Handling Request Limited’s Privacy Policy

Contact Details

Name: Handling Request Limited

Address: 7 ½ Commercial Buildings, St Helier, Jersey, Channel Islands JE2 3NB

Tel: 0330 133 2859

Email: info@handlingrequest.com

This privacy policy applies between you, the User of this Website and Handling Request Limited, the owner and provider of this Website. Handling Request Limited takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website (regardless of where you visit it from). Please use the above contact details should you have any questions regarding our privacy policy or requests to exercise your legal rights.

Please read this privacy policy carefully.

Introduction

Handling Request Limited is registered as a “Controller “under the Data Protection (Jersey) Law 2018.

This privacy notice aims to give you information on how Handling Request Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to a newsletter, contact us via telephone or email, or create an account and use our services.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

You have the right to make a complaint at any time to the Office of the Information Commissioner (OIC), the Jersey supervisory authority for data protection issues (www.oicjersey.org). We would, however, appreciate the chance to deal with your concerns before you approach the OIC so please contact us in the first instance.

Definitions and interpretation

1. In this privacy policy, the following definitions are used:

Data	Collectively all information that you submit to Handling Request Limited via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws. ). For the avoidance of doubt, a user’s data includes any data posted to the website by them – which may include their own clients’ data.
Cookies	A small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies).
Data Protection Laws	Any applicable law relating to the processing of personal Data, including but not limited to the Data Protection (Jersey) Law 2018.
Handling Request Limited, or us, or we	Handling Request Limited, a company incorporated in Jersey with registered number 131528 whose registered office is at Hawk House, 22 Esplanade, St Helier, Jersey JE2 3QA
Service	The use of this website (www.handlingrequest.com) and its features
User or you	Any third party that accesses the Website and is not either (i) employed by Handling Request Limited and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Handling Request Limited and accessing the Website in connection with the provision of such services (including but not limited to aircraft operators, handling agents, fixed based operators). This includes users who do not have an account on the website.
Website	The website that you are currently using, handlingrequest.com, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

• In this privacy policy, unless the context requires a different interpretation:
  • the singular includes the plural and vice versa;
  • references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
  • a reference to a person includes firms, companies, government entities, trusts and partnerships;
  • “including” is understood to mean “including without limitation”;
  • reference to any statutory provision includes any modification or amendment of it;
  • the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

• This privacy policy applies only to the actions of Handling Request Limited and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including any links we may provide to social media websites, nor does it extend to third party users with whom data is shared with.
• For purposes of the applicable Data Protection Laws, Handling Request Limited is the “data controller”. This means that Handling Request Limited determines the purposes for which, and the manner in which, your Data is processed.
• Where we need to collect personal data by law, or under the terms and conditions of this website and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with full use of the services offered by the website). In this case, you may have breached our terms and conditions in which instance, we will not be liable for any loss of service and we may have to cancel a subscription or service you have with us but we will notify you if this is the case at the time.

How we collect data

• We collect Data in the following ways:
• data is given to us by you (be that by post, phone, email, via creating an account on the website, subscribing to publications, giving us feedback or otherwise); and
• data is collected automatically e.g. through using cookies, server logs and other similar technologies. We may also receive such Technical Data about you if you visit other websites employing our cookies; and
• Third Parties or publicly available sources including but not limited to: analytics providers, search information providers, social media pixels and advertising networks any or all of whom may be based either inside or outside of the EU.

Data that is given to us by you

• Handling Request Limited will collect your Data in a number of ways, for example:
  • when you contact us through the Website, by telephone, post, e-mail or through any other means;
  • when you make payments to us, through this Website or otherwise;
  • when you elect to receive marketing communications from us;
  • when you use our services;

in each case, in accordance with this privacy policy.

Data that is collected automatically

• To the extent that you access the Website, we will collect your Data automatically, for example:
  • we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your Internet protocol (IP) address, browser plug-in types and versions, operating system and platform, your login data, times, time zone setting and location, and other technology on the devices you use to access this website.
  • we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies”.

 

What data we collect and why

• Under the Data Protection (Jersey) Law 2018, the lawful bases we rely on for processing this information are:
• Your consent. You are able to remove your consent at any time. You can do this by emailing us at: info@handlingrequest.com
• We have a contractual obligation.
• We have a legal obligation.
• We have a vital interest.
• We need it to perform a public task.
• We have a legitimate interest.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. What we do with your data and the legal basis for processing it is summarised in the table below.

If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below) and you also have the right to withdraw consent to marketing at any time by contacting us.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may wish to publish website user statistics (number of clicks per day etc.). However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we shall treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not ordinarily collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

In some cases, we also collect data indirectly, by hand, from publicly available sources such as Google or individual company websites for the purpose of adding that information to our database including the names, addresses, emails and telephone numbers of users including Handling Agents, Fixed Base Operators and Aircraft Operators.

 

Who we share Data with

1. We may share your Data with the following groups of people for the following reasons:
   1. third party payment providers who process payments made over the Website – to enable third party payment providers to process payments;
   1. any present, past or future sister or group company of Handling Request Limited (including Charter Request Limited) for the purposes of using or promoting their products and services, as part of our regular reporting activities on the company, for system maintenance support and for compliance with imposed regulations.
   1. any customs, law enforcement, other government organisation or regulatory agency upon their request, if we are legally obliged to do so.
   1. We do not send your data to any third country or international organisation (that is, to organisations or individuals outside of  Jersey, Guernsey, the Isle of Man, the UK, Europe or any other country that has “adequacy” status).

in each case, in accordance with this privacy policy.

 

Who you share Data with

1. The user may choose to share data directly with any other third party user on the website. For example an aircraft operator may share data (including passport information, names, addresses, contact information, dates, times, travel plans) with a handling agent, fixed base operator, catering provider, customs authority or similar listed on the website and they do so at their own risk. Information is transmitted via a secure encrypted link and may be made available to other official government boarder agencies.

1. Handling Request Limited is not liable in any way for the copying or use of any data by other website users with whom they have willingly shared that information with via the website or by other means. Whilst every effort has been made to ensure only legitimate users operate on the site, you are solely responsible for verifying the authenticity and identity of the third party user to whom you are sharing the information with and should thoroughly investigate the privacy policy of any such third party user.

1. It is up to you as the user as to who you choose to share data with. As Handling Request Limited offers services based to users around the world, as the user it is your sole liability and responsibility if you send your data to any third country or international organisation (that is, to organisations or individuals outside of  Jersey, Guernsey, the Isle of Man, the UK, Europe or any other country that has “adequacy” status). Please note that if the recipient of such data is a user of Handling Request Limited then they will be bound by our terms and conditions and this privacy policy, however the data protection legislation may otherwise be very different to that in your country or to that of Jersey and as such we recommend you thoroughly investigate the protection offered before sharing data with such individuals.

1. Should you receive data from a third party user on the site (for example, a handling agent receiving dates, times, travel plans and passenger passport information in the customs general declaration), then you are bound by the general Terms and Conditions under the website’s user agreement and as such, must not copy, store, replicate nor use any such information contained within the website for any purpose except for performing the functions required under the terms and conditions.

How we store your information

1. We will use technical and organisational measures to safeguard your Data, for example:
   1. access to your account is controlled by a password and a user name that is unique to you.
   1. we store your Data on secure servers, either on our own servers or on those owned and managed by Air 66 Design Ltd, 66 Airfield Way, Hucknall, Nottingham, United Kingdom NG15 6WZ
2. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: info@handlingrequest.com.
3. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org.

Data retention

• Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy, to continue to offer you the service, or until you request that the Data be deleted.
• Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your rights

• You have the following rights in relation to your Data:
• Your right of access – You have the right to ask us for copies of your personal information.
• Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
• Your right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances.
• Your right to object to processing – You have the the right to object to the processing of your personal data in certain circumstances.
• Your right to data portability – You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.

Please contact us at info@hanldingreuqest.com if you wish to make a request.

• To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us in writing via this e-mail address: info@handlingrequest.com.
• Certain data including saved passenger or crew details can be removed by clicking the appropriate delete button within your account. When pressing this button, sensitive data is erased and cannot be retrieved. Once the data is submitted to the appropriate parties including Handling Agents and customs/boarder force authorities, we have no control over it from that point.
• You will not have to pay a fee to access your personal data (or to exercise any of the other rights above). However we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
• We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights above). This is to ensure that personal data is not disclosed to any person who has no right to receive it. To expedite our response, we reserve the right to contact you for further information in relation to your request.
• We try to respond to all legitimate requests within one month. If your request is particularly complex, or you have made a number of requests, it may take us longer than a month. In this case, we will notify you and keep you updated as to our progress.

How to Complain

• If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For Jersey this is the Jersey Office of the Information Commissioner (JOIC). Address: 2^nd Floor, 5 Castle Street, St Helier, Jersey JE2 3R. Telephone: +44 1534 716530. Email: enquries@jerseyoic.org
• It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

 

Links to other websites

• This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

 

Changes of business ownership and control

• Handling Request Limited may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Handling Request Limited. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
• We may also disclose Data to a prospective purchaser of our business or any part of it.
• In the above instances, we will take steps with the aim of ensuring your privacy is protected.

 

Cookies

• This Website may place and access certain Cookies on your computer. Cookies are small files which can be stored on your computer when you visit a website. These files contain information about the webpages you look at so the next time you visit the site it can be customised to meet your needs. Handling Request Limited uses Cookies to improve your experience of using the Website. Handling Request Limited has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
• All Cookies used by this Website are used in accordance with current United Kingdom and EU Cookie Law.
• Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Handling Request Limited to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
• This Website may place the following Cookies:

Type of Cookie	Purpose
Analytical/performance cookies	They allow us to recognise and count the number of visitors 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.

• You can find a list of Cookies that we use in the Cookies Schedule.
• You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
• You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including personalisation settings.
• It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
• For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

 

General

• You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
• If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
• Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
• This Agreement will be governed by and interpreted according to the law of Jersey, Channel Islands. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the Jersey courts.

 

Changes to this privacy policy

• Handling Request Limited reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law, without notice. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.
  
  You may contact Handling Request Limited by email at info@handlingrequest.com.

04 September 2020

Cookies

Below is a list of the cookies that we use. We have tried to ensure this is complete and up to date, but if you think that we have missed a cookie or there is any discrepancy, please let us know.

Analytical/performance

We use the following analytical/performance cookies:

Description of Cookie	Purpose
_ga	Used to distinguish users.
_gid	Used to distinguish users.
_dc_gtm_GTM-M64ZKTR	Used to throttle request rate.
AMP_TOKEN	Contains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service.
_gac_GTM-M64ZKTR	Contains campaign related information for the user. If you have linked your Google Analytics and Google Ads accounts, Google Ads website conversion tags will read this cookie unless you opt-out.

What is a Cookie?

A cookie is a small text file that may be stored on your computer or mobile device that contains data related to a website you visit. It may allow a website to “remember” your actions or preferences over a period of time, or it may contain data related to the function or delivery of the site and which are deleted the moment you move away from the website. These are known as “persistent” and “session” Cookies. Cookies can be set by the owner of the website or in some cases by third party services the website owner allows to present other information, run content or provide other functionality such as analytics. Some Cookies are essential to make the website work properly and look as it should – others are not.

How do I change cookie settings?

When you land on our homepage, a pop-up banner will appear and you will be told about the type of Cookies we use on our website. You will be given the opportunity to opt-in for certain Cookies.

Within your browser you can choose whether you wish to accept Cookies or not. You can do this at any time. Different browsers make different controls available to you and so we provide links below to popular manufacturers’ instructions on how you can do this. Generally, your browser will offer you the choice to accept, refuse or delete Cookies at all times, or those from providers that website owners use (‘third party Cookies’), or those from specific websites.

Google Chrome

Internet Explorer

Firefox

Safari

Safari Mobile

Opera

This Cookie Policy forms part of our overall Privacy Statement above.

How to complain

You can also complain to the Jersey Office of the Information Commissioner (JOIC) if you are unhappy with how we have used your personal data.

JOIC’s address: 

2nd Floor
5 Castle Street
St. Helier
Jersey
JE2 3BT

enquiries@jerseyoic.org

+44 (0) 1534 716530