This page covers your rights, obligations and restrictions in relation to using the CrewLounge FRIENDS™ web application and support services. The Terms of Use comprise the following:

• View Only Access Terms
• Privacy Policy - Part I (as Controller)
• Privacy Policy - Part II (as Processor)
• Cookie Policy - Tool

CrewLounge AERO™, CrewLounge CONNECT™, CrewLounge DOCS™, CrewLounge FRIENDS™ and CrewLounge PILOTLOG™ are trademarks of AVIOVISION. CREWLOUNGE^® is a registered trademark of AVIOVISION.

Using CrewLounge FRIENDS™ constitutes your acceptance of the Terms of Use as outlined below. We reserve the right to change any part of the Terms of Use without prior notice. A copy of the new Terms of Use will be sent to the email address associated with your CrewLounge FRIENDS™ account. You will also be notified and invited to accept through the web application.

Revision Highlights

Here are the changes we made recently:

20 March 2023

• We have updated the entire Terms of Use, in especially our View Only Access Terms and our Privacy Policy
• More specifically, we now make a clear distinction between professional users of CrewLounge AERO and non-professional users of CrewLounge FRIENDS
• We have split the Privacy Policy into Part I and Part II, to make a clear distinction between our role as Controller and our role as Processor

31 March 2023

• Changed the contracting party from MCC to AVIOVISION, a Thales Group company, following AVIOVISION's acquisition of all CREWLOUNGE products, services, customers and trademark on March 31, 2023.

05 April 2023

• Updated article 17.1 with the THALES group integrity and conformity policy

If you do not agree to the updated Terms of Use, you must stop using CrewLounge FRIENDS™ and submit a request to close your account and delete your personal data.

1.    Scope of the Agreement

1.1	AVIOVISION NV is a Belgian company incorporated under Belgian law, with registered office at 3500 Hasselt, Herkenrodesingel 8/D.3.01, Belgium, and registered with the Belgian Crossroad Bank of Enterprises under number 0823.835.450 (hereinafter referred to as “AVIOVISION” or the “Provider”)
1.2	AVIOVISION has developed and owns the CrewLounge AERO, a software suite for the management and distribution of electronic flight related content, data and information for pilots, crew members, airline staff, aviation companies, aeroclubs, flight training centers and small airfields, containing several modules that a professional user ("User") can subscribe to under the General License Terms of CrewLounge AERO (here).
	One of the CrewLounge AERO modules is CrewLounge FRIENDS ("FRIENDS" or "FRIENDS app"), an online tool available as a Software as a Service, that allows a User to grant access to his friends and family on the ground, to view his roster and flights as contained in the Crewlounge AERO Software Suite, including information (such as weather, city and country information) about layovers. Such friend and/or family member that has received access from the User, and has registered a View Only Access Account, is hereafter referred to as the "Viewer".
	Hereafter, the View Only Access Terms will refer to the FRIENDS app, that is at no cost available to the Viewer, as the "Tool".
1.3	By registering for, accessing and using the Tool and/or the services provided by the Tool, or any part thereof (the "Services"), the Viewer irrevocably acknowledges to have read the View Only Access Terms and to have agreed to the View Only Access Terms (the "Agreement"). The View Only Access Terms always take precedence over any terms and conditions of the Viewer, even if they stipulate that they are the only valid terms and conditions.
	The View Only Access Terms are not a standalone agreement. They are necessarily linked to a User having entered into the General License Terms, and having invited the Viewer to have access to the Tool at no cost for the Viewer. Hence, the View Only Access Terms are always linked to and subject to a User having a valid agreement with AVIOVISION.
1.4	AVIOVISION and the Viewer are hereafter both referred to as a "Party", together as the "Parties" in relation to the Services.

2.    Relationship between the Parties

2.1

In the performance of this Agreement, the Parties hereto shall be deemed to be independent contract parties. Nothing in this Agreement shall be construed to make either Party an agent, employee, joint venturer, partner or legal representative of the other Party. Each Party shall not have, or represent itself to have, any authority to bind or commit the other Party to any oral or written, contract, understanding or obligation.

3.    Ability to contract

3.1	The Viewer represents and warrants to AVIOVISION that it has the legal right and authority to enter into this Agreement and to perform its obligations under this Agreement.
3.2	The Viewer represents to be a natural person aged 18 or older. An account will always be opened upon invitation by a User and on the name of an individual, natural person Viewer that becomes a Party to the Agreement with AVIOVISION.

4.    Access Rights and License

4.1	As of the Effective Date of the Agreement, the Viewer shall be granted a non-exclusive and non-transferable right to access the Tool and Services for the sole purpose of viewing inputs of the User and related data ("View Only Access").
	The View Only Access is granted for the duration of the Agreement and solely for the permitted use defined in Article 5.
	The View Only Access of this Article 4.1 is granted at no cost for the Viewer and is conditional upon the Viewer's strict compliance with Article 5, a valid agreement between AVIOVISION and the User and no revocation of the User's invitation to the Viewer to get View Only Access.
4.2	The Viewer shall be solely responsible for every use of and activity on its account, as well as for its protection, confidentiality and security. The Viewer must create a unique and strong password and change it frequently. The Viewer shall use 2FA (Two Factor Authentication) to further protect access to the Viewer's account.

5.    Permitted use cases and restrictions on use

5.1	Permitted use cases of the FRIENDS app are described on the Provider's website. In essence the Viewer is only permitted to view, and not to process in any other way any data on the Tool.
5.2	Unless such restriction is prohibited by applicable law, the Viewer shall not:
obtain, access, use or copy or try to or allow others to obtain, access, use or copy the source code of the Tool; reverse engineer, decompile, disassemble, translate or change the Tool, create derivative works based on the Tool, probe, scan or test the vulnerability of any system or network associated to the Tool or try to discover the trade secrets behind the Tool; market, sell, license or otherwise deliver the Tool to any third party or allow the Tool to be used by any third party; use the Tool and/or Services for any other purpose than its own civil-end purposes; Viewer will not use the Tool for any purposes prohibited by applicable law, nor in particular for any purpose connected with chemical or biological or nuclear weapons, or missiles or aircraft capable of delivering such weapons; use the Tool and Services in a fraudulent manner (such as making a false account, organizing a denial-of-service attack, applying automated scripts or bots whose sole purpose is to cause a system overload, or hacking or modifying the Tool) and/or impose a disproportionately large load on the cloud; use the Tool and Services in a disloyal manner (such as impersonating another User or Viewer, hiding its own identity or otherwise misrepresenting any affiliation with a person or entity, violating or otherwise infringing the rights of others, including privacy and intellectual property rights, sending unsolicited communications, promotions, advertisements or spam to other Viewers, sharing materials that are pornographic or contain extreme acts of violence, advocating bigotry or hatred against any Viewer of the Tool or sharing materials that are fraudulent, defamatory and/or misleading); and remove, disable, or circumvent any proprietary notices or labels contained on or within the Tool.
5.3	If a court of competent jurisdiction determines that relevant laws in force may imply that certain of the restrictions specified in this Article 5.2 cannot be accepted or can only partly be accepted, then the restrictions will apply to the fullest extent permitted by law.

6.    Intellectual Property Rights

6.1	“Intellectual Property Rights” mean all intellectual, industrial and other property rights (irrespective of whether these are registered or not), including but not limited to copyrights, related rights, marks, trade names, logos, drawings, models or applications for registration as a drawing or model, patents, patent applications, domain names, know-how, as well as rights to databases, computer programs and semi-conductors.
6.2	The Viewer recognizes that all Intellectual Property Rights in the Tool and Services, are vested with AVIOVISION or third parties that AVIOVISION has entered into an agreement with.
6.3	Nothing in these View Only Access Terms will be understood as an assignment, a license or a non-assert of any Intellectual Property Rights from the Provider to the Viewer other than the View Only Access rights explicitly granted to it in Article 4 and under the restrictions of Article 5.
6.4	If the Viewer provides any suggestions, information or user data to help AVIOVISION improve or modify the Tool and/or Services ("Feedback"), the Viewer agrees to assign to AVIOVISION without any additional consideration the entire worldwide right, title and interest in and to the Feedback provided. All Intellectual Property Rights in improvements and modifications shall belong to AVIOVISION.

7.    Third Party Materials

7.1	This Tool is integrated with or may otherwise interact with third party services and websites. Certain Services may display, include or make available content, data, information, applications or materials from third parties or provide links to certain third party websites or services (e.g. weather forecasts, city and country information, aircraft current radar position, etc) (“Third Party Materials”).
7.2	The Viewer is responsible for examining or evaluating the content, accuracy, completeness, timeliness, validity, legality, decency, quality and/or any other aspect of such Third Party Materials, such as compliance with (a) any rights of third parties, including Intellectual Property Rights, personal data protection rights or other rights related to data or (b) any other rights that may be exerted under any applicable legal instrument, national or regional law or regulation.
7.3	Moreover, the Viewer must, out of its own initiative, evaluate, accept and comply with the license terms applicable on the Third Party Materials (if any).
7.4	The Viewer acknowledges and agrees that the Provider does not bear any responsibility related to the Third Party Materials as set out in Article 7.1 thru 7.3.

8.    Term and termination

8.1	This Agreement will enter into force as of the moment that the Viewer creates a View Only Access account through the Tool's registration form upon invitation of a User with a valid agreement with the Provider (the "Effective Date"). This Agreement will remain in effect for the Term or until its termination in accordance with Article 8.2 ("Termination") or Article 8.3 ("Access Revocation").
	The Term of the Agreement is the duration during which the Crewlounge Software Suite is used by the User under the General License Terms and the User has not revoked his View Only Access invitation to the Viewer.
8.2	The Provider may terminate this Agreement with the Viewer, and hence the View Only Access immediately by e-mail notice upon the occurrence of a "Serious Default" by the Viewer. Each of the following occurrences will constitute a Serious Default under this Agreement:
The Viewer infringes the Intellectual Property Rights of the Provider in the Tool or Services; The Viewer infringes on the Restrictions on use defined in Article 5; The Viewer fails to observe any material obligation under this Agreement, and such failure, when capable of being remedied, is not remedied within 90 (ninety) days of receipt of a default notice sent to the Viewer, by the Provider.
	The Viewer may terminate the View Only Access immediately and without any motivation, by e-mail notice to the Provider, or by closing the View Only Access Account.
8.3	The Agreement with the Viewer and hence, the View Only Access, will be terminated at once upon revocation of the View Only Access invitation by the User in relation to the Viewer, or all Users should the Viewer be invited by multiple Users. The User can decide at his discretion to revoke the View Only Access invitation. No motivation has to be given, nor to the Provider, nor to the Viewer.

9.    Effects of Termination

9.1	Upon termination of this Agreement in accordance with Article 8, the Viewer will no longer have any View Only Access Rights to the Tool. The View Only Access rights will be disabled immediately.
9.2	The following sections of the Agreement shall survive the termination of the Agreement: Intellectual Property Rights (Article 6), Third Party Materials (Article 7), Term and termination and Effects of termination (Article 8 and 9), Liability (Article 10), Confidential Information (Article 12), Governing law and jurisdiction (Article 17).

10.    Limitation of Liability

10.1	The Provider and the User have agreed on liability terms in the General License Terms referred to above. Provider does not accept any additional, further or other liability towards the Viewer that is using the Tool for free and upon invitation of the User.
	Hence, the Tool is provided "as is" and "as available", with all faults and without warranty of any kind, whether express, implied, statutory or otherwise, including, but not limited to, the implied warranties of merchantability, fitness for a particular purpose or use, satisfactory quality, accuracy, quiet enjoyment and non-infringement of third party Intellectual Property Rights.
	The Provider disclaims any liability for a lack of security associated with the transmission of information over the Internet.

11.    Privacy Policy and Consent with Use of Data

11.1

The Provider in its capacity of controller for the processing of personal data, will process personal data on the Viewer for the purposes of granting View Only Access and for debugging and optimization of the Tool and Services. The AVIOVISION Privacy Policy - Part I will apply to such processing activities.

11.2

When providing the Services under the General License Terms, the Provider will also process the Viewer's Personal Data on behalf of the User. In that case, the Provider acts as processor on behalf of the User and shall solely act under the User's instruction in relation to the User's Personal Data. The AVIOVISION Privacy Policy - Part II will apply to such processing activities. In that case the User is acting as a data controller for the processing of the Personal Data, and must fully comply with applicable data protection legislation.

12.    Confidential Information

12.1

The Viewer undertakes to treat confidentially the commercial and technical information and trade secrets it learns from the Provider and not to use it for its own purposes, even after the termination of the Agreement. This confidentiality and non-use obligation shall not apply in relation to information that has become part of the public domain otherwise than through a breach of this Agreement.

13.    Entire Agreement

13.1

This Agreement together with the Privacy Policy, form the entire Agreement between the Parties concerning the scope defined in Article 1. This Agreement replaces and annuls any prior written or oral understanding, agreement, offer, correspondence or proposal regarding the scope of the Agreement. Any adjustment or amendment of this Agreement will only be binding upon Parties if agreed upon in writing and duly signed by both Parties.

14.    Waivers

14.1

None of the provisions of this Agreement shall be deemed to have been waived by any act or acquiescence on the part of either Party, unless such waiver is done in writing and signed by an officer of the waiving party. No waiver of any provision of this Agreement on one occasion shall constitute a waiver of any other provision or of the same provision on another occasion.

15.    Void or Unenforceable Provisions

15.1

Should any provision of this Agreement be void or unenforceable, the other provisions will not be affected by this and remain in full force and effect. In this case Parties, within the limits of the applicable law, will draft a new provision that meets the objectives intended by the void or unenforceable provision, and include this as an appendix to this Agreement.

16.    Force Majeure

16.1

Neither Party shall be liable for non-performance or delay in performance of any obligation under this Agreement if such non-performance or delay is caused by an event of force majeure or other circumstance that was reasonably unforeseeable, and which prevents a Party from performing the Agreement. On the occurrence of such event, the affected Party shall immediately inform the other Party of the event, and the reasons why it is not able to perform any or all of its obligations under the Agreement. If within a period of forty five (45) days, the event continues and the Parties are unable to identify a workable alternative, either Party may terminate this Agreement.

17.    Governing law and jurisdiction

17.1	Given the link with the General License Terms entered into with the User, all disputes concerning the validity, interpretation, enforcement, performance and termination of the Agreement with the Viewer shall equally be governed by and construed in accordance with Belgian law. No effect shall be given to any other choice-of-law or conflict-of- laws rules or provisions that would cause the laws of any other jurisdiction to be applicable.
17.2	For the same reason, the competent courts in Antwerp (Belgium) will have exclusive jurisdiction to decide upon any matter in relation to the General License Terms and this Agreement that is linked to the General License Terms. Parties hereby waive any claim of forum non conveniens. By way of exception, in the event of a need for provisional measures, a Party may at its discretion turn to the court in the jurisdiction in which the provisional measures should be implemented.
	Before instituting proceedings before the Court, Parties will, however, attempt to negotiate in good faith in order to reach an out-of-court settlement.

Part I of our Privacy Policy describes the role of AVIOVISION as Controller, in line with the European General Data Protection Regulation (GDPR). Read more about these regulations on the official website of the European Commission (here).

At CrewLounge AERO, a software suite owned and operated by AVIOVISION, we attach great importance to the protection of your personal data. "Personal Data" means any information relating to an identified or identifiable natural person ("Data Subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

This privacy policy sets out how we use and protect your Personal Data and who you can turn to for more information or to invoke your legal rights.

If the User provides us with Personal Data of the Viewer, that will be using the CrewLounge FRIENDS app (the "Tool"), the User must inform the Viewer of our privacy policy before entrusting us with their Personal Data. From our side we will use all opportunity we have to inform and reassure you and these persons that Personal Data are safe with us.

We reserve our right to amend our privacy policy from time to time, if legislation or our internal practices so require. At all times you can find the current version of our privacy policy on our website (the "Website").

The terms with capital letters are either defined hereunder or have the meaning as set out in the General License Terms.

This Privacy Policy - Part I only treats processing operations under AVIOVISION's control, in especially for which AVIOVISION acts as controller. Please revert to our Privacy Policy - Part II (as Processor) below, in relation to processing operations we perform exclusively under the instruction and control of the User, in especially as processor. These processing operations are not treated here in Part I.

The legal entity controlling the processing of your Personal Data is AVIOVISION NV. AVIOVISION NV is a Belgian company with limited liability, whose registered office is located at 3500 Hasselt, Herkenrodesingel 8/D.3.01, Belgium. AVIOVISION NV is registered with the Register for Legal Entities in Belgium under number BE0823.835.450.

AVIOVISION NV is the controller of the processing of your Personal Data because it has determined the purposes and means of the processing.

AVIOVISION NV is hereafter referred to as "AVIOVISION", "us" or "we".

AVIOVISION processes Personal Data of its Users for the following purposes:
1.	Processing of Personal Data of Users for the purpose of invoicing and administration, management of the User or contractual relationship and delivering the Tool and the Services, as well as legally required purposes linked to this purpose;
	If indicated by a User, Personal Data of of other Users, may also be processed for the purpose of delivering the Tool and the Services. Data of a colleague will only be processed if the colleague has a User account of his own.
	If indicated by a User, Personal Data of friends, family of a User may also be processed for the purpose of delivering the Tool and the Services. Data of friends and family of a User will only be processed on the User's initiative to grant these persons a View Only Access through the use of the Crewlounge FRIENDS app, which access is subject to the View Only Access Terms. These friends and family are known as the "Viewer".
2.	Processing of Personal Data of Users and potential users for direct marketing;
3.	Processing of Personal Data of Users (and the case being, friends and family of the User having a View Only Access) of the Tool for the purpose of debugging and optimization of the Tool and the Services for all Users;
4.	Processing of Personal Data of visitors to our Websites that fill out the Contact Form for the purpose of responding to their request or inquiry as sent through the Contact Form.
Additionally, our Websites and Tool (or modules thereof) may use cookies. For more information in relation to cookies, please revert to the Cookie Policy to be found on the respective Website and/or here below.

The legal basis for these processing operations is respectively:
1.	For the processing of Personal Data of Users and/or Viewers, for the purpose of supplying the Tool and Services, our legal basis for the processing of your data is:
the necessity for the purpose of organizing and interacting in relation to the conclusion or performance of a contract to which the User and AVIOVISION are parties.
2.	For the processing of Personal Data of Users and potential Users for direct marketing, our legal basis is either necessity for the purpose of the legitimate interests pursued by AVIOVISION or your consent:
the necessity for the purpose of the legitimate interests pursued by AVIOVISION to promote sales, reinforce the relationship with the User, enhance User loyalty, etc. We may invoke the legal basis of our legitimate interest, for newsletters and promotions sent by e-mail to our own Users if your e-mail contact details were received directly from you in the context of your use of the Tool, and are only used for the promotion of AVIOVISION's own similar products. Every newsletter, however, carries a link allowing you to unsubscribe from the newsletter. Such legitimate interest is in our view not overridden by your interests or fundamental rights and freedoms. Should you consider otherwise, please unsubscribe via the link or revert to title VII below on your legal rights in relation to privacy. "your consent. We will ask for your consent for e-mail newsletters if the aforementioned conditions are not complied with. Your consent will be asked at the moment that we receive your Personal Data (e.g. on the Website). This will normally take the form of a consent box to be ticked: [  ]  I agree to receive news and blogs from CrewLounge AERO. I can unsubscribe from those mailings anytime. The User may revoke his consent at any moment in accordance with title VII below. Additionally, the User can review and revoke his consent via the portal My CrewLounge - User - My Account - Notifications (login here). The Viewer may revoke his consent at any moment in accordance with title VII below. Additionally, the Viewer can review and revoke his consent via the portal CrewLounge FRIENDS - Account - Notifications (login here).
3.	Processing of Personal Data of Users of the Tool, and the case being, their friends and family, for the purpose of debugging and optimization of the Tool for all Users:
the necessity for the purpose of the legitimate interests pursued by AVIOVISION. Given the nature of the Personal Data processed, which is basic information and no sensitive information, and the appropriate safeguards taken by AVIOVISION, such interests are in our view not overridden by your interests or fundamental rights and freedoms. Should you consider otherwise, please revert to title VII below on your legal rights in relation to privacy.
4.	We may also process your Personal Data if required for legal reasons, compliance or tax and accounting reasons. The legal basis of our processing is then to be found in European or national law.
5.	Processing of Personal Data of visitors to our crewlounge.aero Website that fill out the Contact Form for the purpose of responding to their requests or enquiries as sent through the Contact Form;
the necessity for the purpose of the legitimate interests pursued by AVIOVISION to treat and give follow up to the visitor's request. Given your initiative to send your request via the contact page (which we assume you want us to reply to) and the limited use made by us of your contact details to reply, such interests are in our view, not overridden by your interests or fundamental rights and freedoms. Should you consider otherwise, please revert to title VII below on your legal rights in relation to privacy.

For Users

We collect the following personal data from the User:

First and Last name*(1)(2) Address*(1)(2) E-mail address* (1)(2) Telephone and/or mobile number Function and/or rank Airline company Employee ID Gender Date of birth Social media accounts (Facebook, LinkedIn, Instagram) Interests Carpooling location Technical Data (i.e. information associated with the device you use, such as the type of device, IP address, browser type, time, current geographical location and operating system) (3) Flight Data (i.e. information on your flying activity, such as your flight history, your planned flight schedule, your current trip, personal notes that you enter, license and proficiency expiry dates, etc) Profile picture (1) Login & Password* (1) Contract related information (1) Metadata of communications (3) Endorsement signatures and other images Portable data files and other electronic documents

And the case being:

User complaints and details of the complaints (1) Video recordings or screenshots that you share with us (3)

The Personal Data (1) are processed for the purpose of supplying the Tool and Services and legally required purposes linked to that purpose. The Personal Data (2) are processed for direct marketing purposes. The Personal Data (3) are processed for the optimization and debugging of the Tool.

The aforementioned Personal Data indicated with a * have to be provided if the User wants to engage in a relationship with AVIOVISION for the supply of the Tool and/or Services. The provision of the other Personal Data is entirely on a voluntary basis.

For Viewers

We collect the following personal data from the Viewers that have a View Only Access:

First and Last name E-mail address Login & Password The User that initiated the View Only Access

All above specified Personal Data are processed for the purpose of supplying the View Only Access, and, the case being, for debugging and optimization of the Tool.

All Personal Data have to be provided if the User wants to give, and the friend or family member wants to obtain, a View Only Access.

For visitors to the Website

We collect the following personal data from visitors to the crewlounge.aero Website that fill out the Contact Form:

Name* E-mail address* Country Company Aircraft model Software Operating System Any other data filled out in the Contact Form The content of all email messages that respond to the visitor's inquiry

The Personal Data indicated with a * have to be provided if the visitor wants to submit a request through the Contact Form.

For Users

We process your Personal Data for the purpose of supplying the Tool and Services and for the purpose of debugging and optimization of the Tool, as long as you use the Tool and Services.

After Expiration of the Agreement and automatic closure of the User's account pursuant to not using the Tool for a period of 18 months in accordance with Article 10.4 of the General License Terms, Personal Data contained in the Tool, will be deleted unless continued processing of specific Personal Data is necessary for legal, tax and/or accounting purposes. Make sure that you have exported your data prior to the closure of the User's account.

In the event of Termination of the Agreement for Serious Default in accordance with Article 10.2 and 10.3 of the General License Terms, Personal Data in that (part of the) Tool, are retained for 6 months after Termination, to allow you to export your data.

In the event that you decide to stop using our Tool and Services, you should first export all your Personal Data prior to closing the User's Account. Once the User's Account is closed, all data is deleted, forever.

We process your Personal Data for direct marketing purposes until you oppose to the processing of your Personal Data for that purpose, or if the processing was based on your consent, until you withdraw your consent.

For Viewers

Your Personal Data are deleted when all Users that you are linked to, take away your View Only Access or if Personal Data of all these Users are deleted as described under title V, For Users.

For visitors to the Website

We process your Personal Data as long as necessary to deal with and give follow up to your request and no longer than 1 year after dealing with your request. The data are not retained afterwards (unless the case being, in the context of another processing for another purpose as detailed in this Privacy Policy).

The following Personal Data may be shared in accordance with this Privacy Policy:

All Personal Data with third party processors that provide services for us e.g. suppliers of IT and hosting services who are acting on behalf of AVIOVISION and with whom AVIOVISION has entered into adequate written processor contracts. These processors will only use the data for the purposes determined by AVIOVISION and in accordance with this Privacy Policy.

and for Users only:

Financial data with third party suppliers that provide online payment services to you, in especially Paypal®, Mollie®, Apple iTunes® and Google Play®. These suppliers will only use the data for the payment services requested by you. They are obliged to abide by their own Privacy Policy. When using the optional direct messaging chat function upon your initiative, your e-mail address, name and picture with a third party company, Quickblox Injoit Limited.

Notwithstanding the foregoing, it is possible that AVIOVISION must disclose your Personal Data:

To the competent authorities (i) when AVIOVISION is obliged to do so under the law or in the context of legal proceedings and (ii) for the protection and defense of our rights.

Given our collaboration with Gemango Software Services Ltd (in the Philippines) and with CrewLounge Viet Nam Ltd (in Vietnam), we will for the Purposes share your Personal Data with our colleagues vested outside of the European Economic Area (the "EEA"). As Vietnam and the Philippines are not recognized by the European Commission as ensuring an adequate level of protection of Personal Data, AVIOVISION and its partners Gemango Software Services and CrewLounge Viet Nam have implemented appropriate safeguards for the protection of your rights and interests in these countries, by entering into standard contractual clauses "controller-to-processor" (C2P) or "processor-to-processor" (P2P), a copy of which can be requested by sending an e-mail to privacy อ crewlounge.aero.

Given the Tool's essence and finality of management and distribution of electronic flight related content, data and information for pilots, flight attendants, airline staff, aviation companies, aeroclubs, flight training centers and small airfields, Personal Data will necessarily be transferred to countries outside the EEA. You explicitly consent to that transfer when you, out of your own initiative, access the Tool and Services from outside the EEA, e.g. when you travel outside the EEA, or when you reside outside the EEA. In those scenarios the transfer is necessary for the performance of the contract between you and AVIOVISION (i.e. access and use of the Tool and Services from where you are). When you have enabled the sharing and visibility of your user profile and/or your geographical location with other Users of the Tool, Users outside the EEA will also be able to see your Personal Data , and this as a consequence of the performance of our contract with you.

In relation to the Personal Data that are processed by AVIOVISION, you have a number of legal rights:

You have the right to get access to your Personal Data and to have these data corrected. You may ask AVIOVISION to erase your Personal Data, or to restrict the processing thereof. To the extent that the processing is based on the legal basis of a legitimate interest or the processing is done for direct marketing purposes, you have the right to object to that processing. To the extent that the processing is based on your consent, you have the right to revoke your consent at any time.

Within a duration of maximum 30 calendar days after receipt of your request, we will act upon your request and reply. If for some reason we cannot accommodate your request, we will inform you of the reasons thereof. If we are not in a position to identify you properly, we may ask you to provide a proof of your identity as a prerequisite to accommodating your request.

In order to invoke your rights under title VII, please contact us at our dedicated privacy e-mail address ( privacy อ crewlounge.aero ) or send us a letter ( AVIOVISION NV, Department of Privacy, Herkenrodesingel 8/D.3.01, 3500 Hasselt, Belgium ).

In the same way, if you have any questions, remarks or complaints in relation to our privacy policy or how we process your data, do not hesitate to contact us, either by letter or e-mail as described above.

If you have any complaints in relation to how AVIOVISION processes your Personal Data, you may file a complaint with the competent data protection authority in Belgium, being the Belgian Data Protection Authority (here).

Part II of our Privacy Policy describes the role of AVIOVISION as Processor, in line with the European General Data Protection Regulation (GDPR). Read more about these regulations on the official website of the European Commission (here).

At CrewLounge AERO, a software suite owned and operated by AVIOVISION, we attach great importance to the protection of Personal Data. This Policy sets out AVIOVISION's commitments as a processor with regard to the Personal Data we process on behalf and under the instruction of the user (hereafter "User" and "User Personal Data").

We shall process the User Personal Data in a proper and careful way and in accordance with the User's instructions and the data protection legislation and other applicable rules concerning the processing of User Personal Data.

We reserve our right to amend our Processor Policy from time to time, if legislation or our internal practices so require.

When entrusting us with User Personal Data in the context of the CrewLounge AERO software suite or any module thereof (the "Tool"), and by using specific functionalities of the Tool, you determine the specific processing operations that you want the Tool to perform with the User Personal Data. You also determine the privacy settings. It is your initiative to use these functionalities and to use these in relation to specific User Personal Data, for purposes that are determined by you. Hence, you, the User, are the controller of the processing. If you provide us with Personal Data of other persons, such as your family, friends and/or colleagues, that will be using any part of the Tool, you must obtain prior consent from these persons. You must inform these persons of our Processor Policy before entrusting us with their Personal Data.

This Privacy Policy - Part II only treats processing operations under AVIOVISION's control, in especially for which AVIOVISION acts as processor. Please revert to our Privacy Policy - Part I (as Controller) above, in relation to processing operations we perform for our own purposes, in especially as controller.

The processing considered here below is the processing by AVIOVISION and/or in the Tool of User Personal Data such as data of the User, and family, friends and/or colleagues of the User, if indicated by the User.

Data of a colleague will only be processed if the colleague has a CrewLounge AERO User account of his own. Data of friends and family of a User, known as the "Viewer", will only be processed on the User's initiative to grant these persons View Only Access through the CrewLounge FRIENDS app, which access is subject to View Only Access Terms.

These User Personal Data are processed on behalf of the User and for the User's purposes based on the User's instructions, and the functionalities and privacy settings chosen. This processing either forms an inherent part of the User's use of the Tool, either relates to AVIOVISION's support given for the Tool in the event of assistance, issues or bugs. Specific processing operations relate for instance to authentication, reading, creation and submission of flight and business related information, sending of data, monitoring the usage of the Tool, reviewing issues and fixing bugs etc.

With regard to this processing, AVIOVISION processes the relevant User Personal Data on behalf of the User. Therefore AVIOVISION qualifies as processor for these processing activities, and the User qualifies as controller.

The User in its capacity as controller shall be responsible to comply with all (legal) obligations vested in the controller, in particular the obligation to inform the data subjects on the purposes of his processing.

AVIOVISION processes User Personal Data on behalf of its User for the purposes of the User ("User Purposes").

In the context of these User Purposes, AVIOVISION shall perform the following processing operations for the User:

	The delivery of services to the User in accordance with the General License Terms, being amongst others:
Authentication and granting access permissions to parts of the Tool Reading, creation and submission of flight and business related information Sending and receiving of data Storing documents and images Supporting incidents, including bugs and issues Improving data security and software performance

The categories of data subjects are the following:

User Viewer

For Users

The following data are processed on behalf of the User:

Name Address E-mail address Company name Aircraft type Telephone and/or mobile number Company number Employee ID VAT number Login & Password Gender Date of birth Actual flight data Roster schedule data User profile picture Documents and data that are related to conducting flights and flight training

For Viewers

The following data are processed on behalf of the Viewer:

Name E-mail address Login & Password

For Users

AVIOVISION shall retain the User Personal Data as long as User is using the Tool, or any part thereof.

The User explicitly agrees that after Expiration of the Agreement and closure of the User's account, pursuant to not using the Tool for a period of 18 months, in accordance with Article 10.4 of the General License Terms, User Personal Data contained in the Tool will be deleted. Make sure that you have exported your data prior to closure of the User's account.

After Termination of the Agreement for Serious Default in accordance with Article 10.2 and 10.3 of the General License Terms, Personal Data in the Tool are retained for 6 months after Termination, to allow you to export your data.

In the event that you decide to stop using our Tool and Services, you should first export all your Personal Data prior to closing the User's Account. Once the User's Account is closed, all data is deleted, forever.

For Viewers

Your Personal Data are deleted when all Users that you are linked to, take away your View Only Access or if Personal Data of all these Users are deleted as described under title V, For Users.

For the User Purposes specified under Article III, AVIOVISION appeals to the following sub-processors. The User and the Viewer hereby explicitly grants their general authorization to engage the following sub-processors:

Name of the sub-processor:	Gemango Software Services
Address of the sub-processor:	Ayala Business park RM14B (14th Floor) IT Tower 1, Cebu City, 6000 Cebu, Philippines
Description of services provided to Supplier:	ICT Development and Customer Support Services
Is the User Personal Data accessible by the sub-contractor?	Yes, permanent
Name of the sub-processor:	CrewLounge Viet Nam Ltd.
Address of the sub-processor:	Tầng 4, số 20 Đồng Bát, Phường Mỹ Đình 2, Quận Nam Từ Liêm, Thành phố Hà Nội, Việt Nam
Description of services provided to Supplier:	ICT Development
Is the User Personal Data accessible by the sub-contractor?	Yes, permanent

These sub-processors are at least bound by the same obligations by which AVIOVISION is bound under this Processor Policy.

AVIOVISION shall refrain from sharing any User Personal Data to any sub-processor not in the sub-processor list.

AVIOVISION undertakes to inform the User in writing of any change to the aforementioned list (addition or replacement of a sub-processor). Such notice will be given by a pop-up notification inside the Tool as well as via email notification indicating a modification in the Processor Policy. The User has the opportunity to object to such changes in writing and in a reasoned manner within thirty (30) days upon receipt of AVIOVISION's notice.

QuickBlox Injoit Ltd., the provider of the direct messaging chat function inside the Tool, is not considered a sub-processor of AVIOVISION. If you use the direct messaging chat function of QuickBlox on your initiative, QuickBlox's own privacy policy applies between you and Quickblox. You find their Privacy Policy here

Given our collaboration with Gemango Software Services Ltd (in the Philippines) and with CrewLounge Viet Nam Ltd (in Vietnam), we will for the Purposes share your Personal Data with our colleagues vested outside of the European Economic Area (the "EEA"). Refer to title VII here below on how we handle the transfer of your data outside of the EEA.

AVIOVISION shall not transfer User Personal Data, to a country outside the EEA, unless:
(i)	the transfer happens on the initiative of the User through the use of the Tool (i.e. access and use of the Tool and Services made from outside the EEA by the User or the User's contact); or
(ii)	to the processors and sub-processors indicated in Title VI that are located outside the EEA (hereafter data importers).
In the latter case, AVIOVISION as data exporter has implemented appropriate safeguards for the protection of the data subjects' rights and interests in the data importer's country, by entering into standard contractual clauses "controller-to-processor" (C2P) or "processor-to-processor" (P2P) with the data importers, a copy of which can be requested by sending an e-mail to privacy อ crewlounge.aero. The User hereby expressly grants AVIOVISION authorization to engage the above processors or sub-processors and to enter into said standard contractual clauses with them.
AVIOVISION guaranties that its current processors and sub-processors outside of the EEA have signed, and that future processors and sub-processors will sign the standard contractual clauses "controller-to-processor" (C2P) or "processor-to-processor" (P2P) with AVIOVISION.

AVIOVISION commits to deliver the necessary assistance to the User acting as controller, taking into account the nature of the processing, with:
1.	the fulfilment of the User's duty to answer a request of a data subject for exercising the data subject's rights laid down in Chapter III of the GDPR;
2.	taking the appropriate measures for the safety of the User Personal Data and reporting any breaches to the safety and security of User Personal Data;
3.	carrying out a data protection impact assessment, in case the User considers such assessment to be (legally) required.
In case a situation occurs in which the User wishes to call upon the assistance of AVIOVISION, the User will promptly notify AVIOVISION by e-mail support อ crewlounge.aero.

AVIOVISION undertakes to implement the following technical and organisational security measures necessary for the protection of User Personal Data, that the User considers appropriate:

Use of modern ICT hardware and up-to-date software Data protection through strong password as well as 2FA (Two Factor Authentication) Inventory of all hardware and IP addresses that accesses the Tool Monitoring and automatic blocking of suspicious actions

as well as internal:

Data security protocols Company data processing policies Awareness training

When determining the appropriate technical and organisational security measures, AVIOVISION shall take into account (i) the state of the art, (ii) the implementation costs related to these measures, (iii) the nature, scope, context and purposes of the processing, (iv) the risks involved for the data subjects' rights and freedoms, in particular in case of accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or non-authorised access to User Personal Data transmitted, stored or otherwise processed, and (v) the probability that the processing shall have an impact on the rights and freedoms of the data subjects.

AVIOVISION shall review and update these measures on a regular basis.

AVIOVISION shall implement technical measures to:

monitor security events in relation to User Personal Data, and detect a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed ("Data Breach").

In the event of a Data Breach, AVIOVISION shall notify the User without undue delay after becoming aware of the Data Breach and shall provide - to the extent possible - the User with all information needed to inform the competent authorities if deemed necessary by the User.

The User however shall be responsible as controller for his notification obligations toward the competent authorities and/or data subjects.

AVIOVISION shall retain any incident logs related to a Data Breach for six months.

AVIOVISION shall maintain the User Personal Data confidential and not disclose nor sell any User Personal Data to third parties, without the prior written agreement of the User. However, in the event that the User is using the Tool (or part thereof) through an Access Code that is received from and paid by a third party, usually the employer of the User (Article 3.3 of the General License Terms), the User understands and explicitly consents that User Personal Data is shared with that third party.

AVIOVISION will ensure that its employees and sub-processors, engaged in the performance of the Services under the General License Terms, are informed about the confidential nature of the User Personal Data, have received appropriate training on their responsibilities and have executed written confidentiality agreements.

The User is entitled to verify AVIOVISION's compliance with this Processor Policy once per calendar year. During AVIOVISION's regular business hours, and provided that the User has given AVIOVISION at least 30 calendar days prior notice of the date of the audit, AVIOVISION will allow the User to visit the premises where the User Personal Data is processed in order to verify compliance with this Processor Policy.

The costs on the account of the User and the costs on the account of AVIOVISION for the performance of the audit are borne and paid by the User, unless the result of the audit shows that AVIOVISION has committed a serious shortcoming in the implementation or execution of this Processor Policy.

AVIOVISION has appointed the following Privacy Manager:
Name:	Robert DIRKS
Address:	AVIOVISION, Herkenrodesingel 8/D.3.01, 3500 Hasselt, Belgium
E-mail:	privacy อ crewlounge.aero
	privacy อ AVIOVISIONbook.aero

The Cookie Policy - Tool describes the cookies that are used by the Tool, in especially when using the different web apps through the crewlounge.center domain, such as  friends.crewlounge.center .

For the cookie policy regarding the commercial website crewlounge.aero refer to the Cookie Policy - Website (here).

The administrator of this Tool is AVIOVISION NV. AVIOVISION makes use of cookies which are managed in our own name. In this cookie policy you are provided with more information about the types of cookies used, the data each cookie tracks, its purpose and whether or not you have the right to refuse these cookies.

Given that cookies contain personal data, this cookie policy must be read together with our privacy policy, which you find here above.

The processing of personal data is subject to 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) and the Belgian Law of 30 July 2018 on the protection of individuals with regard to the processing of personal data.

As administrator of this Tool, AVIOVISION makes use of so-called 'cookies'. Cookies are small text files that are installed on your computer or mobile device when you visit our Tool. Cookie-files contain unique extracts of information that, for example, allow your browser to recognize you when you visit our Tool and thus improve your user experience. Cookies allow us to store certain usage information and to enable certain features on our Tool.

Cookies have an expiration date depending on whether they are 'session cookies' or 'persistent cookies'.

Session cookies contain information that is used within your current browser session. These cookies are temporary and expire once you close your browser (or once your session ends).

Persistent cookies, however, are used to store information between visits to the Tool. This data enables the Tool to recognise you as a returning visitor and therefore respond accordingly, for example by storing your language preferences. Persistent cookies have an expiration date written into their code and their duration can vary.

There are different types of cookies, depending on what purpose they serve, their time of expiry ('session' and 'persistent' cookies) and their origin ('first-party' and 'third-party' cookies).

AVIOVISION makes use of the following types of cookies on the Tool:

Cookies which are technically necessary for the functioning of the Tool

To make the Tool working, AVIOVISION uses essential and functional cookies. These cookies are technically necessary for the proper functioning and security of the Tool. They help provide a good user experience of our Tool.

By disabling such cookies, certain parts of the Tool may not function properly and certain functionalities and services may not be used.

The cookies are 'first-party' cookies, which means they are stored by our Tool directly. As they relate to the legitimate interests of AVIOVISION, these cookies are placed without your consent.

Name of the Cookie:	shared_did
Cookie Type:	Essential
Personal Data collected:	A random unique string generated by website
Purpose of collecting:	Identify logged in browser for tracking list of devices/browsers of visitors
Legal Basis:	Legitimate
Duration unless deleted:	100 days
Retention period of Personal Data collected:	100 days
First or Third Party Cookie:	First
Name of the Cookie:	shared_jwt
Cookie Type:	Essential
Personal Data collected:	Vistor's access token
Purpose of collecting:	An encoded string sent by API server after logging in. The string is used for authenticating requests on behalf of the visitor instead of using account/password directly.
Legal Basis:	Legitimate
Duration unless deleted:	7 days
Retention period of Personal Data collected:	7 days
First or Third Party Cookie:	First
Name of the Cookie:	shared_jwt_refresh
Cookie Type:	Essential
Personal Data collected:	Vistor's refresh token
Purpose of collecting:	An encoded string sent by API server for renewing the access token automatically when expired. It helps visitors obtain a new access token without the need for a new login.
Legal Basis:	Legitimate
Duration unless deleted:	30 days
Retention period of Personal Data collected:	30 days
First or Third Party Cookie:	First
Name of the Cookie:	aws_id
Cookie Type:	Functional
Personal Data collected:	Amazon Access Id
Purpose of collecting:	The access key ID generated by Amazon for each visitor that identifies the temporary security credentials
Legal Basis:	Legitimate
Duration unless deleted:	12 hours
Retention period of Personal Data collected:	12 hours
First or Third Party Cookie:	First
Name of the Cookie:	aws_secret
Cookie Type:	Functional
Personal Data collected:	Amazon secret access key
Purpose of collecting:	A secret access key generated by Amazon, used to sign requests
Legal Basis:	Legitimate
Duration unless deleted:	12 hours
Retention period of Personal Data collected:	12 hours
First or Third Party Cookie:	First
Name of the Cookie:	aws_token
Cookie Type:	Functional
Personal Data collected:	Amazon session token
Purpose of collecting:	A token generated by Amazon which is required to use temporary credentials
Legal Basis:	Legitimate
Duration unless deleted:	12 hours
Retention period of Personal Data collected:	12 hours
First or Third Party Cookie:	First

Cookies which are intended to improve the interactivity of the Tool

Non-functional cookies are used for analytical and/or commercial purposes. These cookies can be 'first-party' cookies, which means they are stored by our Tool directly, or 'third-party' cookies. Third-party cookies are created by domains/websites other than the one you are visiting directly. They will collect your browsing data and use the data collected via their cookies for purposes they have determined in accordance with their own privacy policy. They can be used for cross-site tracking, retargeting and ad-serving.

The use of non-functional cookies is subject to your prior explicit consent. You can give your consent or refuse by clicking the appropriate button in the cookie banner. You are also able to refuse that such cookies are stored on your computer or mobile device.

AVIOVISION does not use non-functional cookies for the Tool. Hence, there are no buttons on the cookie banner when you browse to friends.crewlounge.center .

All common browsers allow you to define or indicate which cookies you allow in their settings or options. Via your browser, you can view and delete the current cookies on your computer or mobile device, and choose not to accept them in the future.

Here are some useful links to their respective Support pages:

Apple - Safari (here) Google - Chrome (here) Microsoft - Edge (here) Microsoft - Internet Explorer (here) Mozilla - Firefox (here)

If you cannot find these settings, you can consult the help function of your browser.

If you have any questions or comments regarding our cookie policy, please contact us through the Website Contact Form or via email to privacy อ crewlounge.aero

To exercise your rights, you can also find further information in our Privacy Policy, here above.