PRIVACY STATEMENT

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

• 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, Customer name (your employer) and telephone number.
• 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 necessary for invoicing, and to process and receive payment for our products or services, or secure services on your behalf.
• Certain Background Information: Your nationality, date or place of birth, passport or driver’s license details as 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.
• Usage-related Information; 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, and activity while using FlightSafety networks, applications or websites (e.g., device and browser information).
• Other Personal Information you provide when submitting feedback, inquiries, or contacting us in connection with the services or products we provide.

Some information that FlightSafety collects while providing services may be anonymized, aggregated, and analyzed for purposes of improving our services and products.

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 aviation related medical certifications (used, for example, to verify training or flight status, or where a Client seeks a US training, certification, or rating), national identification and other Personal Information solely for purposes of compliance with laws applicable to FlightSafety.

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

• Publicly-available sources (to verify, for example, currency of pilot certificates where necessary).
• Trusted third parties, including use of information stored in our customer resource management provider, sanctions-screening providers, Customer due diligence providers, and other FlightSafety service providers. Please note, that information from trusted third parties typically relates to Customer entities rather than Personal Information.
• Our IT systems, including automated monitoring of our services and technical systems. When you visit our website or use our applications, we collect information through the use of cookies and other trackers. Depending on your tracking preferences, the information we collect my include device IP addresses, referring websites, recently visited pages and the time your device visited our website or applications. We also rely on analytics and tools to prevent spam and other security risks related to use of abusive or malicious software. You can choose your preferences for cookies by accessing the cookie settings preference center. For more information, please see our Cookie Policy.
• You when you use our services or products, including when you provide feedback and through log information when you access our applications.

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.  Additionally, we use Personal Information for purposes made clear to you at the time you submit your Personal Information, for example, to fulfill your request or provide you with information requested about our products or services. Provision of Personal Information may be necessary to enable provision of products or services to you or a Customer, or to comply with our legal obligations. Failure to provide Personal Information may result in the unavailability of products or services.

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.

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 service providers, consultants and other vendors we employ to perform tasks on our behalf (e.g., invoice and database management providers, customer resource management providers (Salesforce), payment service providers, website analytics companies (e.g. Google Analytics), information security, 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. Under certain circumstances, we may also be required to disclose Personal Information in response to valid requests by public authorities, including to meet national security or law enforcement requirements, based on our legitimate interests or legal obligations.
• 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.

While we do not sell Personal Information in exchange for any monetary consideration, we do share Personal Information for other benefits that could be deemed a “sale” under applicable law, including sharing commercial information, usage and other electronic network activity information with advertising networks and website analytics companies through use of cookies. You can choose your preferences for cookies by accessing the cookie settings preference center We do not sell or knowingly collect Personal Information of minors and individuals under age 16.

We retain your Personal Information for as long as needed to fulfill the purpose for which it was collected and, subject to specific retention schedules, 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 and may retain information based on our legitimate interests or legal purposes, such as improvement of our services or products, fraud prevention, record-keeping, or enforcing our legal rights.

The nature of our global operations requires us to transfer and receive data from locations outside of the United States, including the EAA (“EEA”), United Kingdom (“UK”) and elsewhere. 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.

FlightSafety does not “sell” Personal Information for monetary value 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.

a. EAA, 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.

b. California: California residents have specific rights 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 under applicable laws and to the extent applicable to our processing, you may request disclosure, deletion, correction of your Personal Information or to opt-out of sharing for cross-context advertising purposes and processing of sensitive 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 applicable law. 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 (e.g., first and last name, email address used when obtaining our services or products, and details on the Customer account under which you trained or dates and types of training received). 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. Please see Section 6 for more information.

FlightSafety is committed to ensuring your Personal Information is processed securely. We have adopted internal policies and controls, consistent with industry standards, 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.

We may update this Statement 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.

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, Suite 100
Columbus, OH 43219
1-888-874-6795