PRIVACY POLICY

This Hangar 51 website (www.hangar51.com) (the “Website“) is owned by International Consolidated Airlines Group, S.A. (“IAG“, the “Organiser”, “we” or “us“).

We are committed to respecting the privacy of users of the Website and applicants to the Hangar 51 Accelerator Programme, which is the name given to the business development and mentoring programme (the “Programme“) run by the Organiser.

This privacy policy explains how we use any personal data (“information“) we collect from you in connection with your use of the Website and any application you make to the Programme. It describes:

  • what information we collect about you;
  • how we use your information;
  • who we share your information with;
  • your rights regarding our use of your information;
  • how long we keep your information; and
  • how to contact us.

IAG is registered in Spain with company number M-492129, with its registered office address at El Caserio, Iberia Zona Industrial no2 (La Muñoza), Camino de la Muñoza, s/n 28042, Madrid, Spain, with a branch office at Waterside (Speedbird Way), Harmondsworth UB7 0GB, United Kingdom.

  1. APPLICABILITY OF THIS POLICY
    1. This policy applies to any person accessing the Website and to any person submitting an application to participate in the Programme. This policy does not apply to participation in the Programme itself, which is governed by separate terms which will be notified to you if you are invited to participate.
    2. Where you submit an application, this policy applies in addition to our application terms. The submission of an application is conditional upon you agreeing to the terms of this policy.
  2. WHAT INFORMATION DO WE COLLECT ABOUT YOU?
    1. We are committed to protecting your privacy, and will only use your personal information in accordance with applicable data protection legislation, including the EU General Data Protection Regulation (EU) 2016/679.
    2. In the course of using the Website, completing and submitting an application form and participating in the selection process you may provide us with personal information about you such as your name, address, date of birth, telephone numbers (including mobile number) and email addresses. We will also require and collect information on the nature of your business idea, product, past experience and qualifications, roles and responsibilities of team-members, company history and financials. This is information that we consider necessary or desirable so that we can properly consider your application. If you do not agree to us holding this information about you, please do not complete an application.
    3. In completing the application form or participating in the application process you may choose to provide further information about yourself, team members or other associated people. It is entirely your decision as to whether you provide this type of information to us and you should only provide this information if you are comfortable with us storing it and using it to process your application as described in this privacy policy.
  3. PERSONAL INFORMATION RELATING TO OTHER PEOPLE
    1. It is possible that during the application process, for example whilst completing the application form or participating in a pitch event, you may provide us with personal information relating to other individuals, such as team members or other people involved in your business or business idea.
    2. Where you do provide us with personal information relating to other people, it is essential that you:
      1. Inform those people that you will be providing their personal information to us;
      2. Provide them with a copy of these terms so that they are aware of how their personal information may be used and their rights in respect of it; and
      3. Obtain their written consent (for example by way of email) to you providing the information to us.
    3. You agree to indemnify us in respect of any loss, damages, claim, fine or penalty that we may suffer (including any associated costs or expenses that we incur) as a result of your failure to comply with paragraph 3.2.
  4. HOW DO WE USE YOUR INFORMATION?
    1. We may use your personal information for the purposes of:
      1. Responding to any enquiry that you submit to us (whether via the Website enquiry form or otherwise);
      2. Considering your application to participate in the Programme; and
      3. Making arrangements with you to attend and participate in a pitch event and/or the Programme.

      We will process such information in accordance with this policy because we need it to enter into and perform a contract with: (i) applicants who apply to participate in the Programme; and (ii) those applicants who are subsequently selected to participate in the Programme.

    2. We may also use your information for the purposes of:
      1. Ensuring that the Website is presented in the most effective manner for you and your computer;
      2. Notifying you about a change to the Website or the application process;
      3. Record-keeping and tracking your use of the Website through use of cookies and log files (see paragraphs 10 and 11 below); and
      4. Analysing our diversity data statistics and monitoring trends.

      We will process such information in accordance with this policy to pursue our legitimate interests, which include the efficient administration of the Programme.

    3. We may also contact you:
      1. To ask your consent for us to use your information to promote the Programme; and/or
      2. Regarding investment or commercial opportunities that we consider may be of interest to you; and/or
      3. To inform you about any of our future Programmes or events
  5. WHO DO WE SHARE YOUR INFORMATION WITH?
    1. We may share your personal information with the below categories of third parties:
      1. Other members of our group solely in connection with the operation of the Programme;
      2. Third party consultants in order to conduct due diligence on you and your business or business idea (and, where appropriate, on your team or company);
      3. Service providers in order to operate the Programme (e.g. the operator of the venue where a pitch event is held to make arrangements regarding your attendance or a creative agency involved in publicising the Programme);
      4. Regulators and public authorities but only to the extent required by law or regulation, court order, or if necessary to establish, exercise or defend our legal rights, including if we suspect fraud or attempted fraud; and
      5. Other third parties with your prior consent or if they are involved in a merger, de-merger or a sale which involves all or part of our business or assets.

      You can rest assured that any third party to whom we transfer your personal information will be under an obligation to protect the confidentiality and security of your personal information.

    2. We may also aggregate your information with information of other users and disclose such anonymised information to advertisers and other third parties for marketing and promotional purposes. However, we will never disclose your unanonymised/disaggregated information to advertisers and other third parties for marketing and promotional purposes without your express consent.
  6. TRANSFER OF YOUR PERSONAL INFORMATION OUTSIDE OF THE EUROPEAN ECONOMIC AREA (EEA)
    1. Some of the third parties (such as service providers) to whom we may transfer your personal data may be located outside of the EEA. In case we transfer any of your personal data to countries outside of the EEA which do not provide an adequate level of protection according to applicable data protection legislation we will always ensure that appropriate safeguards to protect your data are in place. In this respect we may, for example, rely on standard data protection clauses adopted by the European Commission.
  7. INCOMPLETE APPLICATIONS
    1. Our website offers you the opportunity to save incomplete applications prior to submission. It is important to be aware that where you save an incomplete application we can access that application and the information within it, even if you have not submitted it. It is therefore important that you do not save any information in the application form that you would not be comfortable with us seeing.
    2. If your application remains unsubmitted after the closing date we may nonetheless access your application and consider admitting it to the application process even though it was not submitted. By starting an application you agree to us doing this. If we do decide that we are prepared to consider accepting your application we will let you know, and you will then be able to decide whether you want to proceed with it.
  8. RETENTION OF YOUR PERSONAL INFORMATION
    1. Where you provide us with personal information during the course of your usage of the Website, in the application form or during the application process we may retain this information for future use, including:
      1. To speed up your future use of the Website and application form;
      2. For record keeping and compliance purposes; and/or
      3. For exercising our rights set out in the application terms.
    2. We only keep your information for as long as is reasonably necessary for the purposes set out in this privacy policy and to fulfil our legal obligations. We will securely erase your information in advance of these deadlines if we decide that we no longer need it.
  9. YOUR RIGHTS
    1. You have the following rights in accordance with applicable data protection law; however please note that some of the rights may only apply in certain circumstances:
      1. The right to ask for a copy of the information we hold about you at any time. Please contact us using the details in paragraph 16. In most cases there will be no charge but in certain circumstances, we may charge you a fee for this which shall not exceed £10.
      2. The right to update or amend the personal information we have collected about you if it is inaccurate or incomplete. Until the closing date you will be able to update information via the application form on the Hangar 51 website, so where this personal information changes you can update it yourself. Following closure of the application process, or if you are otherwise unable to do this, you can contact us using the details in paragraph 16;
      3. The right to object to certain uses of your personal information on grounds relating to your particular situation;
      4. The right to request the erasure of personal information that we hold on you. To make a request of this nature, please contact us, providing full details of the personal information you want to be erased and the reason(s) for your request. We will consider all requests upon receipt and confirm to you whether we are able to agree to your request. Please be aware that the erasure of personal information that we hold about you may affect our ability to provide the Website and/or process your application and in some cases our acceptance of an erasure request may require us to cease considering your application;
      5. The right to withdraw any consents you have provided in respect of our use of your information;
      6. The right to the return of information you have provided to us, to use for your own purposes (often called your right to data portability) where the processing is based on your consent or for the performance of a contract; and the processing is carried out by automated means; and
      7. The right to lodge a complaint with the relevant supervisory authority, which for the UK is the Information Commissioner’s Office (see paragraph 13.7). More information about these rights can be found at https://ico.org.uk/for-the-public/.
    2. If you want to withdraw your application at any time please contact us. Your withdrawal will result in the deletion of some of the personal information that we hold about you, but we may still retain some personal information, for example for record keeping purposes.
  10. COOKIES
    1. Certain parts of the Website use “cookies” to keep track of your visit and to help you navigate between sections. A cookie is a small data file that certain websites store in your device’s memory when you visit such websites. Cookies can contain information such as the pages you have visited. The only personal information a cookie contains is information that you have personally supplied.
    2. We may use cookies on the Website to enable us to deliver content that is specific to your interests and gives us an idea of which parts of the Website you are visiting and to recognise you when you return to the Website. Reading cookies does not give us access to other data in your device’s memory and the Website will not read cookies created by other websites that you have visited.
    3. You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. If, however, you select this setting you may be unable to access certain parts of the Website. Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies when you access the Website.
    4. Please note providers of third party content may also use cookies over which we have no control.
  11. LOG FILES
    1. In common with most websites, the Website logs various information about visitors,including internet protocol (IP) addresses, browser type, internet service provider(ISP) information, referring / exit pages and date / time stamp.
    2. We may use this information to analyse trends, administer the Website, track your movement around the Website and gather broad demographic information. However, we do not link this information to personally identifiable information.
  12. GOOGLE ANALYTICS
    1. Our website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google“). Google Analytics uses cookies (text files placed on your computer) to help the website operators analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of our website.
  13. RESPONSIBILITY FOR THIRD PARTY WEBSITES
    1. The Website may, from time to time, contain links to and from other websites. If you follow a link to any of these websites, please note that these websites may have their own privacy policies and that we do not accept any responsibility or liability for these policies or your use of those websites. Please check these policies before you submit any personal data to these websites.
  14. ISSUES AND COMPLAINTS
    1. If you have any concerns about how your personal information is being used, please contact us as described in paragraph 16. This includes situations where you want to exercise any of your rights set out in paragraph 9.
    2. If you make a complaint about our handling of your personal information, it will be dealt with in accordance with our complaints handling procedure.
    3. In the first instance your complaint will be reviewed by an employee of the Organiser within 28 days.
    4. If you are dissatisfied with the response to our initial review you may request that your complaint be escalated, in which case it will be passed to a senior person within the relevant business who will review your complaint and the initial response and provide a further response within 28 days of your request to escalate the matter.
    5. We will endeavour to provide a full response within the relevant review period. However, in some cases further investigation may be necessary in order to properly respond to your complaint.
    6. If we cannot provide a final response within the relevant review period then we will provide an initial response acknowledging your complaint, explaining the reason for the delay and giving an estimate as to when a full response can be provided, and will aim to provide that full response as soon as we reasonably can following the expiry of the relevant review period.
    7. If we are unable to resolve your complaint after you have escalated it to a senior person as described in paragraph 13.4 you may make a complaint to the Information Commissioner’s Office. Please see https://ico.org.uk/for-the-public/raising-concerns/for more information.
  15. CHANGES TO THE PRIVACY POLICY
    1. We reserve the right to alter this policy at any time. Such alterations will be posted on the Website by us.
    2. It is important that you read any alterations as and when they are posted on the Website by us and should you object to any alteration, please contact us as described in paragraph 16.
  16. CONTACTING US
    1. If you have a general query about this policy or the handling of your personal information, or if you have an issue regarding the use or retention of your personal information please contact us by email at: hangar51@iairgroup.com.
  17. FURTHER INFORMATION
    1. We hope that the contents of this policy address any queries that you may have about the personal information we may hold about you and how we may use it. However, if you do have any further queries, comments or requests, please contact us as described in paragraph 16 above.
    2. Whilst this policy sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at
      https://ico.org.uk/for-the-public/.