FlyKly Privacy Policy

FlyKly S.r.l. ("FlyKly"), with registered office in Corso Italia 8, Milan (Italy) which can be contacted at the email address privacy@flykly.it, process - in its capacity of data controller - personal data provided by the user (the "User") of the website www.flykly.com (the "Site") according to the methods and for the purposes set out in this statement, and in compliance with the European Data Protection Regulation 679/2016 (hereinafter the "Privacy Regulation").

1. Type of data processed

The Company processes personal data spontaneously provided by Users in their interactions with the Site, and in particular:

  1. data supplied by Users at the same time as requests for information or assistance;
  2. navigation data relating to the use of services offered through the Site collected through cookies in accordance with the information on cookies available at the following link [*];

(jointly defined "Data").

2. Purposes of the Treatment

FlyKly processes Personal Data for the following purposes:

    1. the provision of the Services offered through the Site, including the provision of responses to the User's requests of information or assistance through the appropriate "Hello Flykly" function;
    2. compliance with the applicable national/EU laws and/or respond to requests from public and government authorities;

(the purposes from letters a) to b) are jointly referred to as "Contractual Purposes")

  1. development and improvement of the Services offered through the Site;
  2. to exercise or defend legal claims in court proceedings or in an administrative or out-of-court procedures;
  3. to complete a potential merger, sale of assets or transfer of all or a material part of its business, by disclosing and transferring the Personal Data to the third party or parties involved in the transaction as part of the transaction;

the purpose as per letters from c) to e) above are jointly referred to as "Legitimate Interest Purposes")

3. Legal basis of the processing

The processing of the Personal Data is necessary with regard to the Contractual Purposes as it is essential:

  • allow users to register with the site and to use the services through this offer, with reference to the cases referred to in paragraph 2 a) to d);
  • and comply with the rules applicable in the case provided for in paragraph 2, point c).

Should the User not provide its Personal Data with regard to the Contractual Purposes, Flykly will not be able to provide the User with the Services.

The processing of the Personal Data with regard to the Legitimate Interest Purposes as per Section 2 is carried out pursuant to article 6, letter f) of the EU General Data Protection Regulation No. 679/2016 (the "Privacy Regulation"), or the pursuit of legitimate interests of the company to defend its rights with regard to the case referred paragraph 2 point e) and society and their counterparts to carry out economic transactions referred to in paragraph 2 letter f). This data processing activity with regard to the Legitimate Interest Purposes is not mandatory and the User can object to the data processing at any time through the modalities as per Paragraph 10 of this Privacy Policy.

In such case no data processing will be carried out by FlyKly, except in case where FlyKly demonstrates the existence of legitimate prevailing arguments or the processing is necessary to exercise or defend FlyKly' s rights pursuant to Section 21 of the Privacy Regulation.

4. Transmission of data

For the Contractual Purposes, the Personal Data may be transferred to the following categories of recipients located both within the EU and, within the limits as per Section 8 below, outside of the EU:

    1. third parties service providers entrusted with processing activities that provide services or assistance and advice to FlyKly, with special - but not exclusive - reference to technology, accounting, administrative, legal, insurance, IT matters;
    2. persons and authorities whose right to access Personal Data is recognized by law, regulations or provisions issued by legally empowered authorities.

For the Legitimate Interest Purposes, Personal Data may be transferred to the following categories of recipients located both within the EU:

  1. potential purchaser of FlyKly and the entities resulting from mergers or any other transformation involving FlyKly,
  2. competent authorities

A complete list of the data processor appointed by FlyKly is available upon request through the modalities as per Paragraph 10 below or can be consulted at the Head Office of the owner

5. Data transfer abroad

The Personal Data will not be transferred to countries outside the European Economic Area.

6. Treatment methods

Personal Data will be processed both electronically and/or manually, in any case in such a way as to guarantee the security, protection and confidentiality of the data, thanks to appropriate administrative, technical, personnel and physical measures against loss, theft and unauthorized use, disclosure or modification.

7. Data retention

Personal data of the User will be stored for the period necessary to fulfil the purposes for which the data was collected as outlined in this Privacy Notice. In any case the following retention periods will apply to the processing of the Personal Data for Contractual Purposes and for Legitimate Interest Purposes is retained during the provision of the Services plus a period of 10 years after the termination of the Services, except when the detention of the data is necessary to respond or to file a legal actions, upon request of the competent authorities or in compliance with the applicable laws.

Once the terms indicated above have elapsed, the User's data may be deleted, anonymised and / or aggregated.

8. User’s rights

The User, at any given time, can exercise the following rights, by sending an email to the following address privacy@flykly.com:

  1. to obtain from FlyKly confirmation of the existence of Personal Data and to be informed of its content and source, verify its accuracy and request its integration, update or amendment;
  2. request the erasure, anonymisation or restriction of the processing of Personal Data processed in breach of the applicable laws;
  3. to withdraw the consent to the processing of the data (if and to the extent such a consent is necessary);
  4. request FlyKly to limit the processing of the Personal Data where:
    • the User contests the accuracy of the Personal Data until FlyKly have taken sufficient steps to correct or verify its accuracy;
    • the processing is unlawful, but you do not want us to erase the Personal Data;
    • FlyKly no longer needs the Personal Data for the purposes of the processing, but the User requires them for the establishment, exercise or defence of legal claims; or
    • The User has objected to processing justified on legitimate interests, pending verification as to whether FlyKly has compelling legitimate grounds to continue processing.
  5. object to the processing of the Personal Data, except in case where FlyKly demonstrates the existence of legitimate prevailing arguments or the processing is necessary to exercise or defend FlyKly' s rights pursuant to Section 21 of the Privacy Regulation;
  6. request the erasure of the Personal Data without undue delay;
  7. receive an electronic copy of the Personal Data, if the User would like to port its Personal Data to itself or a different provider, when FlyKly is relying upon the User's consent or the fact that the processing is necessary for the provision of the Services and the Personal Data is processed by automatic means; and
  8. request the erasure of the Personal Data without undue delay;

9. Data of Users under 18

The Site is not addressed to users under age of 18 and, in any case, FlyKly does not collect and process wittingly Personal Data referred to users under age of 18. In case FlyKly is aware of the collection and processing of such Personal Data, FlyKly will delete it immediately.

10. Contacts

Should the User have doubts, observations or complaints about the methods for collecting or processing the Data by the Data Controller, or would like to exercise one of the rights listed in paragraph 8, he / she may contact the Owner directly through the Contact section of the Website, or send an e-mail to the following address privacy@flykly.com

11. Changes and Updates

This information is valid from the date indicated in its header. The Company could however make changes and / or additions to said disclosure, also as a consequence of any subsequent amendments and / or regulatory additions to the Privacy Regulations. Any changes to the information will be notified in advance to the Users, in any case, the updated text will always be available at https://flykly.com/privacy/.