Privacy Policy

 

1. PROCESSING OF PERSONAL DATA ON EMPLOYEES (CANDIDATES) RECRUITMENT PURPOSES

This section on processing of personal data on employees’ recruitment purposes stipulates the processing of personal data of candidates for relevant job position at FL Technics.

We collect your personal data for the purpose of assessing your candidacy for a specific job position, in cases where you have applied directly for one of the vacant job positions, or where you have given your consent to be contacted in the event of a vacant job position matching your competence, or if we have received your personal data from other sources (e.g., a job search portals, LinkedIn, a recruiting company, etc.).

For any questions regarding this Privacy Policy or any requests regarding the processing of personal data, please contact us at: [email protected].

1.1. Selection of candidates for employees (recruiting)

The categories of processed personal data. What kind of categories of personal data do we process? Considering the requirements of the position applied we may collect, assess, and store the following personal data about you: Personal identification data: your name, surname, age or date of birth.Contact information: your e-mail address, phone number, address of the place of residence. Information on qualification and competence: language proficiency, computer skills, educational, background, profession, working experience and projects you have been involved with, attended courses, training sessions, seminars, development of qualification, licenses held, driver license (for relevant job positions only). Other information: information about expected salary, social media accounts, pictures and other information that you may wish to provide in your CV, motivation letter, interviews. Assessment data: our remarks and assessment of your suitability to perform the duties of a particular position. On what legal basis do we process your personal data? We will process the said personal data in accordance with: – Article 6 Part 1. a) of the GDPR, i.e., with your consent – to the extent described in the relevant consent. – Article 6 Part 1. f) of the GDPR, i.e., our legitimate interest – to have a common and coordinated policy on the selection of personnel and human resources management and to share the information about your candidacy within other Avia Solutions Group companies. The period of processing your personal data We will process the personal information for the recruiting process for 6 (six) months from getting your application unless the selection process continues longer than the indicated period. When you are unsuccessful in your application for a concrete position in a company of Avia Solutions Group you may agree for further sharing your data within all Avia Solutions Group companies. In this case your personal data will be stored for 3 years from the end of selection process for the position you applied or from receiving the data. For more details of personal data processing for selection of candidates please check the privacy notice (https://careers.aviasg.com/en/candidate-privacy-policy). Where from we get the personal data about you? We collect data directly from you. We may also collect personal data about you from: (i)               recruiting agencies; (ii)              job search portals or databases where you have submitted your CV; (iii)             our employee (referrals) who has recommended you as a candidate; (iv)             publicly accessible sources, such as “LinkedIn” and other business-related social media sources and/or collaboration platforms, websites or publicly available publications where you have added information about yourself (your name, surname, e-mail address, work history, and other data included on your profile). Transfer of your data Service providers – we may share your personal data with companies that provide services to us (for example, companies providing data centre, hosting, cloud, IT infrastructure, website managing and related service providers, as well as software development service providers, software database infrastructure and communication service providers, if required, consultants and professional advisers.). Other Avia Solutions Group companies – information about your candidacy within Avia Solutions Group companies based on our legitimate interest to have a common and coordinated policy on the selection of personnel and human resources management. When it is mandatory to transfer your data under applicable law requirements, i.e., courts, law enforcement authorities, external consultants to the extent required or permitted by law, also public authorities (including Lithuanian public authorities, such as, among others, the State tax Inspectorate, Transport Competence Agency (national civil aviation authority), airports, by request of these bodies or in other cases stipulated in regulations. Also, Civil Aviation Administrations of other countries, including those beyond the European Economic Area, during audits or in other cases stipulated in regulations). Kindly note that all our third-party service providers (the data processors) and other Avia Solutions Group companies are required to take appropriate security measures to protect your personal information. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions. For more information, please check the privacy notice (https://careers.aviasg.com/en/candidate-privacy-policy).

The categories of processed personal data. What kind of categories of personal data we process? Kindly note that we may collect, assess, and store the following personal data about the relevant candidates current/former employers: Personal identification data of candidates current/former employee (colleague): name, surname, position, company name; Contact information: e-mail address, phone number; Information on qualification and competence of candidate: qualifications, professional skills, business qualities, performance during previous/current employment, etc. On what legal basis do we process personal data? We will process the said personal data in accordance with: – Article 6 Part 1. a) of the GDPR, i.e., with both candidate and his/her former/current employer’s consent. Kindly note that we presume that candidates inform and obtain the consent of their former/existing employers (its employees) to share their contact details with us and to be contacted for reference purposes. The period of processing We will process this data together with other personal information of the candidate for the recruiting processes. As specified hereabove, we will process candidates’ personal information for the recruiting process for 6 (six) months from getting his/her application unless the selection process continues longer than the indicated period. For more details of personal data processing for selection of candidates please check the Privacy notice (https://careers.aviasg.com/en/candidate-privacy-policy). Where from we get the personal data about you? We collect data from you (respective candidate or his/her former/current employers), i.e. data that you have provided to us directly. Transfer of your data Service providers – we may share your personal data with companies that provide services to us (for example, companies providing data centre, hosting, cloud, IT infrastructure, website managing and related service providers, as well as software development service providers, software database infrastructure and communication service providers, if required, consultants and professional advisers). Other Avia Solutions Group companies – information about your candidacy within Avia Solutions Group companies based on our legitimate interest to have a common and coordinated policy on the selection of personnel and human resources management. When it is mandatory to transfer your data under applicable law requirements, i.e., governmental authorities (local and foreign), courts, law enforcement authorities, external consultants to the extent required or permitted by law. Kindly note that all our third-party service providers (the data processors) and other Avia Solutions Group companies are required to take appropriate security measures to protect your personal information. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions. For more information, please check the privacy notice (https://careers.aviasg.com/en/candidate-privacy-policy).

1.3. Your right to withdraw your consent

In some circumstances, you may have provided consent to us, to enable the processing of your personal information for the purposes of the recruitment exercise (the possibility to be in the candidates’ database). You have the right to withdraw your consent for processing for that purpose at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information and, subject to our retention policy, we will dispose of your personal information securely. To withdraw your consent, please contact our Data Protection Officer by sending an email to [email protected].

1.4. Your other rights in connection with personal data

If you want to enforce any of your rights described Section 8 “Your rights in connection with personal data” hereinbelow, please contact our Data Protection Officer by sending an email to [email protected]. Any request to exercise one of these rights will be assessed by us on a case-by-case basis.

 

2. PROCESSING OF OUR CUSTOMERS AND BUSINESS PARTNERS PERSONAL DATA

FL Technics processes the personal data of different categories of data subjects (clients, business partners, suppliers, other counterparties), interacting with FL Technics in several different ways for the purposes of conclusion, performance, administration, support contractual arrangements, creation, development, improvement of business and related legal interest of FL Technics, defending itself from statements of claims, exercise of its rights and interest as well as fulfilment of obligations imposed on FL Technics by applicable legal acts.

This Privacy Policy on the processing of our business partners personal data, stipulates information on how FL Technics, or any other subsidiary of FL Technics, process personal data of the following persons:

(i)  representatives or contact persons of our business partners (including clients, suppliers, other counterparties);

(ii) business partners who are natural persons (such as self-employed persons);

(iii) professionals and employees contracted by our business partners.

For any questions regarding this Privacy Policy or any requests regarding the processing of personal data, please contact us at: [email protected].

2.1. Drawing up and executing contracts for the purchase and sale of services

The categories of processed personal data. What kind of categories of personal data do we process?	When drawing up and executing contracts we may collect, assess, and store the following personal data about you: Personal identification data: your name, surname, position, employer (i.e., legal entity/company you are representing), signature. Contact information: your e-mail address, phone number. Other information, as may be required for negotiations, concluding, and performing of contracts.
On what legal basis do we process your personal data?	We will process the said personal data in accordance with: –   Article 6 Part 1. b) of the GDPR, i.e. to conclude a contract with you and perform it; –   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).
The period of processing your personal data	Contracts and accounting documents (in physical and electronic form) are kept for 10 years from the date of full performance of the contract.
Where from we get the personal data about you?	We collect data directly from you or your employer (legal entity or company you are working for). Also, we may collect data from third parties – when information about you provides your business partner (i.e., our client, contractor, supplier, etc.).
Transfer of your data	Service providers – we may share your personal data with companies that provide services to us (for example, companies providing data centre, hosting, cloud, IT infrastructure, website managing and related service providers, as well as relevant enterprise resource planning (ERP) system or other software development service providers, software database infrastructure and communication service providers, insurance companies, hotels, airline or travel agency (i.e., for flight bookings), if required, consultants and professional advisers, etc.). Other Avia Solutions Group companies – we may share your personal data for the purposes of: (i) performance of contracts and the management of relationship with customer, (ii) onboarding and due diligence of the counterparty. When it is mandatory to transfer your data under applicable law requirements, i.e., courts, law enforcement authorities, external consultants to the extent required or permitted by law, also public authorities (including Lithuanian public authorities, such as, among others, the State tax Inspectorate, Transport Competence Agency (national civil aviation authority), relevant airports (with regards to the issue of airport permits), by request of these bodies or in other cases stipulated in regulations. Also, Civil Aviation Administrations of other countries, including those beyond the European Economic Area, during audits or in other cases stipulated in regulations). Kindly note that all our third-party service providers (the data processors) and other Avia Solutions Group companies are required to take appropriate security measures to protect your personal information. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

2.2. Responding to your general enquiries or requests of information

Our Website or other public business channels provide our contacts where you can contact us to consult us on issues that concern you.

The categories of processed personal data. What kind of categories of personal data do we process? If you contact us by e-mail, regular mail, or phone, we may process the following personal data of yours: Personal identification data: name, surname. Contact information: e-mail, postal address, phone number. Other information: the text of the correspondence and / or attached documents. This data will be processed for the administration of your enquiry. Please note that we may need to contact you to provide with a reply to your enquiry so be sure to share accurate contact data of yours. On what legal basis do we process your personal data? Article 6 Part 1 f) of the GDPR, i.e., our legitimate interest to communicate with you as a representative or contact person of our potential customer or business partner. The period of processing your personal data Communication with you will be handled until the enquiry is fully processed and stored for 3 year from the date of the last communication with you unless there is another legitimate purpose for storing it longer (e. g. business contract with you has been concluded and communication material can be considered as the proof of negotiation). Where from we get the personal data about you? We collect data directly from you or your employer (e.g., company you are working for). Transfer of your data Service providers – we may share your personal data with companies that provide services to us (for example, companies providing data centre, hosting, cloud, IT infrastructure, website managing and related service providers, as well as software development service providers, software database infrastructure and communication service providers, and other as may be necessary). When it is mandatory to transfer your data under applicable law requirements, i.e., public authorities, courts, law enforcement authorities, external consultants to the extent required or permitted by law. Kindly note that all our third-party service providers (the data processors) are required to take appropriate security measures to protect your personal information. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

2.3. Onboarding and due diligence procedure for counterparties

In order to comply with anti-money laundering and anti-terrorist financing legislation, including compliance with international sanctions legislation, we may collect the personal data of members of the board of directors, directors, representatives, shareholders and ultimate beneficial owners, or other, as appropriate. For more details of personal data processing for onboarding and due diligence please check the relevant privacy notice: https://fltechnics.com/privacy-notice-counterparty-onboarding-and-due-diligence/

2.4. Providing with news, promotions, newsletters, information about products and invitations to events

We kindly inform you that you are free to opt out of our newsletters or any other information sent by e-mail at any time. You may exercise this option by clicking on a corresponding link at the bottom of our e-mail.

You may also refuse receiving information about events or any other information from us by sending an email to [email protected].

The categories of processed personal data. What kind of categories of personal data do we process?	Personal identification data: name. Contact information: phone number, e-mail address.
On what legal basis do we process your personal data?	Personal data for direct marketing is processed in accordance with: –  Article 6 Part 1, a) of the GDPR, i.e., with your consent; –  Article 6 Part 1, f) of the GDPR, i.e., our legitimate offer you a similar goods/services to ones you have purchased from us and to get your feedback about purchased goods/services.
The period of processing your personal data	Your personal data is generally stored for no longer than legally required or absolutely necessary for the purposes we have collected it. Your personal data processed for the purposes of direct marketing will be stored for no longer than 2 years from the date of your most recent consent (if we have received a separate consent) or the date of completion or expiration of the relevant contract (as the case may be).
Where from we get the personal data about you?	We collect data directly from you or your employer (legal entity or company you are working for).
Transfer of your data	Service providers – we may share your personal data with companies that provide services to us (for example, companies providing data centre, hosting, cloud, IT infrastructure, website managing and related service providers, as well as relevant enterprise resource planning (ERP) system or other software development service providers, software database infrastructure and communication service providers, and other as may be necessary). When it is mandatory to transfer your data under applicable law requirements, i.e., public authorities, courts, law enforcement authorities, external consultants to the extent required or permitted by law. Kindly note that all our third-party service providers (the data processors) are required to take appropriate security measures to protect your personal information. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

2.5. Your rights in connection with your personal data

If you want to enforce any of your rights described Section 8 “Your rights in connection with personal data” hereinbelow, please contact our Data Protection Officer by sending an email to [email protected]. Any request to exercise one of these rights will be assessed by us on a case-by-case basis.

 

3. PROCESSING OF PERSONAL DATA ON THE WEBSITE (COOKIE POLICY)

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

For any questions regarding this Cookie Policy or any requests regarding the processing of personal data, please contact us at: [email protected].

3.1. What are 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 behavior of our website users, to analyse trends and improve both the website, your service, as well as the services provided by the owner.

3.2. What cookies and how do we use it?

Cookies will only be placed on your device with your consent, with the exception of cookies that are strictly necessary for the technical operation of the website. It should be noted that if you do not allow the website to use cookies, some of the website’s functions may not work partially or completely.

The legal basis for the use of cookies is the Owner`s legitimate interest in ensuring the technical functioning of the website. Where cookies are used to store your preferences and to compile statistics, the legal basis for the use of cookies is your consent.

The information we collect using cookies is used for the following purposes (Cookie description updated as of April 22, 2024):

3.2.1. Strictly necessary cookies — these cookies are essential for you to browse the website and use its features, such as accessing secure areas of the site.

Name	Purpose	Expiration	Cookie provider
_GRECAPTCHA	to provide spam protection.	6 months	Google LLC
AnalyticsSyncHistory	Used to store information about the time a sync with the lms_analytics cookie took place for users in the Designated Countries.	1 month	LinkedIn Ireland Unlimited Company
li_gc	used to store the consent of guests regarding the use of cookies for non-essential purposes.	6 months	LinkedIn Ireland Unlimited Company
CookieScriptConsent	this cookie is used by Cookie-Script.com service to remember visitor cookie consent preferences. It is necessary for Cookie-Script.com cookie banner to work properly.	1 month	CookieScript

3.2.2. Marketing (targeting) cookies — these cookies track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an ad. These cookies can share that information with other organizations or advertisers.

Name	Purpose	Expiration	Cookie provider
PHPSESSID	Cookie generated by applications based on the PHP language. This is a general purpose identifier used to maintain user session variables. It is normally a random generated number, how it is used can be specific to the site, but a good example is maintaining a logged-in status for a user between pages.	When the browsing session ends (session)	PHP.net
bcookie	Browser Identifier cookie to uniquely identify devices accessing LinkedIn to detect abuse on the platform.	1 year	LinkedIn Ireland Unlimited Company
li_sugr	Store and track a visitor’s identity.	90 days	LinkedIn Ireland Unlimited Company
lidc	To facilitate data center selection.	1 day	LinkedIn Ireland Unlimited Company
UserMatchHistory	This cookie is used to track visitors so that more relevant ads can be presented based on the visitor’s preferences.	1 month	LinkedIn Ireland Unlimited Company
_ga	This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports.	13 months	Google LLC
_gid	According to Google Analytics this cookie is used to distinguish users.	1 day	Google LLC
_fbp	Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.	3 months	Meta Platforms Ireland Limited
_gat	Is used to limit the amount of data recorded by Google on high traffic volume websites.	1 minute	Google LLC
MUID	Identifies unique web browsers visiting Microsoft sites. These cookies are used for advertising, site analytics, and other operational purposes.	13 months	Microsoft Corporation
ANONCHK	This cookie carries out information about how the end user uses the website and any advertising that the end user may have seen before visiting the said website.	10 minutes	Microsoft Corporation
MR	This is a Microsoft MSN 1st party cookie which we use to measure the use of the website for internal analytics.	7 days	Microsoft Corporation
SM	This is a Microsoft MSN 1st party cookie which we use to measure the use of the website for internal analytics.	When the browsing session ends (session)	Microsoft Corporation
CLID	This cookie is installed by Microsoft Clarity and is used to store information about how visitors use a website	1 year	Microsoft Corporation

3.2.3. Preferences cookies — also known as “functionality cookies,” these cookies allow a website to remember choices you have made in the past, like what language you prefer, what region you would like weather reports for, or what your user name and password are so you can automatically log in.

Name	Purpose	Expiration	Cookie provider
pll_language	To store language settings.	1 year	WP SYNTEX S.A.R.L

3.3. How to change cookie settings

You can change your cookie preferences at any time by clicking on the Cookie Settings icon. You can change your settings by ticking existing boxes or unticking boxes and clicking “Save and close”. You may need to refresh your page for your settings to take effect.

To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.

Alternatively, most web browsers allow some control of most cookies through the browser settings. Find out how to manage cookies on popular browsers:

Google Chrome
Safari (iPhone)
Safari (Mac)
Mozilla Firefox
Samsung Internet (Mobile)
Microsoft Edge
Internet Explorer
Opera

3.4. How long will the data be stored?

You can view the cookie retention periods in the list of cookies of this policy (above). Your consent to the use of cookies is valid for six (6) months.

3.5. More information on cookies

To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

 

4. PROCESSING OF PERSONAL DATA OF THE COMPANY’S SHAREHOLDERS

FL Technics processes the personal data of its shareholders as well as information on ultimate beneficial owners (hereinafter – UBO) to fulfil its legal obligations, laid down in applicable securities market, anti-money laundering and related legal requirements.

FL Technics stores personal data of its shareholders and UBO to the extent necessary for achieving the purposes for which they are processed, all in accordance with applicable legal requirements.

For any questions regarding this Privacy Policy or any requests regarding the processing of personal data, please contact us at: [email protected].

The categories of processed personal data. What kind of categories of personal data do we process? Personal identification data: name, surname, signature. Contact information: title, home address, email address, contact details in other videoconferencing platforms (e.g. Skype, Zoom, etc.) and phone number(s). Shareholder information: number of shares and any notes/information to be linked to law, structure of shareholding. Other information: bank account details, any communication between you and FL Technics, and other information as may be required by law and/or requested by third parties (e.g., banks, etc.). On what legal basis do we process your personal data? We process in accordance with: – Article 6 Part 1, c) of the GDPR, i.e., our legal obligation to communicate and implement the rights of shareholders, or otherwise meet our legal responsibilities; – Article 6 Part 1, f) of the GDPR, i.e., our legitimate interest to administer shareholders’ and UBO’s rights.   The period of processing your personal data Personal data is only processed for as long as it is necessary to fulfil the purpose of the processing, or as long as FL Technics is required to store such data by law. The data is erased when you cease to be a shareholder of FL Technics. However, as mentioned, certain data is stored for a longer period of time when required by law, including company, securities and tax legislation. Where from we get the personal data about you? We collect data directly from you or the company you are associated with. Transfer of your data Your personal data may be disclosed to a third party if required by law, regulations or an official decision by a relevant authority or who work with us to help deliver our services, in order to fulfil our legal obligations or at your request. Such third parties may be as following: (i)    other members of Avia Solutions Group (ASG) PLC; (ii)   our service providers and agents (including their sub-contractors); (iii)  your advisers (such as lawyers and other professional advisers) who you have authorised to represent you, or any other person you have told us is authorised to give instructions on your behalf (such as under a power of attorney); (iv)  the legal authorities; (v)   any third party after a restructure, sale or acquisition of any company, as long as that person uses your information for the same purposes you originally provided it for; (vi)  anyone we transfer or delegate our rights or obligations to, as allows under terms and conditions of any agreement you have with us (e.g. if we transfer the management of our share register to another service provider). In some circumstances FL Technics may transfer your personal data to third parties or any other FL Technics group company in a country (including your country of residence) other than the country in which the data was collected. When we transfer your personal data to a different country, we will take steps to ensure that such data transfers comply with applicable laws. For example, if we transfer personal data from the European Economic Area (EEA) to a country outside it, we will implement an appropriate or suitable data transfer safeguards and the means or taking other measures to provide an adequate level of protection under EU law. Your rights in connection with personal data If you want to enforce any of your rights described Section 8 “Your rights in connection with personal data” hereinbelow, please contact our Data Protection Officer by sending an email to [email protected]. Any request to exercise one of these rights will be assessed by us on a case-by-case basis.

 

5. VIDEO SURVEILLANCE (CCTV) PRIVACY POLICY

The transparency of the personal data processing is very important for us; therefore, this Privacy Policy on Video Surveillance (CCTV) describes how and where we process your personal data collected by the video surveillance cameras.

Kindly note that we process your personal data collected by the video surveillance cameras for the purposes of detecting, controlling, and preventing all and any crimes against any property (e.g., theft, etc.) and persons concerned.

For any questions regarding Video Surveillance (CCTV) and this Privacy Policy or any requests regarding the processing of personal data, please contact us at: [email protected].

The categories of processed personal data. What kind of categories of personal data do we process?	Image and other objects relating to personal data.
On what legal basis do we process your personal data?	Article 6 Part 1. f) of the GDPR, i.e., our legitimate interest to protect the safety of property and individuals and to have evidential material for incident or fraud investigation.
The period of processing your personal data	Personal data shall not be stored for as long as necessary to achieve the relevant purpose, considering the specific nature of the objects monitored using CCTV cameras, the conditions and the risks involved. In this respect the retention period may vary, depending on the object monitored. However, in any event, the retention period for video surveillance recordings may not exceed 30 (thirty) calendar days.
Where from we get the personal data about you?	We collect personal data using the technical measures, i.e. video cameras and similar technologies.
Transfer of your data	Avia Solutions Group PLC companies. Usually, we do not share personal data with the other Avia Solutions Group (ASG) PLC companies, but if it becomes necessary for reaching the goals and for the purpose of the principle of legitimate interests, your personal data is likely to be transferred to the associated companies of Avia Solutions Group (ASG) PLC. Law enforcement institutions, public and local authorities. In order to fulfil our legal obligation, we may transfer your personal data to the law enforcement institutions, public and local authorities at their request. Moreover, we may transfer your personal data to the law enforcement institutions, public and local authorities in pursuit of our legitimate interest: to establish, exercise and defend legal claims.
Your rights in connection with personal data	If you want to enforce any of your rights described Section 8 “Your rights in connection with personal data” hereinbelo, please contact our Data Protection Officer by sending an email to [email protected]. Any request to exercise one of these rights will be assessed by us on a case-by-case basis.

 

6. VIRTUAL TRAINING RECORDING PRIVACY POLICY

In order to be compliant with European Union Aviation Safety Agency (hereinafter – EASA) requirements, we are required to ensure student attendance in virtual trainings. In this respect we are recording Virtual Training sessions and, accordingly, process your personal data (your likeness and other), to ensure that we are compliant with EASA requirements as well as to be able to confirm your participation in event of an argument.

For any questions regarding this Privacy Policy or any requests regarding the processing of personal data, please contact us at: [email protected].

The categories of processed personal data. What kind of categories of personal data do we process? We may process your surname, image, audio, email address, date and time (date, start and end hours, duration hours and minutes). On what legal basis do we process your personal data? Your personal data shall be processed in accordance with: – Article 6 Part 1. c) of the GDPR, i.e., legal obligation to ensure student attendance in Virtual Training as well as for internal and external audit purposes according to EASA requirements. The period of processing your personal data Personal data shall not be stored for a period longer than 5 (five) months. Personal data shall be stored for 3 months (2 months maximum length of the Virtual Training course and 1 month for the Virtual Training certificate issuance). After 3 months the recording is being deleted automatically, with the possibility to recover the Virtual Training recording for additional 2 months due to unforeseen circumstances as may be required. Where from we get the personal data about you? We collect personal data using the technical measures, i.e. Microsoft Teams meeting / call recording function (hereinafter – MS Teams). The recording captures audio, video, and screen sharing activity. Transfer of your data Avia Solutions Group PLC – as it is our IT network administrator and IT services supplier. Microsoft Corporation as in regard to use of Microsoft Teams. Kindly refer to the following link which presents a privacy statement explaining the personal data Microsoft Corporation processes and for what purposes: Microsoft Privacy Statement – Microsoft privacy. Civil Aviation Authority for audit purposes (if required) under applicable law requirements. Law enforcement institutions, public and local authorities (if required) under applicable law requirements. Your rights in connection with personal data If you want to enforce any of your rights described Section 8 “Your rights in connection with personal data” hereinbelow, please contact our Data Protection Officer by sending an email to [email protected]. Any request to exercise one of these rights will be assessed by us on a case-by-case basis.

 

7. SOCIAL NETWORKS

In this section, we describe which social networks we use and what personal data we may process about you in this respect. Through various social media channels, we want to introduce you to our wide range of services / products and exchange ideas and opinions with you on important topics.

For any questions regarding FL Technics social networks or any requests regarding the processing of personal data, please contact us at: [email protected].

As a kind note, when you visit social networks, your personal data is processed by a specific social network (e.g., “Facebook”, “Instagram”, “LinkedIn”, etc.), therefore the social media platforms are solely responsible for all data protection topics involving your user profile, to which we have no access. We start processing your personal data when you visit FL Technics on relevant social network.

Your personal data provided on the social network is processed for the following purposes:

–  communicate with our social network visitors;
–  respond to visitor inquiries;
–  obtaining statistical information;
–  conducting customer surveys, marketing campaigns, market analysis, lotteries, competitions or similar actions or events;
–   if necessary, defending the legitimate interests of the Company in institutions and in other cases.

Unless explicitly stated otherwise, the legal basis for data processing is Article 6 part 1 point (f) of the GDPR. Our legitimate interests are to be able to answer your messages or questions and analyze our availability on social networks, to present our products and services. To the extent that you wish to enter into a contractual relationship with us with your request, the legal basis for such processing is Article 6 part 1 point (b) of the GDPR.

If we intend to process your personal data for any other purpose not mentioned above, we will notify you prior to such processing.

Our pages on social networks are managed by specific social networks, so when you visit them, the processing of personal data is based on the social network privacy policies. With some social networks, depending on the social network policy, the purposes and scope of the processing, we are considered as joint data controllers.

Facebook: https://www.facebook.com/FLTechnics/

Instagram: https://www.instagram.com/fltechnics/

LinkedIn: https://lt.linkedin.com/company/fl-technics

X: https://twitter.com/fltechnics

YouTube: https://www.youtube.com/channel/UCQwO-LnzF9VUw_tEvij9TDw

Threads: https://www.threads.net/@fltechnics

TikTok: https://www.tiktok.com/@fltechnics.com

Name of the social network and its Privacy Policy	Personal data we process	Personal data we process as joint data controllers
Facebook You can read their privacy policy by clicking here: https://www.facebook.com/policy.php	Your Facebook username, when you comment, react to the publication, share posts, write us messages, Your activities on our site, e.g. Your page views, duration statistics, query, comment information, and more.	We use statistical information (visits to our website, range of contributions, visits and average video transmission times, information about the countries and cities from which our visitors come, age range, gender). We receive anonymous statistics from Facebook through their service. The data controllers’ agreement can be found here: https://www.facebook.com/legal/terms/ page_controller_addendum
Instagram You can read their privacy policy by clicking here: https://help.instagram.com/1558337 07900388	Your Instagram username, when you comment, react to the publication, share posts, share content in stories section, write us messages, Your activities on our site, e.g. Your page views, duration statistics, query, comment information, and more.	We use statistical information (visits to our website, range of contributions, visits and average video transmission times, information about the countries and cities from which our visitors come, age range, gender). We receive anonymous statistics from Instagram through their service. The data controllers’ agreement can be found here: https://www.facebook.com/legal/terms/ page_controller_addendum
LinkedIn You can read their privacy policy by clicking here: https://www.linkedin.com/legal/ privacy-policy	Your LinkedIn username, when you comment, react to the publication, share posts, write us messages, Your location indicated on the personal account, Your activities on our site, e.g. Your page views, duration statistics, query, comment information, and more.	We use statistical information (visits to our website, range of contributions, visits and average video transmission times, information about the countries and cities from which our visitors come, age range, gender). We receive anonymous statistics from LinkedIn through their service. The data controllers’ agreement can be found here: https://www.linkedin.com/legal/l/dpa
X (Twitter) You can read their privacy policy by clicking here: https://twitter.com/en/privacy	Your X username, when you tweet, retweet (share) the tweet, quote, mention, write us messages, Your activities on our site, e.g. Your page views, duration statistics, query, comment information, and more.	We use statistical information (visits to our website, range of contributions, visits and average video transmission times, information about the countries and cities from which our visitors come, age range, gender). We receive anonymous statistics from X through their service. The data controllers’ agreement can be found here: https://gdpr.twitter.com/en/controller-to-controller-transfers.html
YouTube You can read their privacy policy by clicking here: https://www.youtube.com /howyoutubeworks/our-commitments/protecting-user-data/	Your YouTube username, when you comment, interact with content.	If you are logged in with YouTube, you agree to YouTube terms of use, privacy and cookie policies and to YouTube processing of your personal data, at which we have no control over. If you are not registered with YouTube, YouTube may still perform statistical analysis of your personal data when you access our YouTube channel and provide us with anonymized statistics on this. We use statistical information. Processed data types: – Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers); – Content data (videos etc.); –  Usage data (e.g. websites visited, interest in content, access times, video views, video likes, comments, purchases etc.), meta/communication data (e.g. device information, IP addresses). Video Statistics: – Number of subscribers and changes; – Watch time data (duration, stoppage time, retention rate); – Demographics (gender distribution, age, places of origin, use of devices etc.). We receive anonymous statistics from Youtube through their service. The data controllers’ agreement can be found here: https://business.safety.google/controllerterms/
Threads You can read their privacy policy by clicking here: https://help.instagram.com/ 515230437301944	Your Threads username, when you comment, react to the publication, share posts, share content, write us messages.	We use statistical information (visits to our website, range of contributions, visits and average video transmission times, information about the countries and cities from which our visitors come, age range, gender). We receive anonymous statistics from Threads through their service. The data controllers’ agreement can be found here: https://www.facebook.com/legal/terms/ page_controller_addendum
TikTok You can read their privacy policy by clicking here: https://www.tiktok.com/legal/page/row/ privacy-policy/en	Your TikTok username, when you comment, interact with content.	We use statistical information. We receive anonymous statistics from TikTok through their service. TikTok collects this data: – The videos you watch and rewatch; – The videos you comment on; – The keyboard rhythms you have when you type; – Your phone and location data; – Clipboard data; – Private messages and contacts; – Any information you share while creating your account; – Information from linked social media accounts. The data controllers’ agreement can be found here: https://ads.tiktok.com/i18n/official/article?aid= 998850064133680764

 

8. YOUR RIGHTS IN CONNECTION WITH PERSONAL DATA

If you want to enforce any of your rights herein, please contact our Data Protection Officer by sending an email to [email protected]. Any request to exercise one of these rights will be assessed by us on a case-by-case basis. There may be circumstances in which we may not legally required to comply with your request or because of relevant legal exemptions provided for in applicable data protection legislation.

Under certain circumstances, by law you may have the right to:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive an information on the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

Right to object to processing of your personal information where we are relying on a legitimate interest and there is something about your situation, which makes you want to object to processing on this ground.

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your personal information to another party.

If you are not satisfied with our answer you receive, you have the right to file a complaint to the supervisory authority in the relevant Member State of the European Union in which you have your habitual residence or place of work (please visit the European Data Protection Board website to find the contact details of supervisory authorities in each Member State: https://edpb.europa.eu/about-edpb/about-edpb/members_en).