COVID-19 Privacy Notice
This COVID-19 Privacy Notice (this “Notice”) serves as an addendum to the Marathon Airlines Privacy Policy available here (the “Privacy Policy”) and shall be deemed incorporated into the Privacy Policy up until further notice. All terms and expressions used in this Notice shall have the same meaning as in the Privacy Policy, unless otherwise stated herein. Except as otherwise expressly modified herein, all other terms and conditions of the Privacy Policy shall remain in full force and effect. In the event of any conflict between this Notice and the Privacy Policy, this Notice shall prevail.
1. Contact us
Data Controller: Marathon Airlines SA, 14 Lontou St., 16675 Glyfada, Attica Greece
Email: dpo@marathonairlines.com
Tel: +2109607400– int 1656
This Notice is related to conditions arising and prevailing, during the Coronavirus pandemic (COVID-19).
Marathon Airlines may seek to collect and process client personal data in response to the outbreak of Covid19 and to an extent that shall go beyond the original scope and purpose of the Privacy Policy.
Such personal data processed shall be limited to what is duly proportionate and necessary, under applicable laws and regulations, and the latest requirements and guidance issued by relevant Governments, Agencies, International Organisations and Public Authorities, including without limitation World Health Organisation (WHO).
Please check out our COVID-19 page for more updates.
2. Scope
Marathon Airlines may:
- Collect information related to, health, previous travels, locations of prior visits, contacts tracing, via a declaration or questionnaire which we may require in order to assess risk to our customers, passengers, employees, representatives, agents, contractors and other relevant third parties;
- Request that passengers submit to a thermal and symptom screening process, conducted by duly trained and appointed personnel. This screening shall consist of non-invasive temperature checks to check for symptoms of Coronavirus and record any symptoms.
3. Data Sharing
Any sharing of personal data will be strictly in adherence with our Privacy Policy and applicable legislation.
4. Legal basis for the present data processing.
The GDPR and UK Data Protection Act 2018 (the “UK DPA 18”) require specific conditions to be met to ensure that the processing of personal data is lawful. The relevant GDPR conditions are:
- Article 6(1)(d) – processing is necessary in order to protect the vital interests of the data subject or another natural person. GDPR Recital 46 adds that: “Some types of processing may serve both important grounds of public interest and the vital interests of the data subject as for instance when processing is necessary for humanitarian purposes, including for monitoring epidemics and their spread … ”.
- Article 6(1)(f) – our Legitimate Interest(s) – (i) to provide the safest possible COVID-19 aware environment to provide our services (including without limitation, the operation of flights)safely for our customers, passengers and employees; (ii) to take all reasonable and proactive deterrent measures to prevent enabling the spread of infection by our services and ensure we have appropriate and effective health screening measures in place. Special Category Data: Personal data provided by Marathon Airlines clients – passengers shall be processed per to the following:
- Article 9(2)(i) GDPR – processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of Union or Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject, in particular professional secrecy.
5. Data Storage
Storing of said Data shall take place only to the extend that it is necessary and pursuant to the relevant existing legislation and stipulations, and at any rate, for the duration of the Covid19 Emergency. Following that, said data shall be expunged from our systems in a safe and irretrievable manner, or shall be anonymized and rendered untraceable for use only in statistical or marketing analysis.
6. Data subject rights
The GDPR and UK DPA 18 gives individuals eight data subject rights, which are explained for you below:
- Right to be informed: organisations must tell individuals what data of theirs is being collected, how it’s being used, how long it will be kept and whether it will be shared with any third parties.
- Right of access: individuals have the right to request a copy of the information that an organisation holds on them.
- Right of rectification: individuals have the right to correct data that is inaccurate or incomplete.
- Right to be forgotten: in certain circumstances, individuals can ask organisations to erase any personal data that’s stored on them.
- Right of portability: individuals can request that organisation transfer any data that it holds on them to another company.
- Right to restrict processing: individuals can request that an organisation limits the way it uses personal data.
- Right to object: individuals have the right to challenge certain types of processing, such as direct marketing.
- Rights related to automated decision making including profiling: individuals can ask organisations to provide a copy of its automated processing activities if they believe the data is being processed unlawfully.
Please, contact dpo@marathonairlines.com for any relevant exercise of rights.
Identity verification shall take place, prior to any data request processing.
Europe
In these extremely difficult times for the aviation industry, EASA is putting into place the measures required to ensure that operations can continue in as normal a manner as possible while still remaining safe. We know there are a huge number of urgent issues that need to be tackled – related to the hygienic safety of aircraft, application of existing rules around licensing and training, maintenance issues and many, many more. We are working to steer you through this crisis and address the needs of our stakeholders so as to ensure that aviation can remain operational and safe for everyone involved: pilots, crews, passengers and everyone else who makes this great industry function. To this end, we are in constant contact with the national aviation authorities in Europe and our other stakeholders and working as fast as we can to put the needed measures in place.
USA
The Federal Aviation Administration (FAA) is proactively taking steps to help address the widespread economic and health effects that the COVID-19 pandemic is having on the aviation industry. The FAA continues to evaluate a large number of requests from across all aviation industry sectors to help address COVID-19-related effects.
Africa
Daily updates from #Africa for Africa.