SIMTECH AVIATION LIMITED

Privacy Statement
Simtech Aviation is committed to respecting your privacy and protecting your personal information

This Privacy Statement sets out what we do with your personal information and how we keep it secure. It explains what personal information we collect, where, why and how we collect it, as well as what your rights are over the personal information, we hold about you. We use the terms “personal data” and “personal information” interchangeably in this Statement to mean details which identify you or could be used to identify you, such as your name and contact details, your travel arrangements and purchase history etc. This Privacy Statement gives effect to our commitment to protect your personal information. It applies to personal information about you that we collect, use and otherwise process in connection with your relationship with us as a cadet/customer/staff member or potential cadet/customer, including: when you take part in training with us or use our other services; when you interact with us on social media or use our websites or mobile applications, through our virtual online “chat” service,  contact our administration staff and/or book to use our services through third parties (such flight schools and airlines); The purpose of this Privacy Statement is to enable you to understand how we process your personal data and how we exercise control over it.  The principle of “transparency” in data protection law requires that we communicate to you (via this Privacy Statement) about how we collect and process your personal data in an easily accessible and easy to understand format. As a Simtech Aviation cadet/customer/staff member, your personal privacy is very important to us. Therefore:

• We are transparent about the personal data we collect and what we do with it.
• We use the personal data you give us for the purposes described in this Privacy Statement, (this include providing you with services you have requested / enhancing your experience)
• We also use your personal data to help us understand you better so that we can improve your guest experience / provide you with the best form of training/service.
• If you tell us you don’t want to receive marketing emails we will stop sending them. We will, of course, continue to send you essential information relating to a training course or service you have taken part in to keep you informed about your course and sometimes hospitality.
• We have put in place measures to protect your personal data and keep it secure.
• We respect your data protection rights and aim to give you control over your personal data.

You can access our full Privacy Statement below to help you to understand better how we use your personal information. In it, we explain in more detail the types of personal information we collect, how we collect it, what we use it for and who we share it with. Our “Privacy Essentials” section below summarises the most important parts of our Privacy Statement. In the full Privacy Statement, you can also find some specific examples of why and how we use your personal information. If you have further questions please get in touch with us at kilan.hanratty@simtech.ie, or gdpr@simtech.ie or write to us at Simtech Aviation GDPR, Simtech Aviation, Kestrel House, Dublin Airport Logistics Park, Dublin.  Without prejudice to your rights under applicable laws, this Privacy Statement is not contractual and does not form part of your contract with us.

PRIVACY ESSENTIALS
Key information “at a glance”. For details please read the Privacy Statement in full.

Who is collecting your data? Simtech Aviation Holding Limited and Simtech Aviation Training Limited (Kestrel House, Dublin Airport Logistics Park, Co Dublin, Ireland; email address gdpr@simtech.ie is the data controller of your personal data where you book training courses/services that we provide to you. We may engage certain third parties (e.g.FlightLogger and HelloSign) to provide services on our behalf.

What personal data do we collect? We collect the following data: your name, license details, date of birth, passport details; contact information including email address and phone number; payment details; travel itinerary, purchase history; sales channel; social media interactions, information about your searches and web usage, home airport.

What we do with the personal data we collect? We require your information to deliver services to you and to understand your needs and provide you with a better service. From time to time, we may also use your information to contact you for market research purposes. We may use your information to improve our products and services or customize the website according to your interests. We may send promotional emails about special offers and deals to the email address you have provided (unless you indicate you don’t wish to receive these).

How do we keep your personal data secure? In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect.

How can you control your personal data? If you have previously agreed to us using your personal data for direct marketing purposes, you may change your mind at any time by clicking on the unsubscribe link in each marketing email or via the unsubscribe page. We may use your personal data to send you industry related news and promotional emails. We will not sell your personal data to third parties. If you are a “registered user” of our website you can update your account details on a self-service basis.  You may request details of personal data which we hold about you (see Section 12). If data we hold on you is incorrect/ incomplete, please contact us (gdpr@simtech.ie). We will promptly correct any data found to be incorrect.

How do we use cookies? Cookies help us to keep our website functioning securely and to provide you with a better service. Cookies allow us to recognise your device or computer and to see how you interact with our website, but not to identify you as an individual. You can choose to accept or decline cookies on the website. You can modify your browser settings to decline cookies on our website if you prefer. This may prevent you from taking full advantage of the website. See Cookie Policy.

A note regarding links to other websites Our website contains links to enable you to visit other websites. Once you use those links to leave our service, we do not have any control over the external website. Therefore, we cannot be responsible for the protection and privacy of any data which you provide whilst visiting such other websites and such websites are not governed by this Privacy Statement. You can find out how those sites use and protect your data by reading their privacy statements.

Index

1. Who is the “Data Controller” of your Personal Information.
2. When does this Privacy Statement apply.
3. When do we collect personal information about you.
4. What types of personal information do we collect and retain.
5. What do we use your personal information for.
6. When will we send you marketing communications.
7. What is our legal basis for using your personal information.
8. How long do we keep personal information.
9. Who do we share your personal information with.

• How we keep your personal information secure.
• What is the policy on CCTV.
• Your legal rights in relation to the personal information we hold about you.
• How can you exercise your legal rights in relation to your personal information.
• How will we inform you of changes to this Privacy Statement.
• How to get in touch with us & your right to complain to our supervisory authority. 

Full privacy statement

1. Who is the Data Controller of your Personal Information?

Any personal information processed by Simtech Aviation in connection with this Privacy Statement is controlled by Simtech Aviation Training or Simtech Aviation Holdings, which is therefore considered the “data controller” of your personal information under European Union and Irish data protection law. Our address is Kestrel House, Cedar Drive, Dublin Airport Logistics Park, County Dublin, Ireland and you can contact us at gdpr@simtech.ie

If you have booked a training course with us but through another company then that other company will also separately be considered a “data controller” under European Union and Irish data protection law. You can access the privacy statements of those companies from them directly.

Any third-party provider of services such as additional courses, hotel accommodation and transport will also be separately considered a “data controller”. The applicable booking terms and conditions will identify the third-party provider. Simtech Aviation partners with third parties to provide Hotel and Transportation (e.g. Clayton Hotel), Type Rating/APS/MCC/JOC (Freelance educators and instructors) and additional courses such as Airline Prepared (Aviation Selection Consultants), as well as job referrals to a number of partnered airlines (Aer Lingus, Stobart, CityJet, Flybe, Air Dolomite and Sun Express). You can access the privacy statements of those providers from them directly.

Your information may be shared with relevant aviation authorities as part of our audit process.

2. When does this Privacy Statement apply?

This Privacy Statement applies to personal information about you that we collect, use and otherwise process in connection with your relationship with us as a customer or potential customer, including when you attend Simtech Aviation, use our other services, interact with us on social media or use our websites or mobile applications, contact our staff by digital or traditional means, book to use our services through third parties (such as Flight Schools or Airlines). Where we make reference to third parties including but not limited to instructors/educators, hotel operators, FlightLogger, etc. are also acting as data controllers of your personal data (See Section 1“Who is the Data Controller of Personal Information“ and Section 9 “Who do we share your personal information with?”). You should consult the privacy statements of those third parties for further information.  Additional privacy statements may apply if you elect to take certain additional services from us, such as when using public/private wifi. – if this is the case you will be notified of this prior to use.

3. When do we collect personal information about you?

We collect personal information about you whenever you use our services (whether these services are provided by us or by other companies or third parties acting on our behalf), including when you train with us, when you use our website or mobile applications, interact with us via email or social media or our online “chat” service on our website and mobile applications or contact Simtech Aviation directly.  For additional details about the types of personal data we collect see Section 4 below “What types of Personal Information do we collect and retain?”

In addition, we may receive personal information about you from third parties, such as:

• Flight Schools who book courses on behalf of cadets/customers through their partnership with Simtech Aviation.
• FlightLogger, when cadets/customers upload their licenses and required certificates when completing a course.
• Airlines which use the Simtech Aviation facilities under a housing and maintenance agreement.
• Companies contracted by us to provide services to you.
• Individual or airline booking/s for our courses/services.

If you set up or use a Simtech Aviation FlightLogger account or sign a contract with Simtech Aviation using the third party software Docusign or HelloSign we will also collect data from you as part of your Online User Profile.

Through the use of your profile, information provided by you as a cadet/customer collects data and enables a guest profile to be created. This allows Simtech Aviation to enhance your experience while using the required data provided to maximise the standard of training. This data can be shared with the relevant aviation authorities as part of our compliance process.

When you communicate with us (via email, social media or our online chat service, or via traditional means) we collect the information you provide to assist in your query (for example contact information, course reference and external point of contact) and the contents of the relevant communication, which we use to resolve your query as well as for training and auditing/monitoring purposes.

You may access and update the information which we hold about you as a registered member on FlightLogger by logging in and accessing the relevant section of your account.

4. What personal information do we collect and retain?

Personal information means details which identify you or could be used to identify you, such as your name and contact details, your training records and purchase history.  It may also include information about how you use our websites and mobile applications. When you use our services you will need to provide us with your personal details, training records and bank details.

We collect the following categories of personal information:

• Information you provide to us in order for Simtech Aviation to complete and manage a booking you have made with us or a service you have requested from us.

Examples

Your name, title, address, email, contact details, date of birth, passport number, payment information

If you avail of one of Simtech Aviation’s courses for someone else we may collect your billing information but may communicate with the customer directly about their training.

We will know if you booked your course on simtech.ie or used another sales channel such as a flight school, airline or third-party contact.

• Information collected during your training period with us.

Example

We may collect information such as your interactions with staff and instructors before, during and after your training.

• Information about your travel arrangements.

Example

Details of your booking, travel itinerary, details of any additional assistance you require and other information related to your travel.

• Information about online registration and other interactions.

Examples

We will retain your information to ensure we interact with you appropriately if you have registered with us, either through FlightLogger or as a Registered User of our website and app. 

We will process your information if you have entered a competition and retain your information if you have interacted with us via social media (e.g. Twitter).

• Information about your use of our websites and mobile applications. For more details of the methods please see our Cookie Policy for details.

Examples

To help us to personalise your information and improve our website we collect information about your searches and the content you have viewed on our website using cookies and similar technologies. We will use previous web usage data stored within the cookie to personalise and understand you as a guest.

We are able to understand from your website usage/history that you have visited simtech.ie and searched for a training course but did not complete your booking.  We may use this information to contact you to offer more information about the booking and similar courses (unless you have opted out of receiving marketing materials).

• Information about your location from your device if you have been browsing on simtech.ie
  Example.

Identifying the county from which you are accessing the relevant website or application which will enable us to provide more relevant content and use an appropriate language.

• Your contact details and details of the emails and other electronic communications you receive from us.

Example

We may collect information as to whether a communication has been opened and if you have clicked on any links within that communication. We want to make sure that our communications are useful for you, so if you don’t open them or don’t click on any links in them, we know we need to improve those services;

5. What do we use your personal information for?

The main purposes for which we use your personal information are:

• to fulfil your training arrangements and deliver the services you have asked for

Example.
We will need to use your name, title, address, email, contact details, date of birth, passport number, your account details and payment information so that we can process bookings, fulfil your training requirements, take payment, provide information to relevant authorities (such as training records and certificates to the IAA/EASA) and so that Simtech Aviation staff and instructors know who is booked on a course.

• to validate our training requirements.

Examples.

If you have completed the required training at a recognised training organisation to allow you complete your current/future training at Simtech Aviation. Simtech Aviation uses IAA/EASA and ICAO guidelines.

• to send status updates and service communications to you.

Examples

We may send a form communication informing you your roster has changed, bus times have changed or if a simulator has technical issues resulting in potential downtime.

Even if you have opted-out of receiving marketing information from us, we may still send you communications about the courses you have booked to use, such as your APS/MCC or Type Rating training. These communications will help you get the most from the services we provide and may also contain options and other details about the services you will be using (e.g. transport and accommodation)

We may also send you communications about the services you have previously used, for example, where you experienced some form of issue or problem and we wish to contact you about it proactively in order to resolve it successfully.

• to help keep you safe when you train at Simtech Aviation as a legal and regulatory requirement under Irish law. 
  Examples

As a training provider there are regulatory obligations as a business Simtech Aviation must follow for the health and safety of all staff and guests on the premises.

• to carry out analysis and market research.

Example

We will analyse the way in which our sales channels, training and services are being used by cadets/customers so that we can understand how to improve the training experience and environment we offer and assist all those training at Simtech Aviation to do so to the best of their ability.

• to carry out marketing and keep you informed of Simtech Aviation products and services.

Examples

We may send you information about our training or additional courses and services by email (or other electronic communication).

We may tailor the content of our websites, applications, emails and other communications to ensure they are as relevant to you as possible.

To understand your training and career preferences and provide information about offers, upcoming courses/changes and additional courses options (unless you have opted out of receiving marketing emails).

If you’ve searched for aviation training previously but not booked we may remind you about our services via social media services (e.g. Twitter, Facebook) based on your query.

We may combine/match anonymised customer relationship marketing data with a third party (e.g. Google) so both companies can understand behavioural activities such as knowing other sites visited.

• To send you status updates and service communications.

Examples

Even if you have opted-out of receiving marketing information from us, we may still send you communications about the training you have booked with us. These communications will help you get the most from the services we provide and may also contain options and other details about the services you will be using (e.g. transport and accommodation).

We may also send you communications about the training you have previously used, for example, where you experienced some form of issue or problem and we wish to contact you about it proactively in order to resolve it successfully.

• To improve our websites, products and services.

Example

We may monitor the way that you and other customers use our website so that we can identify ways to improve the website experience.

• For management and administrative purposes
  Example

We may use and retain your personal information, including your purchase history, for administrative purposes, which may include for example, accounting and billing, auditing, credit or other payment card verification, anti-fraud detection / screening (including the use of credit reference agency searches and payment card validation checks) and systems testing, maintenance and development. We will also keep your training file on our systems for future audits for a period of up to 5 years.

• Covid testing
  Example
  Individuals who attend Simtech Aviation may be required to undergo a Covid19 Antigens Test throughout their time with Simtech Aviation. Their personal data will be shared with compliant and regulated medical professional/organisation (i.e. HSE, V1 Medical etc.), this data will include an individual’s name, phone number and email address in order to complete tests undertaken to detect COVID-19. At no point will Simtech Aviation have access to medical reports or the identity of those who complete the test. This information must be volunteered by the individual(s).

6. When will we send you marketing communications?

When we collect information directly from you, we may ask you if you do not want to receive our marketing communications.  If you choose to receive email marketing from Simtech Aviation, we can let you know about special offers, general Simtech Aviation updates and new courses.

You may receive marketing communications from us if you have trained with us (unless you have indicated that you do not wish to receive marketing communications). We will respect your choice as to what communications you wish to receive and how these are sent.  Please be aware that we do sometimes send marketing communications that promote a third party’s products and services as well as our own (for example, we may send Simtech Aviation communications promoting products or services of our course partners including Airline Prepared or Pre-Assessment Preparation).

We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. This enables us to send you only those offers and deals that we think will be of most interest to you.

How can you change what marketing communications you receive and how you receive them?

If you decide you would no longer like to be sent marketing communications you can change your mind at any time. The ways to stop being sent marketing communications are described below.

You can change your marketing preferences for Simtech Aviation marketing communications at any time:

• Once you receive a marketing email from Simtech Aviation, via the third party marketing website MailChimp, at the bottom of the email you will be able “You can update your preferences or unsubscribe from this list”. Then simply follow the onscreen instructions.

In addition, each marketing communication we send by email will also have an “unsubscribe” option which will allow you to stop you receiving further marketing emails.

We aim to action requests to stop being sent marketing communications within 24 hours of receiving those requests (but it may take up to 48 hours) and it is possible you will receive some marketing in the period prior to that change being made. This is very unlikely as we only occasionally send out marketing correspondence.

Please note that if you tell us that you do not wish to be sent further marketing communications, you will still receive service communications which are necessary, for example, to confirm your training/course booking or to provide you with a relevant status update.

Marketing to Children

We do not knowingly send marketing/promotional emails to children under the age of 16.

7. What is our legal basis for using your personal information?

Simtech Aviation will only process your personal information where we have a legal basis to do so. The legal basis will depend on the reason or reasons Simtech Aviation collected and needs to use your information. Under EU and Irish data protection laws in almost all cases the legal basis will be:

• because we need to use your information so that we can process your booking, fulfil your training arrangements and otherwise perform the contract we have with you; or
• because it is in Simtech Aviation’s legitimate interests as an aviation training provider to use your personal information in order to operate and improve our business as an aviation training provider; or
• because Simtech Aviation needs to use your personal information in order to comply with a legal obligation; or
• to protect the vital interests of you or another person; or
• because you have consented to Simtech Aviation using your information for a particular purpose.

More information on each legal basis is provided below.  In the event that processing of your data is subject to any other laws (other than EU and Irish laws) then the basis of processing your data may be different to that set out above and may in those circumstances be based on your consent (as defined according to those laws) in all cases.

Performance of a contract with you

It will be necessary for Simtech Aviation to use your personal information in order to complete a booking you have made with us. For example, we will need to use information such as your contact details and payment information in order to provide you with the training you have requested and paid for.

Legitimate Interests

As an aviation training organisation, Simtech Aviation has a legitimate business interest to use the personal information we collect in order to offer an effective service and carry out our business.
Example
We will carry out analysis and use data to improve and personalise your experience.

When needed for the conduct of legal claims.

We may send you emails about our latest offers/industry news if you have made a training requested or completed your training with us (unless you have opted out of receiving marketing emails).

Compliance with legal obligations

There are situations where Simtech Aviation is subject to a legal obligation and needs to use your personal information in order to comply with those obligations.

To protect the vital interest of you or other people

There are situations where we may need to use your personal information in order to protect the vital interests of you or another person.

Example
If we collect and process medical information in the event of a medical emergency and you are incapable of giving your consent.

Consent

Alternatively, we may collect and use your personal information where you have given your specific consent to us doing so. However, from an IAA regulation requirement, we must keep your training files and contact details on file for up to five years, before all hard copies are shredded and electronic data is deleted.
Example
We will rely on your consent where you have provided information to us voluntarily.

8. How long do we keep personal information?

As a general rule, we will store your personal information which you have provided for a maximum period of five years.

For example, where you book a course with/at Simtech Aviation we will keep the information related to your booking so we can fulfil the specific course/contractual arrangements you have made and after that, we will keep the information for a period which enables us to handle or respond to any complaints, queries or upcoming audits relating to the course in question.  The information may also be retained so that we can continue to improve your experience We will actively review the information we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or customer need for it to be retained. If you stop interacting with us as a customer, we will remove or anonymise information kept for that purpose after a maximum of 5 years.  When we have collected the personal information based on your consent and we have no other legal reason for retaining the information, if you then decide to withdraw your consent, we will delete your information as detailed below in Section 11(e)

9. Who do we share your personal information with?

Your personal information may be shared with third party suppliers/partners, such as our partner airlines including and not limiting to Aer Lingus, Stobart, CityJet, Air Dolomiti, Flybe and Sun Express and hotel providers including the Clayton Hotel. We share information with them so they can assist us in providing services to you and to understand your job status and training history when applying for a job within that company or as part of a booking reservation.

What countries will your personal information be sent to?

Your personal information may be sent to and stored by us and third parties in countries outside the country in which you are located and in particular outside the European Economic Area (“EEA”).

The nature of our business means it is often necessary for us to send your personal information outside the European Economic Area in order to fulfil your course arrangements. This occurs because our business and the third parties identified in “Who do we share your personal information with?” have operations in countries across the world.  For example, we work with companies such as Salesforce, HelloSign and FlightLogger who are located around the world, including their cloud and data centres.

In addition, we may transfer your data to parties in countries outside the country in which you are located to provide services to us.  This may involve sending your data to countries where under their local laws you may have fewer legal rights. However, wherever we store your information we will treat it in accordance with this Privacy Statement and the requirements of European and Irish data protection law which requires adequate safeguards to be put in place for transfers of data outside the EEA, unless a derogation permitted under European and Irish data protection law applies.  If you would like more information on these safeguards please contact https://www.dataprotection.ie or https://ec.europa.eu/info/law/law-topic/data-protection_en

10. How we keep your personal information secure

Simtech Aviation uses sonic wall firewall technology with internet security, intrusion protection, gateway antivirus and content filter.

If your browser supports SSL, and if you entered our website or app via our secure server access, then transmission of your personal data will be protected and will be encrypted as it travels from your computer/mobile device to Simtech Aviation. That includes credit/debit card information you enter to pay for your course/services.  When credit card data is received, the information is decrypted and processed in the same way as a normal credit card transaction would be processed by telephone.

If your browser does not support SSL, we recommend that you upgrade to the latest version of any browser to enhance the security of further transactions, otherwise the transmission of your personal data may not be protected and Simtech Aviation disclaims any responsibility in this regard.

Take a look through some easy to keep your card details safely and securely.  https://www.paysafecard.com/en-ie/security/

11. What is the policy on CCTV.

This policy relates to the use of Closed-Circuit Television (CCTV) systems on the Simtech Aviation premises – Kestrel House, Cedar Drive, Dublin Airport Logistics Park, St Margaret’s Road, Co Dublin.

The Simtech Aviation, Accountable Manager is accountable for the CCTV system overall, while the Engineering Manager is responsible for all technical aspects of the CCTV system. The CCTV system will comply and be regulated under Simtech Aviation’s CCTV Policy and GDPR requirements.

The CCTV system is installed externally for security purposes and the purpose of enhancing health and safety of all staff and visitors. CCTV surveillance at Kestrel House is operational 24/7 for the purposes of health and safety of staff, visitors and customers.  monitoring issues relating to public access, car parking and rear yard activities.

           Compliance with legal obligations

There are situations where Simtech Aviation is subject to a legal obligation and needs to use share its CCTV footage in order to comply with those obligations.

            To protect the vital interest of you or other people

There are situations where we may need to use your personal information in order to protect the vital interests of you or another person. Simtech Aviation owes a duty of care under the provisions of Safety, Health and Welfare at Work Act 2005 and associated legislation and utilises CCTV system and their associated monitoring and recording equipment as an added mode of security

Information obtained through the CCTV system may only be released when authorised by the Accountable Manager.

Example
If An Garda Síochána, is seeking a recording for a specific investigation, any such request made by An Garda Síochána is requested in writing. Any requests for CCTV images from An Garda Síochána are fully recorded.

The CCTV system and associated equipment is required to be compliant with this policy.  Recognisable images captured by CCTV systems are personal data. They are therefore subject to the provisions of the General Data Protection Regulation 2016.

Justification for using CCTV systems

General Data Protection Regulations requires that data is “adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed”. This means that Simtech Aviation needs to be able to justify the obtaining and use of personal data by means of a CCTV system. The use of CCTV to control the perimeter of the building for security purposes and health and safety reasons has been deemed to be justified by Simtech Aviation.

Notification of signage

A copy of this CCTV Policy is available to staff and visitors at reception visiting Kestrel House. This policy describes the purpose and location of CCTV cameras monitoring, a contact number for those wishing to discuss CCTV monitoring and guidelines for its use.

Adequate signage is placed at each location in which a CCTV camera is sited to indicate that CCTV is in operation.

Purpose of CCTV

Simtech Aviation has a statutory responsibility for the protection of its property, equipment and other plant as well as providing a sense of security to its staff and visitors to its premises. Simtech Aviation owes a duty of care under the provisions of Safety, Health and Welfare at Work Act 2005 and associated legislation and utilises CCTV system and its associated monitoring and recording equipment.  This added mode of security is for the safety and welling being of all staff and guests who visit Simtech Aviation.

The use of the CCTV system is conducted in a professional, ethical and legal manner and any diversion of the use of CCTV security technologies for other purposes is prohibited by this policy.

Example
CCTV will not be used for monitoring staff performance.

Storage and Retention

Accordingly, all images captured by the CCTV system are retained on the system and backed up on the cloud for a maximum of 30 days, except where the image identifies an issue and is retained specifically in the context of an investigation of that issue.

Who has access to the footage?

The retained images/recordings are stored in a secure environment with a log of access kept. Access is restricted to authorised personnel, including Simtech Aviation Engineer, Compliance and Accountability Manage which can be obtained/shared with An Garda Síochána.

A Data Protection request must be made by An Garda Síochána when a crime or suspected crime has taken place and/or when it is suspected that illegal/anti-social behaviour has taken place on the premises of Simtech Aviation.

Access Request

To exercise their right of access, a data subject must make an application in writing to Simtech Aviation.  Requests for CCTV footage must be made within 30 days of the relevant date / incident to ensure that footage has not been erased in accordance with Simtech Aviation’s retention policy for CCTV footage.  Footage requested within this time period will be retained for the purposes of the request. A fee shall not be charged for responding to such a request, unless deemed necessary and reasonable based on administrative costs.  Simtech Aviation must respond within 1 calendar month.

In giving an individual/organisation a copy of their data, Simtech Aviation may provide a still/series of still pictures, a tape or a disk with relevant images.  However, other images of other individuals will be obscured before the data is released.

CCTV reviews and amendments

The policy will be reviewed as required in light of any legislative or other relevant developments, taking cognisance of changing information or guidelines from the Data Protection Commissioner, An Garda Síochána, internal policies and Simtech Aviation’s Operations Management Manuals.

• Your legal rights in relation to the personal information we hold about you

Under data protection laws in the European Union and in Ireland, you have certain rights in relation to your personal information.  Responses to exercise your rights will be provided within one month and generally, there is no fee for making these requests. If your request is particularly complicated, we may extend the deadline for responding to two months, but we will let you know if this is the case.

We will handle all requests in accordance with applicable law. However, depending on the right you wish to exercise and the nature of the personal information involved, there may be legal reasons why we cannot grant your request.  Further explanation of those rights and the exceptions to them are set out below.

You may access and update the information which we hold about you as a previous/current or future customer who volunteered their data through website/social media or by traditional means such as in person to a Simtech Aviation staff member or over the phone.

Your rights include the following:

1. your right of access to your personal information we hold.

There are some limited exceptions to this right such as information relating to others who have not consented to the disclosure of their information and information which is legally privileged. Please see “Accessing your personal information” below for more details.

1. your right to ask us to stop sending you direct marketing.

To change your marketing preference please refer to the section “When will we send you marketing communications?” above.

1. your right to ask us to correct the personal information you have shared with us (the ‘right of rectification’) if that information is inaccurate. You may be able to update much of it yourself through your FlightLogger account (should you be a primary user of your account on FlightLogger) including personal and contact details. If you spot any inaccuracies that you can’t fix yourself, please email the details to info@simtech.ie . We are not able to amend any data that has been created as a result of a transaction with us e.g. course booking.

1. your right to withdraw consent to processing of data where consent is relied upon by us as the basis of processing.

Please note that if you withdraw this consent it may mean we will not be able to provide all or parts of the services you have requested from us and in some circumstances you may not be able to cancel your booking or obtain a refund of any charges you have paid.

1. your right to ask for personal information which identifies you to be removed (anonymised)(also known as the “right to be forgotten”) without undue delay in certain circumstances, for example:
   • when you withdraw your consent to processing in circumstances where we have collected the personal information based on your consent and we have no other lawful basis to continue to retain the information;
   • where you object to the processing and there are no overriding legitimate grounds for us to continue the processing (See point f below);
   • where your personal data has been unlawfully processed.

For more information on the basis on which we process your personal information see What is our legal basis for using your personal information?).

Example
As an aviation training organisation regulated by both the IAA/EASA we must maintain training and contact details of all cadets/pilots who book directly onto a Simtech Aviation course for a period of five years, due to auditing legal requirements.

Please note while we will endeavour to erase data in circumstances where an individual has exercise this right and we don’t need the data anymore some personal data sets are impossible (or infeasible) to edit to remove individual records, e.g. a server backup or a piece of microfiche.

1. your right to object to the use of your personal information where the basis of our processing the information is our legitimate interests (unless it is needed for dealing with legal claims or we have other compelling legitimate reasons that override your rights)

1. your right to object to the processing of your personal information for direct marketing purposes including profiling for the purposes of direct marketing.

Please note if you exercise this right in relation to all Simtech Aviation marketing communications we will no longer send you marketing communications however we will still send you communications about the services/courses you have booked to use, such as your course and/or accommodation and transportation itinerary. These communications will help you get the most from the services we provide.

In addition, we will also need to retain and process some of your personal information to make sure you are excluded from future marketing communications.

1. your right to object to automated processing which has a legal effect or similarly significant effects.

• Automated Decision Making refers to a decision which is taken solely on the basis of automated processing of your personal data. This means processing using, for example, software code or an algorithm, which does not require human intervention.
• You have certain rights in respect of automated decision making: you can ask not to be subject to a decision which is based solely on automated processing where that decision produces legal effects concerning you (such as the rejection of a claim); or otherwise significantly affects you. In such situations, you can also obtain human intervention in the decision making, and we will ensure measures are in place to allow you to express your point of view, and/or contest the automated decision.
• Your right not to be subject to automated decision making does not apply where the decision which is made is: (a) necessary for entering into or performing a contract with you; (b) authorised by law and there are suitable safeguards for your rights and freedoms; or (c) based on your explicit consent.  However, in these situations you can still obtain human intervention in the decision making, and we will ensure measures are in place to allow you to express your point of view, and/or contest the automated decision. A Guest can do this (i.e. obtain human intervention in the processing of their refund claim) either by (i) using this form to update their existing issue that they have already submitted.

• How can you exercise your legal rights in relation to your personal information?

Accessing your personal information

You can view the following information we hold on you on a self-service basis:

• If you have provided your data directly to Simtech Aviation, you can contact gdpr@simtech.ie and ask for a full report of what personal data we have on file. This includes contact details and training records – up to a period of 5 years.
• If you are provided with a FlightLogger account, you can view personal information held within your FlightLogger profile by logging into your account.

Alternatively, if you wish to access other personal information, we hold about you or exercise any other rights we recommend that you make your request in writing (Simtech Aviation, Cedar Drive, Kestrel House, Dublin Airport Logistics Park, St Margaret’s Road, Co. Dublin) and include the following information with your request:

• Your name
• The email address used as your primary point of contact (if applicable)
• Details of your request

We need corroborating information to establish your identity.  You must also provide:

• In all cases, a photocopy of your passport or driving licence, so that we can verify your identity
• proof of address (e.g. utility bill) dated within the last 6 months (if you wish to receive a response in hard copy)
• if you are applying on behalf of another person then signed authority (in a form satisfactory to Simtech Aviation) from the individual is required

Any details which may help us locate the information which is the subject of your request, for example:

• Training course and/or dates of training.
• Name/Primary email address.
• Telephone recording details (identifier number, the number you call from, the number and option you dialled, the date and time of your call(s).

Please send your request to: gdpr@simtech.ie
Or alternatively send your request in writing to:

Kilian Hanratty
GDPR Champion
Simtech Aviation
Kestrel House,
Cedar Drive,
Dublin Airport Logistics Park,
St Margarets’s Road,
Co Dublin

If you contact our ‘contact us’ section of the website with a GDPR inquiry, this will be sent directly to info@simtech.ie before being referred to gdpr@simtech.ie

• How will we inform you of changes to this Privacy Statement?

If we change this Privacy Statement, we will let you know about the changes by publishing the updated version on simtech.ie . We are committed to protecting and respecting your privacy and will continue to do so in any future changes we make to this Privacy Statement.

This Privacy Statement came into effect on March 16^th 2020 replacing our previous Privacy Statement. This Privacy Statement applies to all information we process about you in connection with your relationship with us as a customer or potential customer.

Please write to the Data Protection Officer if you would like to find out more about any matters to do with this Privacy Statement.

• How to get in touch with us and your right to complain to our supervisory authority?

If you have any questions about this policy please send them to the Data Protection Officer. The Data Protection Officer for Simtech Aviation can be contacted at gdpr@simtech.ie or in writing to Data Protection Officer, Simtech Aviation, Kestrel House, Cedar Drive, Dublin Airport Logistics Park, County Dublin, Ireland. We work hard to handle your information responsibly.

If you are unhappy about the way we do this please contact the Simtech Aviation Data Protection Officer who will address your concerns. We hope that we will be able to resolve any concerns you may have.

However, you have a right to complain to the Data Protection Commissioner at:

Data Protection Commissioner, Canal House, Station Road, Portarlington, R32 AP23 Co. Laois

https://www.dataprotection.ie/docs/Contact-us/b/11.htm

Last updated 06/01/2021 – Kilian Hanratty