Privacy Notice

FlightSafety International Privacy Notice

Scope:

FlightSafety International’s Privacy Notice applies to all personal data (information relating to an identified or identifiable individual) about our customers, clients, contractors, and other individuals that is collected and used by FlightSafety International and its subsidiaries.

For the purposes of this Privacy Notice FlightSafety includes its Corporate Headquarters, Divisions, Subsidiaries and all of its Learning Centers and facilities located both in the United States and around the world.  Our Learning Centers operate under subsidiaries and/or joint ventures in locations worldwide, including without limitation, Australia, Canada, France, Hong Kong, Japan, Middle East, Netherlands, Norway, Saudi Arabia, South Africa, Thailand, the United Kingdom, and the United States.

Information FlightSafety Collects:

FlightSafety collects information about you from a variety of sources, including:

• Information we collect directly from you.
• Information we collect about you when you contact us, visit our Learning Centers and other sites, visit our websites, visit our booths at industry shows/events, use our mobile and web-based applications and interact with ours Sales team and marketing information.
• Information we collect about you during the course of your contract with us.
• Information we collect about you when you train with us.
• Information we collect about you from public and commercially available sources.

All information that FlightSafety collects about you may be combined to improve our communications with and service to you as well as to enable us to develop and maintain world-class products and services.

Uses/Information Sharing:

FlightSafety is a global business and we may transfer your personal information for the purposes described in this Privacy Notice to other countries which may not have the same data protection laws as the country in which you initially provided the information, but we will take reasonable steps to safeguard and protect your personal information in accordance with this International Privacy Notice, or as otherwise disclosed to you.

FlightSafety collects and uses your Personal Information in connection with our Website and Services to:

• Provide the products and services you request.
• To tell you about our products and services.
• To manage and improve our Learning Centers, sites, products, and services.
• To resolve issues, test and validate our systems.
• To detect, investigate and prevent activities that may violate our policies or be illegal.

We do not sell your personal data to anyone.

We may share your information:

• Internally to administer your account(s) and provide the products and services you request.
• With our carefully selected business partners but only if we have your consent.
• With service providers who perform business operations on our behalf under our direction.
• To protect your vital interests.
• To protect and defend FlightSafety in any legal or regulatory process.
• When required by law and/or governmental authorities.

In some cases, if you do not provide your personal information to us we may be unable to provide the products and services you request.

Lawful Basis for Processing:

Data Protection Law requires us to have a legal justification to process your personal information. We use the following depending on the type of data and the type of processing:

• Consent
• Performance of a Contract
• Compliance with a Legal Obligation
• Protecting Vital Interests
• Necessity
• Legitimate Interests

Privacy Notice Distribution and Updates:

• FlightSafety’s Privacy Notice is published and maintained on all company websites:
  • www.flightsafety.com
  • www.flightsafetyacademy.com
  • www.flightbag.com
  • www.flightsafetysurvey.com
  • www.flightsafetytextronaviationtraining.com
• FlightSafety also publishes and maintains a Teammates and Prospective Teammate Privacy Notice on:
  • careers.flightsafety.com
  • www.flightsafety.com
  • www.flightsafetyacademy.com
• Privacy Notices are updated at least annually to all data subjects and at the time of data collection.
• FlightSafety reserves the right to update this privacy notice at any time without prior notice. Upon a change in notice, we will alert you with a conspicuous website banner.
• Use the “Last Updated” date in this policy and the Revision Log to determine when and what changed.

Types Of Personal Data Collected:

Below are examples of the types of personal data elements FlightSafety may collect, process, share or use for each data subject type.  These lists are examples and do not represent all data elements nor does it imply that all listed data elements are collected, processed, shared, or used for all data subjects in that category:

• Customers – Examples: legal name, company/entity, job title, location, education and training history, qualifications/certifications, professional memberships, contract type, credit check, IP Addresses, email, etc.
• Clients – Examples: gender, national identification number, legal name, company/entity, home address, job title, location, education and training history, course performance metrics, qualifications/certifications, professional memberships, contract type, emergency contact details, Airline, Hotel, and Car Rental Membership Numbers, photography, etc.
• Contractors – Examples: national identification number, legal name, home address, job title, location, salary/wage, education and training history, etc.

Types Of Sensitive And Criminal Data Collected:

FlightSafety may indirectly collect sensitive and criminal data that can be inferred from other personal data that is collected.  We do not directly collect sensitive or criminal data as outlined in Articles 9 and 10 of the GDPR or in other global data protection regulations.  We do not process or store sensitive or criminal data.  The below lists are examples of data that we may indirectly be able to determine:

• Customers – Examples: racial or ethnic origin, religion or religious beliefs, etc.
• Clients – Examples: racial or ethnic origin, religion or religious beliefs, etc.
• Contractors – Examples: drug test results, legal records, health and safety related information, racial or ethnic origin, etc.

Surveillance and Monitoring:

In certain circumstances your activity may be subject to surveillance and monitoring.

• If you use devices on the FlightSafety network, the websites you visit are processed through a service that prevents visits to dangerous or unauthorized websites and provides real-time scans of any downloads to protect network connected devices from malicious content.  This is done to ensure the security of systems as permitted under the GDPR and other global data protection regulations.
• If you visit or train at a FlightSafety facility we may collect date about you through our security cameras.  Our security system do not record sound.  If security cameras are in use there will be clear indicators of their presence as required under the GDPR and other global data protection regulations.

Optional Disclosure:

• You are not required to disclose sensitive or criminal data and data of children under the age of 16 unless required by law or regulatory requirements.

Data Retention:

• FlightSafety’s data retention policies vary by data type and type of processing. In general our retention policies align with the respective regulatory requirements.
• More information is available by contacting our Data Protection Officer at DataProtection@FlightSafety.com.

Your Rights:

• You have the Right to be Informed as to what personal data FlightSafety collects, stores, shares, and processes and how that data is used.
• You have the Right to Access the personal data FlightSafety holds on you. FlightSafety will provide a copy of this information to you at no cost under most circumstances.
• You have the Right to Rectification if the data is inaccurate or incomplete.
• You have the Right to Object to processing of your data. FlightSafety will make every attempt to comply with your request.
• You have the Right to object to Automated Decision Making and request human intervention in the decision making process.
• You have the Right to Restrict and request a ‘block’ on processing of your personal data. FlightSafety will make every attempt to comply with your request.
• You have the Right to Data Portability and to request your personal data back so that it can be reused for the purpose of buying or using similar services from other organizations.
• You have the Right to Erase and request the deletion or removal of your personal data where there is no compelling reason for its continued processing.
• You have the Right to Opt Out of the Sale of Your Data however FlightSafety does not sell personal information for monetary or other valuable consideration.
• You have the Right Not to Be Subject to Discrimination for the Exercise of Rights. FlightSafety will not deny you access to, charge different prices for, impose penalties on or provide a different level or quality of goods or services due to the exercise of rights.

When exercising your rights you may be required to answer questions regarding your relationship with FlightSafety in order to verify your identity.

Exercising Your Rights:

To learn more about or to exercise your rights, please contact our Data Protection Officer at:

DataProtection@FlightSafety.com
Direct Dial at 1-929-208-4042
Toll-free at 1-844-731-7124

Information Security:

• FlightSafety International employs a robust information security program that protects personal data from loss, misuse, and unauthorized access and disclosure.
• The Information Security Program takes into due account the risks involved in the processing and nature of the personal data and incorporates Privacy-by-Design principles.
• A copy of our Information Security Program Overview is available by contacting our Data Protection Officer at DataProtection@FlightSafety.com.

Data Transfers:

In order to transfer your data between FlightSafety locations and to government agencies for the purpose described in this Privacy Notice, FlightSafety relies on one or more of the following depending upon the countries involved:

• Third Country Adequate Level of Protection
• Standard Data Protection Clauses
• Contract Performance
• Your Consent
• Legal Claims

Important Information:

• FlightSafety is committed to working with customers, clients, contractors, and other individuals to resolve any privacy concern.
• FlightSafety complies with all applicable data protection laws.
• You can read our full Privacy Policy on www.flightsafety.com or by contacting us for a paper copy.

How To Contact Us:

• To find out more about the use and disclosure of your information, to learn how to limit it, for all other inquires related to this notice, or to file a complaint, please contact our Data Protection Officer at DataProtection@FlightSafety.com.

Contact Our Corporate Headquarters:

FlightSafety International
Marine Air Terminal – LaGuardia Airport
Flushing, NY 11371
United States of America
(718) 565-4100

EU-US Privacy Shield:

• FlightSafety is committed to comply with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. To learn more about the Privacy Shield program please visit https://www.privacyshield.gov/.
• FlightSafety intends to certify to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
• In compliance with the Privacy Shield Principles, FlightSafety commits to resolve complaints about our collection or use of your personal information. European Union individuals with inquiries or complaints regarding our Privacy Shield policy should first contact our Data Protection Officer at DataProtection@FlightSafety.com.
• We employ other companies (“agents”) and people to perform tasks on our behalf and need to share, and may internationally transfer, your information with them to provide products or services to you;. FlightSafety International is liable under the EU-U.S. Privacy Shield Principles for its agents to process transferred Personal Information in a manner consistent with the Principles.
• Under certain limited circumstances, European Union individuals may invoke binding Privacy Shield arbitration as a last resort if all other forms of dispute resolution have been unsuccessful. To learn more about this method of resolution and its availability to you, please visit https://www.privacyshield.gov/.
• FlightSafety is subject to the jurisdiction of the Federal Trade Commission for purposes of Privacy Shield enforcement.
• FlightSafety is required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Dispute Resolution:

FlightSafety commits to cooperate with the panel established by the EU data protection authorities (DPAs) and comply with the advice given by the panel with regard to human resources data transferred from the EU in the context of the employment relationship.

Privacy Shield organizations must respond within 45 days of receiving a complaint.

If you have not received a timely or satisfactory response to your question or complaint from FlightSafety’s Data Protection Officer, please contact the independent recourse mechanism listed below:

Non-HR Recourse

Federal Trade Commission (DPAs)
600 Pennsylvania Avenue, NW
Washington, DC 20580
Tel. +1 202 326 2222

HR Recourse

EU Data Protection Authorities