(The General Data Protection Regulation)


Scope and Purpose

This Policy hereby aims to determine and regulate the requirements, declare and notify the conditions which Empathy Aviation has to comply with in the conduct of processing the personal data obtained by Empathy Aviation Inc. and its staff, where obtained either directly or indirectly from legal, commercial or financial relations with natural or legal persons, under the scope of Data Protection Act 2018 of 24 May 2018.

Disclosure Obligation 

According to Data Protection Act 2018, which was signed on 24 May 2018 and came into force on 25 May 2018, the personal data of Empathy employees in addition to such data emerged upon their communication and interaction with natural and legal persons, which to be processed by Empathy Aviation, must be legally regulated due to the requirements and obligations imposed by the legislation.

All kinds of personal data (including personal data of special nature) that can be associated with a natural person in accordance with the provisions of the aforementioned law are considered as personal data within the scope of the DP Act 2018. These personal data are processed by the Empathy Aviation in the capacity of Data Specialist, with the methods detailed below and within the limits prescribed by the legislation.

“Processing of Personal Data” refers to all kinds of operations carried out on the data such as retrieval, recording, storing, retention, modification, reorganization, disclosure, transfer, takeover, rendering them obtainable, classification or prevention of their use, by non-automated means, provided that they are part of a fully or partially automated or any form of a data recording system.

Purpose of Personal Data Processing and Legal Basis

According to the legislation, personal data may be automatically or non-automatically obtained by Empathy Aviation electronically or physically in text or speech format for example, through registration for the platform, telephone, fax, e-mail, SMS and social media channels, mobile applications, including voice and video recording.

According to Data Protection Act 2018, when there is:

  1. Open consent of the data owner,
  2. Clearly envisaged in the law,
  3. Compulsory situation where the person cannot express their consent due to physical incapacity or whose consent is not legally valid or shall be for the protection of themselves or someone else’s life or body integrity,
  4. Where it is necessary to process personal data of the parties to the contract, provided that it is directly related to the establishment or execution of the contract approved and/or signed with Empathy Aviation,
  5. Where it is necessary for Empathy Aviation to fulfill its legal obligations,
  6. Where it is already publicized personally by the concerning person,
  7. Where it is necessary to process the data to establish, use or protect a right,
  8. Where data processing data is necessary for the legitimate interests of the Empathy Aviation provided that no damage is given to the fundamental rights and freedom of the person concerned,

and in addition;

  1. Open consent of the data owner,
  2. Other provisions stipulated by law,

mentioned personal data is processed according to the requirements and purposes of data processing.

Sharing and Transfer of The Personal Data

Upon the request by official organizations or institutions as a requirement of the legislation or as a requirement of Empathy Aviation activities and responsibilities, personal data belong to the concerning person is subject to be shared with or transferred to domestic / foreign solution partners, project partners, program and cooperation partners, supplier companies, institutions and organizations, independent auditors, banks and financial institutions and companies which Empathy Aviation has commercial, legal, and economical relations with, and other companies, organizations or individuals from which assistance and support is received, and consultancy firms such as lawyers, financial advisors, law, informatics, quality and financial consultants, provided that electronic and physical security measures are taken. Mentioned sharing and transfer conditions are also valid for overseas.

Empathy Aviation, can transfer, process and store the personal data of the person concerned, in storage means such as servers from where archiving, storage and information technology support is received, at hosting, software, cloud computing, and etc. companies located in Ireland or abroad, mainly in EU countries, the United States, Britain and other countries, by taking the necessary security measures.

Methods Of Collecting Personal Data

Personal data of the person concerned is collected as part of a fully or partially automated or any form of a data recording system and by means of all contracts / information forms and other documents signed by the approval and/or acceptance; approval, acceptance, and notifications by electronic signature and/or approval; the administrative center of the Empathy Aviation, physical environments, call centers, internet sites, mobile applications, internet operations, social media and other public areas, user interviews, scanning forensic records, market research, identity sharing system, SMS, digital applications made to web sites, mobile applications, written/ digital applications made to sales teams; call center methods in forms of verbal, written, video, audio recording or electronic media that can be referred or communicated in the future is stored in accordance with the relevant legislation as well as taking period of limitation into account.

Personal data collected by the company due to legal reasons mentioned above, can be processed or transferred in line with the previously described purposes of this policy, also taking the personal data processing conditions specified in Protection of Personal Data article in the Data Protection Act 2018 into account.

User Rights

In addition to other rights given by the legislation, relevant person has the following rights concerning his/her personal data upon contact via given e-mail of The Empathy Aviation:

  1. To learn if the data is processed,
  2. To demand information if the data is processed,
  3. To learn the purpose of processing and whether the usage fits the purpose
  4. To learn the 3rd persons either domestic or international whom the data is transferred.
  5. To request correction if data is processed as incomplete or incorrect,
  6. To request the deletion, destruction or anonymization of the personal data in case of the conditions requiring the processing of personal data are no longer
  7. To request notification of the transactions made in accordance with the above-mentioned DP Act 2018 against the third persons to whom they are transferred.
  8. To object to the emergence of an unfavorable result due to analysis held exclusively by automatic systems,
  9. To claim compensation for the losses in case of unlawful processing,

Applicable Data Protection Officer Under The Law

“Data Protection Officer” is the contact person of Empathy Aviation and registered at

The relevant persons can submit their requests, complaints and suggestions under the above mentioned rights to the below mentioned address of the Empathy Aviation either personally or through the notary public or to the e-mail below using the email they have registered on the website upon signing up for the account.

Name, surname, identification number, place of residence or place of business subject to notice, mobile phone number, e-mail address and the subject of the request are mandatory to be presented in the application as well as the information and documents related to the request must be added to the application.

The official language is English in correspondence with Empathy Aviation. It is essential that all kinds of applications, correspondences, complaints and suggestions to be written in English.

Wet signature is required for the physically submitted written applications.

As a rule, responses to the requests, inquiries, suggestions and complaints are not charged. However, if there would be an expense, fee or other costs derived from responses to be given, Empathy Aviation reserves the right to demand the fees in the tariffs determined by the GDP Regulations or other authorities. For more detailed information or for any inquiries, requests, suggestions or complaints regarding the GDP Policy, please contact us at

For your physical and written applications:

Empathy Aviation

Office 21, Link Corridor, Terminal 1,

Dublin Airport, Swords, Co.

Dublin K67KD58

Empathy Aviation