Who we are

ASISTIM GmbH, as part of the SITA Group, is committed to protecting the privacy of individuals whose personal data we process in the context of our business operations, services, and online presence.

This Privacy Notice explains how ASISTIM GmbH (“ASISTIM”, “we”) collects, uses, and protects personal data, and informs individuals about their rights. It applies to all data processing activities conducted by ASISTIM, including through our services and our websites (e.g https://www.ASISTIM.aero/).

Our role in Processing Personal Data

Provision of services to our customers  

Acting as a ‘Data Processor’, ASISTIM provides services under contract to our customers who retain ownership and control of the personal data that we process on their behalf as applicable.  We are committed to ensuring the security and confidentiality of customer personal data and only retain it as long as necessary to fulfil the intended purposes, in accordance with customer instructions and our legal obligations. 

ASISTIM as a Data Controller 

As a ‘Data Controller’ ASISTIM will determine the purposes and means of the processing of personal data under our direct control. The remainder of this Privacy Notice explains our practices and obligations as a Data Controller.  

Personal data we collect and how we use it 

In general, we only process the personal data of our users to the extent necessary to provide a functioning website with our content and services. The regular processing of personal data only takes place with the consent of the user. Exceptions include cases where prior consent cannot be technically obtained and where the processing of the data is permitted by law.

Lawful basis under data protection laws  

Where consent is required for processing personal data, Art. 6 (1) (1) (a) GDPR serves as the legal basis to obtain the consent of the data subject for the processing of their data.

As for the processing of personal data required for the performance of a contract of which the data subject is party, Art. 6 (1) (1) (b) GDPR serves as the legal basis. This also applies to processing operations required to carry out pre-contractual activities.

If the processing of personal data is required to comply with a legal obligation to which our company is subject, Art. 6 (1) (1) (c) GDPR serves as the legal basis.

If the processing of data is necessary to safeguard the legitimate interests of our company or that of a third party, and the fundamental rights and freedoms of the data subject do not outweigh the interest of the former, Art. 6 (1) (1) (f) GDPR will serve as the legal basis for the processing of data.

Purposes ASISTIM may collect Personal Data

We may collect, use and process the following categories of Personal Data listed in the table below:

Purposes	Relevant categories of personal data processed	Lawful Basis
Management of business activities related to customers which include contracting, provisioning of services, billing and account management  As a provider of services to our customers (and prospective customers) we collect and process Personal Data for the following:  • to manage sales, contacts, opportunities and development plans with your company • to address and resolve complaints, including customer issues • to communicate with you about inquiries, services, and account management • to analyse, monitor and improve our services	This may include: • Identifying data, such as your name, date of birth, and nationality • Contact data, such as your postal address, email address and telephone number • Professional and business data, including your job title and role, and data relating to your company such as the business name, address and country  • Usernames and passwords, that you create when registering for an account with us • Details of any services we provide to you  • Communication records, including any messages you send to us or that we send to you • Data automatically collected from using our internet-based services (such as, internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp and navigation data)	• Contract performance • Legal obligation • Legitimate interests • Legal claims
Provision of website  Purposes: Ensuring the functionality, optimization, and security of the website.	This may include: • Browser type and version used • The user’s operating system • Date and time of access	• Legitimate interests
Use of cookies When you visit our website, cookies are set to enhance your browsing experience. Cookies are small files stored by the Internet browser on the user’s computer system. This storage of information on the user’s device can be facilitated through unique identifiers (UID), enabling us to identify or associate it with an individual. Technically Necessary Cookies: • Ensure the functionality of the website • Provide the services and features requested by the user Non-Technically Necessary Cookies: • Analytics • Statistics • Personalization • Marketing	This may include • Usage data, such as interaction with and use of our services and websites • Communication records • Data automatically collected from use of internet-based services (e.g., IP addresses, browser type, ISP, referring/exit pages, operating system, date/time stamp and navigation data) • Profile photo	• Consent • Legitimate Interests
Communication with potential and existing customers including use of corporate oriented networks We maintain corporate profiles on professionally oriented networks to enhance our communication and engagement with customers and interested parties. Our corporate presence is established on the following platform: LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland On our site, we provide information and offer users the opportunity to communicate with us. This includes: • Engaging with customers and interested parties • Responding to inquiries and providing requested information • Fulfilling contract performance obligations	This may include: • Name (e.g. full/clear name from user profile) • Profile photo • Comments • Posts/contributions • Likes or other interactions • Publicly available profile information (depending on user’s LinkedIn privacy settings)	• Consent • Legitimate interests
Usage of Plugins We utilize HubSpot a CRM and marketing platform and Google Analytics 4 to analyze the browsing behaviour and improve our website, as well as manage potential customers, segment contacts and optimise our marketing and customer service campaigns.   You have the right to revoke your consent under data protection law at any time. Please note that the revocation of consent does not affect the lawfulness of processing based on consent prior to its withdrawal. The data collected is essential for tracking and analyzing user behaviour, and it is used to improve and optimize our online presence based on user interactions.	This may include: • User activity data, such as pages visited or clicked elements • Device and browser information, such as IP address (anonymized by masking 2 bytes), operating system, browser type/version • Advertising data, such as displayed advertisements and click behavior • Advertising partner Data (Pseudonymized user IDs)	• Consent • Legitimate interests
Hosting Our website is hosted on servers managed by our designated service provider: SiteGround Spain S.L Calle de Prim 19  28004 Madrid, Spain Purpose: • Ensuring the technically flawless presentation of the website • Optimizing and maintaining the website	This may include: • Browser type and version • Operating system used • Referrer URL • Hostname of the accessing computer • Time and date of the server request • IP address of the user’s device	• Legitimate interests
Contact via Email You can reach us via the email address provided on our website. Any personal data transmitted with the email will be stored. This data will be used exclusively for processing the conversation and optimally responding to your request. This also applies when email contacts are used for concluding or performing a contract.	This may include: • Email address of the user • Any personal data included in the email message • Additional metadata collected during the sending process (e.g., time, IP address – if applicable)	• Legitimate interest • Performance of a contract

How your personal data may be shared

Personal Data Sharing and Disclosure 

As an international business and to provide you with our services and products, we will share your Personal Data in the following ways: 

• Group entities – We may share your Personal Data with our subsidiaries, affiliate companies, or agents within our corporate group for operational, administrative, and service-related purposes as outlined in this Privacy Notice.  
• Third-party service providers, agents, and distributors (“service providers”) – We may share your data with our service providers who process Personal Data on our behalf, such as those assisting with website functionality, payment processing, customer support, IT services, and analytics. We have contracts with these providers that prohibit them from sharing your data or using it for any purpose beyond the agreed services. Where we share customer personal data with our authorized sub-processors, we contractually bind them to protect and use customer personal data only for the SITA services that they support, ensuring we have sufficient guarantees of the appropriate technical and organizational measures we require to be in place.  
• Law enforcement bodies, the authorities and courts – Where necessary, we will disclose personal data to prevent, investigate, or prosecute criminal activities, comply with legal obligations, enforce our rights or defend against legal claims involving law enforcement, courts, regulatory bodies, or other authorities. 
• Sale or merger of our business – If our company or any of its affiliates undergoes a business restructuring, including a sale, merger, or transfer of assets, we may transfer your Personal Data to relevant third parties, including potential buyers and their advisors, as part of the due diligence and transaction process. 
• Other disclosures required or permitted by law – We may share your Personal Data with third parties when required by law or where we have obtained your consent.  

Protecting your personal data

Retention of Personal Data

We will retain your Personal Data where we have a legitimate business need to do so. For example, to provide our services, run our business operations, or to comply with applicable legal, tax or accounting requirements, or pursuant to an ongoing service contract. Otherwise, we will either delete or anonymize it.   

Where this this is not possible (for example, because elements of your Personal Data have been stored in backup archives), then we will securely store this Personal Data and isolate it from any further processing until deletion is possible.

Your rights and how to contact us

Your Data rights

ASISTIM operates in Germany which under the GDPR provide different data rights to individuals which may include to:

• Access your Personal Data held by us;
• Know more about how we process your Personal Data;
• Rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete;
• Erase or delete your Personal Data;
• Restrict our processing of your Personal Data;
• Transfer your Personal Data to another controller, to the extent possible;
• Object to any processing of your Personal Data;
• Opt-out of certain disclosures of your Personal Data to third parties;
• Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects 

You can find out more about your data rights and how they apply to your personal data by making a  data rights request or contacting us via our online Privacy Web Form. 

Usage of Plugins

Possibility of revocation of consent and removal

You may withdraw your consent at any time with future effect; the withdrawal will not affect the lawfulness of processing carried out based on the consent before it was withdrawn. To prevent HubSpot from collecting data you can:

• Adjust your selection via our cookie banner; the HubSpot tracking code will not collect data from visitors who decline the analytics cookie category or all cookies knowledge.hubspot.com.
• Configure your browser to block or delete third-party cookies, including preventing your browser from storing HubSpot cookies.
• Use your browser’s “Do Not Track” mode or a script blocker to prevent analytical scripts from executing.

For more information about HubSpot’s data processing and how to exercise your rights, please refer to HubSpot’s privacy policy https://legal.hubspot.com/privacy-policy 

Changes to this Privacy Notice

From time to time, we may update this Notice in response to changing legal, technical or business developments. When we do, we will publish the changes on this Website, as appropriate and update the ‘last updated’ date below. If material changes are made to this Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.  We encourage you to periodically review this Privacy Notice to stay informed about our collection, processing and sharing of your Personal Data. 

Contact us

The data controller responsible in accordance with the purposes of the General Data Protection Regulation (GDPR) of the European Union and other data protection regulations is:

ASISTIM GmbH
Kirchhorster Str. 31
D-30659 Hannover
Germany
Phone: +49 511 450 318 0
www.ASISTIM.aero

The designated data protection officer is:

ASISTIM GmbH
Kirchhorster Str. 31
D-30659 Hannover
Phone: +49 511 450 318 0
Email: privacy@sita.aero
www.ASISTIM.aero

You can submit any questions or concerns that you may have regarding this Privacy Notice by contacting us at privacy@sita.aero