Laminaar Aviation Infotech Pte Ltd (being referred to as LAMINAAR in this policy document – also includes it’s subsidiary companies, Laminaar Aviation Infotech India Private Limited and Laminaar Aviation Infotech Americas Inc) brings application software products and solutions for the aviation industry, which may be availed as a suite covering the entire spectrum of operations, or as a stand-alone module addressing a single functional area.
LAMINAAR provides various proprietary applications software, e.g., ARMS®, ARMS® NS, ARMS on the Tab® and more. All of LAMINAAR’s products, applications, custom solutions, including this website are collectively called Services. LAMINAAR is committed to maintaining the privacy of all client proprietary information including of their personnel, that it collects or the client discloses, during the use or operation of its Services.
DATA CONTROLLER AND DATA PROCESSOR
LAMINAAR processes two main types of personal data. Of personal data that is part of the data provided by clients and their end-users for processing, LAMINAAR is a Processor of this data. Of personal data about client owners, visitors and other individuals that is collected and processed directly for marketing purposes, LAMINAAR is a Controller of this data.
WHAT INFORMATION DOES LAMINAAR COLLECT
Clients provide LAMINAAR with data for processing and usage of its software application. Client Data is processed by LAMINAAR when the clients or their end-users, provide LAMINAAR or upload information into a LAMINAAR Service, e.g., a client may upload data about their employees. This data may include recruitment, payroll, employee personal details, tax records etc.
Client data necessary to create user accounts. For creation of user accounts, clients provide their personnel’s or end-users’ names names, email address, passwords, job titles, telephone numbers, correspondence address. Examples of data collected on using LAMINAAR applications/websites or provided directly are:
- Log Data – LAMINAAR servers automatically collect information when a visitor or user accesses or uses its applications and services. This data is recorded in log files. Examples of such data include IP Address.
- Subscription Data – LAMINAAR also collects information that users provide as part of signing up for its newsletters, or requests demos of products.
- Contact Us Data – When a visitor or user enquires about LAMINAAR products and services, data collected and stored for the express purpose of communication and response to an enquiry.
- Seminars and Conferences – LAMINAAR also collects and retains the information that a visitor or user provides during events and seminars, information that is volunteered during formal and informal exchanges, e.g., via business cards and social media contact addition.
- Social Media: Other data that a visitor or user may provide directly, e.g., LAMINAAR also collects data from social media locations and sites such as LinkedIn and Facebook for marketing and sales.
The information collected includes the user or visitor’s IP address, when the site was visited and what pages were visited. In some instances, cookies are used to collect information in connection with future visits from that website, to recognize them as a previous visitor, or to track activity on the LAMINAAR site. If a visitor or user follows a link to the site from an affiliate or promotion, LAMINAAR stores information about the arrival from that affiliate or promotion in a session cookie.
HOW LAMINAAR USES CLIENT OR VISITOR DATA
How personal data is used depends on which Services and how those Services are availed. Client Data is used in accordance with a client’s instructions, including any applicable Ts & Cs in the signed client agreements and as required by applicable law. LAMINAAR is a processor of Client Data and the Client is the controller.
Other Data is used for effective communication for responding to requests, comments and questions.
LAWFUL BASIS FOR PROCESSING
LAMINAAR has lawful bases to process personal data. It has a legitimate interest in processing, in some cases use client consent as basis for lawfully processing their personal data.
LAMINAAR processes client personal data only when it has a lawful basis. Presently, LAMINAAR’s lawful basis is performance of contract for processing of Client Data and Legitimate Interest or Consent for processing Other Data. In some cases, LAMINAAR may also have a legal obligation to collect personal information from clients.
Note: As clients agree to a particular processing of their data with LAMINAAR, they also have a right to withdraw the consent at any time.
LAMINAAR uses client data to authenticate and authorize access to its services. It only processes Client Data on their behalf and in accordance with their instructions provided in the applicable services agreement. Client data is used to provide a better experience and support with services. In each case, LAMINAAR collects such information only when it is necessary and appropriate to fulfil the purpose of the interaction with its services.
- To provide Services. LAMINAAR processes Client Data as a Data Processor to provide services to clients through LAMINAAR proprietary applications or solutions.
- To send emails and other communications. LAMINAAR may send service, technical and other administrative emails, messages and other types of communications. LAMINAAR may also contact clients to inform about changes in its Services and Services offerings. These communications are considered part of the Services and client may not opt out of them unless one chooses not to use LAMINAAR Services.
- Customer Support. If clients send a request (for example via a support email or via a feedback mechanism), LAMINAAR responds to the request to assist in resolving the issue faster.
- Other purposes: For any other purpose as provided for in the Services Agreement between LAMINAAR and the customer, or as otherwise authorized by the customer. In accordance with or as may be required by law.
HOW LAMINAAR USES OTHER DATA?
LAMINAAR may send service related messages or marketing/promotional materials. Clients may choose to restrict the collection or use of personal information. Other Data may be used to arrange a demo of a product on request, sending promotional material and updates about the company or inviting to conferences and events that are relevant. Direct marketing is carried out only on express consent provided by a client to receive such communications from LAMINAAR.
USERS UNDER 16 YEARS OF AGE
The Sites and Services do not knowingly collect personal information from users under the age of 16.
If a visitor or user is under the age of 16, they are not permitted to use the Services or to disclose Personal Information. If LAMINAAR learns that it has collected or received Personal Information from a child under 16, it will delete that information. If anyone believes LAMINAAR might have any information from or about a child under 16, one is requested to contact LAMINAAR immediately using the contact information on this website.
DATA RETENTION POLICY
Client Data – LAMINAAR will retain client information as long as a client has an active Services account. LAMINAAR may also retain client personal information for extended period under applicable statutory laws. LAMINAAR will retain client data in accordance with a Client’s instructions, including any applicable terms in agreements and as required by applicable law. When a client decides to stop using the said services, LAMINAAR will either delete or return all Client Data, as per their specific instructions.
CLIENT, VISITOR & USER RIGHTS
A client or visitor can request to access, update or correct their personal information. They also have the right to object to direct marketing.
They may have additional rights pursuant to their local law applicable to the processing. For example, if the processing of personal information is subject to the EU General Data Protection Regulation (“GDPR”), and their personal information is processed based on legitimate interests, they have the right to object to the processing on grounds relating to their specific situation. Under GDPR they also have the right to request for deletion or restriction of their personal data and ask for portability of their personal information.
CLIENT & VISITOR’S RIGHTS TO CONTROL DATA
When a client uses LAMINAAR’s services, it is aimed to provide them easy means to access, modify, delete, object to or restrict use of their personal information.
LAMINAAR strives to provide clients ways to access, update/modify their data quickly or to delete it unless that information has to be retained for legal purposes. Some rights can be access from within the LAMINAAR applications or solutions. For visitors, these rights can be exercised by contacting LAMINAAR with their specific request.
- Right to Rectify: One can edit some of of their personal data through their accounts. They can also ask LAMINAAR to change, update or fix their data in certain cases, particularly if it is inaccurate.
- Right to Erase: One can ask LAMINAAR to erase or delete all or some of their personal data (e.g. if it is no longer necessary to provide Services).
- Object or Limit or Restrict, Use of Data: One can ask LAMINAAR to stop using all or some of their personal data (e.g. if LAMINAAR does not have a legal right to continue using it) or to limit the use (e.g. if their personal data is inaccurate or unlawfully held).
- Right to Access/Take their Data: One can ask LAMINAAR for a copy of their personal data that they have provided in machine readable form.
CLIENT OR VISITOR INFORMATION SHARED WITH OTHERS
Client of visitor data will be shared with other recipients only in order to provide them with services. While LAMINAAR aims to limit the sharing of client of visitor data, at times, it is necessary to share their data with certain service providers. Examples of when and for what purpose their data is shared include, data center/hosting services, email marketing services, etc.
The following categories of recipient will most likely receive client of visitor data for LAMINAAR to provide services.
- Third Party Data Center Services
- Third Party SMTP and SMS notification services
To Comply with Laws: If LAMINAAR receive a request for information, it may disclose if they reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process. LAMINAAR may also share client of visitor data to an acquirer in the event of a sale of substantially all of their assets or other change of control transaction.
Cross-Border Data Transfers
Client or visitor data may be stored and processed in multiple countries including outside of the European Union (EU) Region
Since LAMINAAR is an international company, client or visitor data may be processed outside of the EU region. Data will be processed within Third Party Data Centers in India and Singapore. Some countries where LAMINAAR processes data may not have the same laws as the client’s own country and as such there are risks associated with such transfer.
LAMINAAR offers European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our Customers that operate in the European Union, and other international transfers of Customer Data. These clauses are contractual commitments between parties transferring personal data (for example, between LAMINAAR AVIATION and its Clients, suppliers or data processors outside the EU), binding them to protect the privacy and security of the data.
SECURITY MEASURES TO PROTECT CLIENT DATA
LAMINAAR implements security controls to prevent breaches and unauthorized access to client or visitor data. It maintains appropriate security measures to protect Client Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Examples of security measures include physical access controls, HTTPS, restricted access to data, monitoring for threats and vulnerabilities etc.
If there are any questions or queries regarding this Policy, please contact LAMINAAR through email at firstname.lastname@example.org.