This privacy policy governs the application called “icao4pilots” (hereinafter the “App”) available in the Google Play Store and the Apple Store for download on mobile devices and is the property of ICAO4PILOTS LLC (hereinafter the Company) with address at 3785 NW 82ND AVE SUITE 302, Miami, Florida, United States of America. It also applies to the site available at www.icao4pilots.com (hereinafter the Site).
The App offers users (hereinafter referred to as “clients”, interchangeably) the possibility of training and perfecting themselves as aircraft pilots to apply for the ICAO (International Civil Aviation Organization English test) through its different functionalities.
This policy is intended to inform the Company’s customers about the collection, use and processing of their personal information and the protection of their personal data. The legal basis for the processing of personal data is the consent of the clients, so using the App implies acceptance of this privacy policy.
All information that the Company receives from its clients will be duly protected and may not be communicated, modified or disclosed except as provided in this privacy policy. The Company will act, at all times, proactively, in good faith, subject to the principles of trust, transparency and protection of personal data applicable to the processing of its clients’ data, having adopted the appropriate technical and organizational measures to guarantee adequate treatment.
Below we inform you of the aspects you should know for the proper protection of your personal data:
1- What information do we collect?
Information that you provide to us: We receive and collect the information that you provide to us when registering and using the App and/or logging into the Site and in particular, your first and last name, date of birth, email address, country of residence. , your photograph, your professional level as an aircraft pilot, the type of aircraft for which you are qualified to fly, flight hours and if you ever took the ICAO English exam, as well as the score obtained in the latter case.
Information about your Facebook account and your Gmail email: If you choose to log in using your Gmail or Facebook username, we can obtain access to the information existing in said social network and in your Gmail email account whose terms of use and privacy policies you previously accepted. For example: if you choose to connect your App access account to Facebook, we will access, if you allow it, information such as your list of friends, your use of applications such as “likes” and your personal data such as such as your name, email and profile photo.
Transactional payment information: The Company also collects information corresponding to transactions made by customers linked to the “paid services” offered by the Company. These data are necessary for the proper execution of the contract formalized between the Company and the client and to allow the provision of payment services.
Also, when you use the App and/or the Site, we may obtain information about your IP address (Internet Protocol Address) and your Internet access provider, as well as access data from other sources, including data providers. obtained both online and offline. This supplemental information may include demographic data and Internet browsing behaviors. We may use this additional information for purposes consistent with this privacy policy such as analyzing and understanding our customers’ preferences.
In no case will the Company request information that is incompatible with the purpose provided in this privacy policy for the collection of personal data or that directly or indirectly reveals sensitive data, such as data of racial and ethnic origin, political opinions, religious convictions, philosophical or moral, union membership, information regarding health or sexual life.
2 – For what purpose do we use the information collected?
The Company uses the information it collects from its clients in order to manage and administer the functionalities provided by the App and/or the Site, communicate with its clients, offer services and products as well as personalize the services that the Company provides.
We also use your personal data for advertising and direct marketing activities, to establish specific profiles for advertising, promotional or commercial purposes or to establish consumer habits, provided that your personal data has been provided by you, obtained with your consent or appears in documents accessible to the public.
For example, we may use the information we collect to recommend services or products marketed by the Company that we think you may like, prevent, detect and investigate potentially prohibited or illegal activities, such as fraud; send you emails, automatic notifications or other types of correspondence and advertising related to any service and/or product sold by the Company, promotions and surveys.
Likewise, said information is used to offer you new services and/or products and to send you administrative, technical, organizational and/or commercial information, in documentary or electronic form, related to the Company’s activities.
3 – With whom do we share the collected information?
The Company does not share or commercialize its clients’ information in any way except in the particular cases indicated below.
The Company contracts with suppliers and third parties, natural or legal persons (hereinafter the Third Parties) for certain tasks such as the development of the App and/or the Site, its updates, implementation and different tasks such as the management of marketing and advertising activities. . These Third Parties will have access to customers’ personal information necessary to perform their functions, but may not use it for other purposes. In addition, they must treat personal information in accordance with this privacy policy and the applicable legislation regarding the protection of personal data, respecting their confidentiality at all times.
In the case of processing of personal data of clients by Third Parties, a contract must be signed with such Third Parties in relation to the processing that establishes that said Third Party may not apply or use the personal data to which it accesses for a purpose other than that which appears in the service contract, nor assign them to other people. It must also be foreseen that once the contractual provision has been fulfilled, the personal data processed must be destroyed, unless there is express authorization from the Company when the possibility of subsequent orders is presumed, in which case they may be stored with due security conditions for a period up to two years. These contracts must contain the confidentiality and confidentiality obligations that Third Parties must maintain regarding the information to which they access.
In the event that the Company or most of its assets are acquired in the future by a third party, the personal information of clients will be one of the transferred assets, being subject to the commitments acquired in this privacy policy (or in the that is in force) unless otherwise expressly authorized by the client. The same criteria will be applied in cases of merger, transformation or corporate division in which the Company intervenes.
The Company may disclose information about its clients in the following cases: (a) when legally required to do so; (b) when you believe in good faith that it is necessary to comply with applicable law or respond to valid legal process by competent authorities (including government agencies); (c) where necessary to protect our customers (for example to prevent spam or fraud attempts or to help prevent loss of life or serious injury to any person); (d) when necessary to operate and maintain the security and integrity of our computer systems and (e) when necessary to protect the rights and/or property of the Company.
4 – What are the personal data protection principles that you should know?
The Company will process the personal data of its clients in accordance with the following principles regarding the protection of personal data:
Right to property over personal data: It is important that you are fully aware that your personal data is your exclusive property and that you have the right to manage and control the use given to your personal information.
Data quality: The Company uses appropriate technology and well-defined personnel practices to process your personal data accurately and quickly. We do not collect data for any purpose other than or incompatible with the purpose set forth in this privacy policy nor do we collect data by unfair or fraudulent means. The data we collect from you must be true, adequate, relevant, accurate and not excessive in relation to the purpose for which it was collected. They will be stored, facilitating, at all times, the exercise of the rights of their owners and updated if necessary, as well as destroyed when they are no longer necessary or relevant to the purposes for which they were collected through an appropriate policy. deletion of personal data.
Data category: No person can be forced to provide sensitive data. The Company does not collect or process this category of data.
Information and consent in data processing: The Company only processes your personal data with your free and express consent and only for the purposes that we have informed you of, for the purposes permitted by you or in the manner permitted by applicable law. . You have the right to object to any data processing that does not comply with this privacy policy and to cancel your user account and unsubscribe from the App at any time.
Security: The Company implements all necessary measures to maintain the security of its clients’ personal information, contemplating the practical, technical and internal organizational measures necessary to guarantee the security, integrity and confidentiality of the data, diligently trying to avoid unauthorized access. , destruction, use, modification or disclosure of data. However, due to the current state of technology, the Company cannot guarantee 100% that unauthorized access will never occur.
Duty of Confidentiality: the Company and the people involved in any phase of the processing of your personal data are obliged to maintain professional secrecy regarding the same and absolute confidentiality. Such obligation will subsist even after your contractual relationship with the Company has ended. The person obliged to maintain the duty of confidentiality may be relieved of said obligation by judicial resolution and when there are well-founded reasons related to public security, national defense or public health. In this regard, we inform you that the Company keeps your personal data confidential and limits access to your personal data to those people who specifically need it to carry out their activities linked to the Services we provide.
Right to personal image: One of the features of the App allows you to publish your personal image. The right to the image is a very personal right and personal data with respect to which you grant us express authorization for its treatment and use in accordance with the guidelines established in this privacy policy.
5 – What rights do you have for the protection of your personal data?
To provide adequate protection to your personal data, we indicate below which rights you have:
Right of access: any client of the Company, owner of personal data, can exercise the right of access to their personal information existing in the Company’s database, free of charge.
Right to rectification, update and deletion: you also have the right to have the personal data of which you are the owner hosted in the Company’s database which, if applicable, be rectified, updated or deleted, free of charge. , must proceed to rectify, update or delete them.
Right to withdrawal or blocking: You may also request, free of charge, the withdrawal or blocking of your name and email from the Company’s files or databases for advertising purposes.
Right to suspension of personal data processing: You may request that the processing of your personal data be limited when you require the rectification or deletion of personal data stored in the Company’s database until your request is resolved.
Right to data portability: You may request that all your data existing in the Company’s database be provided to you or that it be transferred to another person responsible for processing personal data when technically possible.
To exercise the aforementioned rights, as well as if you wish to revoke your consent for the processing of your personal data, contact us by email at info@icao4pilots.com “Ref: “Privacy Policy. Personal Data. Rights”.
6 – What is our policy for minors?
Minors under 17 years of age cannot download or use the App. Any use of the App not authorized by the Company, which may be made by a minor under 17 years of age, is under the exclusive responsibility of their parents, guardians or legal representatives who will be responsible for all the acts carried out through the App by the minors in their care.
Where is our clients’ personal data stored?
Customers’ personal data are stored on servers of a third party hired by the Company (Amazon Web Service) that provides the data hosting service in the cloud (Cloud Computing).
The Company complies with the Privacy Shield framework between the European Union and the United States as well as the Privacy Shield framework between the United States and Switzerland as provided by the Department of Commerce of the United States of America regarding the collection, use and the retention of personal data transferred from the European Union and Switzerland to the United States. If there is any conflict between the terms of this privacy policy and the Privacy Shield principles, the latter will govern with priority. For more information about the Privacy Shield you can consult the following website: https://www.privacyshield.gov/
7 – What is our cookie policy?
The Company uses cookies or other information storage and retrieval devices in its mobile applications and/or when accessing the Site.
In particular, the App uses Cookies, that is, small files or files sent to the client’s device to make their experience more efficient by providing faster access to the functionalities offered by the App and store their preferences and configuration, that is, personalize the services. offered.
As with computer browsers, mobile device browsers allow you to make changes to privacy options or settings to disable or delete cookies. If you wish to modify your privacy options, follow the instructions specified by the developer of your mobile browser. If you do not want a cookie to be installed on your hard drive, you can configure your computer’s browser not to receive them.
“Cookies” are only associated with an anonymous user and their computer and do not provide the user’s personal data on their own, nor can they read data from their hard drive, nor read cookie files created by other providers.
8 – What definitions apply to this Privacy Policy?
For the purposes of an adequate interpretation of this privacy policy, you must consider the following definitions:
Personal data: Information of any type referring to natural persons.
Archive, registry, database or database: Indistinctly, they designate the organized set of personal data that is the subject of treatment or processing, electronic or not, regardless of the method of its formation, storage, organization or access.
Data processing: Systematic operations and procedures, electronic or not, that allow the collection, conservation, organization, storage, modification, relationship, evaluation, blocking, destruction, and in general the processing of personal data, as well as its transfer to third parties. through communications, consultations, interconnections or transfers.
Responsible for file, registry, database or database: Natural person or public or private ideal existence, who is the owner of a file, registry, database or database.
Data owner: Any natural person whose data is subject to processing.
Right of access: is the right that allows the owner of the data to know whether or not it is included in a data bank; all data relating to your person included in that database; the purpose of the treatment and the possible transferees of the information.
Right to rectification, updating and deletion: these are the rights that allow any person to correct false, erroneous, incomplete or incorrect information existing in a database.
Right to data portability: it is the right of the data owner to receive from the controller the personal data that he or she has provided to the controller with his or her consent or the right to have said data transmitted to another controller when said data is processed. automated way. Portability allows the data owner to transfer or reuse their personal data with other companies.
Right to suspension of personal data processing: it is the right of the data owner to request the person responsible for a database to limit the processing of his or her personal data until the request for rectification or deletion of personal data hosted in the database is resolved. said database.
Sensitive data: are personal data that affect the intimate sphere of its owner with the potential to give rise to illicit or arbitrary discrimination, in particular, those that reveal racial or ethnic origin, political opinions, religious, philosophical or moral convictions, participation or affiliation in a union organization, information regarding health or sexual preference.
9- What definitions apply to this Privacy Policy?
For the purposes of an adequate interpretation of this privacy policy, you must consider the following definitions:
Personal data: Information of any type referring to natural persons. Archive, registry, database or database: Indistinctly, they designate the organized set of personal data that is the subject of treatment or processing, electronic or not, regardless of the method of its formation, storage, organization or access.
Data processing: Systematic operations and procedures, electronic or not, that allow the collection, conservation, organization, storage, modification, relationship, evaluation, blocking, destruction, and in general the processing of personal data, as well as its transfer to third parties through communications, consultations, interconnections or transfers.
Responsible for file, registry, database or database: Physical person or public or private ideal existence, who is the owner of a file, registry, database or database.
Data owner: Any natural person whose data is processed.
Right of access: is the right that allows the owner of the data to know whether or not it is included in a data bank; all data relating to your person included in that database; the purpose of the treatment and the possible transferees of the information.
Right to rectification, updating and deletion: These are the rights that allow any person to correct false, erroneous, incomplete or incorrect information in a database.
Right to data portability: is the right of the data subject to receive from the controller the personal data that he or she has provided to the controller with his or her consent or the right to have such data transmitted to another controller when such data is processed. automated way. Portability allows the data owner to transfer or reuse their personal data with other companies.
Right to suspension of personal data processing: this is the right of the data owner to request the person responsible for a database to limit the processing of his or her personal data until the request for rectification or deletion of personal data hosted in the database is resolved. said database.
Sensitive data: are personal data that affects the intimate sphere of its owner with the potential to give rise to illicit or arbitrary discrimination, in particular, those that reveal racial or ethnic origin, political opinions, religious, philosophical or moral convictions, participation or affiliation in a union organization, information regarding health or sexual preference.
10 – Changes in the privacy policy?
This privacy policy may be modified from time to time. The latest version will be available for review on the Site www.icao4pilots.com.
The use of the App and/or the Site, after the changes in the privacy policy have been made, implies acceptance of them. If you do not agree with said modifications, you may unsubscribe from the App and cancel your account immediately. Under no circumstances will we substantially modify our policy to make it less effective in protecting your personal data.
11 – What is our contact channel?
If you have any questions regarding this privacy policy, please contact us by email at the following address: info@icao4pilots.com “Ref: “Privacy Policy. “Personal Data.” The Company’s data protection officer, who is responsible for ensuring the correct and effective application of this policy, will answer your query and respond to your request.