Privacy Policy | AviationCV

WHO ARE WE AND HOW YOU CAN CONTACT US

Contact details of the Data Controller: UAB AviationCV.com, number of legal entity 302615625, address Dariaus ir Girėno str.. 21, 02189 Vilnius, Lithuania, e-mail address privacy@aerotime.aero (hereinafter “We”, “Ours”, “Company”) process the personal data of the users of it’s services, visitors of managed websites (www.aviationcv.com, www.aerotime.aero, (hereinafter – the Websites), individuals who have been active on its social media accounts, persons participating in the campaigns and content creation organized by the Company, persons who have agreed to receive it’s marketing messages, promotions and other outreach activities (hereinafter - you, your) personal data in accordance with the provisions of the legal acts regulating the legal protection of personal data and applying the highest technical and legal standards of protection and taking all necessary measures to prevent possible breaches of personal data protection. This Privacy Policy (hereinafter referred to as the "Privacy Policy") sets out the basic rules for the collection, processing and storage of your personal data and other information related to you, the scope, purposes, sources, recipients of your personal data and your rights as a personal data subject and other important aspects of your use of the Company’s services. This information is important, so we hope you will read it carefully.

As used in this Privacy Policy, the term “personal data” (the “Personal Data”) means any information about you relating to you as a natural person, a data subject whose identity is known or can be directly or indirectly identified through the use of certain data (e.g. name, surname, personal identification number, address, telephone number, etc.).

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.

In the event that you provide us with personal information other than your own (for example, identifying another person as a beneficiary), please inform them of this Privacy Policy and its contents.

If the user of the services is a legal entity, this Privacy Policy applies to natural persons whose personal data is transferred to us by a legal entity. The user must duly comply with Art. 14 of the GDPR. to inform data subjects (managers, beneficiaries, representatives, etc.) about the transfer of their personal data to the Company.

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

By visiting the Company's websites and / or using the information contained therein and / or our services, you acknowledge and confirm that you have read and understood this Privacy Policy.

TO WHOM THE PRIVACY POLICY APPLIES

This Privacy Policy applies to all ours Websites and any service provided by the Company or other activities of the Company where personal data is being processed.

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 links to other entities websites provided on our websites; therefore, we recommend that you read the personal data processing rules applied on such websites.

WHAT PRINCIPLES DO WE COMPLY TO?

When processing your personal data, we:

comply with current and applicable legislation, including the GDPR;
we will process your personal data in a lawful, fair and transparent manner;
we will collect your personal data for specified, clearly defined and legitimate purposes and will not continue to process it in a way incompatible with those purposes, except to the extent permitted by law;
take all reasonable steps to ensure that personal data which are inaccurate or incomplete, having regard to the purposes for which they are processed, are rectified, supplemented, suspended or destroyed without delay;
we will keep them in such a form that your identity can be established for no longer than is necessary for the purposes for which the personal data are processed;
we will not disclose or disclose personal data to third parties except as provided in the Privacy Policy or applicable law;
ensure that your personal data is processed in such a way as to ensure the appropriate security of personal data through appropriate technical or organizational measures, including protection against unauthorized or unlawful processing of personal data and against unintentional loss, destruction or damage. Contact details of our Data Protection Officer: privacy@aerotime.aero.

WHAT PERSONAL DATA, FOR WHAT PURPOSE AND BASIS DO WE PROCESS

The purpose of the processing of personal data. Why we process personal data?

The categories of processed personal data. What kind of categories of personal data we process?

On what legal basis do we process personal data?

The period of processing

Administering of our Websites

When you visit our Websites, data about your browsing on the Websites is collected using cookies. We use necessary / technical cookies to ensure the proper functioning of the Websites and / or other third-party cookies in order to improve your browsing experience (i.e. to consider your needs, to continuously improve the Websites and to make offers that suit your interests)

Data using cookies and similar technologies related to Internet browsing, etc. are collected (processed) in accordance with Article 6 Part 1. a) of the GDPR, i. e. with your consent (except for necessary cookies)

You can find more information about cookies and their storage terms in the Cookies Policy on our Websites

Providing you with news, promotions and information

We process the following personal data: your name, surname, email address, phone number, company name. If you agree to subscribe or otherwise receive our newsletter, we will use your email address for general and / or individual marketing and we will contact you for these purposes. The information collected will only be used for direct marketing. When submitting joint marketing offers, you will be sent general information that we will share with all our customers. In some cases, when we want to send to you personalized marketing information, we might use additional data for this purpose, such as your age, your job position, your companies’ location

Personal Data for direct marketing is processed in accordance with Article 6 Part 1. a) of the GDPR, i. e. with your consent or Article 6 Part 1. f) of the GDPR, i. e. our legitimate interest to offer you a similar goods/services to ones you have purchased / used from us and to get your feedback about purchased goods/services

Your data will be used for direct marketing purposes for 3 years after your consent is obtained or until you withdraw your consent. We consider you to be our customer:
– 3 years after you used our service

Providing you with commercial offers

We might process name, surname, company, position, contact details

Personal Data is processed in accordance with Article 6 Part 1. f) of the GDPR, i. e. our legitimate interest to offer advisory, recruitment, event, media and content services

Collected data will be stored for 6 months if no business relations agreed

Responding to your general enquiries

Our Websites provide contacts where you can contact us to consult us on issues that concern you. We will accept, review and respond to all your messages. If you contact us by e-mail, regular mail, using the contact form function on our Websites or social networks, we will process the following Personal Data of yours: your name, surname, e-mail, phone number, postal address, company and position (if applicable) and the text of the correspondence and / or attached documents as well as any other information you provide to us on the Websites or social networks or in any other way. This data will be processed for the administration of your enquiry. Please note that we may need to contact you by mail, email, so be sure to notify us of any changes to your Personal Data

All Personal Data you provide when communicating with us is used only for the above purposes and to view messages and to administer (manage) communication flows and provide you with a response. We will process the said Personal Data in accordance with Article 6 Part 1. a) of the GDPR, i. e. with your consent, which you express by contacting us by e-mail, mail, contact form on our Websites or social networks

Communication with you will be handled until the enquiry is fully processed and stored for 3 months from the date of the last communication with you

Selection of candidates for employees

We process name, surname, address, e-mail address, telephone number, education, additional qualifications, work experience, etc. information voluntarily provided by the candidate

Collection and use of data are based on your consent (Art. 6 (1) (a) of the GDPR).

3 months or until withdrawal of consent

Sending you important communication regarding the Websites

If you register on our Websites, we will send you emails and messages via the Website’s messaging system for the purpose of providing important notifications such as Terms of Use, Privacy Policy changes

Legal basis for the collection and use of data is the performance of a contract (compliance with our Terms of Use) to which you are party (Art. 6 (1) (b) of the GDPR) and compliance with the legal obligations to which AviationCV.com is subject (Art. 6 (1) (c) of the GDPR)

We will process your Personal Data collected for this purpose during the use of your account

Registration on our Websites using third parties account details

If you register using your Google Ireland Ltd. (Ireland), Google LLC (USA) (“Google”), Meta Platforms Ireland Ltd. (Ireland), Meta Platforms, Inc. (USA) (“Facebook”), Twitter Inc. (USA or LinkedIn (USA) account or later on decide to connect your Google, Facebook, Twitter or LinkedIn account to your www.aviationcv.com or www.aerotime.aero account, you will be transferred from our Platform to the website of Google, Facebook, Twitter or LinkedIn and asked to enter the log-in details for your Google, Facebook, Twitter or LinkedIn account.

The data we obtain from Google, Facebook, Twitter or LinkedIn will be used to set up your account (full name, email address, account ID, profile photo when applicable). This means that we will use the member name of your Google, Facebook, Twitter or LinkedIn account as the member name for your account. Other data obtained from Google, Facebook, Twitter or LinkedIn will not be visible on the Platform.

Collection and use of data are based on your consent (Art. 6 (1) (a) of the GDPR).

We collect and use your personal data for this purpose until the deactivation of your Website account or for 3 years of inactivity on your account

Administering your www.aerotime.aero account, publishing informational articles and providing you with the services

Using additional services provided by the Company via www.aerotime.aero Website requires you to create a personal account. For this reason, we may ask you to provide us with the Personal Data to be used to contact or identify you: your name, surname, e-mail. After creating an account and using our services We process information on published articles (name of the article, date of publication, reviews collected), any other data you voluntary submit when creating a profile (such as your image, description of yourself)

To manage your registration as a user of the Website, we will process all Personal Data you provide only for the above purposes. We will process the said Personal Data in accordance with Article 6 Part 1. a) of the GDPR, i. e. with your consent, which you express by submitting and entering any voluntary information on the Website; and b) in order to conclude and / or perform a contract concluded with the data subject. Terms of Use of our Website is considered to be a contract in a meaning of this Privacy Policy To administer your account, provide and maintain our service on the Website to you as a registered user, including to monitor the usage of our service, your Personal Data is processed in accordance with Article 6 Part 1. b) of the GDPR, i. e. in order to conclude and / or perform a contract concluded with the data subject; and f), i. e. our legitimate interest to keep our services up-to-date, safe and free of errors, including implementation of new features and versions

We will delete your account and other related information to your account on our Website after 3 years of inactivity on your account

Administering your www.aviationcv.com account and informing the candidate about the potential jobs

Your name, surname, contact data, year and month of birth, work permit, visa and information related to these documents, licences or certificates of qualification related to the specifics of the work, information about and references from former workplaces and work experience, education information

We will delete your account and other related information to your account on our Website after 3 years of inactivity on your account

Introducing and presenting a potential candidate to the prospective employers

We will process the said Personal Data in accordance with Article 6 Part 1. a) of the GDPR, i. e. with your consent, which is provided by you at the time of creation of your www.aviationcv.com account or when you submit the application and CV for open positions

We will process your personal data during the recruitment process and 2 months after it.

If you are unsuccessful in your application with us (or if you reject the position), but you would like to be in the database of the candidates, under your separate consent the personal data will be stored for 2 years from receiving the consent.

For the purpose of registration for the recruitment event or career show

Your name, surname, email address, telephone number, name of the company represented, job title, other information provided by you that we might need for the provision of services

We will process the said Personal Data in accordance with Article 6 Part 1. a) of the GDPR, i. e. with your consent, which you express by submitting the registration form online

Your data will be deleted once the event is completed

Client Verification and Onboarding Procedure

We process the following personal data: full names, date of births, other identification details (citizenship, copies of passport/ ID, proof of living address, bank information, contact details, source of wealth/ funds) of the members of the Board of Directors, directors and secretaries (e.g., CEO, COO, CFO, Deputies, Heads of departments), persons assigned to represent the Party, shareholders with more than 25 % ownership and ultimate beneficial owners, client’s declarations’ data regarding compliance with trade restrictions and sanctions

Personal Data for Client Verification and Onboarding Procedure is processed in accordance with Article 6 Part 1. f) of the GDPR, i. e. our legitimate interest to fulfill the requirements for money laundering and financing terrorism prevention, prevention of corruption, bribery and fraud, international, US, UK sanctions (restrictions), to verify the liability of the parties

We will process the Personal Data collected for this purpose for 5 years

Concluding contracts with contractors

We may process name, surname, contact information, position, signature, other information required for negotiations, concluding and performing of contracts

We will process this Personal Data of yours in accordance with Article 6 Part 1. b) of the GDPR, i. e. to conclude a contract with you and perform it, as well as Article 6 Part 1. c) of the GDPR., i. e. we are subject to a legal obligation to keep contracts and accounting documents and Article 6 Part 1. f) of the GDPR, i. e. our legitimate interest in asserting and / or defending our legal claims (where applicable)

We will process the Personal Data collected for this purpose for 10 years

Talent acquisition for campaigns, content creation, collaborations, Award recipients

We may process name, surname, contact information, image, other information provided by talents participating in campaigns, interviews, collaborations, Aviation Achievement Award recipients

We will process the said Personal Data in accordance with Article 6 Part 1. a) of the GDPR, i. e. with your consent

We collect and use your personal data for this purpose as long as there is the continuity of our business

If you do not provide personal data, the provision of which to the Company is necessary to ensure compliance with the requirements of legal acts and / or the conclusion and / or performance of the contract, we will not be able to provide you with services or conclude another transaction.

DIRECT MARKETING, PROMOTIONS AND OTHER OUTREACH ACTIVITIES

Direct Marketing, promotions and other outreach activities of UAB „AviationCV.com“ include AeroTime Recruitment, AeroTime Events, AeroTime Pilot Training, AeroTime Advisory, AeroTime Content and AeroTime News products and services.

All UAB „AviationCV.com“ products and services has special offers and product-related information that users will be notified by the email. In Example we are sending events invitations, job offers and newsletters on various AeroTime Hub services, as well other information.

For direct marketing, promotions and other outreach activities purpose, we process your personal data in the following cases:

when we obtain your explicit consent to such processing;

With your expressed consent you agree to receive direct marketing messages, newsletters, promotions and other outreach activities from UAB AviationCV.com containing the information of UAB AviationCV.com and its affiliates, partners and clients about their services, products, invitation to event. Your data will be used for direct marketing, promotions and other outreach activities purposes for 3 years after your consent is obtained or until you withdraw your consent.

Please note that your Personal Data is safe with us and none of it will be transferred to these affiliates, partners and/or clients. In this case we act as an advertising agency and only provide advertising and marketing services to our partners and clients (in a form of sending newsletter with their provided information).

when you are a customer of us who have not objected to the processing of personal data for the purpose of direct marketing, marketing of similar services or products.

If you are our customer who is using our services and have not objected to receive UAB AviationCV.com direct marketing communications, promotions and other outreach activities we will send you information regarding goods and services that are similar to the services provided or purchased to you. In this case your data will be used for direct marketing purposes, promotions and other outreach activities for as long as you are our customer or until you refuse such processing.

We consider you to be our registered user:

when you have your created account on our Websites or
3 years after your order or purchase of our product or service.

For direct marketing purpose, promotions and other outreach activities we process your Personal Data which is described in part “WHAT PERSONAL DATA, FOR WHAT PURPOSE AND BASIS DO WE PROCESS” of this Privacy Policy. With you expressed consent to receive direct marketing messages, newsletters, promotions and other outreach activities you subscribe, you agree to receive our news about new services, products, invitations to events etc.

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.

HOW WE PROCESS YOUR PERSONAL DATA

Our use of your personal data will always have a lawful basis. Most commonly, we use your personal data:

Where we need to conclude any contract and/or perform any contract we have entered into with you (for example, to comply with the Terms and Conditions which you agree with when you create your account on our Website and start using our services and/ or to comply with our contract to provide services to you, your academic institution, your employer, or other organization that may be providing you with access to our services);
Where we need to comply with a legal obligation (for example, when performing accounting, archiving, data breach notification processes);
Where we have your consent (for example, in cases when you agree to receive our newsletters);
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interest. “Legitimate interest” means our interest to enhance our services, products, to manage the processes of businesses and activities. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. The legitimate interests that we pursue include:
provision of marketing offers of our similar services or products;
presentation of our services on social networks, submission of answers to your queries or messages on social networks, analysis of our accessibility on social networks;
provision of information to your request, responds to your queries;
establishment, exercise or defense of legal claims;
analysis, expansion and improvement of our services, customer service quality assurance and compilation of statistics and analysis related with it;
protection of information related to the provision of our services, improvement, development and maintenance of the security of IT systems.

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 or is required for the defence of the Data Controller's legitimate interests in judicial, other public institutions etc.

We ensure and take all necessary measures to avoid storing outdated or unnecessary personal data about You and to keep Your personal data up-to-date and accurate. You may find retention periods of your Personal Data in part “WHAT PERSONAL DATA, FOR WHAT PURPOSE AND BASIS DO WE PROCESS” of this Privacy Policy.

HOW DO WE PROTECT YOUR DATA?

We responsibly implement appropriate organisational and technical personal 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.

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

We may share some of your personal data with the following categories of third parties:

any Avia Solutions Group (AVIA SOLUTIONS GROUP PLC, a private limited liability company, established and acting under the laws of the Republic of Cyprus, registration code HE 380586, registration address 28 Oktovriou, 1, ENGOMI BUSINESS CENTER BLC E, Flat / Office 111 Egkomi, 2414, Nicosia, Cyprus) company (listed at https://aviasg.com/en/the-group/general-contacts) for the purposes set out in this Privacy Policy (for example, for the purposes of performance of contracts and the management of relationship with customer);
representatives acting on our behalf with respect to the promotion of our services in particular territories;
companies providing data centers, hosting, cloud, site administration and related services, software developers, providing, maintaining and developing companies, companies providing information technology infrastructure services, companies providing communication services;
credit and debit card companies used to facilitate payment transactions related to the provision of our services, banks and other credit and/or payment companies;
our professional advisors, freelance journalists, auditors, lawyers and/or financial advisers;
our other service providers (data processors) or our subcontractors;
notaries, if the contract concluded with you requires a notarial form;
judicial officers, entities providing legal s and/or debt recoveries services, subrogator of claim right;
companies providing advertising and marketing services;
companies providing archiving, physical and / or electronic security, asset management and/or other business services;
in accordance with the laws to state institutions, establishments, etc.;
law enforcement authorities at their request or on our own initiative if there is a suspicion that a criminal offense has been committed, as well as courts and other dispute resolution bodies; tax administrators
in the event of a company restructuring, transfer / acquisition and / or business transfer / acquisition, to a third party acquiring the business and processing personal data for the same purposes as specified in this Privacy Policy and/or doing the Due Diligence by our and/or their legal and/or financial advisors, etc.

DATA TRANSFER OUTSIDE THE EUROPEAN ECONOMIC AREA

As a general rule, your personal data will be processed in the countries of the European Economic Area (hereinafter - EEA). However, in certain cases, your personal data may be transferred to non-EEA countries. 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 personal data protection, the transfer must take place in the same manner as in the EEA. 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 personal 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 or the EEA.

DO WE APPLY AUTOMATED DECISION-MAKING OR PROFILING?

We do not normally use automated decision-making under Article 22 of the GDPR to initiate and execute contractual relationships. Should we apply this procedure in individual cases, we will inform you separately, if required by law.

We process your personal data in a partially automated way in order to assess certain personal aspects (hereinafter - Profiling). We use profiling, for example, when we are required by law to prevent money laundering or manage financial risk.