1. Introduction

1.1        Flight Simulation Company B.V. (“FSC“), including its affiliates, is committed to respecting your privacy and to complying with applicable data privacy laws. This privacy statement describes how we collect and use personal data where FSC is the data controller or where we refer to the applicability of this statement. Personal data means information about you or another identifiable individual. We are registered in The Netherlands with the Chamber of Commerce under registration number 815057386 and our registered office is at Fokker Logistics Park, Fokkerweg 300, 1D, 1438AN, Schiphol-Oude Meer, The Netherlands.

1.2        We are committed to safeguarding the privacy of our website visitors, facility visitors and service users.

1.3        This statement applies where we are acting as a data controller with respect to the personal data of our website visitors, facility visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.4        In this statement, “we”, “us” and “our” refer to Flight Simulation Company B.V. or its subsidiaries.

1.5        In matters pertaining to FSC’s privacy practices you can contact us:

(a)         by post, to the postal address given above;

(b)         by telephone, +31 (0)20 304 3200

(c)         by email, using privacy@fsctraining.com

2. Types of personal data, purpose and legal basis

2.1        In this Section 2 we have set out:

(a)         the general categories of personal data that we may process;

(b)         in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c)         the purposes for which we may process personal data; and

(d)         the legal bases of the processing.

2.2        We may process information contained in any enquiry you submit to us regarding our services (“enquiry data“). The enquiry data may include your name, telephone number, email address, and company name. The enquiry data may be processed for the purpose of enabling us to answer your questions. The legal basis for this processing is our legitimate interests, namely the ability to communicate with our customers and answer their inquiries.

2.3        We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.

2.4        We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and any other information you choose to provide us with. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our business and communications with contacts.

2.5        We may process information relating to your travel and lodging arrangements when visiting our training center (“hospitality data“). The hospitality data may include your name, contact information, vehicle registration, passport, travel arrangements, visa applications and lodging information. The hospitality data may be processed for the purposes of arranging travel and lodging for you. The legal basis for this processing is our legitimate interests, namely the ability to assist our customers with their travel and lodging requests.

2.6        We may process information relating to your license data (“license data“). The license data may include your name, your employer, your job title or role, your employment history, your contact details, your pilot license and associated certificates including your medical certificate. The source of the license data is you or your employer. The license data may be processed for the purposes of determining suitability to make use of our services. The legal basis for this processing are the EASA regulations.

2.7        We may process information relating to the camera surveillance at our facilities (“camera data“). The camera data may include video images of you. Camera data may be processed for safety and security reasons. The legal basis for this processing is our legitimate interests, namely our responsibility for the safety and security of our personnel, customers and visitors and the safeguarding of our assets.

2.8        As part of the personal data we may process data that falls under one of the special categories as described in Art. 9 of the GDPR, specifically data concerning health (your medical certificate). We will only process this data when we are explicitly required to do so by law or regulation.

2.9        We may process any of your personal data identified in this statement where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.10     In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation, from Civil Aviation Authorities or otherwise, to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.11     Please do not supply any other person’s personal data to us, unless we prompt you to do so.

3. Providing your personal data to others

3.1        We may disclose your personal data to our subsidiaries in so far as reasonably necessary for the purposes, and on the legal bases, set out in this statement.

3.2        We may disclose license data to Civil Aviation Authorities or airlines in so far as reasonably necessary for satisfying their requests or aiding you in obtaining certification.

3.3        Your personal data of all categories may be disclosed to third parties who process personal data for FSC for the purposes described in this statement. This may include our IT partners for the purpose of backup and development management and our marketing partners for the purpose of sending you our newsletter or other promotional information. These third parties are not permitted to use your personal data for any other purposes. We require them to act consistently with this statement and to use appropriate security measures to protect your personal data.

3.4        In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

4. Transfer of your personal data to third countries

4.1        In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (“EEA“).

4.2        We may be prompted by Civil Aviation Authorities or customer airlines outside of the EEA to disclose license data. We will only transfer this data if it is protected by appropriate measures, in accordance with the EU data protection law, that accomplish the extension of the safeguards provided in this privacy statement to their operation.

5. Retaining and deleting personal data

5.1        This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2        Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3        We will retain your personal data as follows:

(a)         Inquiry data will be retained for as long as necessary to satisfy our legitimate interests, namely the ability to communicate with our customers and answer their inquiries.

(b)         Customer relationship data will be retained for as long as necessary to satisfy our legitimate interests, namely the proper management of our customer relationships.

(c)         Correspondence data will be retained for as long as necessary to satisfy our legitimate interests, namely the proper administration of our business and communications with contacts.

(d)         Hospitality data will be retained for as long as necessary to satisfy our legitimate interests, namely the ability to assist our customers with their travel and lodging requests.

(e)         License data will be retained for as long as necessary to comply with aviation regulation record keeping terms, with a maximum of 10 years.

(f)          Camera data will be retained for a period of 28 days, unless there are good reasons for storing the images for a longer period, for example the investigation of an incident.

5.4        Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Amendments

6.1        We may update this statement from time to time and we will publish the newest version on our company’s website (www.fsctraining.com).

6.2        We recommend you to check this page occasionally to ensure you are happy with any changes to this statement.

6.3        We may notify you of significant changes to this statement by email prior to these changes taking effect.

7. Your rights

7.1        In this Section 7, we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, we recommend you to read the applicable laws and guidance from the regulatory authorities for a full explanation of these rights.

7.2        Your principal rights under data protection law are:

(a)        The right to access:

You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data.

(b)        The right to rectification:

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

(c)         The right to erasure:

In some circumstances you have the right to the erasure of your personal data without undue delay. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for compliance with a legal obligation, specifically aviation regulation’s mandatory retention periods; or for the establishment, exercise or defense of legal claims.

(d)        The right to restrict processing:

In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

(e)        The right to object to processing:

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.

(f)         The right to data portability:

To the extent that the legal basis for our processing of your personal data is:

(i)   consent; or

(ii) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

(g)        The right to withdraw consent:

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

(h)        The right to complain to a supervisory authority:

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority. The supervisory authority responsible for Flight Simulation Company B.V. is the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) located in The Hague, the Netherlands.

7.3        You may exercise any of your rights in relation to your personal data by contacting us via the means as laid out in paragraph 1.5, in addition to the other methods specified in this Section 7.

 

End of Statement

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FSC Privacy Statement v 1.0