Air Turquoise SA, Route du Pré-au-Comte 8, 1844 Villeneuve (VD), Switzerland(theCompany) respects your privacy.

To run our business, we collect and use information about users of the website accessible at and any other products and/or services available at the same URL address (referred to as personal data).

The protection of this personal data is important to the Company. We therefore process any personal data entrusted to us in compliance with the law.

As part of our commitment to protect your personal data, we want to inform you:

  1. why and how the Company collects, uses and stores your personal data, for how long and under which legal basis;
  2. with whom we share your personal data;
  3. our role as the legal entity deciding about the processing of your personal data (referred to as the controller);
  4. and what your rights and our obligations are in relation to such processing.



This policy applies to any and all forms of use of personal data (a processing). Unless defined in this policy, terms beginning with a capital letter shall have the meaning set forth in the Terms of Use of the Company.

Who is responsible for the processing of your personal data?

The Company is responsible for the processing, as controller, of your personal data [and has appointed as representative in the EU [name and contact details of Company entity selected as EU representative]][1].



We collect and process identification information about all individuals with whom we interact, such as the [name, title, position, company name, email and/or postal address, the professional fixed and/or mobile phone number and information related to the Reports][2].

This information may either be directly provided by you or provided by the legal entity for whom you work (e.g. if you are the contact person designated by your employer to manage the Company account).

We also collect and process the following information in relation to your use of the Website:

  1. the IP address of your equipment;
  2. your internet service provider;
  3. the type and version of your browser and your operating system;
  4. information regarding the pages you visit, the information researched, the time spent on our website and other statistics regarding your browsing experience on our website;
  5. information regarding your preferences on our website;
  6. and [other][3].

[Whenever personal data is collected (e.g. in application forms), we will indicate whether the provision of such data is mandatory (e.g. with an asterisk) and the consequences of a refusal to provide the requested data.]



4.1. Legal basis for the processing

We only process your personal data provided:

  1. such processing is necessary to perform our contractual obligations towards you or to take pre-contractual steps at your request; or
  2. we have obtained your prior consent; or
  3. such processing is necessary for the legitimate interest of Company to the extent it is not overridden by your own interest or fundamental rights and freedom.


4.2. Purposes of the processing of your personal data

We process your personal data for specific purposes and only to the extent relevant to achieve these purposes. In particular, we process your personal data for the following purposes:

to undertake marketing/procurement activities;

  1. to manage our customers and suppliers;
  2. to implement tasks in preparation of or under existing contracts;
  3. to supply our services;
  4. to manage our IT resources, including infrastructure management & business continuity;
  5. to manage our archiving and records;
  6. to track our activities (measuring sales, number of calls, visits to our website, etc.);
  7. for invoicing purposes;
  8. to improve our existing services (or those under development) by means of customer and non-customer surveys, statistics and testing;
  9. to improve the quality of services to our clients by taking into account their preferences in terms of means of communication (phone, e-mail, etc.), frequency and otherwise;
  10. to reply to any official request from a public or judicial authority in compliance with legal requirements;
  11. more generally, to comply with any legal, accounting and tax obligations imposed on Company in its relation with its customers and suppliers;
  12. to periodically send promotional emails about our products, special offers and information which you or your company may find interesting, using the email address which you have provided (if any).
  13. to manage and improve our websites;
  14. to measure the usage of our websites (including drawing up statistics);
  15. to manage users (such as account management and answering questions);
  16. and [other] [4].



5.1. Outside the Company

We may transfer personal data to third parties outside the Company, acting as processors, to achieve the purposes listed in Section 4.2 above, to the extent they need it to carry out the instructions we have given to them. [We do not transfer personal data to these third parties for commercial use.][5] Such third parties include our (IT) systems, cloud service and database providers, as well as our payroll providers.

As processors, the above third parties have entered into agreements with the Company to process your personal data.

Where required, we may also transfer your personal data to:

  1. any third party to whom we assign or novate any of our rights or obligations under a relevant agreement;
  2. and any national or international public or judicial authority, where we are required to do so by applicable law or regulation or at their request, in compliance with law.


5.2. Transfers outside the European Economic Area

The personal data transferred within or outside the Company as set out in Section 5.1, may also be processed in a country outside the European Economic Area and Switzerland. [In particular, your personal data may be transferred to [●]][6]. These countries may not offer the same level of personal data protection as EEA countries and Switzerland.

If your personal data is transferred to a country that has not been recognised as offering an adequate level of protection for personal data, we will put in place legally required safeguards or rely on the relevant legal derogations to ensure such transfer is carried out in compliance with the applicable law.

You may request additional information in this respect and obtain a copy of the relevant safeguard by exercising your rights as set out below.


5.3. Third party websites

Our websites (including mobile apps) may contain links to other websites such as Facebook, Twitter, LinkedIn, Google or Apple. This policy does not apply to the practices of any company or individual that the Company does not control, nor to any websites that may be linked from our websites. You should carefully review the privacy policies of any websites that you visit from our websites to learn more about their information and privacy practices. The collection and use of your personal information shall be governed by such other party or website’s privacy policy and the Company shall not be held responsible for their privacy practices.


5.4. Cookies and analytics tools

The Company also uses “cookies” or other analytics tools to collect information. A cookie is a small data file that the Company transfers to your electronic device and is stored on your electronic device. e.g. the Company uses cookies or other analytics tools to measure the traffic to and usage of our websites and their different features, and other miscellaneous uses.

If you do not wish to have cookies placed on your electronic device, you should set your browser or electronic device to refuse cookies before using our websites, with the drawback that certain features of the websites may not function properly without the help of cookies.



We will only retain personal data for as long as necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.

Personal data we hold in our database about you will be stored for maximum [6/12/18/24] months after your last interaction with the Company.



7.1. Your rights

Within the limits and under the conditions set forth in the law, you have the following rights:

  1. to access your personal data as processed by us and obtain a copy thereof;
  2. to request any correction or update thereof;
  3. to request the erasure of your personal data;
  4. to request the restriction of the processing of your personal data;
  5. to withdraw your consent where Company based its processing of your personal data on your consent (without such withdrawal affecting the lawfulness of processing prior thereto);
  6. to object to the processing of your personal data;
  7. to request the portability of your personal data (i.e. to obtain the personal data you have provided to Company in a structured, commonly used and machine-readable format and/or to request the transmission of such personal data to a third party, without hindrance from Company and subject to your own confidentiality obligations).


7.2. Exercising your rights

To exercise the above rights, you may send a request by post or by email to [Air Turquoise SA, Route du Pré-au-Comte 8, 1844 Villeneuve (VD), Switzerland and/or This email address is being protected from spambots. You need JavaScript enabled to view it.]. We will respond in compliance with applicable law.

If you are not satisfied with how Company processes your personal data, please let us know and we will investigate your concern.

In addition, you have the right to make a complaint to the competent data protection authority.



This policy may be subject to amendments. Any future changes or additions to the processing of personal data as described in this policy affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.



[1] To be confirmed.

[2] Please adapt/complete the list of personal data collected on all Users.

[3] Please adapt/complete the list of personal data collected through the use of the Website.

[4] Please adapt/complete.

[5] Please confirm.

[6] Please complete if relevant.