Legal | Flight Media | Airport Advertising

At Flight Media Airport Specialists (Pty) Ltd we respect your privacy and is committed to protecting your Personal Information. This policy (“Policy”) explains how we process personal information and your privacy rights.

It is important that you read this Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing Personal Information about you so that you are fully aware of how and why we are using your information.

Reference to “Consent”, “your Consent” or “your explicit Consent” shall include the ticking of a tick box or when ticking "Send Message” or “I agree” on our Contact page to send your details requesting us to contact you or sending a reply by email after we have made available our Privacy Policy to you, or submitting an instruction via email to us (or any of our Personnel) or completing a form where we require more information from you for use of our Services

1. IMPORTANT INFORMATION AND WHO WE ARE

a): Responsible Party
i): Flight Media Airport Specialists (Pty) Ltd is the Responsible party when engaging with you as a user of the Flight Media website (https://www.flightmedia.co.za/) and other social media sites (“Sites”), and responsible for your Personal Information (also referred to as "Flight Media", "we", "us" or "our" in this Privacy Policy) and when you (as customer) signs up for our services.
ii): Take note that occasionally we act as Operator and only act on instructions from an applicable Responsible party. Where we act as Operator, we will process Personal Information in accordance with the service agreement between us and the Responsible party (i.e. where we act on the instructions of our clients).
iii): Taking into account the nature, scope, context and purposes as well as the risks of varying likelihood and severity of the rights and freedoms of natural persons, we have implemented appropriate technical and organisational measures to ensure and be able to demonstrate that processing is performed in accordance with POPIA. We shall review and update where necessary
b): Contact details
i): We have appointed an Information Officer (IO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests, please contact the IO using the details set out below:
(1): Information Officer: Edward Stenri
(2): Email address: edward@flightmedia.co.za.
ii): ii) You have the right to make a complaint at any time to the Information Regulator's office (IR), the Republic of South Africa’s authority for data protection issues (https://www.inforegulator.org.za). We would, however, appreciate the chance to deal with your concerns before you approach the IR, so please contact us in the first instance.
c): Changes to the Policy and your duty to inform us of changes

i): We keep our Policy under regular review. This version was last updated as per the date in the footer. Archived versions can be obtained by contacting us. Any changes made to our Policy in future will be posted on our website. The new version will apply the moment it is published on our website.
i): It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.
d): Third party links: Our Sites may include links to Third party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow Third parties to collect or share data about you. If you disclose your Personal Information to a Third party, such as an entity which operates a website linked to this website or our social media sites, WE WILL NOT BE LIABLE FOR ANY LOSS OR DAMAGE, HOWSOEVER ARISING, SUFFERED BY YOU AS A RESULT OF THE DISCLOSURE OF SUCH INFORMATION TO THE THIRD PARTY. This is because we do not regulate or control how that Third party uses your Personal Information. You should always ensure that you read the privacy policy of any Third party. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

a): Personal Information means the information as per the Definitions. Personal Information does not include data where the identity of the Data subject has been removed (anonymous data).
b): We may process different kinds of Personal Information about you when we engage with you, which we have grouped together as follows:
i): Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
ii): Contact Data includes billing address, email address and telephone numbers.
iii): Financial Data includes banking details.
iv): Special Personal Information includes biometric and health information.
v): Children information Personal Information about a Child;
vi): Transaction Data includes details about payments to and from you and other details of products and services you have acquired from us or accessed on our website.
vii): Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
viii): Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
ix): Usage Data includes information about how you use our website, and services. This information shall include the full Uniform Resource Locators (URL) Clickstream to, through and from our website (including the date and time) and the services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page and any phone number used to call us.
x): Marketing and Communications Data includes your preferences in receiving marketing from us and our Third parties and your communication preferences.
c): The Responsible Party also collect, use and share aggregated data and pattern data such as (but not limited to) statistical or demographic data for any purpose (Aggregated Date). Aggregated Data could be derived from your Personal Information but is not considered Personal Information in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if the Responsible Party combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this privacy policy.
d): We do not collect any Special Personal Information about you or your child. When you visit our offices, you may provide Special Personal Information about yourself and/or your child to the reception or one of our representatives/Franchisees (COVID19 questionnaire).
e): We do not process Information of Children.
f): Submission of Personal Information on behalf of another: If you provide information on behalf of someone else, then it is your responsibility to obtain the necessary consent from the person/ user before making the Personal Information available to us. On receipt of Personal Information, we assume that the necessary consent has been obtained and will process the Personal Information as per your instructions. By submitting such Personal Information on behalf of another person/ user, you indemnify us against any Third party claim, where such Third party claim relates to Personal Information that has been processed without the necessary consent or other available exception allowed by law.
g): If you fail to provide Personal Information: Where we need to collect Personal Information by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services (including services for no charge)). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL INFORMATION COLLECTED?

We use different methods to collect data from and about you including through:

a): Direct interactions. You may directly provide Personal Information when you:
i): instruct us to provide certain Services;
ii): engage with us via Microsoft Teams, Zoom, Skype or any other Video conferencing facility;
iii): completion of a COVID-19 questionnaire;
iv): request information about other services we or any of related parties may be able to provide;
v): give us feedback;
vi): visit and use our website or various other social media platforms; or
vii): visit our, our supplier’s or our client’s offices/ facilities/ premises or meet with our professional staff at any other location as instructed by you.
b): Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment/ devices, browsing actions and patterns. We collect this Personal Information by using cookies (see clause 4 below), server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
c): Third parties or publicly available sources. We will receive Personal Information about you from various Third parties and public sources as set out below:
i): Technical Data from the following parties:
(1): analytics providers such as Google ("How Google uses information from sites or apps that use our services", (located at https://policies.google.com/technologies/partner-sites);
(2): advertising networks; and
(3): search information providers.
ii): Contact, Financial and Transaction Data from providers of technical and payment services.
iii): Technical and Transactional Data from Third-party service providers that provide a service to you, subject to your consent to us to collect the information.
iv): Identity and Contact Data from publicly available sources such as CIPC.

4. COOKIES

a): Our sites make use of cookies to help us understand our users better. Cookies are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit. Cookies do not harm your computer or any files on your computer. Depending on the type of cookie we use, cookies also allow us to make our websites more user friendly.
b): Flight Media may use Third party vendors, including but not limited to Google and MSN/ Bing to show Flight Media-related ads on sites on the internet. Third party vendors use cookies to serve ads based on a user’s prior visits to our sites or other websites. Users may opt-out of Google’s use of cookies by visiting the Google Advertising Settings Page or the Network Advertising Initiative's opt-out page for other Third party vendors’ use of cookies.
c): You should be able to adjust your browser so that your computer does not accept cookies.
d): You can, alternatively, adjust your browser to notify you when a website attempts to put a cookie on your computer. How you adjust your browser to stop it accepting, or to notify you of, cookies will depend on the type of internet browser programme your computer uses.
e): Please remember, cookies do not contain identity, contact or financial information. We do not exchange cookies with any Third party websites or external data suppliers.

5. HOW WE USE YOUR PERSONAL INFORMATION

a): We will not sell your Personal Information. We will only use your Personal Information within the framework of the law. Most commonly, we will use your Personal Information in the following circumstances:
i): where you have given your Consent; or
ii): where it is needed to perform the contract that we or our Franchisees are about to enter into or have entered into with you; or
iii): where it is necessary for the protection of the Data Subject’s legitimate interest; or
iv): where it is necessary for our or our Franchisees legitimate interests (or those of a Third party) and your interests and fundamental rights do not override those interests; or
v): where we need to comply with a legal obligation.
b): Generally, we do not rely on consent only as a legal basis for processing your Personal Information although we will get your consent before sending Third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
c): Purposes for which we will use your Personal Information
i): We have set out below, in a table format, a description of all the ways we plan to use your Personal Information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
ii): Note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Information where more than one ground has been set out in the table below.
d): Flight Media only shares Personal Information with other companies or individuals outside of Flight Media in the following circumstances:
i): We have your consent. We require opt-in for the sharing of any Special Personal Information (where applicable).
ii): We may provide such information to collaborating companies or other trusted businesses or persons for the purpose of processing Personal Information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other confidentiality and security measures.
iii): We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to:
iii): 1) satisfy any applicable law, regulation, legal process or enforceable government request;; 2) enforce applicable terms of use, including investigation of potential violations thereof;; 3) detect, prevent, or otherwise address fraud, security or technical issues; or; 4) protect against imminent harm to the rights, property or safety of Flight Media, its users or the public as required or permitted by law.
e): Marketing: We strive to provide you with choices regarding certain Personal Information uses, particularly around marketing and advertising (where applicable).
i): Promotional offers from us
(1): Information about our Services as a customer of Flight Media:
(a): When you acquired any of our Services or make use of our website (browse wrap agreement) we will deal with you as a client under POPIA.
(b): We will use your identity and contact information to submit to you information/ material of our other Services that are related and that we feel may be of interest to you.
(c): Important: you may ask us on submission of your identity and contact information not to send you the above-mentioned information. At any time, subsequent to our initial engagement, you can make use of the opting out options under par. aiii) below;
(2): Not a customer of Flight Media yet:
(a): We may collect through one of our employees or through our mailing system, your email address; however
(b): Before we use same for any direct marketing purposes, we will ask you for consent (opt-in) prior to sending you direct marketing material.
ii): Third-party marketing
(1): We will get your express opt-in consent before we share your Personal Information with any Third party for marketing purposes.
(2): TAKE NOTE: We may provide (without your consent) Third party marketing parties/ advertisers with anonymous aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on a specific product or advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in Gauteng). We may make use of the Personal Information we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.IMPORTANT: We do not disclose information about identifiable individuals to our advertisers.
(ii): Opting out
(1): You can ask us or Third parties to stop sending you marketing messages at any time and requesting to op-out of our marketing services.
(2): Where you opt out of receiving these marketing communications, we will remove you from our mailing list. However, take note that we will continue to use your Personal Information as stated under the table above.
(e): Change of purpose
(i): We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
(ii): If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
(iii): Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. DISCLOSURES OF YOUR PERSONAL INFORMATION

a): We may share your Personal Information with the parties set out below for the purposes set out in the table above.
i): Internal Third parties as set out in the Definitions. Where we share your Personal Information to our collaborating companies/ related parties/ partners / agents, as the case may be, we ensure your Personal Information is protected by requiring all collaborating parties to follow this Policy when processing your Personal Information.
ii): External Third parties as set out in the Definitions and to those external parties as per your instructions.
1): We may provide such information to collaborating companies/ partners of Flight Media or other trusted businesses/ correspondents or persons for the purpose of processing Personal Information on our behalf.
2): We may disclose Personal Information to Third parties to whom we choose to sell, transfer or merge all or parts of our business or our assets.
3): We may provide such information where we seek to acquire other businesses or merge with them. If a change happens to our organisation, then the new members may use your Personal Information in the same way as set out in this Privacy Policy.
4): We require all Third parties to respect the security of the Personal Information we make available to them and to treat it in accordance with the law. We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.
5): We do not allow our Third-party service providers to use your Personal Information for their own purposes and only permit them to process your Personal Information for specified purposes and in accordance with our instructions.

7. INTERNATIONAL TRANSFERS

a): Some of our External Third-parties may be based outside the Republic so their processing of your Personal Information could involve a transfer of data outside South Africa.
b): Whenever we transfer your Personal Information out of the country, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
i): Flight Media enters into written contracts with Third party service providers that contain terms substantially the same as those set out in this Privacy Policy, in particular, in relation to requiring appropriate technical and organisational data security measures and relating to the further transfer of Personal Information from the Third party recipient to Third parties who are in a foreign country.
ii): Processing of Personal Information takes place in a territory which is subject to Data Protection Laws similar to our Data Protection Legislation and that the territory provides adequate protection for the privacy rights of individuals.
iii): Confirming that the necessary pre-authorisation from the information Regulator (only where said pre-authorisation is required by the Data Protection Legislation), has been obtained by the Responsible party, i.e. section 57 of POPIA.
c): By submitting your Personal Information to us you consent to the transfer of your Personal Information outside the borders of South Africa (when required).

8. DATA SECURITY

a): We have put in place appropriate technological and organisational measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other Third parties who have a business need to know. They will only process your Personal Information on our instructions, are subject to a duty of confidentiality.
b): Where required by law we will notify you and any applicable regulator of a breach where we are legally required to do so.
c): Where we act as Operator, the Responsible party must ensure that it has implemented appropriate technical and organisational measures against unauthorised or unlawful processing, access, disclosure, copying, modification, storage, reproduction, display or distribution of Personal Information. Other than securing the Personal Information on collection of same from the Responsible party via the Flight Media Services, Flight Media shall not be responsible for any other Responsible party’s security safeguard obligations.

9. DATA RETENTION

a): We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or regulatory requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we need to resolve a dispute or exercise our rights under any Contract.
b): To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory or other requirements.
c): In some circumstances you can ask us to delete your data: see YOUR LEGAL RIGHTS below for further information.
d): In some circumstances we will anonymise your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

10. RECORDS

We will keep detailed, accurate and up-to-date written records regarding any processing of Personal Information we carry out, including but not limited to, the access, control and security of the Personal Information and approved subcontractors, the processing purposes, categories of processing, any possible transfers of Personal Information to a Third party country and related safeguards, the instructions as received from our clients and a general description of the technical and organisational security measures and retention and destruction of Personal Information.

11. SOCIAL MEDIA

a): Our website may, in certain circumstances, provide you with social plug-ins from various social media networks. If you choose to interact with a social network such as LinkedIn (for example by registering an account), your activity on our websites will also be made available to that social network. This is necessary for the performance of your contract with us, which allows you to interact with a social network. If you are logged in on one of these social networks during your visit to one of our websites or are interacting with one of the social plug-ins, the social network might add this information to your respective profile on this network based on your privacy settings. If you would like to prevent this type of information transfer, please log out of your social network account before you enter one of our websites, or change the necessary privacy settings, where possible.
b): Communication, engagement and actions taken through external social media networks that we participate in are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.
c): You are advised to use social media networks wisely and communicate/ engage with them with due care and caution in regard to their own privacy policies (if any). PLEASE NOTE: WE WILL NEVER ASK FOR PERSONAL OR SENSITIVE INFORMATION THROUGH SOCIAL MEDIA NETWORKS AND ENCOURAGE USERS, WISHING TO DISCUSS SENSITIVE DETAILS OR TO RESOLVE ISSUES/ CONCERNS, TO CONTACT US THROUGH PRIMARY COMMUNICATION CHANNELS SUCH AS BY TELEPHONE OR EMAIL.
d): Our social media network page(s) may share web links to relevant web pages. By default some social media platforms shorten lengthy URL's. You are advised to exercise caution and due care before clicking on any shortened URL's published on social media platforms by this website. Despite our best efforts to ensure that only genuine URL's are published many social media platforms are prone to spam and hacking and therefore our website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.

12. YOUR LEGAL RIGHTS

a): Under certain circumstances, you have the following rights under data protection laws in relation to your Personal Information:
i): Request access to Personal Information (commonly known as a "data subject access request"). There may be a fee associated with this request – see c) below. This enables you to receive a copy of the Personal Information we may hold about you and that you are entitled to obtain and to verify whether we are lawfully Processing it. See the Flight Media Promotion of Access to Information Manual (“PAI Manual”).
ii): Request correction of Personal Information. This enables you to have any incomplete or inaccurate data we may hold about you corrected, though we may need to verify the accuracy of the new data you provided to us.
iii): Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a Third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
iv): Request restriction of processing of your Personal Information. This enables you to request that the processing of your Personal Information is suspended in the following scenarios:
1): If you want to establish the data's accuracy.
2): Where the use of the data is unlawful but you do not want the data to be erased.
3): Where you need the data to be held even if it is no longer required as you need it to establish, exercise or defend legal claims.
4): You have objected to the use of your data but it is needed to verify whether there are overriding legitimate grounds to use it.
v): Withdraw Consent at any timeat any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
b): If you wish to exercise any of the rights set out above, please contact our Information Officer at the details mentioned 1)b) above.
c): Fee required: Apart from the prescribed fees under the PAI Act, you will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, a reasonable fee may be charged if your request is clearly unfounded, repetitive or excessive. Alternatively, your request could be refused in these circumstances.
d): What we or our Franchisee may need from you: We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
e): Time limit to respond: We try to respond to all legitimate requests within 30 (thirty) days. Occasionally it could take us longer than 30 (thirty) days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

13. SUBCONTRACTORS

a): We may authorise a Third party (subcontractor) to process the Personal Information on our behalf. Where we use sub-contractors, we will:
i): enter into a written contract with the subcontractor that contains terms substantially the same as those set out in this Privacy Policy, in particular, in relation to requiring appropriate technical and organisational data security measures; and
ii): maintain control over all Personal Information we entrust to the subcontractor.
b): We agree to select subcontractors carefully according to their suitability and reliability.
c): A subcontractor within the meaning of this Privacy Policy shall not exist if we commission Third parties with additional services, that are not an essential part of this Privacy Policy.
d): Where the subcontractor fails to fulfil its obligations under such written agreement, we remain fully liable to you for the subcontractor's performance of its agreement obligations.
e): The parties consider Flight Media to control any Personal Information controlled by or in the possession of its subcontractors.
f): We undertake to ensure that all subcontractors who process Personal Information of Data subjects shall not amend, modify, merge or combine such Personal Information and process same as per our instructions.

14. DEFINITIONS

a): Consent: means any voluntary, specific and informed expression of will in terms of which permission is given for the processing of Personal Information;
c): Client or Customer means a Data subject who is a client/customer of Flight Media, including the client’s representatives.
d): GDPR means the General Data Protection Regulation of the European Union.
e): Legitimate Interest means the interest of our organisation in conducting and managing our affairs to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests override the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
f): Operator means a person or entity who processes Personal Information for a Responsible party in terms of a contract or mandate, without coming under the direct authority of the party.
g): PAIA means the Promotion of Access to Information Act, Act 2 of 2000.
h): Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
i): Personnel means Flight Media employees, directors or authorised sub-contractors.
j): Personal Information means information as defined under POPIA.
k): POPIA means the Protection of Personal Information Act, Act 4 of 2013.
l): Responsible party means a public or private body or any other person which, alone or in conjunction with others (Joint Responsible party) determines the purpose of and means for processing Personal Information.
m): Special Personal Information means information as defined under section 26 of POPIA (this includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and biometric information or criminal convictions and offences).
n): THIRD PARTIES
i): Internal Third parties: Partners, affiliates, employees, shareholders, directors and/ or agents/ correspondents of Flight Media (as the case may be), acting as Joint Responsible parties or Operators and who are based in South Africa and who may also provide IT and system administration services and undertake leadership reporting.
ii): External Third parties:
1): Joint Responsible parties based who may be based outside the borders of South Africa.
2): Third parties as instructed by you under the service agreement between you and Flight Media, including but not limited to South African Revenue Service.
3): Service providers acting as Operators who provide IT and system administration services.
4): Professional advisers acting as Operators or Joint Responsible parties, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
5): Regulators and other authorities acting as Operators, Joint Responsible parties who require reporting of processing activities in certain circumstances. These parties may be based in the Republic of South Africa or abroad.
6): Courts of law or any other authority where we have an obligation under law to share your Personal Information.