1. In order to deliver Flyte Zone’s services and to give you the best possible experience whilst using the Application, Flyte Zone will need to collect and process some of your Personal Information. In doing so, Flyte Zone is committed to safeguarding your privacy and the security of your Personal Information.
2. It is the policy of Flyte Zone to protect the privacy of individuals with respect to Personal Information in its custody and control, including that of its Users, contractors and business partners. Flyte Zone recognises that effective systems and measures to protect such Personal Information are important to safeguarding the interests of its Users, employees, customers, business partners, and other individuals who share their information with Flyte Zone.
3. Flyte Zone will manage its personal information holdings in a responsible and business-like manner, control the collection and accuracy of personal information, and protect that information from unauthorised use, disclosure, and retention in accordance with the terms of this privacy notice ("Privacy Notice").

1. Please read this Privacy Notice to understand how we collect and use your information.
2. This notice describes how Flyte Zone and its Affiliates collect and use Personal Information. This Privacy Notice applies to all employees, customers, business partners, and other individuals anywhere in the world who share their information with Flyte Zone.
3. The terms governing your use of the services are defined in our Terms and Conditions of Use (the "Terms of Use"), available here
4. If there are any changes to Flyte Zone’s data processing practices or to this Privacy Notice, the updated Privacy Notice will be made available on our website at www.flyte.zone and will be applicable to an Individuals use of the Application from the date of publication.
5. By agreeing to this Privacy Notice, the individual agrees to Flyte Zone Processing their Personal Information for the purposes set out in this Privacy Notice, including providing the individual with access to the services provided by Flyte Zone, in accordance with the terms of this Privacy Notice and applicable laws, including POPIA.

1. "Application" means the Flyte Zone web applications currently hosted at www.flyte.zone and , as Flyte Zone may choose to use from time to time and the Flyte Zone mobile applications; and
2. "Information Officer" means Matthew van Eden;
3. "Personal Information" means ‘personal information’ as that term is defined in POPIA, being:
   information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including, but not limited to:
   1. information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the person;
   2. information relating to the education or the medical, financial, criminal or employment history of the person;
   3. any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the person;
   4. the biometric information of the person;
   5. the personal opinions, views or preferences of the person;
   6. correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence;
   7. the views or opinions of another individual about the person; and
   8. the name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person;
4. "POPIA" means the Protection of Personal Information Act 4 or 2013, as amended;
5. "Processing" means ‘processing’ as that term is defined in POPIA, being:
   any operation or activity or any set of operations, whether or not by automatic means, concerning personal information, including—
   1. the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use;
   2. dissemination by means of transmission, distribution or making available in any other form; or
   3. merging, linking, as well as restriction, degradation, erasure or destruction of information;
6. "we", "us", "our" and "Flyte Zone" means Flyte Zone Proprietary Limited, with registration No: 2022/233841/07, being a company incorporated and carrying on business in accordance with the company laws of South Africa; and
7. "You", "individual" or "User" means all employees, customers, business partners, and other individuals anywhere in the world who share their information with Flyte Zone, unless covered by a separate privacy notice.

1. Flyte Zone is responsible for Personal Information under its control and has designated the Information Officer as its information officer, accountable for Flyte Zone’s compliance with the POPIA. Comments and questions regarding this Privacy Notice or its administration should be forwarded to the Information Officer.
2. Flyte Zone is responsible for Personal Information in its possession or custody, including information that has been transferred to a third party for Processing. Flyte Zone uses contractual or other means to provide a comparable level of protection while a third party is processing the information.
3. Flyte Zone has implemented policies and practices to give effect to the principles of POPIA, including:
   1. procedures to protect Personal Information;
   2. procedures to receive and respond to inquiries and complaints;
   3. training staff and communicating information to staff about Flyte Zone’s policies and practices; and
   4. materials to explain Flyte Zone’s policy and procedures.

1. Flyte Zone collects Personal Information for the following purposes:
   1. to provide safe air navigation services, such as air traffic management, advisory and alerting services, requiring the collection, use, and transfer of aircraft movement data between air navigation service facilities, including those providing services in Canadian and adjacent airspace;
   2. to provide an appropriate supply of well-trained employees for all of its critical functions;
   3. to comply with its regulatory obligations with respect to safety, document retention and reporting;
   4. to levy and collect user charges for air navigation services;
   5. to recruit and train professionals for air navigation services;
   6. to deliver service to customers, including air carriers, business and general aviation, and airport authorities;
   7. to comply with obligations to provide aircraft movement data to South African Civil Aviation Authority and Air Traffic Navigation Services (ATNS), airport authorities, and customs agencies;
   8. For purposes of management, labour relations, and human resources and other related matters;
   9. to manage property and facilities, ensure environmental compliance, and perform risk management; and
   10. for all other purposes necessary to provide safe, efficient and cost-effective air navigation services.

1. The knowledge and consent of the individual are required for the collection, use, or disclosure of Personal Information, except where inappropriate, such as in cases of implied consent or for statutorily required purposes.
2. POPIA sets out specific circumstances under which Flyte Zone may further process Personal Information (collect, use, or disclose) without the knowledge or consent of the individual and such processing shall be deemed to be compatible with the purpose of the collection. These include, among others, the following:
   1. Collection
      When the collection is clearly in the interests of the individual and consent cannot be obtained in a timely way;
   2. Use
      When Flyte Zone becomes aware during its activities of information:
      1. When it has reasonable grounds to believe could be useful in investigating or preventing a contravention of the laws of South African or a foreign jurisdiction, that has been, is being, or is about to be committed, and the information is used to investigate that contravention;
      2. when the information is used to act in an emergency that threatens the life, health or security of an individual; or
      3. when the information is publicly available and is specified by regulation.
   3. Disclosure
      Disclosure will be made:
      1. when required to comply with a subpoena or warrant issued or an order made by a body with jurisdiction to compel the production of information, or to comply with court rulings relating to the production of records;
      2. to a government institution or part of a government institution that has requested the information, identified its lawful authority to obtain the information, and indicated that:
         1. it suspects that the information relates to national security, the defence of South Africa, or the conduct of international affairs,
         2. the disclosure is requested for the purpose of enforcing any law of South Africa or a foreign jurisdiction, carrying out an investigation relating to the enforcement of any such law, or gathering intelligence for the purpose of enforcing any such law, or
         3. the disclosure is requested for the purpose of administering any law of South Africa.
      3. on the initiative of Flyte Zone to an investigative body, a government institution, or a part of a government institution, and Flyte Zone:
         1. has reasonable grounds to believe that the information relates to a breach of an agreement or a contravention of the laws of South Africa or a foreign jurisdiction, that has been, is being or is about to be committed, or
         2. suspect that the information relates to national security, the defence of South Africa, or the conduct of international affairs;
      4. When made to a person who needs the information because of an emergency that threatens the life, health, or security of an individual and, if the individual whom the information is about is alive, the organisation informs that individual of the disclosure in writing without delay.
3. Other than in those exceptions set out above, Flyte Zone requires individuals to consent to the collection of Personal Information and its subsequent use or disclosure. Typically, Flyte Zone will seek consent for the use or disclosure of information at the time of its collection. In certain circumstances, consent for the use or disclosure may be sought after the information has been collected, but before it is used (for example, when Flyte Zone wants to use information for a purpose not previously identified).
4. The consent principle requires "knowledge and consent." Flyte Zone will make a reasonable effort to ensure that individuals are advised of the purposes for which their information will be used. To make the consent meaningful, the purposes will be stated in such a manner that the individual can reasonably understand how the information will be used or disclosed.
5. Flyte Zone will not, as a condition of the supply of a product or service, require an individual to consent to the collection, use, or disclosure of information beyond that required to fulfill the explicitly specified and legitimate purposes.
6. In determining the form of consent, Flyte Zone will take into account the sensitivity of the information involved.
7. In obtaining consent, Flyte Zone also takes into account the reasonable expectations of the individual.
8. Flyte Zone may seek consent in various ways, depending on the circumstances and the type of information collected. Flyte Zone will generally seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate when the information is less sensitive. Less sensitive information may include providing flight plan information to an air navigation services provider in adjacent airspace, or passing on radar data to such an operator for the purposes of air traffic management.
9. Individuals can give consent in a number of ways. For example:
   1. an application form may be used to seek consent, collect information, and inform the individual of the use that will be made of the information. By completing and signing the form, the individual gives consent to the collection and the specified uses;
   2. a checkoff box may be used to allow individuals to request that their names and addresses not be given to other organisation. Individuals who do not check the box are assumed to consent to the transfer of this information to third parties;
   3. consent may be given orally when information is collected over the telephone.
10. An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Flyte Zone will inform the individual of the implications of such withdrawal.
11. Flyte Zone periodically transfers personal information in its possession or custody to third parties for Processing. This type of Personal Information transfer is not considered to be a disclosure of Personal Information under the legislation and, as such, consent is not required for such a transfer of information. However, in such cases, it is Flyte Zone’s practice to use contractual or other means to provide a comparable level of protection while a third party is Processing the information. In some cases, the external service providers retained by Flyte Zone may be located outside of South Africa. Therefore, some personal information collected by Flyte Zone may be retained in countries other than South Africa where privacy laws may offer different levels of protection from those in South Africa and Personal Information may be subject to access by and disclosure to law enforcement agencies in those jurisdictions.

1. Flyte Zone will limit the collection of Personal Information to that which is necessary for the purposes that it has identified. Such information will be collected by fair and lawful means.
2. Flyte Zone will not collect Personal Information indiscriminately or in a misleading manner. Both the amount and the type of information collected will be limited to that which is necessary to fulfil the purposes identified. Flyte Zone will specify the type of information collected as part of its information-handling policies and practices.
3. Personal Information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information will be retained only as long as necessary to fulfill those purposes.

1. Flyte Zone developed guidelines and implemented procedures for the retention of Personal Information, which will include minimum and maximum retention periods. Flyte Zone is subject to various legislative, regulatory, and auditing requirements concerning retention periods. Personal Information that has been used to make a decision about an individual will be retained long enough to allow the individual access to the information after the decision has been made. Flyte Zone will retain Personal Information that is the subject of a request for as long as is necessary to allow individuals to exhaust any recourse they may have under the POPIA. Flyte Zone may also retain information for a reasonable amount of time after it is no longer relevant to an individual in order to comply with its objectives and statutory mandate.
2. Flyte Zone will not retain an individuals Personal Information longer than is necessary to achieve the purpose for which the information was initially collected, or subsequently Processed unless we are required to do so by law.
3. If you request, Flyte Zone will delete or anonymise your Personal Information so that it no longer identifies an individuals, unless we are legally allowed or required to maintain certain Personal Information, including situations such as the following:
   1. where Flyte Zone is required to retain the Personal Information for our legal, tax, audit, and accounting obligations, Flyte Zone will retain the necessary Personal Information for the period required by applicable law; and/or,
   2. where necessary for Flyte Zone’s legitimate business interests such as fraud prevention or to maintain the legitimacy of the services offered by of Flyte Zone.
4. Personal Information no longer required to fulfil the identified purposes will be destroyed, erased, or made anonymous. Flyte Zone will develop guidelines and implement procedures to govern the destruction of Personal Information.

1. Security safeguards are to protect Personal Information against loss or theft, as well as unauthorised access, disclosure, copying, use, or modification. Flyte Zone will protect Personal Information regardless of the format in which it is held.
2. The nature of the safeguards vary depending on the sensitivity of the information that has been collected, the amount, distribution, and format of the information, and the method of storage. A higher level of protection is used to safeguard more sensitive information.
3. The methods of protection used include:
   1. physical measures, for example, locked filing cabinets and restricted access to offices;
   2. organisational measures, for example, security clearances and limiting access on a "need-to-know" basis; and
   3. technological measures, for example, the use of passwords and encryption.
4. Flyte Zone will make its employees aware of the importance of maintaining the confidentiality of personal information.
5. Flyte Zone will use care in disposing of or destroying personal information to prevent unauthorised parties from gaining access to the information.

1. Flyte Zone will make readily available to individuals specific information about its policies and practices relating to the management of Personal Information.
2. Flyte Zone will be open about its policies and practices regarding the management of Personal Information. Individuals will be able to acquire information about its policies and practices without unreasonable effort. This information will be made available in a form that is generally understandable.
3. The information made available will include:
   1. the name or title, and the address, of the person who is accountable for Flyte Zone’s policies and practices and who receives inquiries or complaints;
   2. the means of gaining access to Personal Information held by Flyte Zone;
   3. a description of the type of Personal Information held by Flyte Zone, including a general account of its use;
   4. a copy of any brochures or other information that explain Flyte Zone’s policies, standards, or codes; and
   5. what Personal Information is made available to related organisations (e.g., subsidiaries and Affiliates).
   6. Flyte Zone will provide information about its policies and practices in various ways, including providing on-line access through the Flyte Zone Portal, and via the Internet to customers and the public.

1. Upon request, an individual will be informed of the existence, use, and disclosure of his or her Personal Information and will be given access to that information subject to the exclusions set out in POPIA. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
2. Flyte Zone is not required to give access to personal information if:
   1. the information is protected by attorney-client privilege;
   2. doing so would reveal confidential proprietary or commercially sensitive information;
   3. doing so could reasonably be expected to threaten the life or security of another individual; or
   4. the information was generated in the course of a formal dispute resolution process.
3. Subject to the exceptions in section 11.2 above, upon written request, Flyte Zone will:
   1. inform an individual whether or not it holds information about the individual;
   2. use its best efforts to indicate the source of this information;
   3. allow the individual access to this information;
   4. assist any individual who informs Flyte Zone that he or she needs assistance in preparing a request for information;
   5. provide an account of the use that has been made or is being made of this information and of the third parties to which it has been disclosed.
4. Within the time limit for responding, Flyte Zone will inform an individual in writing of the reasons for refusing to grant access to Personal Information and describe what recourse exists for the individual under the Act. The appeal mechanism within Flyte Zone is to the Human Resources director.
5. An individual may be required to provide sufficient information to permit Flyte Zone to provide an account of the existence, use, and disclosure of personal information. The information provided will be used only for this purpose.
6. Flyte Zone will respond to an individual’s request within a reasonable time and at minimal cost to the individual. If there is a cost to the individual for access, Flyte Zone will provide the individual an estimate of the cost, and the individual must advise Flyte Zone that he or she is not withdrawing the request. Flyte Zone will make the requested information available in a form that is generally understandable, including explaining any abbreviations or codes.
7. Flyte Zone will respond to a request with due diligence and in any case not later than 30 (thirty) days after receipt of a written request. Flyte Zone may extend the time limit for responding for a maximum of thirty days if:
   1. meeting the time limit would unreasonably interfere with the activities of Flyte Zone, or
   2. the time required to undertake any consultations necessary to respond to the request would make the time limit impracticable to meet.

1. Whilst Flyte Zone will make all effort to ensure the integrity and accuracy of an individuals Personal Information, this may not at all times be possible. Following this, the individual accepts the responsibility for the accuracy of the Personal Information the individual provides to Flyte Zone and for keeping their Personal Information up to date, and the individual undertake to inform Flyte Zone of any changes to the individuals Personal Information.
2. An individual has the right to request that Flyte Zone corrects any inaccuracies in or to any such Personal Information. Please contact Flyte Zone using the information provided in the "Enquiries" section of this Privacy Notice to the correction of inaccuracies in or to any such Personal Information
3. When an individual successfully demonstrates the inaccuracy or incompleteness of Personal Information, Flyte Zone will amend the information as required. Depending upon the nature of the information challenged, amendment involves the correction, deletion, or addition of information. Where appropriate, the amended information will be transmitted to third parties having access to the information in question.

1. Flyte Zone does not knowingly collect Personal Information from persons under 18 years. If you are under the age of 18 (eighteen) years of age, please do not use the Applications, and do not provide any Personal Information to Flyte Zone.
2. If you are a parent of a child under the of 18 (eighteen) years of age and become aware that your child has provided personal data to Flyte Zone, please contact us using the information provided in the "Enquiries" section of this Notice, and you may request exercise of your applicable rights detailed in the paragraph 8.3 of this Notice.
3. If Flyte Zone learns learn that we have collected the Personal Information of a child under the age of 18 years, Flyte Zone will take reasonable steps to delete the Personal Information.

If you have any queries about this Notice you are welcome to send us an email to privacy@flyte.zone

Flyte Zone (Pty) Ltd
20 Wesley Street
Gardens,
Cape Town
8001