Privacy Notice (Website, Candidates & Recruitment Services)

Effective date: 03-December-2025

Last updated: 03-December-2025

1. Who we are

For the purposes of the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the Data Protection Act 2018, SG Aviation Services Ltd. is the data controller in respect of the Personal Data described in this Privacy Notice.

Our contact details:

SG Aviation Services Ltd.
20 Harcourt Street, Dublin 2, D02 H364, Ireland
Tel: +353 1 908 1132
Email: info@sgaviationservices.com

Data protection contact:

If you have any questions about this notice or how we process your Personal Data, you can contact us at:
Email: info@sgaviationservices.com
Tel: +353 1 908 1132

2. Purpose and scope of this notice

This Privacy Notice explains:

• what Personal Data we collect;
• how and why we use it;
• the lawful bases we rely on;
• who we share it with;
• how long we keep it; and
• your rights under data protection law.

This notice applies to:

1. visitors to our website; and
2. individuals who engage with us for recruitment and contracting services (including candidates, applicants, and contractors).

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of those sites.

3. What Personal Data we process

“Personal Data” means any information about a living individual which identifies them, or could be used to identify them.

3.1 Candidate and recruitment data

We collect Personal Data to provide recruitment services, communicate with you, and assess your suitability for roles with client airlines. Personal Data we may collect includes:

• Identification and contact details (e.g., name, phone number, email address, date of birth, nationality);
• Professional and career information (e.g., CV content, qualifications, licence type, work history);
• Aviation regulatory documentation where relevant (e.g., licence copy, medical copy, passport copy, criminal record check);
• Reference check information where you have provided express consent;
• Bank details if you become a directly engaged contractor and we manage payroll.

3.2 Website and technical data

When you visit our website, we may collect:

• IP address and device information;
• browser type/version and operating system;
• usage data and analytics about how you interact with the site;
• cookie identifiers.

3.3 Data from third parties

In some cases your data may also be contained in information we receive from third-party platforms (e.g., job boards where your settings allow recruiter access).

3.4 Special category data

Recruitment in aviation may involve collecting certain sensitive data (for example medical status or related regulatory fitness information). We only process special category data where necessary and in accordance with GDPR requirements.

4. How and why we use your Personal Data

We use your Personal Data for the following purposes:

• to provide recruitment and contracting services;
• to communicate with you about roles and opportunities;
• to submit applications and represent your candidacy to client airlines (with your express permission);
• to collect and verify required documentation in line with aviation regulatory standards;
• to conduct assessments and, where applicable, reference checks (with your explicit consent);
• to operate payroll for directly engaged contractors;
• to administer, maintain, and improve our website, including analytics and security;
• to meet legal, regulatory, and contractual obligations; and
• to protect our reputation, systems, and services (including fraud and security prevention).

5. Lawful bases for processing

We process your Personal Data under one or more of the following lawful bases:

5.1 Contract (Article 6(1)(b))

to meet our contractual obligations to client airlines; and

to take steps at your request prior to entering a contract (e.g., helping you apply for roles).

5.2 Consent (Article 6(1)(a))

We rely on consent where required, for example:

• introducing you to a client airline;
• sharing your Personal Data or documents with a client airline;
• conducting reference checks;
• specific communications you opt into.

You may withdraw consent at any time (see Section 12).

5.3 Legitimate interests (Article 6(1)(f))

We may process Personal Data where necessary for our legitimate interests, such as:

• running and promoting our recruitment services;
• maintaining processing records for compliance;
• addressing enquiries and legal claims;
• safeguarding our reputation;
• maintaining secure system backups;
• evaluating service quality and compliance.

We only rely on this basis where your rights do not override these interests.

5.4 Legal obligation (Article 6(1)(c))

Where we must process data to comply with applicable law or valid governmental/regulatory requests.

6. Cookies and analytics

Our website uses cookies to help us understand usage and improve performance. This includes Google Analytics first-party cookies and WordPress cookies used for basic site functionality and visitor preference tracking.

You can set your browser to refuse cookies before using our site. If you disable cookies, some parts of the website may not function as intended.

7. Sharing your Personal Data

We do not sell, broker, or rent your Personal Data. We only share it in the following circumstances:

7.1 Service providers (processors)

Third-party suppliers who support our operations (e.g., database software, website hosting, IT or system administration). They may access Personal Data only to perform services for us and must process it under contract and our instructions.

7.2 Client airlines (controllers)

We may share your Personal Data with airline clients to submit applications and represent your candidacy for specific roles. We will always seek your express consent before doing so.

7.3 Legal and regulatory disclosures

We may disclose Personal Data where required to comply with law, regulation, or valid governmental requests, or to protect rights, property, safety, or investigate fraud/security issues.

8. International transfers

We store and process Personal Data in Ireland and do not store data outside the European Economic Area (EEA).

If in future we transfer Personal Data outside the EEA, we will ensure appropriate safeguards are in place in line with GDPR (such as adequacy decisions or Standard Contractual Clauses).

9. Data security and storage

We hold data in Ireland using multiple servers and apply appropriate technical and organisational security measures, including access controls and secure backups, to protect Personal Data from loss, misuse, unauthorised access, or disclosure.

Where a Personal Data breach occurs that is likely to risk your rights and freedoms, we will notify you and the relevant supervisory authority where legally required.

10. How long we keep your Personal Data

We retain Personal Data only for as long as necessary for the purposes described above, including legal, regulatory, and contractual requirements. Our core retention periods are:

• CVs: up to age 70 (or for as long as aviation regulatory guidelines require);
• Application documents: 6 years after the relevant vacancy closes;
• Bank details (contractors): 6 years after the contract expires.

After these periods, Personal Data that is no longer needed is deleted securely.

11. Your rights

You have the following rights under data protection law, subject to certain conditions:

• Right of access – request a copy of the Personal Data we hold about you;
• Right to rectification – correct inaccurate or incomplete data;
• Right to erasure – request deletion where there is no lawful reason to keep processing;
• Right to restrict processing – ask us to limit how we use your data;
• Right to data portability – receive your data in a structured, commonly used format;
• Right to object – object to processing based on legitimate interests or for direct marketing;
• Right to object to automated decision-making/profiling – where applicable.

If we refuse a request, we will explain why and you may challenge that decision.

11.1 Identity verification

To protect your privacy, we may need to verify your identity before releasing Personal Data. We accept: national ID card, driving licence, passport, birth certificate, and a utility bill less than three months old.

11.2 How to exercise your rights

Contact us at:
Email: info@sgaviationservices.com
Tel: +353 1 908 1132
Post: SG Aviation Services Ltd., 20 Harcourt Street, Dublin 2, D02 H364, Ireland.

We will respond within one calendar month.

12. Right to withdraw consent

Where we rely on consent, you may withdraw it at any time by emailing us at info@sgaviationservices.com. Withdrawal will not affect processing already carried out on the basis of your prior consent.

13. Complaints

If you have a concern about our use of your Personal Data, please contact us first so we can try to resolve it. You may also complain to the Data Protection Commission (Ireland):

Data Protection Commission
Canal House, Station Road, Portarlington, Co. Laois, Ireland
Tel: +353 57 868 4800
Email: info@dataprotection.ie
Website: dataprotection.ie

14. Sale of Business

If we sell, transfer, or reorganise all or part of our business, assets, or operations, Personal Data held by us may be transferred as part of that transaction. In such circumstances, the relevant Personal Data would become the property of the buyer or successor organisation and may be used by them in accordance with this Privacy Notice (or a replacement notice communicated to you), and as permitted by applicable data protection law.

Where required, we will notify you of any change in data controller and any material changes to how your Personal Data will be used.

15. Updates to this notice

We may update this Privacy Notice from time to time. The latest version will always be posted on our website and will apply from the effective date shown at the top.