Privacy Policy

Date of Last Revision: August 5, 2022

WHO ARE WE AND HOW YOU CAN CONTACT US

Contact details of the Data Controller: UAB Aeroclass, number of legal entity 305623132, address Dariaus ir Girėno g. 21A, LT-02189 Vilnius, Lithuania, e-mail address [email protected] (hereinafter “We”, “Ours”, “Company”) processes the Personal Data of the users of it’s services, visitors of managed website www.aeroclass.org, individuals who have been active on it’s social media accounts, persons who have agreed to receive it’s marketing messages  (hereinafter – you, your)  in accordance with the provisions of the legal acts regulating the legal protection of Personal Data and applying the highest technical and legal standards of protection and taking all necessary measures to prevent possible breaches of Personal Data protection. This Privacy Policy (hereinafter referred to as the “Privacy Policy“) sets out the basic rules for the collection, processing and storage of your Personal Data and other information related to you, the scope, purposes, sources, recipients of your Personal Data and your rights as a personal data subject and other important aspects of your use of services provided by the Company. This information is important, so we hope you will read it carefully.

As used in this Privacy Policy, the term “personal data” (the “Personal Data”) means any information about you relating to you as a natural person, a data subject whose identity is known or can be directly or indirectly identified through the use of certain data (e.g. name, surname, personal identification number, address, telephone number, etc.).

In processing the Personal Data, we responsibly comply to the regulation No 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”), the Republic of Lithuania Law on the Legal Protection of Personal Data, the Republic of Lithuania Law on Electronic Communications and other directly applicable legal acts regulating the protection of Personal Data, as well as instructions from competent authorities.

In the event that you provide us with personal information other than your own (for example, identifying another person as a beneficiary), please inform them of this Privacy Policy and its contents.

If the user of the services is a legal entity, this Privacy Policy applies to natural persons whose Personal Data is transferred to us by a legal entity. The user must duly comply with Art. 14 of the GDPR. to inform data subjects (managers, beneficiaries, representatives, etc.) about the transfer of their Personal Data to the Company.

If you have any questions regarding this Privacy Policy or requests regarding the processing of your Personal Data, please contact us by email: [email protected].

By visiting the Company’s websites and / or using the information contained therein and / or our services, you acknowledge and confirm that you have read and understood this Privacy Policy.

TO WHOM THE PRIVACY POLICY APPLIES

This Privacy Policy applies to Company’s Website www.aeroclass.org  and any service provided by the Company or other activities of the Company where Personal Data is being processed.

The terms and conditions of the Privacy Policy apply to you every time you access the content and/or the service we provide, regardless of which device (computer, cell phone, tablet, TV, etc.) you are using.

This Privacy Policy does not apply to links to other entities websites provided on our websites; therefore, we recommend that you read the Personal Data processing rules applied on such websites.

WHAT PRINCIPLES DO WE COMPLY WITH?

When processing your Personal Data, we:

  • comply with current and applicable legislation, including the GDPR;
  • we will process your Personal Data in a lawful, fair and transparent manner;
  • we will collect your Personal Data for specified, clearly defined and legitimate purposes and will not continue to process it in a way incompatible with those purposes, except to the extent permitted by law;
  • take all reasonable steps to ensure that Personal Data which are inaccurate or incomplete, having regard to the purposes for which they are processed, are rectified, supplemented, suspended or destroyed without delay;
  • we will keep them in such a form that your identity can be established for no longer than is necessary for the purposes for which the Personal Data are processed;
  • we will not disclose or disclose Personal Data to third parties except as provided in the Privacy Policy or applicable law;
  • ensure that your Personal Data is processed in such a way as to ensure the appropriate security of Personal Data through appropriate technical or organizational measures, including protection against unauthorized or unlawful processing of Personal Data and against unintentional loss, destruction or damage. Contact details of our Data Protection Officer: [email protected].

WHAT PERSONAL DATA, FOR WHAT PURPOSE AND BASIS DO WE PROCESS

The purpose of the processing of personal data. Why we process personal data?The categories of processed personal data. What kind of categories of personal data we process?On what legal basis do we process personal data?The period of processing
Administration of our WebsiteWhen you visit our Website, data about your browsing on the Website is collected using cookies. We use necessary / technical cookies to ensure the proper functioning of the Website and / or other third-party cookies in order to improve your browsing experience (i.e. to consider your needs, to continuously improve the website and to make offers that suit your interests).Data using cookies and similar technologies related to Internet browsing, etc. are collected (processed) in accordance with Article 6 Part 1. a) of the GDPR, i. e. with your consent (except for necessary cookies).You can find more information about cookies and their storage terms in the Cookies Policy on our Website.
Responding to your general enquiriesOur Website provides contacts where you can contact us to consult us on issues that concern you. We will accept, review and respond to all your messages. If you contact us by e-mail, regular mail or using the contact form function on our Website, we will process the following Personal Data of yours: your name, surname, e-mail, postal address and the text of the correspondence and / or attached documents. This data will be processed for the administration of your enquiry. Please note that we may need to contact you by mail, email, so be sure to notify us of any changes to your Personal Data.All Personal Data you provide when communicating with us is used only for the above purposes and to view messages and to administer (manage) communication flows and provide you with a response. We will process the said Personal Data in accordance with Article 6 Part 1. a) of the GDPR, i. e. with your consent, which you express by contacting us by e-mail, mail or contact form on our Website.Communication with you will be handled until the enquiry is fully processed and stored for 3 months from the date of the last communication with you.  
Administration of your account on the Website and providing you the servicesUsing of services provided by the Company via Website requires you to create a personal account. For this reason, we may ask you to provide us with the Personal Data to be used to contact or identify you: your name, surname, e-mail. After taking you online courses, we issue the certificates and store information of your taken course’s history.To manage your registration as a user of the Website, we will process all Personal Data you provide only for the above purposes. We will process the said Personal Data in accordance with Article 6 Part 1. a) of the GDPR, i. e. with your consent, which you express by registering your account on the Website; and b) in order to conclude and / or perform a contract concluded with the data subject. Terms of Use of our Website is considered to be a contract in a meaning of this Privacy Policy To administer your account, provide and maintain our service on the Website to you as a registered user, including to monitor the usage of our service, your Personal Data is processed in accordance with Article 6 Part 1. b) of the GDPR, i. e. in order to conclude and / or perform a contract concluded with the data subject; and f), i. e. our legitimate interest to keep our services up-to-date, safe and free of errors, including implementation of new features and versions.We will delete your account and certificates issued to you on our Website after 3 years when your account becomes inactive.
Selling you coursesIf you decide to purchase our courses, we will ask you to provide us with your personal details. Such Personal Data includes the buyer’s name, surname, email, residence country and payment details that we must collect in order to enter into a contract with you and sell you courses. We will use this information to manage and administer the purchasing process (your subscription plan and virtual credits) and our relationship with you, for example by contacting you by email / phone and notifying you about upcoming courses. Your name, surname, bank account details (when paying via wire transfer), country of residence (when applying value added tax) are processed for this purpose.

We process:

1. Your name, surname, bank account details (when paying via wire transfer);

2. Your name, surname, last 4 digits of your Credit Card, expiry date, type of Your Credit Card, location email, IP address address, (when you pay with Credit Card);

3. Additionally your country of residence (when applying value added tax).		We will process this Personal Data of yours in accordance with Article 6 Part 1. b) of the GDPR, i. e. to conclude a contract with you and perform it, as well as Article 6 Part 1. c) of the GDPR., i. e. we are subject to a legal obligation to keep contracts and accounting documents and Article 6 Part 1. f) of the GDPR, i. e. our legitimate interest in asserting and / or defending our legal claims (where applicable).  Contracts and accounting documents (in physical and electronic form) are kept for 10 years from the date of full performance of the contract.
Providing you with news, promotions and information (direct marketing)If you agree to subscribe or otherwise receive our newsletter, we will use your email address for general and / or individual marketing (e.g. about goods, services, discounts, offers, competitions, events, news, surveys and other news) and we will contact you for these purposes. The information collected will only be used for direct marketing. When submitting joint marketing offers, you will be sent general information that we will share with all our customers.Personal Data for direct marketing is processed in accordance with Article 6 Part 1. a) of the GDPR, i. e. with your consent or Article 6 Part 1. f) of the GDPR, i. e. our legitimate interest to offer you a similar goods/services to ones you have purchased from us and to get your feedback about purchased goods/services.We w     Your data will be used for direct marketing purposes for 3 years after your consent is obtained or until you withdraw your consent. We consider you to be our customer: 
– 3 years after your order or purchase of our product or service.  
Selection of candidates for employeesWe process name, surname, e-mail address, telephone number, education, additional qualifications, work experience and other information voluntary provided by the candidateCollection and use of data are based on your consent Article 6 Part 1. a) of the GDPRWe will process Personal data 3 months or until withdrawal of candidate’s consent
Drawing up and executing contracts for the purchase and sale of servicesWe may process name, surname, contact information, position, signature, other information required for negotiations, concluding and performing of contracts.  We will process this Personal Data of yours in accordance with Article 6 Part 1. b) of the GDPR, i. e. to conclude a contract with you and perform it, as well as Article 6 Part 1. c) of the GDPR., i. e. we are subject to a legal obligation to keep contracts and accounting documents and Article 6 Part 1. f) of the GDPR, i. e. our legitimate interest in asserting and / or defending our legal claims (where applicable).We will process the Personal Data collected for this purpose for 10 years.
Drawing up and executing contracts with InstructorsWe may process name, surname, contact information, signature, work experience, payment details.We will process this Personal Data of yours in accordance with Article 6 Part 1. b) of the GDPR, i. e. to conclude a contract with you and perform it, as well as Article 6 Part 1. c) of the GDPR., i. e. we are subject to a legal obligation to keep contracts and accounting documents and Article 6 Part 1. f) of the GDPR, i. e. our legitimate interest in asserting and / or defending our legal claims (where applicable).  Contracts and accounting documents (in physical and electronic form) are kept for 10 years from the date of full performance of the contract.
 Legal duty to ensure adherence to KYC proceduresWe process the following personal data: full names, date of births, other identification details (citizenship, copies of passport/ ID, proof of living address, bank information, contact details, source of wealth/ funds) of the members of the Board of Directors, directors and secretaries (e.g., CEO, COO, CFO, Deputies, Heads of departments), persons assigned to represent the Party, shareholders with more than 25 % ownership and ultimate beneficial owners.  Personal Data for Client Verification and Onboarding Procedure is processed in accordance with Article 6 Part 1. f) of the GDPR, i. e. our legitimate interest to fulfill the requirements for money laundering and financing terrorism prevention, prevention of corruption, bribery and fraud, international, US, UK sanctions (restrictions), to verify the liability of the partiesWe will process the Personal Data collected for this purpose for 5 years.

If you do not provide Personal Data, the provision of which to the Company is necessary to ensure compliance with the requirements of legal acts and / or the conclusion and / or performance of the contract, we will not be able to provide you with services or conclude another transaction.

DIRECT MARKETING

For direct marketing purpose, we process your Personal Data in the following cases:

  • when we obtain your explicit consent to such processing;
  • when you are a customer of us who have not objected to the processing of Personal Data for the purpose of direct marketing, marketing of similar services or products.

For direct marketing purpose, we process your Personal Data which is described in part “WHAT PERSONAL DATA, FOR WHAT PURPOSE AND BASIS DO WE PROCESS” of this Privacy Policy.

With you expressed consent to receive direct marketing messages or newsletters you subscribe, you agree to receive our news about new services, products, invitations to events etc.

We inform you that Visitors may at any time refuse our newsletters or other promotional messages by clicking on a link to this in our outgoing newsletters and/or messages.

HOW WE PROCESS YOUR PERSONAL DATA

Our use of your Personal Data will always have a lawful basis. Most commonly, we use your Personal Data:

  • Where we need to conclude any contract and/or perform any contract we have entered into with you (for example, to comply with the Terms and Conditions which you agree with when you create your account on our Website and start using our services and/ or to comply with our contract to provide services to you, your academic institution, your employer, or other organization that may be providing you with access to our services);
  • Where we need to comply with a legal obligation (for example, when performing accounting, archiving, data breach notification processes);
  • Where we have your consent (for example, in cases when you agree to receive our newsletters);
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interest. “Legitimate interest” means our interest to enhance our services, products, to manage the processes of businesses and activities. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. The legitimate interests that we pursue include:
  • provision of marketing offers of our similar services or products; 
  • presentation of our services on social networks, submission of answers to your queries or messages on social networks, analysis of our accessibility on social networks; 
  • provision of information to your request, responds to your queries; 
  • establishment, exercise or defense of legal claims; 
  • analysis, expansion and improvement of our services, customer service quality assurance and compilation of statistics and analysis related with it; 
  • protection of information related to the provision of our services, improvement, development and maintenance of the security of IT systems. 

HOW LONG WE WILL RETAIN YOUR PERSONAL DATA

We will retain your Personal Data for as long as necessary to achieve and fulfil the purposes set out in this Privacy Policy, considering the nature of the services provided to you and the contracts you enter into, unless longer storage of Personal Data and related documents is required by applicable laws and regulations or is required for the defense of the Data Controller’s legitimate interests in judicial, other public institutions etc.

We ensure and take all necessary measures to avoid storing outdated or unnecessary Personal Data about you and to keep your Personal Data up-to-date and accurate. You may find retention periods of your Personal Data in part “WHAT PERSONAL DATA, FOR WHAT PURPOSE AND BASIS DO WE PROCESS” of this Privacy Policy.

HOW DO WE PROTECT YOUR DATA?

We responsibly implement appropriate organisational and technical Personal Data security measures intended for the protection of the Personal Data against accidental or unlawful destruction, alteration and disclosure as well as against any other unlawful processing. The security measures we implement include the protection of personnel, information, IT infrastructure, internal and public networks as well as office buildings and technical equipment.

In the event of Personal Data breach of security that could seriously jeopardise your rights or freedoms and determine the circumstances with which unauthorised access to Personal Data has been obtained, we will immediately inform you about it.

TO WHOM IS YOUR DATA ARE DISCLOSED

We may share some of your personal data with the following categories of third parties:

  • any Avia Solutions Group[i] company (listed at https://aviasg.com/en/the-group/general-contacts) for the purposes set out in this Privacy Policy (for example, for the purposes of performance of contracts and the management of relationship with customer);representatives acting on our behalf with respect to the promotion of our services in particular territories;
  • companies providing data centers, hosting, cloud, site administration and related services, software developers, providing, maintaining and developing companies, companies providing information technology infrastructure services, companies providing communication services;
  • credit and debit card companies used to facilitate payment transactions related to the provision of our services, banks and other credit and/or payment companies;
  • our professional advisors, auditors, lawyers and/or financial advisers;
  • our other service providers (data processors) or our subcontractors;
  • notaries, if the contract concluded with you requires a notarial form;
  • judicial officers, entities providing legal s and/or debt recoveries services, subrogator of claim right;
  • companies providing advertising and marketing services;
  • companies providing archiving, physical and / or electronic security, asset management and/or other business services;
  • in accordance with the laws to state institutions, establishments, etc.;
  • law enforcement authorities at their request or on our own initiative if there is a suspicion that a criminal offense has been committed, as well as courts and other dispute resolution bodies; tax administrators
  • in the event of a company restructuring, transfer / acquisition and / or business transfer / acquisition, to a third party acquiring the business and processing Personal Data for the same purposes as specified in this Privacy Policy and/or doing the Due Diligence by our and/or their legal and/or financial advisors, etc.

DATA TRANSFER OUTSIDE THE EUROPEAN ECONOMIC AREA

As a general rule, your Personal Data will be processed in the countries of the European Economic Area (hereinafter – EEA). However, in certain cases, your Personal Data may be transferred to non-EEA countries. Please note that in non-EEA states, Personal Data may be subject to less protection than within the EEA, but we carefully evaluate the conditions under which such data will be processed and stored after being transferred to the above-mentioned entities.

Please note that if the European Commission has determined that the third country, territory or one or more specified sectors in that third country or international organization concerned provides an adequate level of Personal Data protection, the transfer must take place in the same manner as in the EEA. Please be informed that you can have access to the information as to the states in respect of which the decision of the European Commission has been taken, here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.

In other cases, we take all necessary measures to ensure that your Personal Data is transferred to the recipient safely processing the data. The tools we use: a contract with a non-European recipient of Personal Data includes specific clauses for the secure processing of the data. In certain cases, we ask for your consent to transfer your data outside the Republic of Lithuania or the EEA.

DO WE APPLY AUTOMATED DECISION-MAKING OR PROFILING?

We do not normally use automated decision-making under Article 22 of the GDPR to initiate and execute contractual relationships. Should we apply this procedure in individual cases, we will inform you separately, if required by law.

We process your Personal Data in a partially automated way in order to assess certain personal aspects (hereinafter – Profiling). We use profiling, for example, when we are required by law to prevent money laundering or manage financial risk.

RIGHTS GUARANTEED TO YOU

We guarantee the implementation of these rights and the provision of any related information at your request or in case of your query:

  • know (be informed) about the processing of your Personal Data;
  • to get access to your Personal Data which are processed by the Data Controller;
  • request correction or addition, adjustment of your inaccurate, incomplete Personal Data;
  • require the destruction of Personal Data when they are no longer necessary for the purposes for which they were collected;
  • request the destruction of Personal Data if they are processed illegally or when you withdraw your consent to the processing of Personal Data or do not give such consent, when is necessary;
  • disagree with the processing of Personal Data or withdraw the previously agreed consent;
  • request to provide, if technically possible, the provision of your Personal Data in an easily readable format according to your consent or for the purpose of performing the contract, or request the transfer of data to another data controller.

In order to exercise your rights, please send us the request by e-mail [email protected] or directly coming to the Company by address Dariaus ir Girėno str. 21A, LT-02189 Vilnius, Lithuania.

Upon receipt of your request, we may ask you to provide proof of your identity or other identifying information to ensure that we are exercising your rights as a data subject and to prevent unauthorized disclosure of Personal Data or information to others who are not entitled to it. If we are unable to identify you, we will not be able to exercise your rights as a data subject.

We provide information about the processing of your Personal Data free of charge. If your request is unfounded, repetitive or disproportionate, we may charge a fee commensurate with our administrative costs.

Upon receipt of your request, we will respond to you within 30 calendar days of receipt of your claim and the due date for submission of all documents necessary to prepare the answer.

In exceptional circumstances, which may require us to have additional time, the deadline for replying may be extended for a further two months, depending on the complexity of the situation. In this case, it is mandatory to inform the Data Subject in writing about such extension within 1 (one) month from the receipt of the request and indicate the reasons for the delay. If we think we need to, we will stop the processing your Personal Data, except for storage, until your application is resolved. If you have legally waived your consent, we will immediately terminate the processing of your Personal Data and within no more than 30 calendar days, except in the cases provided for in this Privacy Policy and in the cases provided for by law when further processing of your Personal Data is binding on us by the legislation in force, the legal obligations we are facing, court judgements or binding instructions from the authorities. The response will be provided in the same way as your request was received.

By refusing to comply with your requirement, we will clearly indicate the grounds for such refusal.

If you disagree with our actions or the response to your request, you can complain to the competent state authority (the list of supervisory authorities by each EU countries: https://edpb.europa.eu/about-edpb/board/members_en). In all cases, we recommend that you contact us before making a formal complaint so that we can find the right solution.

WHAT HAPPENS IF OUR BUSINESS CHANGES HANDS?

We may, from time to time, expand or reduce the scope of our business operations and this may involve the sale and/or the transfer of control of all or part of our business. Any Personal Data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this notice, be permitted to use that data only for the same purposes for which it was originally collected by us.

Our Websites may contain links to other websites, which are not operated by us. We have no control over how your data is collected, stored, or used by such other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

SOCIAL NETWORKS

When you visit social networks, your Personal Data is processed by a specific social network, and we start processing your Personal Data when you visit us on social networks. Through various social media channels, we want to introduce you to our wide range of services / products and exchange ideas and opinions with you on important topics.

Your Personal Data provided on the social network is processed for the following purposes:

  • communicate with our social network visitors;
  • respond to visitor inquiries;
  • obtaining statistical information;
  • conducting customer surveys, marketing campaigns, market analysis, lotteries, competitions or similar actions or events;
  • if necessary, defending the legitimate interests of the Company in institutions and in other cases.

Unless explicitly stated otherwise, the legal basis for data processing is Article 6 part 1 point (f) of the GDPR. Our legitimate interests are to be able to answer your messages or questions and analyze our availability on social networks, to present our products and services. To the extent that you wish to enter into a contractual relationship with us with your request, the legal basis for such processing is Article 6 part 1 point (b) of the GDPR.

If we intend to process your Personal Data for any other purpose not mentioned above, we will notify you prior to such processing.

Our pages on social networks are managed by specific social networks, so when you visit them, the processing of Personal Data is based on the social network privacy policies. With some social networks, depending on the social network policy, the purposes and scope of the processing, we are considered as joint data controllers.

Currently we use these social networks:

Facebook:  Aeroclass | Facebook

LinkedIn:  Aeroclass.org | LinkedIn

Twitter:  Aeroclass.org (@Aeroclass_org) / Twitter

Instagram:  Aeroclass Aviation E-learning (@aeroclass_org)

Name of the social network and its Privacy PolicyPersonal Data we processPersonal Data we process as joint data controllers
Facebook You can read their privacy policy by clicking here: https://www.facebook.com/policy.php  Your Facebook username, when you comment, react to the publication, share posts, write us messages;Your activities on our site, e.g. Your page views, duration statistics, query, comment information, and more.  We use statistical information (visits to our website, range of contributions, visits and average video transmission times, information about the countries and cities from which our visitors come, age range, gender). We receive anonymous statistics from Facebook through their service. The data controllers’ agreement can be found here: https://www.facebook.com/legal/terms/page_controller_addendum]
Instagram You can read their privacy policy by clicking here: https://help.instagram.com/519522125107875/?helpref=uf_shareYour Instagram username, when you comment, react to the publication, share posts, share content in stories section, write us messages;Your activities on our site, e.g. Your page views, duration statistics, query, comment information, and more.  We use statistical information (visits to our website, range of contributions, visits and average video transmission times, information about the countries and cities from which our visitors come, age range, gender). We receive anonymous statistics from Instagram through their service. The data controllers’ agreement can be found here: https://help.instagram.com/494561080557017/?helpref=hc_fnav
LinkedIn You can read their privacy policy by clicking here: https://www.linkedin.com/legal/privacy-policy  Your LinkedIn username, when you comment, react to the publication, share posts, write us messages;Your location indicated on the personal account.Your activities on our site, e.g. Your page views, duration statistics, query, comment information, and more.We use statistical information (visits to our website, range of contributions, visits and average video transmission times, information about the countries and cities from which our visitors come, age range, gender). We receive anonymous statistics from LinkedIn through their service. The data controllers’ agreement can be found here: https://www.linkedin.com/legal/l/dpa
Twitter You can read their privacy policy by clicking here: https://twitter.com/en/privacy  Your Twitter username, when you tweet, retweet (share) the tweet, quote, mention, write us messages;Your activities on our site, e.g. Your page views, duration statistics, query, comment information, and more.We use statistical information (visits to our website, range of contributions, visits and average video transmission times, information about the countries and cities from which our visitors come, age range, gender). We receive anonymous statistics from Twitter through their service. The data controllers’ agreement can be found here: https://gdpr.twitter.com/en/controller-to-controller-transfers.html

CHANGES TO OUR PRIVACY POLICY

We reserve a right to change this Privacy Policy unilaterally from time to time (for example, if the law changes). Any changes will be immediately posted on our websites. We recommend that you check this page regularly to keep up-to-date.

This Privacy Policy applies from the date it is posted on the Websites. Last review of the Privacy Policy: 05/08/2022. If you continue to use our services (such as the Website) after changing the terms of the Privacy Policy, you will be deemed to have read and understood the changed terms of the Privacy Policy.

[i] AVIA SOLUTIONS GROUP PLC, a private limited liability company, established and acting under the laws of the Republic of Cyprus, registration code HE 380586, registration address 28 Oktovriou, 1, ENGOMI BUSINESS CENTER BLC E, Flat / Office 111 Egkomi, 2414, Nicosia, Cyprus.