Privacy policy

Data protection - personal information

BERLARIC shall collect personal information from the User relating to him/herself, as well as to parties linked to him/her, in the context of the booking of flights and ancillary services. BERLARIC shall treat the protection of personal information as a priority in its role as ‘Data Controller as defined in French Law No. 2018-493 of 20th June 2018 promulgated on 21st June 2018 having amended French Law No. 78-17 of 6th January 1978 regarding data processing, data files and liberties, pursuant to Regulation (EU) 2016/679 regarding data protection (‘the GDPR ’), with regard to the confidentiality and security of data.

The personal information transmitted by the Users shall be collected in order to perform the Services available on the Site (names, electronic and postal contact details, bank information, information relating to Gift Cards, etc.)

Information we collect from Other Sources

If you create or log into your Wingly account through a third-party platform (such as Facebook or Google), we will have access to certain information from that platform, such as your name, email, birthday, and profile picture, in accordance with the authorization procedures determined by such platform.

The social login data collected is used for the following purposes:
1. Creating and managing the user’s account on Wingly’s platform.
2. Facilitating the login process for users.
3. Personalizing the user experience on the Wingly platform.
4. Communicating with users about our services.

Wingly treats the protection of this social login data with the same priority as other personal information, in accordance with applicable data protection laws, including the GDPR.

Use of cookies during User visits to the website

For this reason, and in order to simplify User access to the Services and their Profile during visits after their first connection to the Site, BERLARIC also uses cookies which reside on the hard drive of the User’s computer once the web browser is closed. BERLARIC also uses ‘session cookies’ for the analysis of the use and content of the Site, in the interest of continuous improvement of the Services and the technical means available to the Site User. Some cookies are essential for use of the Site, others enable the optimisation of the use of the Site and the customisation of the content displayed.

Thus, Cookies permit:

  • The measurement and analysis of the frequency with which the Site is used, and the sections and flight services for posts, and to study the ergonomics of the Site with a view to improvement;
  • The User reserved access and personal spaces on the Site or our Services (registration, account access) or information which the User has selected (services, or flights posted, shopping basket contents);
  • The implementation of safety and security measures;
  • The limiting of the number of advertisements displayed.

(Hereafter referred to as ‘the Purposes’)

Solely the issuer of the relevant cookie can read or modify the information contained therein.

The User can always delete these cookies manually or manage their authorisations for their implementation by amending the parameters in their web browser.

BERLARIC does not use these tracking tools to transmit this information to third parties or E-commerce platforms, nor to link this data to personal data (names, addresses etc.) without the express consent of the User. Where appropriate, this consent shall be sought from the User in advance.

Communication of personal data to related third parties

In order to accomplish the Purposes outlined here above, the User shall expressly consent to the data collected being transmitted to the following recipients:

  • Social media platforms which may offer functions which allow it to integrate information from their account on such platforms into their Wingly profile;
  • The insurance partners of BERLARIC, e.g. BERLARIC shall potentially provide certain information to its insurer, Allianz GC&S and its broker, SAAM Verspieren Group in order to confirm the eligibility of Users for its insurance programme.
  • The marketing trading partners and service providers of BERLARIC within the limits authorised by law.
  • The voluntary sector partners of BERLARIC, such as the FFA (French Aeronautical Federation);
  • Organisations which carry out questionnaires and surveys;
  • More generally, the service providers, agents and subcontractors contractually linked with the BERLARIC company, for the performance of tasks which are directly linked to the purposes described here above;

The User acknowledges and expressly accepts that certain personal information collected by BERLARIC for the management of their Post and the management of the flight reservations and related tasks requires the transmission to Users of certain information, such as surnames, first names, postal, electronic and telephone contact details, aircraft names, precise location of the aircraft, with the specific exception of bank details.

Right of access to and rectification of personal information

Personal data may give rise to the exercise of a right to access and rectification under the conditions provided for in the GDPR, as well as by Law No. 78-17 of 6th January 1978, amended, relating to data processing, files and consumer rights. The User may obtain a copy of the data relating to him/her and, where appropriate, have it corrected and updated, or have information which is inaccurate, incomplete or out of date, removed. The User may also exercise their right to object, notably in respect of commercial or prospective marketing, and limitation of the use of their data, as well as their right to portability of the data relating to them.

The exercise of these rights shall be by sending an email to contact@wingly.io or a letter to the Registered Head Office of BERLARIC:

BERLARIC

7 Rue Voltaire

92300 Levallois Perret

France

Any question relating to the use of personal data may be addressed to BERLARIC at the above- mentioned address. For all requests for access to the data, the User is required to enclose proof of identity with their letter.

Deletion of the Account and personal data

Any User can delete their Account by logging in to the Site, but they shall remain committed with respect to any outstanding transaction(s) with any other User. To delete their account, the User must connect to their Wingly profile in the Security section (https://www.wingly.io/en/account/security) and click on “Delete account” at the bottom of the page. It should be noted that the deletion of the account and its data is irreversible for the User who will no longer be recoverable thereafter. It should be noted that BERLARIC is likely to keep certain information concerning the User when the law requires it or when BERLARIC has a legitimate reason to do so. This is the case, for example, if BERLARIC considers that the User has committed fraud or violated its General Conditions of Use.

BERLARIC reserves the right to delete any User Account, particularly in the event of:

  • Violation of one of the provisions of the T&C, specifically with regard to misappropriation of the Services offered by the Site;
  • Absence of any log-in to the User Account for a period of two (2) years, following the sending of an email alerting the User that if no response is received, the Account will be deleted in eight (8) weeks;
  • Legal action being taken by a User against other Users, specifically with respect to damage or regular destruction to Aircraft or other equipment attached to it;
  • Bypass or attempting to circumvent the Wingly website (i.e. an attempt to carry out a flight by circumventing the Wingly Platform). Any exchange of contact details (phone number, email, social media profile...) by the Wingly messenger may be considered as an attempt of bypass and can be punishable by banning of the user and the account in question;

The User undertakes to set up one sole Account, and not to create or use any other Account(s) which they have previously created, whether in their own name or that of a third party.

Exceptions to this rule shall subject to a direct request being sent from the User, and express authorisation from BERLARIC. The setting up or use of new accounts under their own identity or that of any third party without having requested and obtained authorisation from BERLARIC could result in the immediate suspension of the User's account(s) and all associated Services.

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