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Last updated May 25th, 2018 

In this Policy "SPA" "we," "our," and "us" refers to Small Planet Airlines UAB. It may also, depending on the context, refer to Small Planet Airlines Sp.z o.o., Small Planet Airlines GMBH and/or to any one or more of the other firms of the Small Planet Airlines group. 
SPA is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, SPA is committed to the appropriate protection and use of personal information (sometimes referred to as “personal data”, "personally identifiable information" or "PII") that has been collected online. 
Generally, our intent is to collect only the personal information that is provided voluntarily by online visitors so that we can offer information, flight booking, flight check-in and/or other services to those individuals or offer information about employment opportunities. Please review this privacy statement ("Privacy Statement") to learn more about how we collect, use, share and protect the personal information that we have obtained. 

1. Collection and use of personal information

1.1 What information we collect 
We obtain personal information about you if you choose to provide it — for example, to contact mailboxes, to book or check-in for a flight, or interact with our customer care. In some cases, you will have previously provided your personal information to SPA (if, for example, you are a former visitor). Other information we collect will depend on the privacy settings you have set with your social media provider (i.e. Facebook), so please review the privacy statement or policy of the applicable service. 
When you submit personal information to SPA we will use this information in the manner outlined in this privacy statement. Your personal information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards. If you send us a resume or curriculum vitae (CV) to apply online for a position with SPA, we will use the information that you provide to match you with available SPA job opportunities. 
In some cases where you have registered for certain services we will store your email address temporarily until we receive confirmation of the information you provided via an email (i.e. where we send an email to the email address provided as part of your registration to confirm a subscription request). 
1.2 The legal grounds we have to use your personal information 
SPA generally collects only the personal information necessary to fulfill your request. Where additional, optional information is sought, you will be notified of this at the point of collection. 
The law in the EU countries allows us to process personal information, so long as we have a ground under the law to do so. It also requires us to tell you what those grounds are. As a result, when we process your personal information, we will rely on one of the following processing conditions: 
  • Performance of a contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract; 
  • Legal obligation: this is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency; 
  • Legitimate interests: we will process information about you where it is in our legitimate interest in running a lawful business to do so in order to further that business, so long as it doesn’t outweigh your interests; or 
  • Your consent: in some cases, we will ask you for specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to us doing so. You may withdraw your consent at any time by contacting SPA at  
Examples of the ‘legitimate interests’ referred to above are: 
  • To offer information and/or services to individuals who visit our website or offer information about employment opportunities. 
  • To prevent fraud or criminal activity and to safeguard our IT systems. 
  • To customize individual’s online experience and improve the performance usability and effectiveness of SPA's online presence. 
  • To conduct, and to analyze, our marketing activities. 
  • To meet our corporate and social responsibility obligations. 
  • To exercise our fundamental rights in the EU under Articles 16 and 17 of the Charter of Fundamental Rights, including our freedom to conduct a business and right to property. 
In some cases, the personal data that we collect will also include special categories of data, such as diversity related information (including data about racial and ethnic origin, political opinions, religious beliefs and other beliefs of a similar nature, trade union membership and data about sexual life and sexual orientation), or health data and data about alleged or proven criminal offences in each case where permitted by law. 
1.3 Automatic collection of personal information 
In some instances, SPA and its service providers uses cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online, as well as through emails that we may exchange. The collection of this information allows us to customize your online experience, improve the performance, usability and effectiveness of SPA's online presence, and to measure the effectiveness of our marketing activities. 
1.3.1 IP addresses 
An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate will be recorded for IT security and system diagnostic purposes. This information will also typically be used in aggregate form to conduct web site trend and performance analysis. 
1.3.2 Cookies 
Cookies will typically be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves a number of purposes. 
On some of our web sites, a notification banner will appear requiring your consent to collect cookies. If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing-related activities. A secondary type of cookie referred to as "user-input" cookies may still be required for necessary functionality. Such cookies will not be blocked through the use of this notification banner. Your selection will be saved in a cookie and is valid for a period of 180 days. If you wish to revoke your selection, you may do so by clearing your browser's cookies. 
Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser's settings (often found in your browser's Tools or Preferences menu). You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our web sites' features. 
Further information about cookies can be found on sites such as 
Other third party tools and widgets will be used on our individual web pages from time to time to provide additional functionality. Use of these tools or widgets will typically place a cookie on your device to make their service easier to use, and ensure your interaction is displayed on our webpages properly. 
Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we will obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our web sites and geographic origin of visitor trends, and not to identify individual visitors. 
1.4 Social media widgets and applications 
SPA web sites will typically include functionality to enable sharing via third party social media applications, such as the Facebook Like button. These social media applications will collect and use information regarding your use of SPA web sites. Any personal information that you provide via such social media applications will often be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information. 
1.5 Children 
SPA understands the importance of protecting children's privacy, especially in an online environment. In particular, our sites are not intentionally designed for or directed at children under the age of 13. It is our policy never to knowingly collect or maintain information about anyone under the age of 13, except as part of an engagement to provide professional services. 

2. Sharing and transfer of personal information 

2.1 Transfer within the group of SPA firms 
We share information about you within SPA group as part of international engagements and where required or desirable to meet our legal and regulatory obligations around the world. Other parts of the SPA group are also used to provide services to us and you, for example hosting and supporting IT applications, assisting with client services and otherwise as required in order to continue to run SPA’s business. 
2.2 Transfers to third parties 
We do not share personal information with third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards. For more information on such third parties, please see this link. In addition, SPA will transfer certain personal information outside of the EEA to outside companies working with us or on our behalf for the purposes described in this Privacy Statement. SPA might also store personal information outside of the EEA. We might send personal information to the following countries. If we do this, your personal information will continue to be protected by means of contracts we have in place with those organizations outside the EEA, containing standard data protection clauses which are in a form approved by the European Commission. 
SPA will not transfer the personal information you provide to any third parties for their own direct marketing use. 

3. Choices 

In general, you are not required to submit any personal information to SPA, but we will require you to provide certain personal information in order for you to receive additional information about flights and/or other services. SPA will also ask for your permission for certain uses of your personal information, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request. 
As described in "Cookies" above, if you wish to prevent cookies from tracking you as you navigate our sites, you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of our sites may not work properly if you elect to refuse cookies. 

4. Your rights 

If SPA processes personal information about you, you have the following rights: 
  • Access and correction: you have the right to access to that data. This is sometimes called a ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you, we will provide it to you free of charge. Before providing personal information to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. If the information we hold about you is incorrect, you are entitled to ask us to correct any inaccuracies in the personal information. 
  • Object to processing: you have the right to object to us processing your personal information if we are not entitled to use it any more 
  • Other Rights: in addition, you may have rights to have your information deleted if we are keeping it longer than it is necessary for our legitimate professional and business needs, have its processing restricted in certain circumstances and/or to obtain copies of information we hold about you in electronic form. 
You can make a request or exercise these rights by contacting SPA at and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards. 

5. Data security and integrity 

SPA has reasonable security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Despite SPA’s best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information. 
We also make reasonable efforts to retain personal information only for so long i) as the information is necessary to comply with an individual’s request, ii) as necessary to comply with legal, regulatory, internal business or policy requirements, or iii) until that person asks that the information be deleted. The period for which data is retained will depend on the specific nature and circumstances under which the information was collected; however, subject to requirements of i)-iii) above, personal information will not be retained for more than 2 years.

6. Links to other sites 

Please be aware that SPA web sites will typically contain links to other sites, including sites maintained by other firms that are not governed by this Privacy Statement but by other privacy statements that will often differ. We encourage users to review the privacy policy of each Web site visited before disclosing any personal information. 

7. Changes to this statement 

SPA may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the "updated" date at the top of this page. Any changes to the processing of personal data as described in this Privacy Statement affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you. 

8. Policy questions and enforcement 

SPA is committed to protecting the online privacy of your personal information. If you have questions or comments about our administration of your personal information, please contact us at You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement. 
If you are not satisfied with the response you receive, you may escalate your concern to our Data Privacy Officer by sending an email to We will acknowledge your email within 14 days and seek to resolve your concern within one month of receipt. Where the concern is complex or we have a large volume of concerns, we will notify you that the concern will take longer than one month to resolve, and we will seek to resolve your concern within three months of the concern being first raised. We may accept your concern (and in that case implement one of the measures set out in the ‘Your Rights’ section above), or we may reject your concern on legitimate grounds. 
In any event, you always have the right to lodge a complaint with your local regulator in charge of protecting personal information.