Privacy policy for Agnet

Privacy policy for Agnet

This document reflects how Airbus Public Safety and Security (PSS) (formerly Secure Land Communications / SLC), a business unit of Airbus, may process your Personal Data while you are using Agnet as a Processor (as described in the Privacy Statement) and/or as a Controller (as described in the Privacy Notice). 

Within the frame of this document, the following definitions are applicable:

- “Controller”, “Processor”, “Data Subjects”, “Personal Data”, “Processing”, “Personal Data Breach”, “Binding Corporate Rules”, “Supervisory Authority”, shall have the meaning of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC (“General Data Protection Regulation” or “GDPR”).

- “Customer” means Airbus Public Safety and Security’s customer who entered or is considering entering into a relationship with Airbus Public Safety and Security.

 

PRIVACY STATEMENT (PSS as Processor)

 

Last updated – July 2024

This Privacy Statement explains what Personal Data may be processed by Airbus Public Safety and Security on behalf of its Customers. Unless where permitted by law or otherwise agreed by PSS and the Customer, those Personal Data are processed on the Customer’s documented instructions and on its behalf whether the Customer is acting as Controller or as Processor on behalf of a third party. 

Consequently, please note that:

  • Where the Customer resells Agnet (VAR, VAD, etc.), the Controller will likely be the Customer’s customers.
  • The Data Controller (which is usually your employer) is responsible for providing you with information about which Personal Data will be processed, for which purpose(s) and how to exercise your rights, and, if applicable, for obtaining your prior consent. 

For more information about how your data may be processed by the Controller, we invite you to directly contact them.

 

What is Personal Data?

Personal data is information that can be used to identify a person either directly or indirectly. It includes information such as name, contact details, identification numbers, financial data, location data or online identifiers. 

1 - What Personal Data may we process on behalf of the Customer?

While you use Agnet, Airbus Public Safety and Security may process the following categories of Personal Data to provide you with the service, depending on which features have been activated by the Customer and/or the Controller (where different from the Customer) and how they have been set-up:

  • Identification data (name, surname, image, voice);
  • Professional data (employer name, email address, phone number, position);
  • Location data;
  • Communication data (messages, attachments, and audio/video calls) ;
  • Personal data that may be revealed by the Agnet’s configuration (user alias, operational status, connection data such as logs, etc.).

Please note that:

  • Where Agnet is used to communicate with or about third parties, their Personal Data might also be processed by Airbus Public Safety and Security.
  • Unless expressly asked to by the Customer, the communication data will not be consulted by Airbus as Processor even when it is technically possible.
  • The amount of Personal Data processed by Airbus greatly relies on the deployment model (SaaS / On Premises).

 

2- What are the purposes of the processing of your Personal Data? 

Depending on the options and deployment model chosen by the Customer and/or the Controller (where different from the Customer), Airbus Public Safety and Security may process your Personal Data on behalf of the Customer for the following purposes:

  • Installing the solution and creating user accounts;
  • Hosting the Personal Data provided by the Customer and/or by you;
  • Performing maintenance and support services;
  • Performing training programs;
  • Complying with the Customer’s legal obligations that impact us, including responding to an authority or court order or discovery requests that the Controller or the Customer may receive.

Please refer to the Controller’s documentation to receive more accurate information.

3- Who will receive your Personal Data? 


 

Where Airbus Public Safety and Security is acting as a Processor, we may communicate your Personal Data to:

  • Employees from Airbus Public Safety and Security who are involved in the provision of the services above described;
  • The Customer on behalf of which PSS is processing personal data;
  • You as user of Agnet;
  • Other recipients defined by the Customer or by you.

However, the Controller is responsible to inform you of the recipients who may receive your Personal Data.

4- Will your Personal Data be transferred to a third country/region outside the European Economic Area (EEA)? 

Please refer to the information provided by the Customer to learn about any transfer of your Personal Data to a third country/region outside the EEA. As Airbus Public Safety and Security mainly operates from France, Finland and Germany, please note that transfers outside the EEA are likely to happen whenever a Customer is located outside this region.

5- What are your rights and how to exercise them?

Depending on the legal basis defined by the Controller, you may at any time exercise your Personal Data protection rights as listed below by contacting the Controller at the contact details mentioned in their privacy policy:

  • Right to access/obtain a report detailing the information held about you;
  • Right to correct Personal Data;
  • Right to be forgotten;
  • Right to restrict the processing of your Personal Data;
  • Right to data portability;
  • Right to object;
  • Right to withdraw consent.

 

PRIVACY NOTICE (PSS as Controller)

 

Last updated – July 2024

Airbus Public Safety and Security is committed to protecting the privacy of individuals and to complying with applicable Personal Data protection laws and regulations. We want you to feel comfortable about how we collect, process, secure and share your Personal Data. This Privacy Notice details the types of Personal Data we collect, how we use your Personal Data, who we share it with and how you can control its use.

This Privacy Notice applies to the main Personal Data processing Airbus Public Safety and Security performs while providing and maintaining Agnet. For processing activities not directly linked to such purposes, please refer to https://www.securelandcommunications.com/privacy-policy 

1 - What Personal Data do we use?

Depending on the nature of your relationship with Airbus Public Safety and Security, we collect, use and process the following categories of Personal Data:

  • Identification data (name, surname, image, voice);
  • Professional data (employer name, email address, phone number, position);
  • Location data from your smartphone GPS sensor;
  • Communication data (messages, attachments, and audio/video calls) ;
  • Personal data that may be revealed by Agnet’s configuration (user alias, operational status, connection data such as logs, etc.);

 

Airbus Public Safety and Security may collect this Personal Data:

  • directly from you when you complete a form and you provide us such information, and/or 
  • indirectly through the organisation you are working for if needed for a purpose listed below or information made publicly available.

2- What are the purposes of the processing of your Personal Data?

Airbus Public Safety and Security may process your Personal Data for the following purposes: 

1. Website Browsers and Applications / Administration

  •  
    • We may use your Personal Data for administrative purposes, including to help us better understand how our customers, or third parties access use Agnet via your feedbacks or requests or as a part of our contractual obligations detailed below; to implement and maintain security, anti-piracy, fraud prevention, and other services designed to protect our customers, partners and us; and to enforce our policies, directives and processes.


2. Research and development

  •  
    • We may use your Personal Data (provided via your feedbacks, requests or as a part of our contractual obligations detailed below) for research and development purposes, including public funding submission requests, improving our websites, applications, services, and customer experience and for other research and analytical purposes dedicated to improving our products, services, businesses, operations and processes.

3. To comply with contractual obligations

  •  
    • We may use your Personal Data to comply with the contractual obligations we have towards your employer, the monitoring of the performance of the services (wheref relevant, for instance if a Service Level Agreement (SLA) has been signed) or for preventive maintenance purposes.

4. To comply with legal obligations

  •  
    • We may use your Personal Data to comply with applicable legal obligations, including responding to an authority or court order or discovery requests, and to comply with export control and sanctions requirements.

5. To protect us and others

  •  
    • Where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of policies, terms, and other policies. 

We will use your Personal Data for the above purposes only, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose (for preserving particular evidence or in the context of legal statutes of limitation for example). If we need to use your Personal Data for an unrelated purpose, we will notify you prior to this further Personal Data processing and provide you with the relevant privacy information notice.

3 - What is the legal basis for the processing of your Personal Data? 

Subject to the applicable law, we process your Personal Data under the following legal basis:

1. To comply with contractual obligations. When you subscribe to a particular service through a website, the purposes of processing your personal data are primarily determined by that service and we will process your information so that we can provide that service to you. 

2. Within the scope of a legitimate interest. On occasion taking into account the minimum privacy impact for you, the processing of your Personal Data might be necessary:
 

  • For the administration and management and performance of our business relationship including accounting, auditing, performance of the contract.
  • For research and development purposes.
  • To protect us and others (to detect security threats, frauds or other malicious or criminal activities, to prevent and investigate criminal acts, to monitor the compliance with our policies and standards).

Depending on our obligations towards the Customer, some of these purposes may be implemented by PSS in order to comply with our legal obligations (cf. part 3,1).

3. On the basis of Airbus’ legal obligations or in the public interest. Airbus, as any other company, is subject to legal obligations and regulations. In some cases, the processing of your Personal Data will be necessary for Airbus in order to fulfil these legal obligations.

4. As a result of your consent. When you have consented to the processing of your Personal Data by us for certain services, you can withdraw consent at any time by following the instructions provided in the application process or by contacting us at dataprotection@airbus.com. For further information on the right of withdrawal, please see below Section “How to exercise your rights and/or contact Airbus in respect of your Personal Data?”

4 - Who will receive your Personal Data?

Subject to the applicable law, we may disclose your Personal Data to the following recipient(s) on a need-to-know basis:

  • Authorised persons working for or on behalf of Airbus Public Safety and Security, including our agents, service providers and advisers providing the variety of products and services we need (including IT, procurement, communication, compliance, security, training, hosting, maintenance and support services);
  • Airbus Group and its Affiliates;
  • Airbus business partners in connection with Airbus Public Safety and Security activities (including law firms, auditors, consultants, insurance companies);
  • Airbus Public Safety and Security’s Customers;
  • Other authorised third parties in connection with any merger, reorganisation, sale of Airbus assets, or a financing or acquisition of our business by another company;
  • Law enforcement or authorities where necessary to comply with applicable law.

 

5 - Is any of your Personal Data transferred overseas? 

Except for Airbus Public Safety and Security Affiliates operating outside the European Economic Area, your Personal Data will generally be processed in the European Economic Area, especially in Finland, France and Germany where most of Airbus Public Safety and Security’ Personal Data activities take place. On occasion Personal Data may be transferred to the UK or to a third country. 

Where necessary, we may share your Personal Data within Airbus. Any transfers within Airbus for Airbus daily business activity and internal organisation are covered by an intra-group agreement (see Binding Corporate Rules). The Binding Corporate Rules includes contractual protections to ensure that your Personal Data receives an adequate level of protection wherever it is transferred to within Airbus.

In addition, we may share some Personal Data to third parties located outside the European Economic Area. We always take steps to ensure that any transfer of information is carefully managed to protect your privacy rights:

  • We will only transfer Personal Data to countries which are recognised as providing an adequate level of legal protection or where we are satisfied that arrangements are in place to protect your privacy rights,
  • transfers to service providers and other third parties will be protected by contractual commitments (such as the European Commission-approved Standard Contractual Clauses) or other legally acceptable mechanisms that ensure an adequate level of protection, and
  • any requests for Personal Data information we receive from law enforcement or regulators will be carefully checked before Personal Data is disclosed.

We may also collect and process Personal Data in third countries; in line with local Personal Data protection laws and regulations and detailed in a dedicated privacy notice. 

If you have any questions regarding transfers, please contact us (dataprotection@airbus.com) for further details.

 

6 - How long will your Personal Data be retained?

We retain your Personal Data as long as is reasonably necessary for the purposes for which it was collected. In some circumstances we may retain your personal information for longer periods of time than is needed for those purposes, such as where we are required to do so in accordance with legal, regulatory, tax or accounting requirements.

 

7 - What about the security of your Personal Data?

We use technical and organizational security measures in order to protect the Personal Data we control against accidental or intentional manipulation, loss, destruction and against access by unauthorized persons. Our security procedures are continually enhanced as new technology becomes available.

8 - What are your rights?

At any time you may exercise your Personal Data protection rights as listed below by contacting us at dataprotection@airbus.com: 

  • Right to access/obtain a report detailing the information held about you: You have the right to obtain confirmation as to whether or not your Personal Data is being processed by Airbus and if so, what specific Personal Data is being processed.
  • Right to correct Personal Data: You have the right to change any inaccurate Personal Data concerning you. 
  • Right to erasure:  In some cases, for instance, when the Personal Data is no longer necessary in relation to the Purposes for which they were collected, you have the right for your Personal Data to be erased. 
  • Right to restrict the processing of your Personal Data: You have the right to restrict the processing of your Personal Data by Airbus, for instance when the processing is unlawful and you oppose the erasure of your Personal Data. In such cases, your Personal Data will only be processed with your consent or for the exercise or defence of legal claims. 
  • Right to data portability: Under some circumstances provided by law, you have the right to receive the Personal Data concerning you in a structured, commonly used and machine-readable format and/or transmit those Personal Data to another data controller. 
  • Right to object: In some cases defined in law, you may ask us to stop processing your Personal Data. 
  • Right to withdraw consent: Where your consent is required, you may at any time withdraw such consent.  However, please note that if you withdraw your consent, you may not be able to access and use certain information, features or services. 

9 - How to exercise your rights?

If you want to exercise your rights, if you are unhappy with the way in which your Personal Data has been processed, or you have questions regarding the processing of your Personal Data, please contact the Airbus Personal Data Protection Officer at the following email address: dataprotection@airbus.com

In case of doubt of your identity, we may ask you to justify it by enclosing a copy of any identity document.

For the newsletters, you may update your Personal Data at any time directly in the Preference Centre if available, or unsubscribe from our marketing communications by clicking on the "unsubscribe" link located on the bottom of our e-mails, or contact us at the following email address: dataprotection@airbus.com

10 - Do we use automated decision-making or profiling ?

As a matter of principle, we do not use fully automated decision-making processes such as profiling. If this were to change, you would be informed.  

11 - How to ask for assistance from the competent authorities? 

If you remain unsatisfied, then you have the right to apply directly to a Data Protection Supervisory Authority. Listed below are the main countries where Airbus Public Safety and Security operates and the relevant Supervisory Authority.

FRANCE: CNIL: Supervisory Authority France

GERMANY: Each federal state has its own Data Protection Authority that can be found under the following link: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html

FINLAND:   ODPO: Supervisory Authority Finland

12 - Additional Notice 

for California residents

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”): We do not sell your personal information to third parties and we will not sell your personal information to third parties unless provided otherwise by a specific privacy notice. We do not discriminate against California residents who exercise their CCPA privacy rights. To exercise your California privacy rights please refer to the section “How to exercise your rights”.

for Chinese residents

We may provide and transfer your personal information to other entities in and outside of China in accordance with this privacy notice or for other legitimate reasons. We will comply with the applicable obligations and requirements under PIPL in relation to sharing and cross-border transfers of personal information.

13 - Modification of the Privacy Notice

Airbus will regularly update this Privacy Notice to reflect any changes in our practices and services. We will inform you of any substantial modification in how we process your Personal Data.

14 - Enforcement of this privacy policy and contact information

Airbus Public Safety and Security welcomes your comments regarding our privacy policy.

If you are unhappy with the way in which your Personal Data has been processed or should you have questions regarding the processing of your Personal Data, you can contact us by email: dataprotection@airbus.com.

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