Introduction
Le Bas International Air Division (“Le Bas”) is strongly committed to protecting the privacy of its user community. The intent of this privacy statement is to detail the information Le Bas may gather about individuals who visit its website and how that information is used.

This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain, and the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data.

Personal Data
Le Bas uses the information collected from you to provide quotation and make telephone contact and if you so consent by opting-in, to email you marketing information which Le Bas believes may be of interest to you and your business. You can opt out at any stage.

Le Bas also acts on behalf of its clients in the capacity of data processor. When working exclusively as a data processor, Le Bas will be acting on the instruction of its client, and, if applicable, will work to ensure that the client is fully GDPR compliant.

Some personal data may be collected about you from the forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to personally identifying information like Internet Protocol (IP) addresses.

Cookies Policy
Le Bas may from time to time use such information to identify its visitors. Le Bas may also collect statistics about the behavior of visitors to its website.

We use cookies to store information, such as your personal preferences when you visit our site. This could include only showing you a popup once in your visit, or the ability to login to some of our features, such as forums.

Cookies and Web Beacons: We may also use third party advertisements on www.LeBas.com to support our site. Some of these advertisers may use technology such as cookies and web beacons when they advertise on our site, which will also send these advertisers (such as Google through the Google AdSense program) information including your IP address, your ISP, the browser you used to visit our site, and in some cases, whether you have Flash installed. This is generally used for geotargeting purposes (showing New York real estate ads to someone in New York, for example) or showing certain ads based on specific sites visited (such as showing cooking ads to someone who frequents cooking sites).

DoubleClick DART Cookies: We also may use DART cookies for ad serving through Google’s DoubleClick, which places a cookie on your computer when you are browsing the web and visit a site using DoubleClick advertising (including some Google AdSense advertisements). This cookie is used to serve ads specific to you and your interests (“interest based targeting”). The ads served will be targeted based on your previous browsing history (For example, if you have been viewing sites about visiting Las Vegas, you may see Las Vegas hotel advertisements when viewing a non-related site, such as on a site about hockey). DART uses “non personally identifiable information”. It does NOT track personal information about you, such as your name, email address, physical address, telephone number, social security numbers, bank account numbers or credit card numbers. You can opt-out of this ad serving on all sites using this advertising by visiting http://www.doubleclick.com/privacy/dart_adserving.aspx

You can choose to disable or selectively turn off our cookies or third-party cookies in your browser settings, or by managing preferences in programs such as Norton Internet Security. However, this can affect how you are able to interact with our site as well as other websites. This could include the inability to login to services or programs, such as logging into forums or accounts.

Deleting cookies does not mean you are permanently opted out of any advertising program. Unless you have settings that disallow cookies, the next time you visit a site running the advertisements, a new cookie will be added.

Log Files: We collect and use the data contained in log files. The information in the log files include your IP (internet protocol) address, your ISP (internet service provider, such as AOL or Shaw Cable), the browser you used to visit our site (such as Internet Explorer or Firefox), the time you visited our site and which pages you visited throughout our site.

Analytics: This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies” as outlined above. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, 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. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

You can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en.

Link to Third Party Sites
Please note that this policy applies only to the Le Bas website and not to the websites of other companies or organizations to which we provide links. Any third-party websites are viewed at your own risk.

Legal basis for processing any personal data
To meet Le Bas contractual obligations to clients and to also respond to marketing enquiries, or provide services requested directly by you.

Legitimate interests pursued by Le Bas Group and/or its clients
To promote the services offered by Le Bas and/or to market the services and/or products offered by Le Bas to existing clients.

Consent
Through agreeing to this privacy notice you are consenting to Le Bas processing your personal data for the purposes outlined. You can withdraw consent at any time by emailing dpo@lebas.com or calling us or writing to us.

Acquisition of Data
All Data will be collected in an open and honest manner and obtained fairly. We will make you aware of all purposes that we intend to use your Data for, when we collect your data and prior the use of your data.

Data will be accurate and complete and, where necessary, kept up to date.

Data will be adequate, relevant and not excessive in relation to the purposes for which it was obtained.

The acquisition methods we use for example account application forms, marketing surveys, or competition entries will have clear information to explain the intended purposes including secondary uses that may not be obvious to you for example if a competition entry is intended to be used for marketing purposes we will clearly advise you of this and the appropriate opt out mechanism.

You should read this statement carefully before using the website.

How data is obtained
Information can be provided to us through our website, Livechat, emails or on calls when you enquire about a service, enquire about bill, or call to pay a bill or place an order and book a service.

Information that has been provided by other organizations that obtained your permission to share the data.

Call data
Information can be obtained on calls in and out of Le Bas which may be recorded for quality and training purposes but are only kept for a period of 30 days.

How we use your data
We need your data so as to be able to enquire about, and provide the services to you, as per your contract. The details will only be accessible by Le Bas agents or approved third parties to assist in identification of your account. Your data will be used in the performance of a contract to be able to communicate with you on Sales, Support, Billing, Service delivery issues and to meet our regulatory requirement and adherence to applicable Laws.

Marketing Preference
From time to time we may send you a marketing message that could be of interest in relation to amending your product from a service or contract issue, or to partake in a survey.

You can amend your preferences at any time to unsubscribe from direct marketing messages by clicking unsubscribe on a marketing email. This will not unsubscribe you from receiving communications from Le Bas in relation to information on your account in the performance of service to you.

Disclosure
Le Bas may on occasions pass your Personal Information to third parties exclusively to process work on its behalf. Le Bas requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and, if applicable, with GDPR.

Le Bas do not broker or pass on information gained from your engagement without your consent. However, Le Bas may disclose your Personal Information to meet legal obligations, regulations or valid governmental request. Le Bas may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of Le Bas, its clients and/or the wider community.

Data storage
Data is held in the United States and Ireland using different (multiple) servers.

Securing your Data
Le Bas takes technical measures as well as organizational security measures which are set out in law and by industry standards to ensure that we protect your personal data from unauthorized access, use or disclosure.

We will ensure that we use your personal information as set out in our privacy notice and to the choices that you have made regarding permission. Le Bas only partner with reputable service providers who contract to provide the same level of security on information so that your data is at all times protected and used in accordance with our Privacy Notice.

Retention Policy
Le Bas will process personal data during the duration of any contract and will continue to store only the personal data needed in accordance with Le Bas Data Retention Policy and as required by Law or Regulations

Record Retention Period
Recorded Calls Recorded Calls are stored for a period of up to 30 days.
Invoice Details Invoice details are required to be maintained for a minimum period of 6 years plus the current year.
Customer Support Information Customer communications in relation to a contracted service are maintained for a minimum of 6 years plus the current year.
Customer Contracts Contracts are stored to support invoices raised which must be kept for a minimum period of 6 years plus the current year.
CCTV Images Images are stored for a period of up to 30 days.
Cookies • Session cookies are only stored on a per session basis to assist in the customers navigation of our web-sites, so that we offer personal content for you.

• Persistent cookies are only stored to assist in the customer’s navigation of our web-sites using the stored data to display related preferences.

Customer can control cookies by changing the options on their computer / browser

Your rights as a data subject
At any point whilst Le Bas is in possession of or processing your personal data, all data subjects have the following rights:

Right of access – you have the right to request a copy of the information that we hold about you.
Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
Right of portability – you have the right to have the data we hold about you transferred to another organization.
Right to object – you have the right to object to certain types of processing such as direct marketing.
Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.

In the event that Le Bas refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.

Le Bas at your request, can confirm what information it holds about you and how this information is processed.

You can request the following information:
• Identity and the contact details of the person or organization that has determined how and why to process your data.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of Le Bas or a third party such as one of its clients, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority (Data Protection Regulator).
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

To access what personal data is held, identification will be required
Le Bas will accept the following forms of ID when information on your personal data is requested: a copy of your national ID card, driving license, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If Le Bas is dissatisfied with the quality, further information may be sought before personal data can be released.

All requests should be made to dpo@lebas.com or writing to us at the address further below.

Link to Third Party Sites
Please note that this policy applies only to the Le Bas website and not to the websites of other companies or organizations to which we provide links. Any third-party websites are viewed at your own risk.

Changes to Privacy Statement
Le Bas may change this Privacy Statement from time to time. It is advisable that you review this Privacy Statement regularly for any such changes.

Governing Law
This Privacy Statement shall be construed in accordance with, and governed by, the laws of the State of California, United States of America without regard to any conflict of law principles. The parties stipulate that any litigation or arbitration will take place in Orange County, California, or, as to matters subject to federal jurisdiction, the U.S. District of California, Central District. The prevailing party in any dispute shall be entitled to recover reasonable attorneys’ fees and cost of suit.

Complaints
In the event that you wish to make a compliant about how your personal data is being processed by Le Bas or its partners, you have the right to complain to Le Bas.

The details for each of these contacts are:
Le Bas International Air Division
16152 Beach Blvd., Suite 220, Huntington Beach, CA 92647 USA
Telephone +1 (805) 593-0510 or email dpo@lebas.com