Privacy Policy
Last updated: 14 July 2026
This Privacy Policy explains how PMT Group ("PMT", "we", "us") collects, uses, shares, and protects personal data when you visit our website, contact us, or work with us as a trade partner. We process personal data in accordance with the EU General Data Protection Regulation (GDPR) and the applicable data protection laws of the Republic of Serbia.
1. Who we are (data controller)
PMT Group is a General Sales Agent (GSA) representing flydubai and Emirates across twelve markets in Southeast and Eastern Europe. For the purposes of the GDPR, PMT Group is the controller of the personal data described in this policy.
2. What personal data we collect
Data you give us
- Contact details — name, business email address, phone number, company name, and job title when you email us, request a partnership, or otherwise get in touch.
- Business relationship data — information exchanged in the course of a trade or agency relationship, such as agency identifiers (e.g. IATA codes), booking-related correspondence, and contract details.
- Correspondence — the content of messages you send us.
Data collected automatically
- Usage and log data — IP address, browser type and version, device type, operating system, referring pages, pages visited, and the date and time of access.
- Cookies and similar technologies — see section 5 below.
We do not knowingly collect special categories of personal data (such as health or biometric data), and we ask that you do not send us such data.
3. Why we process your data and on what legal basis
- To respond to your enquiries — legal basis: our legitimate interest in communicating with prospective partners (Art. 6(1)(f) GDPR), or steps taken at your request prior to entering into a contract (Art. 6(1)(b)).
- To manage trade and agency relationships — legal basis: performance of a contract (Art. 6(1)(b)) and our legitimate interest in operating our GSA business (Art. 6(1)(f)).
- To operate, secure, and improve our website — legal basis: our legitimate interest in maintaining a functional and secure website (Art. 6(1)(f)).
- To send trade communications and updates — legal basis: your consent (Art. 6(1)(a)), which you may withdraw at any time.
- To comply with legal obligations — such as tax, accounting, and aviation-industry requirements (Art. 6(1)(c)).
4. Who we share data with
We do not sell personal data. We share personal data only where necessary, with:
- Our airline principals — flydubai and Emirates, where required to deliver GSA services (for example, processing trade bookings, incentive programmes, or escalations).
- Service providers — IT, hosting, email, and analytics providers who process data on our behalf under data processing agreements (Art. 28 GDPR).
- Authorities — where disclosure is required by law, regulation, or a valid legal request.
5. Cookies
Our website uses the cookies and similar technologies necessary for it to function, plus — with your consent — Google Analytics 4 cookies that help us understand how the site is used (provided by Google Ireland Ltd. / Google LLC). Analytics cookies are set only after you accept them in our cookie banner; IP addresses are anonymised.
You can withdraw or change your choice at any time via the "Cookie settings" link in the footer, or configure your browser to refuse cookies entirely; core parts of the site will continue to work. For more on how Google processes data, see Google's privacy documentation.
6. International data transfers
PMT Group is based in Serbia, and our airline principals are based in the United Arab Emirates. Where personal data originating in the EU/EEA is transferred to countries that the European Commission has not deemed to provide an adequate level of protection, we rely on appropriate safeguards under Chapter V of the GDPR — in particular the European Commission's Standard Contractual Clauses — together with supplementary technical and organisational measures where needed. You may request a copy of the relevant safeguards using the contact details above.
7. How long we keep data
- Enquiries — up to 24 months after our last exchange, unless a business relationship follows.
- Trade and contract records — for the duration of the relationship and thereafter as required by statutory retention periods (typically 5–10 years for accounting and tax records).
- Website logs — typically no longer than 12 months.
When data is no longer needed, we delete or irreversibly anonymise it.
8. Your rights
Under the GDPR (and, where applicable, Serbian data protection law), you have the right to:
- Access your personal data and receive a copy (Art. 15);
- Rectify inaccurate or incomplete data (Art. 16);
- Erase your data in certain circumstances (Art. 17);
- Restrict processing in certain circumstances (Art. 18);
- Data portability — receive data you provided in a structured, commonly used, machine-readable format (Art. 20);
- Object to processing based on legitimate interests, and to direct marketing at any time (Art. 21);
- Withdraw consent at any time, without affecting the lawfulness of processing before withdrawal (Art. 7(3)).
To exercise any of these rights, contact us at Serbia@flydubai.com. We will respond within one month, as required by Art. 12 GDPR. We may need to verify your identity before acting on a request.
You also have the right to lodge a complaint with a supervisory authority — in the EU, the data protection authority of your member state of residence or workplace; in Serbia, the Commissioner for Information of Public Importance and Personal Data Protection.
9. Security
We apply appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or destruction — including access controls, encryption in transit, and staff confidentiality obligations. No method of transmission or storage is completely secure, but we work to protect your data in line with industry practice and Art. 32 GDPR.
10. Children
Our website and services are directed at businesses and the travel trade. We do not knowingly collect personal data from children under 16. If you believe a child has provided us personal data, please contact us and we will delete it.
11. Changes to this policy
We may update this Privacy Policy from time to time. The "Last updated" date at the top shows the current version. Material changes will be highlighted on this page, and — where we hold your contact details and the change significantly affects you — communicated directly.
12. Contact
Questions, requests, or concerns about this policy or our handling of personal data can be sent to:
This policy is provided as a template for PMT Group's website and should be reviewed by qualified legal counsel before publication — in particular the sections on international transfers, retention periods, and any cookie/analytics tooling actually deployed.