GENERAL PROVISIONS

Contact details of the Data Controller UAB AviationCV.com: number of legal entity 302615625, address Saltoniðkių g. 29, 08105 Vilnius, Lithuania E-mail privacy@aerotime.aero (hereinafter “We”, “Ours”) stores the personal data of its customers (hereinafter Below you can read how we handle the data you submit to us.

In processing the personal data, we responsibly comply to the regulation No 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (GDPR), the Republic of Lithuania Law on the Legal Protection of personal data, the Republic of Lithuania Law on Electronic Communications and other directly applicable legal acts regulating the protection of personal data, as well as instructions from competent authorities.

If you have any questions regarding this Privacy Policy or requests regarding the processing of your personal data, please send us an email to: privacy@aerotime.aero.

TO WHOM THE PRIVACY POLICY APPLIES?

This Privacy Policy applies to all Data Controller’s Websites https://www.aviationcv.com; https://www.aerotime.aero/; https://www.airconvention.com/;europe.airconvention.com; https://asia.airconvention.com; https://www.pilotcareershow.com| and any service provided by the Company that is provided by the Data Controller, including the website support, regardless of the devices used by the customer of the Data Controller and/or the visitor to the website to visit the website or use the Services provided by the Data Controller. The terms and conditions of the Privacy Policy apply to you every time you access the content and/or the service we provide, regardless of which device (computer, cell phone, tablet, TV, etc.) you are using.

This Privacy Policy does not apply to references to other entities websites provided on the Website, therefore we recommend that you read the personal data processing rules applied on such websites.

ESSENTIAL CONCEPTS OF PRIVACY POLICY

Data controller – UAB AviationCV.com.

Websites managed by the Data Controller – https://www.aviationcv.com; https://www.aerotime.aero/; https://www.airconvention.com/;europe.airconvention.com; https://asia.airconvention.com; https://www.pilotcareershow.com

Terms and Conditions are the terms of the contract for our website visitors/customers regarding the use of the services provided by the Data Controller.

Data Recipient means a natural or legal person who uses the services of the Data Controller for the purpose of searching for, or screening for its own needs or the needs of its customers or in order to obtain other services provided to employers by the data Controller. The Data Controller transmits or makes available your data to these persons in accordance with this Privacy Policy and Data protection regulation including GDPR requirements.

Services – all services provided by the Data Controller to jobseekers, including employment services, training, organisation thereof, retraining, upgrade or change of qualification, jobseeker services, services for employers looking for employees services for employed persons taking part in the carrier improvement or other events related to aviation organised by the Data Controller, other services offered by the Data Controller to which you agree.

WHAT PERSONAL DATA DO WE PROCESS AND FOR WHAT PURPOSE?

For the purposes of administering the www.aviationCV.com account and other Services provided for jobseekers by the Data Controller, we process the following personal data:

• Full name;
• Contact details, including correspondence address, telephone number, email address;
• Place of residence;
• Residential address
• Nationality;
• Work permit, visa and information pertaining to these documents;
• Personal identification data;
• Licenses and records;
• Height;
• Weight;
• Family status information;
• Information about former workplaces (company name, position title, professional experience);
• References from former workplaces;
• Licenses or certificates of qualification related to the specifics of the work;
• Other work experience;
• Education information (training institutions, types of qualifications obtained and dates of acquisition);
• Date and time of last login;
• Date of registration on the website;
• Payment details if you are making payments;
• Health data if required during the recruitment process;
• Criminal record information (where such information is required to provide the Services);
• Information about accidents (incidents) experienced during work (when such information is required in order to provide the Services);
• Other information provided by the user of the Data Controller and required to provide the Services.

For the purpose of direct marketing, including profiling, carried out by the Data Controller, we process the following data of natural and legal persons (their staff):

• E-mail address;
• Telephone number.

When sending employment-related notices, the following data may be processed by the customer of the profession concerned:

• Aircraft type
• Position /
• Category (pilot, etc.)
• State
• In some cases, the age if the prospective employer has set an age requirement.

For the purpose of the provision of services by the Data Controller on the websites www.airconvention.com, europe.airconvention.com, asia.airconvention.com, we process the following personal data:

• Name;
• Surname;
• E-mail address;
• Tel.;
• Name of the company represented
• Job title
• Additional information provided by the customer/visitor and required to provide the Service.

For the purposes of administering the www.areotime.aero user account and publishing informational articles, we process the following personal data:

• Name;
• Surname
• E-mail address.
• Optional are the data that a person may voluntarily submit when creating a profile:
• Image;
• Description of oneself;
• Social account data;
• Information on published articles (name of the article, date of publication, reviews collected);
• Date and time of last login;
• Last login IP address;
• Login username.

For the purpose of registration for the event of www.pilotcareershow.com, the following data is processed:

• Name,
• Surname;
• E-mail address;
• License type;
• Information about the country issuing the licence
• Information on professional experience (aircraft type, number of hours, etc.)
• Telephone number;
• Job title.

The following data is processed for the purpose of administering requests made on the websites:

• Name,
• Surname;
• E-mail address;
• Telephone number;
• Information provided in the request.

Your contact information and the content of the consultation may be processed for the purpose of live chat.

In addition to the information you provide, we may collect information about your use of our websites in order to improve our analytics, services and the website quality. For example, we may collect the following information:

• Device information, i.e. IP address, version of the operating system and parameters of the device that you use to access content/products.
• Login information, i.e. duration and length of your session, search terms that you enter on our site, and any information stored in the cookies we have identified on your device (the cookie policy is provided below).
• Location information, i.e. your device's GPS signal, or information about the nearest Wi-Fi hotspots and mobile communication towers that may be passed on to us by using our site content.

Information from third-party sources

• We may receive information about you from public and commercial sources (as permitted by applicable law) and associate it with other information we receive from you or about you. We can also receive information about you from third-party social networking services when you sign in, for example through the Facebook accounts of UAB AviationCV.com.

HOW DO WE OBTAIN YOUR DATA AND ON WHAT LEGAL BASIS DO WE PROCESS IT?

• When you submit data to us through our websites;
• By concluding both electronic (Term and Conditions) and paper service or other contracts;
• During events/meetings, by submitting business cards or other personal data;
• By email when contacting at our general email addresses: info@aviationcv.com; info@aerotime.aero; recruitment@aerotime.aero; info@airconvention.com; applications@aviationcv.com; pilotcareer@aviationcv.com;
• When you contact by email any of our employees;
• When you agree to provide your data, for example by subscribing to a newsletter;
• When you access your account through third party accounts (Facebook, Linkedin, Google);
• When you agree to the installation of cookies on your device;
• Or otherwise, when you provide to us, or when we obtain information from third parties with your consent.

Basics of lawful management:

Contract (sale/purchase of products/services);

Consent to receive offers and news from us and our affiliates https://aviasg.com/ en/media/logos, event invitations (for direct marketing purposes). You may revoke your consent to process their personal data at any time. Unless the Company has any other legal basis for processing personal data, the Company will terminate the processing of such personal data and destroy the data;

Legitimate interest is to respond to your queries, to provide the information you request, to improve our service quality and products, statistics and analytics, personalised services, etc.

Implementation of legal obligations (accounting, archiving, data breach notification, etc.).

DIRECT MARKETING

For direct marketing purposes, we process data in the following cases:

• when we obtain your explicit consent to such processing;
• when you are a customer of us who have not objected to the processing of personal data for the purposes of direct marketing, marketing of similar services or products.

For the purpose of direct marketing, we process the following of your personal data: full name, email address, phone number, location, work experience.

With you expressed consent to receive direct marketing messages or newsletters you subscribe, you agree to receive the news of the Data Controller and its affiliates about new services, products, invitations to events of the Controller and related companies https://aviasg.com/en/media/logos.

We inform you that Visitors may at any time refuse our newsletters or other promotional messages by clicking on a link to this in our outgoing newsletters and/or messages.

You can also at any time refuse to receive information about events or any other information we send by sending an email to privacy@aerotime.aero.

HOW LONG WE WILL RETAIN YOUR PERSONAL DATA?

We will retain your personal data for as long as necessary to achieve and fulfil the purposes set out in this Privacy Policy, taking into account the nature of the services provided to you and the contracts you enter into, unless longer storage of personal data and related documents is required by applicable laws and regulations and is necessary (e.g. mandatory time limits for accounting and others, etc.) or is required for the defence of the Data Controller's legitimate interests in judicial or other public institutions.

We ensure and take all necessary measures to avoid storing outdated or unnecessary information about you and to keep your data up-to-date and accurate.

We will retain and use your data for direct marketing purposes for 3 years after your last active step. We consider your active steps as showing that our Services are relevant to you. We consider the following to be the last active step: giving a consent, ordering, purchasing, requesting a product or a service, logging in to an account on a website.

HOW DO WE PROTECT YOUR DATA?

We responsibly implement appropriate organisational and technical data security measures intended for the protection of personal data against accidental or unlawful destruction, alteration and disclosure as well as against any other unlawful processing. The security measures we implement include the protection of personnel, information, IT infrastructure, internal and public networks as well as office buildings and technical equipment.

We recommend that you additionally comply with the following minimum safeguards for personal data protection:

• do not visit suspicious websites;
• do not open links of uncertain origins;
• update your software regularly;
• independently take care of using antivirus protection.

Unfortunately, the transmission of any information on the Internet is not completely secure. Although we are endeavouring to protect your personal data, it is not possible to ensure the full security of personal data when you provide the data on the Website, therefore, you must assume the risks associated with the transfer of personal data to the Website.

In the event of personal data breach of security that could seriously jeopardise your rights or freedoms and determine the circumstances with which unauthorised access to personal data has been obtained, we will immediately inform you about it.

TO WHOM IS YOUR DATA ARE DISCLOSED?

Your personal data may only be accessed to a limited number of our employees and to our company's IT, legal, personnel service providers, and only to the extent necessary for the proper processing of your personal data, and subject to strict confidentiality requirements.

To achieve the purposes set out in this Privacy Policy, we may transfer or grant access to your data to the following data recipients/processors:

• Certain technical data on your visits on the website (IP address, cookies, technical information of your browser, other information related to the browser's activity and browsing the site) may be transmitted or made available to the website's for statistics, analyzes and related purposes both for entities operating in the EU and outside the EU (e.g., when we use the Google Analytics service).
• For the provision of some of our services, data can also be transferred to the companies of the Avia Solution Group, which we belong to (https://aviasg.com/en/media/logos), including those located outside the European Economic Area (EEA).
• within the interest and according to the order of data processors who provide services and process your data on our behalf (e.g. consultants, etc.) We note that our data processors process your data only on the basis of our explicit instructions, by committing to ensure the proper processing of data protection, organizational and technical measures compliant to confidentiality and security requirements, as specifically discussed in the agreements concluded between us and the service providers regarding the processing of data.
• Entities entitled to receive information in accordance with legal requirements (e.g. courts, state and municipal authorities, etc.) only to the extent necessary for the proper performance of the requirements of the legislation in force.
• For data recipients (e.g. for employers, training companies, selecting or employing you, providing training etc.) to whom we transfer data in order to provide you with access to employment, training, accommodation, permits, etc. Legal basis of data transmision is your application to the appropriate position, performance of the service agreement or consent. The most common category of recipients of our data is the various companies in the aviation services sector, who are looking for staff, who teach staff or upgrade a qualification of a specific profession. However, we always transfer your data in accordance with the highest standards of personal data protection.

Data transfer outside the EU and EEA

Please note that in non-EEA states, personal data may be subject to less protection than within the EEA, but we carefully evaluate the conditions under which such data will be processed and stored after being transferred to the above-mentioned entities.

Please note that if the European Commission has determined that the third country, territory or one or more specified sectors in that third country or international organization concerned provides an adequate level of data protection, the transfer must take place in the same manner as in the EU. Please be informed that you can have access to the information as to the states in respect of which the decision of the European Commission has been taken, here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.

In other cases, we take all necessary measures to ensure that your data is transferred to the recipient safely processing the data. The tools we use: a contract with a non-European recipient of personal data includes specific clauses for the secure processing of the data. In certain cases, we ask for your consent to transfer your data outside the Republic of Lithuania, the EU or the EEA.

RIGHTS GUARANTEED TO YOU

We guarantee the implementation of these rights and the provision of any related information at your request or in case of your query:

• know (be informed) about the processing of your personal data;
• to get access to your personal data which are processed by the Data Controller;
• request correction or addition, adjustment of your inaccurate, incomplete personal data;
• require the destruction of personal data when they are no longer necessary for the purposes for which they were collected;
• request the destruction of personal data if they are processed illegally or when you withdraw your consent to the processing of personal data or do not give such consent, when is necessary;
• disagree with the processing of personal data or withdraw the previously agreed consent;
• request to provide, if technically possible, the provision of your personal data in an easily readable format according to your consent or for the purpose of performing the contract, or request the transfer of data to another data controller.

In order to exercise your rights, please send us an e-mail to: privacy@aerotime.aero or directly. Upon receipt of your request, we may ask you to provide proof of identity, as well as any additional information required by us for the request, which we undertake to delete after identification.

Upon receipt of your request, we will respond to you within 30 calendar days of receipt of your claim and the due date for submission of all documents necessary to prepare the answer.

If we think we need to, we will stop the processing your personal data, except for storage, until your application is resolved. If you have legally waived your consent, we will immediately terminate the processing of your personal data and within no more than 30 calendar days, except in the cases provided for in this privacy policy and in the cases provided for by law when further processing of your data is binding on us by the legislation in force, the legal obligations we are facing, court judgements or binding instructions from the authorities..

By refusing to comply with your requirement, we will clearly indicate the grounds for such refusal.

If you disagree with our actions or the response to your request, you can complain to the competent state authority – the State Data Protection Inspectorate (for more information – www.ada.lt). In all cases, we recommend that you contact us before making a formal complaint so that we can find the right solution.

CONTACT US

If you have any request concerning the processing of your data or any question relating thereto, please email us at privacy@aerotime.aero or contact us at Saltoniškių g. 29, Vilnius, Republic of Lithuania.

Our Data Protection Officer's contacts: privacy@aviasg.com

HOW DO I LEARN ABOUT CHANGES TO THIS POLICY?

This Privacy Policy is reviewed at least once every two years. Once we update our Privacy Policy, we will notify you of the update by posting a notice on a specific website or social networking accounts. If you login or use our content and/or services after posting such notice, we will assume that you agree to the new requirements specified in the update notice.

This Privacy Policy applies from the date it is posted on the Website. Last review of the Privacy Policy: 2 August 2019

HOW DO WE USE COOKIES?

In order to improve your experience of visiting the websites, we use cookies – small pieces of text information that are created automatically when you browse the site, and stored on your computer or other terminal device. The information collected by the cookies allows us to provide you with the opportunity to browse through more convenient, attractive offers and learn more about the behaviour of our website users, to analyse trends and improve both the website, your service, as well as the services provided by the Data Controller.

You can choose whether or not you want to accept cookies. If you do not agree that cookies are stored on your computer or other end device, you can change your web browser settings and turn off all cookies or turn them on/off one by one. However, please bear in mind that in some cases this may slow down the speed of browsing, restrict the functionality of certain sites or block access to the website. Further details can be found on AllAboutCookies.org| or www.google.com/privacy_ads.html.

The information we collect using cookies is used for the following purposes:

• Functional cookie usage and service provision. Cookies are very important for the operation of our website and electronic services, and they ensure the smooth use of their experience for the consumer. For example, if the user so requests, he does not need to enter his full name, password or other data every time he connects.
• For service development. By monitoring the use of cookies, we can improve the functioning of our website and electronic services. We receive information, for example, about which parts of our website are most popular, to which websites users connect from our site, from which websites they come to our site, and how much time users spend on our site.
• Usage analysis. We use cookies for statistical data on the number of users visiting our websites and for the use of electronic services for the accumulation and evaluation of the effectiveness of advertising. We can collect information, for example, for emails and newsletters for marketing purposes, in order to find out if the emails were opened and whether they prompted users to take any action, such as whether the user clicked on the link provided in the letter, on our website.
• Targeted marketing orientation. By using cookies, the Company can collect information to provide a specific browser or ad serving content by creating different targeting groups; All information on the cookies used by the website, their purpose, validity and the data used is provided given below:

Cookies used on the website:  Cookie Policy

Websites may contain links to third-party websites, products and services, as well as social network extensions (such as Facebook plug-ins for social networks). Third-party services or applications provided on our websites are subject to the privacy notice of the respective third party. We encourage you to familiarize yourself with the privacy practices of such third parties.