These Terms are effective as of 01 July 2025 (Version 1.0)


PRIVACY POLICY AND COOKIE USAGE POLICY

1. GENERAL PROVISIONS
1.1 About This Policy
This Privacy Policy and Cookie Usage Policy (the "Policy") establishes the rules, principles, and procedures for the collection, processing, use, transfer, storage, and protection of personal data when using the interactive media kit of the SkyStream platform.
This Policy has been developed in accordance with the requirements of the legislation of the Republic of Kazakhstan on personal data and their protection, as well as taking into account international best practices and standards, including but not limited to the General Data Protection Regulation (GDPR), to the extent that they do not conflict with applicable national legislation.
1.2 Scope of Application
This Policy applies to all individuals who interact with the SkyStream platform media kit, including but not limited to potential advertisers, company representatives, and other interested parties.
1.3 Data Processing Entities
Data Controller: Aviasoft Inc., a corporation organized and existing under the laws of the United States of America, with its principal place of business at 16192 Coastal Highway, Lewes, DE 19958, United States of America.
Data Processor: "In-Flight Commerce and Entertainment" LLP (ICE), Republic of Kazakhstan, acting as the authorized data processor and local representative of the Controller within the territory of the Republic of Kazakhstan.

2. CONSENT TO DATA PROCESSING
By clicking the "Download" button when completing the media kit form, you provide your voluntary, informed, and unambiguous consent to:
  • Processing of personal data in accordance with this Policy;
  • Cross-border transfer of data for technical service provision;
  • Use of cookies and similar technologies.
The fact of consent is automatically recorded with the logging of IP address, date, time, and Policy version number.

3. CATEGORIES OF PERSONAL DATA PROCESSED
3.1 Data Provided During Form Completion:
  • Name
  • Company name
  • Email address
  • Description of business case or interest
3.2 Technical Data Collected Automatically:
  • Device IP address
  • Date and time of interaction
  • Browser and operating system information
  • Session identifier
3.3 Derivative Data:
In the course of business relationships, additional data categories may be formed, including: correspondence history, preferences, negotiation status, and information about commercial proposals.

4. PURPOSES OF PERSONAL DATA PROCESSING
Personal data is processed for the following purposes:
4.1 Commercial Purposes:
  • Processing requests for media kit access
  • Establishing business contacts and conducting negotiations
  • Preparing individualized commercial proposals
  • Providing consultations on SkyStream platform capabilities
4.2 Marketing Communications:
  • Distribution of informational materials about the platform and new opportunities
  • Sharing examples of successful case studies and advertising campaigns
  • Personalized offers based on expressed interests
4.3 Administrative Purposes:
  • Maintaining client database
  • Analyzing marketing activity effectiveness
  • Compliance with legal requirements
  • Protection of the company's legitimate interests

5. DISCLOSURE OF PERSONAL DATA
5.1 Intra-Corporate Transfers:
Data is transferred between Aviasoft Inc. and ICE LLP, as well as to authorized employees for the purposes specified in Section 4.
5.2 Transfers to Business Partners:
When necessary to address specific inquiries, contact data may be transferred to:
  • Partner airlines for discussing specialized advertising formats
  • Onboard service providers for comprehensive solutions
5.3 Technical Service Providers:
For technical support, data may be transferred to:
  • Customer Relationship Management (CRM) systems
  • Email and marketing distribution services
  • Cloud platforms for corporate document management
5.4 Restrictions:
Personal data is NOT transferred for commercial sale, to third parties for their own marketing purposes, or without ensuring an appropriate level of data protection.

6. CROSS-BORDER DATA TRANSFERS
Due to the international nature of our operations, personal data may be processed in various jurisdictions:
6.1 Republic of Kazakhstan: Processing by local representative, maintenance of local client database, communication with data subjects.
6.2 Other Jurisdictions: Processing by the Controller, use of international technical services, corporate systems.
Legal Safeguards: Cross-border transfers are conducted based on the data subject's consent with the application of encryption, secure communication channels, and data processing agreements with recipients.

7. COOKIES AND SIMILAR TECHNOLOGIES
7.1 What are Cookies:
Cookies are small text files stored in your browser when visiting websites to enhance functionality and analyze usage patterns.
7.2 Types of Cookies Used:
  • Essential Cookies: Ensure basic form functionality and security
  • Analytics Cookies: Help understand how visitors interact with the media kit
  • Functional Cookies: Remember preferences to improve user experience
7.3 Cookie Management:
You can manage cookie settings through your browser:
  • Chrome: Settings → Privacy and Security → Cookies
  • Firefox: Settings → Privacy & Security → Cookies
  • Safari: Preferences → Privacy → Cookies
Disabling certain cookies may affect the functionality of the media kit.

8. DATA RETENTION PERIODS
8.1 Active Negotiations: Until completion of the negotiation process or 30 days of inactivity.
8.2 Marketing Database: Until unsubscription from mailings or 12 months from the last interaction.
8.3 Client Data: Throughout the entire duration of contractual relationships plus 5 years after termination for warranty obligations.
8.4 Opted-Out Subjects: 3 years in "blacklist" to prevent repeated solicitations.
8.5 Technical Data: 2 years for proof of consent and security assurance.

9. SECURITY MEASURES
9.1 Technical Measures:
  • Data encryption during transmission (TLS 1.2+)
  • Two-factor authentication for system access
  • Regular protected backup procedures
  • Security monitoring and operation logging
9.2 Organizational Measures:
  • Access restriction to authorized personnel only
  • Staff training on data protection principles
  • Confidentiality agreements with employees
  • Regular security audits

10. DATA SUBJECT RIGHTS
Data subjects have rights provided under the legislation of the Republic of Kazakhstan and international standards, including:
10.1 Fundamental Rights:
  • Access to information about processing of personal data
  • Rectification of inaccurate or incomplete data
  • Erasure of data where legally justified
  • Restriction of processing in prescribed circumstances
  • Withdrawal of consent for data processing
10.2 Exercising Rights:
  • Contact: hello@aviasoft.us
  • Response Time: 30 calendar days
  • Free of charge (except for repeated requests for identical information)
10.3 Procedure:
To exercise rights, submit a written request specifying:
  • Full name and contact details
  • Nature of the request
  • Identity verification documents (if necessary)

11. POLICY AMENDMENTS
11.1 Grounds for Amendments:
  • Changes in legislation
  • Technological developments
  • Changes in business processes
11.2 Notification:
We notify about material changes through:
  • Publication on website
  • Email distribution to active contacts
  • Media kit interface
11.3 Effective Date:
  • Non-material changes: immediately
  • Material changes: 30 days after notification

12. CONTACT INFORMATION
12.1 For Data Subject Inquiries:
  • Email: hello@aviasoft.us
  • Controller: Aviasoft Inc., 16192 Coastal Highway, Lewes, DE 19958, USA
  • Local Representative: ICE LLP, Republic of Kazakhstan
12.2 Processing Times:
  • Business days: Monday through Friday
  • Response time: up to 30 calendar days
  • Receipt confirmation: within 3 business days

13. FINAL PROVISIONS
13.1 Policy Effectiveness:
This Policy remains effective from the date of publication on the website until revocation or replacement with a new version.
13.2 Governing Law:
This Policy is governed by the laws of the Republic of Kazakhstan. Disputes are subject to pre-litigation settlement procedures, and if unsuccessful, to resolution in the courts of the Republic of Kazakhstan.
13.3 Consent Confirmation:
By clicking the "Download" button when completing the media kit form, you confirm that you:
  • Have read this Policy in its entirety
  • Understand the legal consequences of processing your personal data
  • Voluntarily consent to personal data processing and cookie usage
  • Confirm the accuracy of the information provided
LANGUAGE VERSION NOTICE:
In the event of any discrepancy between the English, Russian, and Kazakh language versions of this Policy, the English version shall take precedence and prevail.

This Policy is a public document. The current version is published on the official website of the SkyStream platform.
Last Updated: July 1, 2025
Document Version: 1.0
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