PRIVACY POLICY
IN ACCORDANCE WITH EUROPEAN REGULATION 2016/679 OF APRIL 27, 2016 (CALLED "GENERAL REGULATION ON DATA PROTECTION" OR GDPR)

Objective of this policy

As part of the use of its airport platform, its services and in particular the services accessible on its website, Air'Py (SIRET N ° 822 864 500 00019, RCS Pau 822 864 500), in its capacity as data controller, is likely to collect and process personal data concerning you.

Air'Py is particularly attached to respecting the rules for protecting the privacy of passengers, visitors to its website, its business partners, employees and subcontractors.

All the processing of personal data implemented within the framework of the accessible services complies with the local regulations applicable in terms of the protection of personal data and in particular the provisions of the law "Informatique et Libertés" of January 6, 1978 as amended and the General Regulations on Data Protection (EU Regulation 2016/679) or "RGPD".

In order to ensure the proper application of these rules, Air'Py has appointed a data protection officer who is the privileged relay of the National Commission for Computing and Liberties (CNIL). Air'Py also implements the appropriate internal procedures to educate its employees and ensure compliance with these rules within its organization.

This Charter applies to the Data collected:

• by simply browsing the Site
• Via e-mails exchanged between Air'py Aéroport Pau Pyrénées and you or any other e-mail tool as well as via complaint forms.

It does not apply to information collected by any third party or through sites managed by them, including through applications or content (including advertisements) redirecting the user to the Site. We thank you for carefully reading the Charter concerning the processing of your Data and we inform you that browsing our Site necessarily implies acceptance of this Charter. If the latter does not obtain your membership, we invite you to leave our Site. It is your responsibility to check that the Data communicated to Air'py Aéroport Pau Pyrénées is compliant.

1. WHAT DATA IS COLLECTED BY AIR'PY AéROPORT PAU PYRéNéES?

Air'Py is committed to providing clear, concise information in accordance with regulatory requirements for each processing of personal data implemented. The purpose of this policy is to provide general information on the main principles of processing of this data by Air'Py, each processing being covered by specific and precise information.

Depending on the nature and purpose of your interaction with Air'py Aéroport Pau Pyrénées (information on contact forms, as well as during any telephone exchanges) we are likely to collect the following Data:

• Your email address will necessarily be requested if you communicate with us through the contact forms.
• Data relating to your identity such as your last name, first name, email address, postal address and telephone number may be requested from you.

• Data relating to browsing: this is Data relating to the way in which you use the Site including: the IP address, the browser used, the browsing time, the search history, the operating system used , the language and the pages viewed
• Data relating to your visits to the Site, including traffic data, log files and other data or communication resources that you use while accessing the Sites
• Data relating to the use of social networks when you use their functionalities.

2. HOW IS YOUR DATA COLLECTED?

Data may be collected in different ways on the Site. Data may be collected directly when you transfer them to us by means of the contact and user account creation, newsletter subscription forms available on the Site and / or communicated when you contact us by telephone. When you contact us using these different means, a copy of your exchanges with Air'py Aéroport Pau Pyrénées, including email addresses, can be made and archived. Air'py Aéroport Pau Pyrénées also indirectly collects certain Data by means of cookies / tracers. We invite you to read our Cookies Charter, intended to help you better understand these technologies and the use we make of them on the Site and in the context of our services, applications and tools.

3. WHY IS YOUR DATA COLLECTED?

If you are a simple user, we collect your Data to:

• Send you our Newsletter and / or personalized commercial offers if you have consented to it
• Manage your requests sent via the contact page
• Respect our rights and obligations stipulated in the contracts concluded with the users as well as for any other legal purpose.

We can also use cookies or tracers to:

• Secure your browsing and improve your user experience,
• Analyze traffic and data on the Site in order to measure the number of users of the Site, to make it easier to use and to ensure its ability to respond quickly to your requests.

Refusing to correctly complete the form (s) on the Site may block access to certain pages.

4. WHO PROCESSES YOUR DATA?

Your Data is processed by the staff and collaborators of Air'py Aéroport Pau Pyrénées in charge of:

• Management of exchanges via the Site (Contact form)
• Support management, to answer all your questions outside the Site

In addition, as part of our activity, and for processing purposes, your Data may be communicated to subcontractors, service providers or other third parties, and in particular:

• Google analytics
• Facebook
• Each of its actors respecting a confidentiality commitment concerning the use and processing of personal data.

All of the aforementioned subcontractors, service providers, Partners or other third parties are bound by contractual obligations to respect the confidentiality and protection of Data and to process them only for the purposes for which we transmit them.

Your Data may be transmitted to any buyer or other successor in the event of a merger, sale, restructuring, reorganization, dissolution or other sale or transfer of part or all of the assets of Air'py Aéroport Pau Pyrénées due to uncertainties. or bankruptcy, liquidation or other processes in which the Data of Air'py Aéroport Pau Pyrénées users are among the transferred assets.

Finally, we are also likely to disclose your Data:

• to comply with any mandate required by applicable laws, including government and regulatory requests
• if we believe that disclosure is made necessary or required to protect the rights, property or safety of Air'py Aéroport Pau Pyrénées, its customers or other stakeholders.

This possible disclosure includes exchanging information with other companies and organizations for the purposes of fraud and counterfeit protection.

The Site may contain links to various sites and social network platforms managed on third-party servers, by people or organizations over which Air'py Aéroport Pau Pyrénées has no control. Therefore, we can in no way be held responsible for the way your Data will be stored or used on the servers of these third parties. We advise you to read the applicable personal data protection charter of each third-party website that you access via the Site in order to assess the way in which your Data will be used.

5. HOW LONG IS YOUR DATA KEPT?

Air'py Aéroport Pau Pyrénées only keeps your Data for the time necessary for the purposes set out in Article 3. This retention period is not the same depending on the Data in question, the nature and purpose of the collection being likely to vary this duration. Likewise, certain legal obligations impose a specific retention period.

When you have subscribed to the Newsletter, we will keep your email address until you unsubscribe.

When you contact Air'py Aéroport Pau Pyrénées using the contact form or when you communicate with us by phone, your data may be stored:

• up to one (1) year from the last contact via the contact form or by phone or e-mail
• In all other cases, the retention period of these exchanged Data may not exceed one (1) year.

If you make a request for the deletion of Personal Data, they will be deactivated and then completely deleted at the end of the aforementioned periods from the day on which you made the request. As regards the Data collected by means of cookies or tracers, they will be kept for up to six (6) months for cookies or tracers measuring the audience and up to thirteen (13) months for others. Beyond the aforementioned retention periods, your Data will be anonymized to be kept for exclusively statistical purposes.

6. HOW IS YOUR DATA PROTECTED?

Your Data is kept on a secure server hosted in France and protected by a firewall and antivirus. We have implemented technical and organizational measures intended to guarantee the security and confidentiality of your Data against any accidental loss and against any unauthorized access, use, modification and disclosure. Taking into account the inherent characteristics of the Internet, it is however impossible for us to guarantee the absolute security of information exchanges on this network. We implement best practices and CNIL recommendations in order to best protect your personal data. In addition, we invite you to be particularly vigilant regarding your personal data. For example, you are responsible for keeping the password that allows you to access your user account secret. Under no circumstances divulge it to third parties. Likewise, be vigilant when disclosing information in the public sections of the Site, which can be viewed by any user of the Site.

7. DATA TRANSFER

Air'Py does not, as far as possible, transfer personal data outside the European Union. Otherwise, the information relating to the processing in question expressly states this, and a precise legal framework is defined with the recipient in order to ensure the continuity of the protection of your data.

8. WHAT ARE YOUR RIGHTS?

You can choose how the Data you send us is used:

• You can browse the Site without providing any Data. This will in no way hinder your visit to the Site.
• You can refuse to communicate your personal details. In this case, you will not be able to send us a message using the contact form.

In accordance with the provisions of the applicable regulations on the protection of personal data, in particular the European regulation 2016/679 on data protection (the "RGPD") as well as the law of January 6, 1978 n ° 78-17 known as "Informatique et Libertés" and its modifications, you have a right of access and a right of rectification on your Data.

In addition, subject to the conditions provided for by said regulation for the exercise of these rights, you benefit from:

• A right to the erasure of your Data (Excluding accounting data whose retention of 10 years is required by French law - article L123-22 of the Commercial Code)
• A right to limit the processing of your Data
• A right to object to the processing of your Data for legitimate reasons, in accordance with Article 21 of the GDPR
• A right to portability on the Data you have provided (for automated processing based on consent or the execution of a contract)
• The right to withdraw consent, when you have been requested to do so. When the processing of your Data is carried out on the basis of your consent, you can withdraw it at any time.

This right can be exercised by using the rectification request form accessible here: request form

You acknowledge however that the processing carried out before the revocation of your consent remains perfectly valid. You also have the right to object without reason for Air'py Aéroport Pau Pyrénées to analyze your Data in order to share them for marketing purposes.

However, in accordance with article 12.6 of the GDPR, for the exercise of these rights, Air'py Aéroport Pau Pyrénées, as responsible for this processing, reserves the right to ask you to justify your identity. We inform you that the data allowing to justify your identity will be deleted once we have answered your request. You can exercise these rights by sending an email in French to contact@pau.aeroport.fr or to the following address:

Air'py Pau Pyrénées Airport – Route de l’Aéroport - F 64230 Uzein

We have one month to respond to any request relating to the exercise of your rights. This period may be extended by two months, due to the complexity or too many requests.

9. STORAGE OF DATA COLLECTED BY AIR'PY AéROPORT PAU PYRéNéES

The Data collected in the context of the use of the Site are stored exclusively on a server located in Europe (France), hosted by the company Héliantis - Ama Dablam center, 20 rue Johannes Kepler, F-64000 Pau - contact@heliantis.fr - + 33 820 82 68 28.