Privacy Policy

Aviato Academy NV (hereinafter referred to as “Aviato Academy” or “we”) respects your privacy and protects and processes your personal data in accordance with Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (or General Data Protection Regulation; “GDPR”), and the Belgian law of 30 July 2018 on the protection of natural persons with regard to the processing of personal data (Framework law).

This Privacy Policy contains important and relevant information concerning the processing of your personal data by Aviato Academy. This information will provide you with answers to the following questions, among others:

  • When does this Privacy Policy apply?
  • Who is responsible for your personal data and how can you contact us?
  • What personal data do we process and for what purposes?
  • For how long do we retain your personal data?
  • Who has access to your personal data and how are your personal data protected when they are transferred outside the European Economic Area (EEA)?
  • How do we protect your personal data?
  • What are your rights regarding your personal data and how can you exercise these rights?

Should you have any further questions, please contact our Data Protection Officer by post at Aviato Academy NV, attn. the Data Protection Officer, Brussels National Airport, Building 1C – Satellite A, 1930 Zaventem, or by email at privacy@brusselsairport.be.

The terms personal data, data subject, processing, etc. used in this Privacy Policy have the corresponding meaning as given in the GDPR and in the Framework law.

  1. When does this Privacy Policy apply?

This Privacy Policy applies to the processing of your personal data via the website, the LMS platform and in the context of providing training.

However, this Privacy Policy does not apply to the processing of personal data by third parties such as training providers and IT providers. Aviato Academy has no access to the processing activities carried out by such third parties and can therefore not be held liable for them.

Aviato Academy reserves the right to change and update its Privacy Policy from time to time. Should Aviato Academy use your personal data in a manner substantially different from that at the time of their collection, we will send you a notice through the means deemed most appropriate and in any event inform you by posting a notice on our website indicating that the Privacy Policy has been changed or updated.

  1. Who is responsible for your personal data and how can you contact us?

Aviato Academy NV is the controller of the personal data that falls within the scope of this Privacy Policy.

Should you have any questions or comments, please contact our Data Protection Officer by post at Aviato Academy NV, attn. the Data Protection Officer, Brussels National Airport, Building 1C – Satellite A, 1930 Zaventem, or by email at privacy@brusselsairport.be. 

  1. What personal data do we process and for what purposes?
  • Website and LMS platform

Aviato Academy can collect different types of personal data from data subjects who visit the website and/or the LMS platform and store them on its servers.

Personal data we process

We can process different categories of personal data, such as:

  • Direct identifiers (e.g. your first and last name)
  • Contact details (e.g. your postal address, email address, phone number, mobile phone number)
  • Information provided during helpdesk requests
  • Web behaviour information, such as information related to the way data subjects use the website/platform (e.g. browser type, domains, page views) collected via cookies and other automated technology (see our cookie policy for further information)
  • Electronic identifiers, i.e. IP addresses (a unique set of numbers that identifies any device connected to the network, such as a laptop, tablet or smartphone, which enables communication and exchange of information with other devices via an IP-based network, such as the internet) to manage the website/platform and ensure that relevant information is sent to your computer
  • Location information (based on your IP address)

If you visit the LMS platform and create an account to register online, the following personal data can be collected:

  • Direct identifiers (e.g. your first and last name)
  • Indirect identifiers (e.g. your country, postcode, date of birth)
  • Contact details (e.g. your postal address, email address, phone number, mobile phone number)
  • Personal characteristics (e.g. your gender, language)
  • Your profile picture

Purposes for which we process personal data

Aviato Academy processes personal data provided by the data subject or collected by Aviato Academy for all purposes necessary for the proper technical functioning of the website and/or the LMS platform and/or for the creation of an account.

In general, Aviato Academy collects your personal data for the overarching purpose of offering every data subject who uses the website/platform a secure, optimum and personal experience. Other purposes for collecting and processing your personal data through the website/platform include:

  • Providing access to and participation in the website/platform and the use of the services and products offered there, including customer service (Article 6.1, (b) GDPR)
  • Diagnosing technical problems and managing technical support and processing queries relating to the website/platform (Article 6.1, (b) and (f) GDPR)
  • Commercialization of the website/platform (Article 6.1 (a) GDPR)
  • Direct marketing purposes, insofar as Aviato Academy has obtained the data subject’s explicit consent to do so (Article 6.1 (a) GDPR)
  • Operating, evaluating and improving the website/platform (including developing additional products/services, adapting and improving the current website/platform, analyzing the website/platform, quality control activities and performing internal corporate functions such as accounting and auditing) (Article 6.1, (b) and (f) GDPR)
  • Protecting against and identifying and preventing fraud and other illegal activities, claims and other liabilities (Article 6.1, (c) and (f) GDPR)

 

  • Provision of training

Aviato Academy can collect different types of personal data from data subjects to whom it provides training.

Personal data we process

We can process different categories of personal data, such as:

  • Direct identifiers (e.g. your first and last name)
  • Indirect identifiers (e.g. your place of birth, date of birth, visual material during training)
  • Company data (e.g. company name, address, VAT number)
  • Contact details (e.g. your postal address, email address)
  • Personal characteristics (e.g. your gender, language)

Purposes for which we process personal data

Aviato Academy processes personal data provided by the data subject or collected by Aviato Academy for all purposes necessary for the performance of the contract concluded with the data subject (or the data subject’s employer), in particular to provide the training programmes and related services offered by Aviato Academy to the data subject (training courses, programmes, seminars, coaching, learning solutions, coaching programmes, development paths, e-learning, online training programmes and other forms of training, logistics and organisational support via the LMS platform and the provision of training rooms).

Other purposes for collecting and processing your personal data in the context of providing training include:

  • Checking attendance by drawing up participant lists (Article 6.1, (b) GDPR)
  • Identity check when taking exams (Article 6.1, (b) GDPR)
  • Drawing up personal certificates after completion of the training programme/exam (Article 6.1, (b) GDPR)
  • Registration of participants with the necessary authorities for certification of certain training programmes, such as EASA/IATA (Article 6.1, (b) GDPR)
  • Informing the participants and their supervisor of the status of their training programme, such as the validity period of the certificate obtained (Article 6.1, (b) GDPR)
  • Commercialising training programmes (Article 6.1, (a) and (f) GDPR)
  • Direct marketing purposes, insofar as Aviato Academy has obtained the data subject’s explicit consent to do so (Article 6.1 (a) GDPR)
  • Protecting against and identifying and preventing fraud and other illegal activities, claims and other liabilities (Article 6.1, (c) and (f) GDPR)
  1. For how long do we retain your personal data?

Aviato Academy will not retain your personal data any longer than is necessary for the purpose(s) for which they were collected or for which they will be further processed. The retention of certain personal data can be subject to a minimum retention period as stipulated by law, to which Aviato Academy must adhere.

  1. Who has access to your personal data and how are your personal data protected when they are transferred outside the EEA?

Aviato Academy will not sell, transfer or otherwise disclose your personal data to third parties without having obtained your prior explicit consent, unless otherwise provided in this Privacy Policy and unless it is necessary for the purpose(s) set out in this Privacy Policy, or if we are required by law to do so.

Aviato Academy can share personal data with cloud service providers, training providers, affiliated companies and other service providers that help us to deliver, understand, commercialise and improve our business. Aviato Academy does not authorise these service providers to use or disclose your personal data unless this is strictly necessary to perform services under our supervision or to comply with applicable legislation. Aviato Academy guarantees that your personal data will only be disclosed to such service providers to the extent necessary for them to fulfil their specific function.

In any event, such service providers are required to handle your personal data in accordance with the terms of this Privacy Policy. However, Aviato Academy cannot be held liable for any damage, directly or indirectly, that can result from misuse of your personal data by such service providers.

As a user of the website/platform, you acknowledge and agree that certain content or services offered by third parties can be made available to you through the website/platform, or that it is possible to click through to third party websites. You agree that an autonomous Privacy Policy of such third parties can apply in relation to the linked content and/or services, for which Aviato Academy cannot be held liable (including for compliance with it). Aviato Academy does not in any way review the privacy policies and/or practices of such third parties, and we advise you to carefully read the privacy policies of such third parties, where relevant, as their terms and conditions can differ from our privacy policies.

In some exceptional cases, Aviato Academy can transfer and/or store your personal data in countries outside the European Economic Area. In such cases, however, we ensure that the transfer takes place in accordance with the relevant legal requirements and that the third country can ensure an adequate level of protection of your personal data. Where necessary, contractual clauses standard in the EU are used and appropriate data transfer agreements are concluded.

  1. How do we protect your personal data?

Aviato Academy will at all times take appropriate technical, organisational and administrative measures against unauthorised or unlawful processing of your personal data or against accidental loss, destruction or damage, access, disclosure or use thereof.

In the event of a personal data breach (such as a breach of security of personal data, or access by an unauthorised person), Aviato Academy will take all necessary measures to mitigate the consequences of such breach and to prevent such breaches in the future. Aviato Academy has a legal obligation to inform you if the personal data breach can affect your fundamental rights and freedoms and constitutes a risk to your privacy.

  1. What are your rights regarding your personal data and how can you exercise these rights?

Aviato Academy will only process your personal data in a fair and lawful manner, which means that the personal data provided to us will only be processed for the purposes described in this Privacy Policy. We ensure that the personal data processed are adequate, accurate, relevant and not excessive. However, as a data subject you are also granted certain rights regarding the personal data you have shared with us:

  • Right of access;
  • Right to correct inaccurate personal data;
  • Right to erasure;
  • Right to limit data processing;
  • Right to object to data processing;
  • Right to transfer data;
  • Right not to be subject to automated individual decision-making, including profiling.

These rights are described in more detail below.

You can exercise the aforementioned rights or ask questions about this Privacy Policy or your personal data by means of a signed, written request to Aviato Academy, by post to Aviato Academy NV, attn. the Data Protection Officer, Brussels National Airport, Building 1C – Satellite A, 1930 Zaventem, or by email to privacy@brusselsairport.be.

Notwithstanding all our efforts to protect your privacy and to comply with relevant legislation, you might not agree with how we collect, use and/or process your personal data. In that case, you can also file a complaint with the Data Protection Authority, which you can contact by post at Data Protection Authority, Drukpersstraat 35, 1000 Brussels or by email at contact@apd-gba.be.

You can then file a claim with the competent court if you have suffered losses.

For more information on complaints and legal remedies, we invite you to consult the website of the Data Protection Authority: https://www.gegevensbeschermingsautoriteit.be.

7.1 Right of access

If you are concerned about the processing of your personal data or if you have any questions regarding your personal data, you have the right to request access to your personal data that Aviato Academy processes or stores

7.2 Right to correct inaccurate personal data

We are committed to keeping all your personal data accurate and up to date, but we might sometimes miss a few updates. You therefore have the right to request us, free of charge, to rectify and correct any inaccuracies or omissions in your personal data.

7.3 Right to erasure

Under certain predefined conditions, you have the right to ask us to erase your personal data without undue delay. Aviato Academy will assess whether your request qualifies for the erasure of your personal data on a case-by-case basis. If your request falls under any of the predefined conditions and there are no exceptions as set out in the GDPR, your personal data will be erased from Aviato Academy’s internal systems. However, the erased personal data might be temporarily stored in Aviato Academy’s back-up system. We will take all reasonable steps to erase all personal data as far as possible.

Besides the right to erasure, you also have the right to be forgotten in the event your personal data has been made public. Your personal data will then be erased from the internal system and reasonable technical and organisational measures will be taken to remove all links to, and copies or reproductions of, the personal data.

7.4 Right to limit data processing

Under certain predefined conditions, you can request Aviato Academy to temporarily stop and restrict the processing of the personal data in question. Aviato Academy will assess whether your request qualifies for restriction of processing on a case-by-case basis. If your request falls under any of the predefined conditions, Aviato Academy can still store your personal data but any further processing of your personal data will be limited and may only be carried out with your consent, for instance for the establishment, exercise or defence of legal claims, for the protection of the rights of another natural or legal person, or for important reasons of public interest.

In the event that the processing of your personal data is restricted as a result of your request, we will inform you before any such restriction of processing is lifted.

7.5 Right to object to data processing

Under certain predefined conditions, you can object to the processing of your personal data by Aviato Academy. Briefly, this is the case where the processing is based on a public or legitimate interest, where the personal data are processed for direct marketing purposes or where the personal data are processed for statistical purposes. Whether your request to object to data processing meets the requirements will be assessed by Aviato Academy on a case-by-case basis.

We can only use your personal data to contact you by email for direct marketing purposes in the event you have expressly given your consent to this. If you have agreed to this in the past but no longer wish to receive suggestions and/or direct marketing via email, you can object to such processing at any time and opt out of the mailing list.

7.6 Right to transfer data

If your personal data is processed on the basis of your consent or contract and the processing is carried out by automated means, you have the right to receive all your personal data in a structured, commonly used and machine-readable format. If technically feasible, you can also ask us to forward such personal data directly to another controller without any obstruction, insofar as this does not adversely affect the rights and freedoms of others.

7.7 Right not to be subject to automated individual decision-making, including profiling

With respect to your right to object to data processing, you have the right not to be subject to decisions based solely on automated processing, including profiling, that have legal consequences for you or have a significant impact on you. However, you will only have this right under certain predefined conditions and whether your request qualifies or not will be assessed by Aviato Academy on a case-by-case basis. Automated processing must be understood to mean processing carried out by machines without human intervention, such as direct marketing, targeted advertising and e-recruitment processes which are carried out electronically instead of by a human and on which basis decisions are made. In other words, in the case of individual automated decision-making, there is no (significant) human intervention that could correct possible outcomes.

Aviato Academy currently does not use automated decision-making.

Profiling, on the other hand, must be understood to mean the automated processing of your personal data in order to identify certain personal characteristics, in particular to be able to categorise you on the basis of your personal data. Individual decisions (including automated) can be made based on these categorisations. Profiling is subject to the right not to be subject to automated individual decision-making if such decision-making is fully automated without any (significant) human intervention that could correct the possible outcomes.

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