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PRIVACY STATEMENT

Last Updated: March 4, 2022

FLIGHTSAFETY PRIVACY STATEMENT

FlightSafety International Inc. (“FlightSafety”), including its affiliates, subsidiaries, and related entities (wherever located), values protecting your privacy and is committed to compliance with applicable data protection laws. Please read this Privacy Statement (“Statement”) carefully, as it contains important information about how and why we collect, store, use, and share Personal Information, as well as any rights you may have with respect to such information. Please do not provide any Personal Information if you do not agree with this Statement.

When does this Statement apply?

This Statement applies when FlightSafety processes Personal Information of Clients, Customers, and prospective Clients and Customers in the context of FlightSafety’s business operations. This Statement also applies to applicants for employment with FlightSafety.

It does not apply to Customers or Clients who enter into separate agreements governing the processing of their Personal Information. Such agreements take precedence over any conflicting provision in this Statement. Finally, this Statement does not apply to any third-party websites, applications, services, or content linked from FlightSafety’s websites.

1. Key Terms
FlightSafety, we, us, our FlightSafety International Inc. and its subsidiaries, affiliates, and related entities (including joint ventures), wherever located.
you, your Individuals (to include Clients) and Customers about whom we may collect or process personal or other information.
Customer In general, a corporate or legal entity that contracts with FlightSafety for the purchase or lease of services, products, or training.
Client In general, an individual or, employee or contractor of a Customer, who receives services or products for the benefit of the Client or the Customer.
Personal Information Any information relating to an identified or identifiable individual.
2. Categories of Personal Information We Collect

Depending on the nature of your relationship with us, we may collect and process the following types of Personal Information. Because the Personal Information we collect is important to our business operations, we may delay, deny, or prohibit providing any services or products to you if you decline to provide your Personal Information.

  • Identifiers/Contact Information: Information we collect directly from you (or, when applicable, a Customer that employs you), including basic contact information such as name, address, email, address and telephone number(s).
  • Commercial Information Related to Delivery of Our Services: Information we collect about you or you provide when you contact us, visit our Learning Centers and other facilities, visit our websites, interact with us at industry shows/events, use our mobile and web-based applications, and communicate with our sales, marketing, or scheduling teams. Such information can include products or services you have purchased, obtained, or considered.
  • Certain Financial Information: Financial and other payment-related information needed to invoice, process, receive payment for our products or services, or secure services on your behalf, such as financial account numbers or credit card information.
  • Certain Background Information: Your nationality, date or place of birth, passport or driver’s license details, and similar information necessary to provide you products or services in a legally-compliant manner.
  • Professional or Employment-related Information: Information we collect from you (or, when applicable, a Customer that employs you) about your employer, past employment, professional experience, and education.
  • Network-related, Photo, and Video Information: Information we collect about you when you train with us or use our products or services, including video surveillance and photo identification when accessing certain physical controlled areas, marketing-related photographs or videos, and network activity, browser, and device information when you access FlightSafety networks or websites.
  • Other Personal Information you provide when submitting feedback, inquiries, or contacting us in connection with the services or products we provide.

All information that FlightSafety collects about you may be combined to improve our communications with and service to you and reviewed, aggregated, or analyzed to enable us to develop and maintain world-class products and services.

In some circumstances, as permitted by law, we may collect certain Personal Information considered “sensitive” or of a “special category” under applicable law. This may include medical information (used, for example, to verify training or flight status, or Client seeks US training, certification, or rating) and other Personal Information for purposes of compliance with laws applicable to FlightSafety.

3. How We Collect Personal Information

We collect most of the above Personal Information directly from you, or when applicable, a Customer that employs you.  However, we may also collect information from:

  • Publicly-available sources.
  • Third parties with your consent, including sanctions-screening providers, Customer due diligence providers, and other FlightSafety service providers.
  • Cookies—for more information, please see our Cookie Policy.
  • From our IT systems, including automated monitoring of our services and technical systems.
4. How and Why We Use Personal Information

FlightSafety processes Personal Information only when we have a legitimate business purpose and, where required, a lawful basis for doing so. Depending on applicable law, the lawful basis may include:

  • Performance of a Contract: When processing is necessary to provide services or products to you, or for formation and performance of a contract with you.
  • Legal Obligations: When processing is necessary for compliance with applicable legal and regulatory obligations.
  • Legitimate Interests: When processing is necessary to achieve a legitimate interest that is not overridden by your data protection rights.
  • Consent: When you have provided consent in accordance with applicable law.

The below table details these lawful bases further based upon the category of Personal Information.

Personal Information Category Business Purpose Lawful Basis
Identifiers/ Contact Information We process this information to provide products and/or services to you, verify identity and communicate with you to provide our services and products.

Performance of a Contract

Legal Obligations

Legitimate Interest

Consent

Commercial Information Related to Delivery of our Services We process this information to provide or promote our services, or to perform a contract with you.

Performance of a Contract

Legal Obligations

Legitimate Interest

Consent

Certain Financial We process this information to process payments and screen for applicable issues related to fraud financial restrictions, sanctions, embargoes or similar regulatory limitations or prohibitions

Performance of a Contract

Legitimate Interest

 

Certain Background Information We process this information to conduct checks to identify you and for other processing necessary to comply with professional, legal and regulatory obligations that apply to our business and the services or products we provide to you.

Legal Obligations

Consent

Professional or Employment-related Information We process this information to identify training needs, comply with legal and regulatory obligations, and to assist in providing our services to you. In the context of an application for employment, we process this information to assess suitability for a position.

Performance of a Contract

Legal Obligations

Consent

Network-related, Photo, and Video Information This information is collected to ensure physical security of FlightSafety facilities, maintain network security, market and promote our products and services, and support the provision of our services or products.

Legal Obligations

Legitimate Interest

Consent

Other Personal Information We collect and process this information to address complaints or inquiries from you, and to improve out services.

Performance of a Contract

Legal Obligations

Legitimate Interest

Consent

5. Promotional Communications

You may opt out of receiving promotional communications at any time by clicking on the relevant link in those communications or by contacting us at DataProtection@FlightSafety.com.

If we are notified that you do not want to receive further promotional or marketing communications from us, we will not contact you with additional direct marketing or promotional communications. However, FlightSafety may retain your Personal Information for other lawful purposes or to ensure you are no longer contacted.

6. Sharing Your Personal Information

Because FlightSafety is a global, complex business, we may share Personal Information internally with our employees or with third parties for the purposes described in this Statement. These third parties include:

  • Our carefully selected service providers (e.g., invoice and database management providers, customer resource management providers, payment service providers, IT and professional advisors such as auditors and legal counsel) that assist in the operation or our business, under our direction or on our behalf;
  • Government regulators that oversee and regulate certain activities in our business and operations;
  • Third parties approved by you, for example, your employer or other parties who need records of your training with us.

We may also disclose Personal Information to other third parties to comply with legal obligations, enforce and support our corporate policies, respond to claims, and fulfil our contractual obligations.

We do not sell your personal information to anyone.

7. How Long We Keep Personal Information

We retain your Personal Information for as long as needed to fulfill the purpose for which it was collected and for a reasonable period thereafter to comply with audit, contractual, or legal requirements. When no longer necessary to retain your Personal Information, we will delete or anonymize it (so that the information cannot be attributed to a specific individual without additional information) as applicable. FlightSafety also periodically reviews the need to process certain Personal Information.

8. Transferring Personal Information

The nature of our global operations requires us to transfer and receive data from locations outside of the United States. With respect to such transfers, we are subject to regulatory and enforcement authority of U.S. law. In certain situations, we may be required to disclose Personal Information to comply with applicable legal or regulatory requirements.

9. Data Protection Rights

FlightSafety does not sell Personal Information or discriminate against individuals for exercising their privacy rights. More specific rights are listed below. If you believe that the processing of your Personal Information is not compliance with applicable law, you have the right to lodge a complaint with the appropriate data protection authority or regulatory body. We ask that you attempt to resolve any issues with us before lodging a compliant.  Please refer to Section 12 “How to Contact Us” for more details.

European Economic Area, UK, and elsewhere: To the extent FlightSafety is a controller of Personal Information, your data protection rights are as follows:

  • If you wish to access, correct, update or request deletion of your Personal Information, you can do so at any time by contacting us using the details provided below.
  • You can object to processing of your Personal Information, request that we restrict processing, or request portability of your Personal Information. You can do so at any time by contacting us using the details provided below.
  • You have the right to opt-out of marketing communications. You can exercise this right by clicking “unsubscribe” or “opt-out” in any marketing emails we send you. To exercise this right with other forms of marketing, please contact us using the details provided below.
  • If we have collected and presently process your Personal Information with your consent, you can withdraw consent at any time. However, this will not affect the lawfulness of any processing we conducted prior to your withdrawal of consent, nor the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.

California Consumer Protection Act: California residents have specific rights under the California Consumer Privacy Act (“CCPA”) with respect to processing of their Personal Information. Section 2 of this Statement lists the categories of information that we processed or used for a business purpose in the last 12 months. Section 6 of this Statement lists the categories of third parties with whom we share Personal Information. Subject to exceptions, you may request disclosure or request deletion of your Personal Information at any time by using the contact details below in Section 12.

However, we can only respond to verifiable requests received from individuals who desire to exercise their rights consistent with the CCPA. When contacting us, you must provide sufficiently detailed information about the Personal Information we are to update, correct, amend, or remove, and include the timeframe and method used to collect your Personal Information. If the information was obtained from a Customer or third party acting on your behalf, you must contact the individual or entity you provided your information to.

California residents have the right to direct a company not to sell their Personal Information. Because FlightSafety does not sell your Personal Information, this does not apply.

10. Keeping Personal Information Secure

FlightSafety is committed to ensuring your Personal Information is processed securely. We have adopted internal policies and controls, consistent with commercially reasonable efforts, to help prevent your Personal Information from being lost, destroyed, misused, unintentionally disclosed, or accessed by anyone other than our employees or third parties with proper authority. We also train our employees on data protection and information security best practices and our policies.

11. Changes to this Privacy Statement

We may update this Statement and its revision data at any time to reflect changes to our information practices or applicable laws. If we make material alterations in our use of your Personal Information, we will post a notice on our website. You are encouraged to periodically check this page for the latest information on our privacy related practices.

12. How to Contact Us

To exercise your rights, please contact our Data Protection Officer at: DataProtection@FlightSafety.com or use the automated webform on this page. FlightSafety can also be reached at:

FlightSafety International Inc.
3100 Easton Square Place
Columbus, OH 43219
1-800-488-3214