage my booking: Passengers can check and modify the status of their reservation. The data processing also integrates into the overall Amadeus process.

2.3.2.9 Disputes and claims: A specific site is dedicated to collecting claims requests. Personal data collected to create the claim file are securely stored on the servers of GuyaneFly by VanAir Europe.

2.3.2.10 Electronic message sending forms: Forms are available to facilitate sending messages to the various services of GuyaneFly by VanAir Europe. The personal data contained in these messages are used only to respond to customer requests.

This concludes the information from the privacy policy of GuyaneFly by VanAir Europe starting from section 2.3.2.6.

CHAPTER II – Processing of Personal Data Related to the Websites of GuyaneFly by VanAir Europe

3.1 – General Principles at GuyaneFly: Booking a plane ticket is not limited to using our website.

You also have the option to book through a travel agency, tour operator services, a specialized partner site of our company, or via one of our mobile applications. It is also possible to contact our call center or make a reservation directly at the counter in one of the airports served by GuyaneFly.

In all these cases, we apply the same principles to ensure the compliance of your personal data processing.

We ensure that all our marketing channels strictly comply with current regulations. This implies a rigorous requirement on our part when establishing distribution agreements with our partners.

3.2 – Processes Carried Out on Our Reservation System: Regardless of the means chosen to purchase a ticket on one of our flights, your reservation will eventually be recorded in our system.

3.2.1 Purchase of a Ticket from GuyaneFly: When you book one or more plane tickets and associated services directly from GuyaneFly, we collect the following data:

• Title
• First Name
• Last Name
• Email
• Phone
• Date of birth for babies, children, youth, and seniors.

These data are recorded in our reservation system, managed by our partner Amadeus.

Amadeus, a Spanish law company, was created in 1987 by several European airlines. It aims to provide a common structure for the computerized distribution of air segments and to group the ticket sales offer of different airlines.

Your data is kept and used until the end of your trip and is also necessary for ground operations, such as check-in and boarding control.

These data are stored during this period on Amadeus’s servers, located in Germany, and are in full compliance with personal data protection regulations, notably the GDPR.

GuyaneFly also retains part of this data in its accounting and for regulatory obligations related to national security.

3.2.2 Purchase of a Ticket from One of Our Partners: Like most airlines, GuyaneFly markets its services via selected partners.

In this case, unless otherwise indicated, it is with this entity that you contract your ticket purchase, whether for a flight alone or an organized trip.

We encourage you to check the guarantees offered by these providers regarding the processing of your personal data. Although we adopt a strict policy on this subject, we cannot be held responsible in case of failure on the part of these providers.

In case of a request or complaint concerning the processing of your personal data, you should first address this provider. However, GuyaneFly remains your final contact for exercising your rights to access personal data, in case the partner cannot respond to your request.

Chapter 4 – Organizational and Technical Measures Related to the Protection of Personal Data

5.1 – DATA RETENTION PERIOD

We retain your personal data for a period not exceeding that necessary for the purposes for which they are collected and processed.
The data recorded after completion by you of a form will be kept for a maximum of 60 months, except for any legal obligation to the contrary.

1. Management of prospects (emailings, phone calls, SMS, etc.)

• Purposes of processing:
  • Identify new potential customers
• Duration of retention:
  • Archives (active base) for a maximum of 3 years from the end of the commercial relationship or after the collection of data or the last contact with the prospect.
• Archives (intermediate base) for 13 months if the prospect gives explicit consent to continue to be solicited.
• Legal basis:
  • Legitimate interest

2. Management of cookies and other trackers

• Purposes of processing:
  • Generate website traffic statistics,
  • improve website navigation performance,
  • personalization, and targeted advertising
• Duration of retention:
  • Retention for 13 months of data (Simplified Standard No. 48 of the CNIL)
• Legal basis:
  • Consent

3. Management of the customer file

• Purposes of processing:
  • Know and retain customers,
  • adapt offers,
  • provide adapted services (personalized),
  • customer relationship management (reservation modification, assistance, etc.),
  • legal and fiscal procedures
• Duration of retention:
  • Retention in active base for the duration of the contractual relationship,
• • retention in intermediate base for 5 years from the end of the commercial relationship.

However, retention in the intermediate base may be extended considering the applicable limitation periods with respect to legal and fiscal obligations. Indeed, legal provisions require collecting and sharing identification data, reservation and travel information with public authorities or governmental organizations for border control, immigration, entry into a state’s territory, security, or counter-terrorism purposes.

• Legal basis:
  • Contract,
  • Legal obligation

4.Management of newsletter subscriptions

• Purposes of processing:
  • Management of subscriptions;
  • management of electronic mailings (offers),
  • development of statistics related to the service
• Duration of retention
  • Retention until the person concerned unsubscribes (via the unsubscribe link integrated into the newsletters)
• Legal basis:
  • Consent

5.Credit Card Payments

• Purposes of processing:
  • Single payment for purchase or travel reservation
• Duration of retention
  • Until effective payment (deleted upon transaction completion)
  • Intermediate archive for the purpose of proof in case of possible dispute of the transaction for a duration of 13 months following the debit date or 15 months in case of deferred debit payment cards.
• Legal basis:
  • Contract,

6.GManagement of Customer Disputes and Claims

• Purposes of processing:
• • Processing of claims (mediation procedure),
  • recovery of amounts due,
  • improvement of service quality,
  • ensuring the establishment, exercise, or defense of legal rights
• Duration of retention

• Commercial Claims:
• The data necessary for the execution of a contract are retained for the duration of the contractual relationship.
• Retention in intermediate base for 5 years from the end of the commercial relationship.

• Litigation Files:
• Intermediate archives of litigation files: retention for the time necessary to manage the litigation (including appeal periods) after becoming aware of a dispute, until the prescription of the action.
• Legal basis:
  • Contract,
  • Legal obligation

7.Management of the Subscription Program

• Purposes of processing:
  • Management of subscriptions;
  • management of electronic mailings (offers),
  • development of statistics related to the service
• Duration of retention
  • Retention until the person concerned unsubscribes
• Legal basis:
  • Consent

8. Management of “Resident” Accreditation

In the context of the “Resident” accreditation (paragraph 2.3.2.4 of this document), all documents uploaded to the site by the passenger are destroyed after 24 hours from the information systems following the acceptance or refusal of the accreditation request.

Only the following data are kept for a duration of 5 years as proof, in a secure digital safe, solely to justify in case of a posteriori control by an authorized body, the attribution of a resident rate to a passenger, namely: the birth and marital name(s), first name(s), date of birth, postal code, and vintage of the passenger’s tax notice, name(s) and first name(s) of minor children, name(s) and first name(s) of students and vintage of the study year.

5.2 – YOUR RIGHTS

In accordance with the texts in force at the time of writing this document, you have the following rights regarding the personal data processed by us:

Right to information,

Right to rectification or deletion,

Right to limit processing,

Right to data portability.

For the exercise of these rights or any question related to the protection of your personal data, you can contact our DPO by email: willy.navarro@guyanefly.com.

You also have the right to file a complaint with the National Commission on Informatics and Liberty (“CNIL”) regarding the processing of your personal data. You can address your complaint on the CNIL website, or by postal mail by writing to: CNIL – Complaints Service – 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07. The procedures for filing a complaint with the CNIL are detailed at this link: https://www.cnil.fr/fr/cnil-direct/question/adresser-une-reclamation-plainte-la-cnil-quelles-conditions-et-comment.

5.3 – DATA TRANSFER

If personal data are transmitted to third parties for the purpose of executing the transport contract and ancillary services, we ensure beforehand that our partners comply with the applicable regulations and are in conformity with the GDPR.

5.4 – PERSONAL DATA CONCERNING MINORS UNDER 15 YEARS OF AGE

GuyaneFly by VanAir Europe does not collect or process personal data relating to children under 15 years old without prior consent from the parents or legal guardians of the child.

If you use the website of GuyaneFly by VanAir Europe on behalf of your child and in your capacity as the holder of parental authority, you are informed that the personal data relating to your child under 15 years old will be processed and used by GuyaneFly by VanAir Europe in accordance with this Privacy Policy.

In the event that your child is under 15 years old, and their consent is necessary for the processing of personal data in accordance with Article 6(1)(a) of the GDPR, you will be invited, in your capacity as the holder of parental authority, to consent to the processing of your child’s data by GuyaneFly by VanAir Europe.

In accordance with the recommendations of the CNIL, in any situation where the age of the concerned person is collected and it is possible to determine that they are 15 years old or younger, the email address of a parent or legal guardian will be requested before collecting personal data from that child. The email addresses of the holders of parental authority provided for the purpose of obtaining parental consent will be used for the purpose strictly defined in this Privacy Policy.

If you have learned that your minor child under 15 years old has provided personal information to GuyaneFly by VanAir Europe without your supervision, you can contact us at willy.navarro@guyanefly.com so that we can take appropriate measures.