PRIVACY POLICY PROVIDED PURSUANT TO ART. 13 AND 14 EU REGULATION N. 679/2016 (GDPR) BY PROFESSIONAL AVIATION S.r.l. 

  1. INTRODUCTION

Professional Aviation S.r.l. (VAT number 04288680285) with registered office in Ozzano dell’Emilia (BO), Via Sabbionara n. 5 (“Professional Aviation”), as Data Controller of Personal Data, is aware of the importance of a correct and legitimate processing of Personal Data and Sensitive Data and undertakes to comply with legal obligations and apply the normal standards of the sector in collecting, processing and storing the Personal Data and Sensitive Data of the Data Subjects.

This information, provided by the Data Controller pursuant to art. 13 and 14 of the EU Regulation n. 679/2016, contains detailed information on the collection, processing and storage of Personal Data and Sensitive Data carried out by Professional Aviation as part of its business.

For any further information regarding the collection, processing and storage of Personal Data and Sensitive Data carried out by Professional Aviation, as well as for the exercise of the rights referred to in point 9 below, it is possible to contact the Data Controller’s email address at address privacy@professionalaviation.it

  1. DEFINITIONS

In this Privacy Notice, the following terms are intended as defined.

– GDPR: Regulation UEN.679 / 2016.

– Data Controller: Professional Aviation S.r.l. (VAT number 04288680285), with registered office in Ozzano dell’Emilia (BO), Via

Sabbionara n. 5.

– Personal Data: any information concerning a person who is identified or identifiable, directly or indirectly.

– Sensitive Data: any information revealing racial or ethnic origin, religious, philosophical beliefs, political opinions, trade union membership, data relating to health, life or sexual orientation, as well as genetic data, biometric data relating to an individual

– Interested parties: the subjects with the right to privacy and the correct processing of Personal Data and Sensitive Data that are identified or identifiable through information that, directly or indirectly, concern them.

  1. OBJECT OF THE TREATMENT

Professional Aviation, with the express consent of the interested parties, acquires, processes and stores the Personal Data and / or Sensitive Data of potential, current and previous students and customers, of its staff, collaborators and external consultants, candidates for job positions, suppliers and, in any case, of all subjects whose Personal Data and / or Sensitive Data must be collected, processed and stored by Professional Aviation for the purposes referred to in point 7 below.

The Personal Data acquired, processed and stored by Professional Aviation for the sole purposes referred to in point 7 below, may specifically concern:

– name, surname, date and place of birth, nationality, social security number, residential address, billing address, email address, telephone number, school and work curriculum, foreign language certificates, contacts of videoconferencing platforms, static copy or digital identity document, health card, driving license and / or passport;

– results of selection tests administered by Professional Aviation to verify the suitability of candidates to attend a course;

– family status and employment of the parents of the interested parties;

– bank references of the interested parties;

– certificates from the criminal record;

– details of the pilot licenses of the interested parties and relative static copy;

– minutes of ENAC or other authorized body examinations;

– details of the “Finanziamento Per Merito” that may have been opened by the interested party with Intesa Sanpaolo S.p.A .;

– recordings and acquisitions of images, videos and sounds, subject to the signing of a specific release where required pursuant to

articles 96 – 97, Law no. 633/1941 on copyright;

– recordings and acquisitions of images, videos and sounds by means of the video surveillance cameras installed in the premises of

Professional Aviation, and in general at the airfield of Ozzano dell’Emilia (BO);

– data and statistics regarding the theoretical and practical activities carried out by the students of the School, as resulting from the flight account of each interested party;

As part of its business, Professional Aviation, pursuant to art. 9 of the GDPR, it may have to collect, process and store Sensitive Data of the Data Subjects; in particular:

– medical certificates;

– Class 1/2/3 / LAPL aero-medical certificates issued by qualified AME doctors and by the Air Force Institutes as well as

the related renewals;

– results of psycho-aptitude tests possibly administered, also through authorized third parties, to the interested parties;

– body temperature measurement data and serological test results and COVID-19 swabs of the interested parties.

In addition to all the foregoing expressly provided, Professional Aviation may collect, process and store any other Personal Data and / or Sensitive Data of the Data Subjects that are necessary for the purposes referred to in point 7

  1. DATA COLLECTION METHOD

Professional Aviation, also through its authorized personnel, collects the Personal Data and Sensitive Data referred to in point 3 above in different ways, in particular:

– personally or by telephone to the interested parties;

– from electronic and paper documentation, including the Enrollment Form Professional Aviation, emails, paper letters, consent forms;

– from the personal data sheets administered by Professional Aviation to the Interested parties and the related questionnaire;

– from medical documentation;

– from selection tests administered by Professional Aviation to Interested candidates to attend a course;

– by contracts stipulated with the interested parties;

– automatically, through its website (usage data only);

– through its website and, in particular, through the collection of data entered by the interested parties in the contact form and by any documents attached;

– via digital apps and social media;

– from invoices or accounting documents;

– from static or digital copies of identity documents, passports or other personal documents required if necessary;

– from static copies of pilot licenses;

– from aircraft documentation;

– by means of video surveillance cameras installed in the premises of Professional Aviation, and in general at the airport of Ozzano dell’Emilia (BO), as well as from the webcams of the interested parties;

– through third parties to whom the interested parties have already expressed their consent to the transmission of personal data and data

Sensitive collected at Professional Aviation;

– by means of publicly available resources.

  1. DATA PROCESSING METHOD

The Personal Data and Sensitive Data collected in the manner referred to in point 4 above, will be processed by Professional Aviation in accordance with the provisions of the law and according to the principles of correctness, lawfulness and transparency. In particular, the Personal Data and Sensitive Data will be processed in an adequate, relevant and limited manner to what is necessary for the purposes referred to in point 7 below.

The processing will be carried out using automated and / or manual methods and will be carried out by means of suitable tools, as far as reason and the state of the art, to guarantee adequate security and confidentiality through internal procedures and security software that avoid the risk of loss. , unauthorized access and accidental dissemination or manipulation of the same.

The processing will be carried out by persons authorized to carry out this task, appropriately trained and trained on the current legislation on the processing of Personal Data and Sensitive Data as well as informed of the importance of the correctness of the processing in order to prevent or minimize the risks i) of accidental destruction or loss of Personal Data and Sensitive Data, ii) any unauthorized access, iii) treatment that does not comply with the purposes set out in point 7 below and in any case not permitted or contrary to the consent given by the interested parties.

Personal Data and Sensitive Data, subject to the consent of the Interested parties and limited to the purposes referred to in point 7 below, will be processed by personnel belonging to Professional Aviation and, where necessary, also by authorized third parties in possession of the necessary requirements.

  1. DATA STORAGE METHOD

The Personal Data and Sensitive Data collected will be kept by Professional Aviation for as long as necessary to carry out the purposes for which they were collected and in compliance with the time limits prescribed by law; cases where it is an exception are

 necessary to keep Personal Data and Sensitive Data longer in compliance with legal obligations or to exercise or defend a right in a judicial or extrajudicial way as well as in cases in which a specific period of time has been communicated to the Data Subjects.

Personal Data collected for marketing purposes will be kept by Professional Aviation until the consent of the interested party is withdrawn.

Personal Data and Sensitive Data will be stored on paper and electronic media suitable to prevent or minimize the risks i) of accidental destruction or loss, ii) any unauthorized access, iii) treatment that does not comply with the purposes set out in the following point 7 or in any case not permitted or contrary to the consent given by the interested parties.

The Personal Data and Sensitive Data collected will be processed and stored through the company intranet system and on the Professional Aviation file server; even in this case, compatibly with the state of the art, all measures will be taken to prevent or minimize the risks i) of accidental destruction or loss, ii) any unauthorized access, iii) treatment that does not comply with the purposes provided for in point 7 below or in any case not permitted or contrary to the consent given by the interested parties.

  1. LEGAL BASIS AND PURPOSE OF THE PROCESSING

Professional Aviation processes the Personal Data and Sensitive Data of the Data Subjects in cases where:

  1. a) the interested party has given his consent for one or more specific purposes identified in this Privacy Policy (Article 6, paragraph 1, letter a, GDPR);
  2. b) the processing is necessary for the execution of a contract of which the interested party is a party or for the execution of pre-contractual measures adopted upon request by the same (Article 6, paragraph 1, letter b, GDPR);
  3. c) the processing is necessary to fulfill a legal obligation to which the data controller is subject (Article 6, paragraph 1, letter c., GDPR),

If the Personal Data and / or Sensitive Data requested are not provided, Professional Aviation may not be able to provide information, advice, services or products that are the subject of the Data Subject’s request.

The Personal Data and Sensitive Data of the Data Subjects will be processed by Professional Aviation in order to:

– provide information on the activity carried out by Professional Aviation and make commercial proposals to the interested parties;

– send newsletters, invite to events, presentations, open days;

– fulfill the obligations assumed by Professional Aviation under a contract;

– carry out their own flight school activity;

– carry out the necessary procedures so that the Interested parties obtain the Loan thanks to Intesa Sanpaolo S.p.A., as well as to fulfill all the subsequent formalities required by the general conditions provided by Intesa Sanpaolo S.p.A .;

– enroll students attending the Flight School for exams and qualifications;

– support the operational management of Professional Aviation, including all administrative duties, the management of

invoices, fees and accounts, as well as for research and statistical analysis and conservation of historical archives;

– contact personally, by telephone, by computer, social media and any other suitable means of communication those who have consented to the use of Personal Data for commercial, management or otherwise carrying out the Professional Aviation activity;

– carry out marketing in favor of their business (only with specific consent);

– manage social media accounts;

– establish employment, consultancy, supply and assistance relationships;

– administer the employees and / or collaborators of Professional Aviation;

– provide references;

– establish disciplinary procedures;

– administer the records of human resources;

– administer the salaries, pensions and sick leave of Professional Aviation personnel;

– take out any insurance coverage;

– manage accounting;

– protect the safety of people and property at the Professional Aviation headquarters;

– prevent the contagion from COVID 19 in compliance with the laws in force;

– carry out any activity related to the purposes referred to in the previous points even if not specifically identified

  1. COMMUNICATION OF DATA TO THIRD PARTIES

In the event that it is necessary for the purposes referred to in point 7 above, Professional Aviation may communicate the Personal Data and Sensitive Data of the Data Subjects to third parties, even if not established in the territory of the European Union and also not specified in this point 8.

In particular, Professional Aviation may communicate or allow the collection of Personal Data and Sensitive Data of Data Subjects to the following third parties:

  1. I) ENAC (Ente Nazionale per l’Aviazione Civile)

p.iva 97158180584 – Viale Castro Pretorio n. 118 – 00185 – Roma (RM) – Italia

  1. II) Intesa Sanpaolo S.p.A.

p.iva 11991500015 – Piazza San Carlo 156 – 10121 – Torino (TO) – Italia

III) FlightLogger ApS

VAT DK35469222 – Grønnegade 2, 2. Tv, 8000 Aarhus C – Denmark

  1. IV) Federal Aviation Administration

800 Independence Avenue SW – Washington DC 20591 8 – USA

  1. V) CAE Oxford

London Oxford Airport – Kidlington, Oxford – OX5 1QX – UK

  1. VI) AECI (Aero Club d’Italia)

Via Cesare Beccaria 35/a – 00196 – Roma (RM) – Italia

VII) DropBox inc.

1800 Owens St – San Francisco – CA – 94158 – USA

VIII) Zucchetti S.p.A.

p.iva 05006900962 – Via Solferino 1 – 26900 – Lodi (LO) – Italia

  1. IX) EBIS S.r.l.

p.iva 06587170728 – Via Nicola De Giosa 54, presso la Accademia del Levante – 70121 Bari (BA) – Italia

  1. X) Facebook Ireland Limited

4 Canal Square – Gran Canal Harbour – Dublin 2 – Ireland

  1. XI) Instagram

1 Hacker Way, Manlo Park – CA  – 94025 – USA  

XII) Linkedin Ireland Limited

Gardner House, 2 Wilton Pl, Dublin 2, Irlanda

XIII) Whatsapp Ireland Limited

4 Canal Square – Gran Canal Harbour – Dublin 2 – Ireland

XIV) Cirrus Design Corporation
4515 Taylor Circle
Duluth, MN 55811
Stati Uniti

Even without the prior consent of the Data Subjects, Professional Aviation is authorized to communicate the Personal Data and Sensitive Data of the Data Subjects if forced to do so by law or by order of the Judicial Authority, including foreign ones.

  1. RIGHTS OF THE INTERESTED SUBJECT

By virtue of the provisions of the GDPR, the Data Subjects have particular rights with reference to the collection, processing and storage of Personal Data and Sensitive Data.

Interested partis have the right:

– access to Personal Data and Sensitive Data stored by Professional Aviation;

– to request that the Personal Data and Sensitive Data stored by Professional Aviation be rectified, integrated and / or updated

– to request that the Personal Data and Sensitive Data stored by Professional Aviation be deleted (this right is subject to limitations and exceptions if there are legitimate reasons to keep such Personal Data and Sensitive Data);

– to request Professional Aviation to interrupt or limit the processing of Personal Data and Sensitive Data (this right is subject to limitations and exceptions if there are legitimate reasons to continue the processing of such Personal Data and Sensitive Data regardless of consent);

– to lodge a complaint with the Guarantor Authority.

  1. REQUEST FOR ACCESS BY THE INTERESTED PARTY

Interested parties have the right to request information and / or request that the information held by Professional Aviation concerning them be deleted without incurring any cost, without prejudice to the provisions of point 9 above. Professional Aviation is obliged to provide the interested parties that they request only information concerning them. Personal Data and Sensitive Data referable to other subjects are excluded from the right of access.

Professional Aviation is not allowed to disclose confidential information.

Any request relating to the Personal Data and Sensitive Data collected, processed or stored concerning the Data Subjects must be made in writing. The Data Subject Access Request form can be obtained at the following internet address https://www.garanteprivacy.it/home/modulistica-e-servizi-online

The Data Protection Law allows us to provide a response to such written requests within one calendar month. Excessive requests or simultaneous requests for the same information may imply an administrative burden or be rejected when the Personal Data Protection Law allows it.

  1. METHOD OF EXERCISE OF RIGHTS

To assert their rights, the interested party may, at any time, send the form referred to in point 10 above:

  • by registered letter with return receipt addressed to Professional Aviation S.r.l. (VAT number 04288680285) with registered office in Ozzano dell’Emilia (BO), Via Sabbionara n. 5 or, alternatively, an e-mail to the address: privacy@professionalaviation.it

It is understood that, where the access request is submitted by electronic means, the information may be provided in a commonly used electronic format.

  1. CONSENT

Professional Aviation is obliged to obtain consent in order to process the Personal Data and Sensitive Data of the Data Subjects. This obligation is, however, subject to limitations and exceptions if there are legitimate reasons for processing such data, in order to support the work of Professional Aviation or to comply with legal obligations, regardless of consent. Professional Aviation, in the collection of Personal Data and Sensitive Data from the Data Subjects, adopts the necessary measures to notify the Data Subjects about certain topics, including the purpose of the processing and the methods of accessing, updating and correcting the information. stored concerning the interested parties.

The consent forms will be provided on paper or electronically.

If they agree, the interested parties must clearly and unambiguously express their consent by signing the appropriate form.

The Data Controller may submit to the interested parties a form for the collection of consent equipped with a specific link / QR code that refers to this Information, in which case it is the responsibility of the interested parties to view this information before giving consent to the processing of personal data and Sensitive data. Interested parties also have the right to request a printed copy of this Information from the Data Controller.

  1. UPDATE OF THE PRIVACY POLICY

Professional Aviation will update this Privacy Policy over time. Any substantial change that may affect the methods of processing Personal Data and Sensitive Data will be made known on the website or through a specific newsletter. 

13 bis. SPECIAL PROVISIONS FOR COVID-19

With regard to the containment measures of the Covid-19 epidemic and the prevention of contagion, Professional Aviation, in accordance with the provisions of the law in force from time to time as well as the health protocols adopted, could submit the

Interested parties who need to access the Owner’s premises and / or vehicles and / or aircraft, or in any case referable to the same, for the instantaneous measurement of body temperature using appropriate instrumentation.

In the event that the interested party refuses to undergo such measurement, Professional Aviation could legitimately refuse access to the premises and / or vehicles and / or aircraft.

For the same purposes, Professional Aviation could collect the results of swabs and serological tests carried out by the interested parties from the interested parties as well as request information on the presence of COVID-19 symptoms. In the event that these tests, even if otherwise named, are found to be positive, Professional Aviation is entitled to prevent the interested parties from accessing its premises and / or vehicles and / or aircraft. Equally in the event that the interested party has reported the presence of COVID-19 symptoms.

The data collected will not be recorded except in the event that this is necessary in order to document the reasons that prevented access to the premises and / or vehicles and / or aircraft of Professional Aviation as well as if the conservation is necessary to make assert a right of the Data Controller, including any disciplinary measures for the violation of the anti COVID-19 protocols.

Any data collected for the purposes described in this point 13 bis will be deleted at the end of the health emergency, except as provided in the previous paragraph.

The data collected for the purposes indicated above will not be disclosed to third parties unless this is required by specific provisions of the law (eg in the event of a request by the Health Authority for the reconstruction of the supply chain of any close contacts of a subject positive for COVID-19).

  1. COOKIES POLICY

Professional Aviation uses cookies on its websites to provide advanced features and improve the user experience. Cookies are small data files that are sent from the Professional Aviation website to the computer or mobile phone used for navigation and stored on the hard drive of the device. Some are kept only for the duration of the visit to the site, others are kept for longer periods. For more information on cookies in general, we recommend that you visit the website: https://www.garanteprivacy.it/cookie.

The Professional Aviation website does not use cookies that give access to all personal information of the interested parties. The Professional Aviation website uses cd cookies. “Technical”, useful because they can make web browsing faster and faster

Professional Aviation uses cookies to compile anonymous and aggregate statistics that allow us to understand how users use the website and to improve its structure and content. It is not possible to identify the individual visitor to the website through this information.

The authorized Professional Aviation staff and the Data Processor, if appointed, will have access to the data collected through cookies. The data collected through cookies will be shared with the competent authorities (pursuant to applicable laws), third parties who provide technical and organizational services functional for the use of cookies.

Visitors to the Professional Aviation website will be able to change their preferences regarding cookies at any time or manage their preferences directly from the browser.

PRIVACY POLICY PROVIDED PURSUANT TO ART. 13 AND 14 EU REGULATION N. 679/2016 (GDPR) BY PROFESSIONAL AVIATION SERVICE S.r.l. 

  1. INTRODUCTION

Professional Aviation Service S.r.l. (VAT number 03657391201), with registered office in Ozzano dell’Emilia (BO), Via Sabbionara n. 5 (“Professional Aviation Service”), as Data Controller of Personal Data, is aware of the importance of a correct and legitimate processing of Personal Data and Sensitive Data and undertakes to comply with legal obligations and apply normal standards of the sector in collecting, processing and storing the Personal Data and Sensitive Data of the Data Subjects.

This information, provided by the Data Controller pursuant to art. 13 and 14 of the EU Regulation n. 679/2016, contains detailed information on the collection, processing and storage of Personal Data and Sensitive Data carried out by Professional Aviation Service as part of its business.

For any further information regarding the collection, processing and storage of Personal Data and Sensitive Data carried out by Professional Aviation Service, as well as for the exercise of the rights referred to in point 9 below, you can contact the Data Controller’s email address: privacy@professionalaviation.it

  1. DEFINITIONS

In this Privacy Policy, the following terms are intended as defined.

– GDPR: EU Regulation No. 679/2016.

– Data Controller: Professional Aviation Service S.r.l. (VAT number 03657391201), with registered office in Ozzano dell’Emilia (BO), Via Sabbionara n. 5.

– Personal Data: any information concerning a natural person that makes him identified or identifiable, directly or indirectly.

– Sensitive Data: any information revealing racial or ethnic origin, religious, philosophical beliefs, political opinions, trade union membership, data relating to health, life or sexual orientation, as well as genetic data, biometric data relating to an individual.

– Interested parties: the subjects with the right to privacy and the correct processing of Personal Data and Sensitive Data that are identified or identifiable through information that, directly or indirectly, concern them.

  1. OBJECT OF THE TREATMENT

Professional Aviation Service, with the express consent of the interested parties, acquires, processes and stores the Personal Data and / or Sensitive Data of potential, current and previous customers, of its staff, collaborators and external consultants, candidates for job positions, suppliers and, in any case, of all the subjects whose Personal Data and / or Sensitive Data must be collected, processed and stored by Professional Aviation Service for the purposes referred to in point 7 below.

The Personal Data acquired, processed and stored by Professional Aviation Service for the sole purposes referred to in point 7 below, may specifically concern:

– name, surname, date and place of birth, nationality, social security number, residential address, billing address, email address, telephone number, school and work curriculum, foreign language certificates, contacts of videoconferencing platforms, static copy or digital identity document, health card, driving license and / or passport;

– bank references of the interested parties;

– certificates from the criminal record;

– details of the aircraft documentation referable to the interested parties;

– details of the pilot licenses of the interested parties and relative static copy;

– recordings and acquisitions of images, videos and sounds, subject to the signing of a specific release where required pursuant to art. 96 – 97, Law no. 633/1941 on copyright;

– recordings and acquisitions of images, videos and sounds by means of video surveillance cameras installed in the premises of Professional Aviation, and in general at the airfield of Ozzano dell’Emilia (BO);

– any other Personal Data or Sensitive Data that must be collected, processed or stored for the purposes referred to in point 7 below.

As part of its business, pursuant to art. 9 of the GDPR, Professional Aviation Service may have to collect, process and store Sensitive Data of the Data Subjects; in particular:

– medical certificates;

– body temperature measurement data and serological test results and COVID-19 swabs of the interested parties.

In addition to all the foregoing expressly provided, Professional Aviation Service may collect, process and store any other Personal Data and / or Sensitive Data of the Data Subjects that are necessary for the purposes referred to in point 7 below.

  1. DATA COLLECTION METHOD

Professional Aviation Service, also through its authorized personnel, collects the Personal Data and Sensitive Data referred to in point 3 above in different ways, in particular:

– personally or by telephone to the interested parties;

– from electronic and paper documentation, emails, paper letters, consent forms;

– by contracts stipulated with the interested parties;

– automatically, through the website https://www.professionalaviation.it/ (usage data only);

– through the website https://www.professionalaviation.it/ and, in particular, through the collection of the data entered by the interested parties in the contact form and any attached documents;

– from invoices or accounting documents;

– from static or digital copies of identity documents, passports or other personal documents required if necessary;

– from static copies of pilot licenses;

– from the documentation of aircraft that can in any case be referred to the Interested parties;

– by means of surveillance cameras installed in the premises of Professional Aviation Service, and in general at the airfield of Ozzano dell’Emilia (BO), as well as from the webcams of the interested parties;

– through third parties to whom the Interested parties have already expressed their consent to the transmission of Personal Data and Sensitive Data collected to Professional Aviation Service;

– by means of publicly available resources.

  1. DATA PROCESSING METHOD

The Personal Data and Sensitive Data collected in the manner referred to in point 4 above, will be processed by Professional Aviation Service in accordance with the provisions of the law and according to the principles of correctness, lawfulness and transparency. In particular, the Personal Data and Sensitive Data will be processed in an adequate, relevant and limited manner to what is necessary for the purposes referred to in point 7 below.

The processing will be carried out using automated and / or manual methods and will take place by means of suitable tools, as far as reason and state of the art is concerned, to guarantee adequate security and confidentiality through internal procedures and security software that avoid the risk of loss. , unauthorized access and accidental dissemination or manipulation of the same.

The processing will be carried out by persons authorized to carry out this task, appropriately trained and trained on the current legislation on the processing of Personal Data and Sensitive Data as well as informed of the importance of the correctness of the processing in order to prevent or minimize the risks i) of accidental destruction or loss of Personal Data and Sensitive Data, ii) any unauthorized access, iii) processing that does not comply with the purposes set out in point 7 below and in any case not permitted or contrary to the consent given by the interested parties.

The Personal Data and Sensitive Data, subject to the consent of the Interested parties and limited to the purposes referred to in point 7 below, will be processed by personnel headed by Professional Aviation Service and, where necessary, also by authorized third parties in possession of the necessary requisites.

  1. DATA STORAGE METHOD

The Personal Data and Sensitive Data collected will be kept by Professional Aviation Service for as long as necessary to carry out the purposes for which they were collected and in compliance with the time limits prescribed by law; the cases in which it is necessary to keep Personal Data and Sensitive Data longer in compliance with legal obligations or to exercise or defend a right in a judicial or extra-judicial way as well as cases in which a specific period has been communicated to the Data Subjects of time.

Personal Data collected for marketing purposes will be kept by Professional Aviation Service until the consent of the interested party is withdrawn.

Personal Data and Sensitive Data will be stored on paper and electronic media suitable to prevent or minimize the risks i) of accidental destruction or loss, ii) any unauthorized access, iii) treatment that does not comply with the purposes set out in the following point 7 or in any case not permitted or contrary to the consent given by the interested parties.

The Personal Data and Sensitive Data collected will be processed and stored through the company intranet system and on the Professional Aviation Service file server; even in this case, compatibly with the state of the art, all measures will be taken to prevent or minimize the risks i) of accidental destruction or loss, ii) any unauthorized access, iii) treatment that does not comply with the purposes provided for in the following point 7 or in any case not permitted or contrary to the consent given by the interested parties.

  1. LEGAL BASIS AND PURPOSE OF THE PROCESSING

Professional Aviation Service processes the Personal Data and Sensitive Data of the Data Subjects in cases where:

  1. a) the interested party has given his consent for one or more specific purposes identified in this Privacy Policy (Article 6, paragraph 1, letter a, GDPR);
  2. b) the processing is necessary for the execution of a contract of which the interested party is a party or for the execution of pre-contractual measures adopted upon request by the same (Article 6, paragraph 1, letter b, GDPR);
  3. c) the processing is necessary to fulfill a legal obligation to which the data controller is subject (Article 6, paragraph 1, letter c., GDPR),

If the Personal Data and / or Sensitive Data requested are not provided, Professional Aviation Service may not be able to provide information, advice, services or products subject to the request of the interested parties.

The Personal Data and Sensitive Data of the Data Subjects will be processed by Professional Aviation Service in order to:

– provide information on the activity carried out by Professional Aviation Service and make commercial proposals to the interested parties;

– send newsletters, invite to events, presentations;

– fulfill the obligations assumed by Professional Aviation Service under a contract;

– carry out ordinary and extraordinary maintenance on aircraft;

– support the operational management of Professional Aviation Service, including all administrative duties, the management of invoices, fees and accounts, as well as for research and statistical analysis and conservation of historical archives;

– contact personally, by telephone, by computer, social media and any other suitable means of communication, those who have consented to the use of Personal Data for commercial, management purposes or in any case for the performance of Professional Aviation Service activities;

– carry out marketing in favor of their business (only with specific consent);

– manage social media accounts;

– establish employment, consultancy, supply and assistance relationships;

– administer the employees and / or collaborators of Professional Aviation Service;

– provide references;

– establish disciplinary procedures;

– administer the records of human resources;

– administer the salaries, pensions and sick leave of the employees of Professional Aviation Service;

– take out any insurance coverage;

– manage accounting;

– protect the safety of people and property at the Professional Aviation headquarters;

– prevent the contagion from COVID 19 in compliance with the laws in force;

– carry out any activity related to the purposes referred to in the previous points even if not specifically identified.

  1. COMMUNICATION OF DATA TO OTHERS

In the event that it is necessary for the purposes referred to in point 7 above, Professional Aviation may communicate the Personal Data and Sensitive Data of the Data Subjects to third parties even if not established in the territory of the European Union and also not specified in this point 8.

In particular, Professional Aviation Service may communicate or allow the collection of Personal Data and Sensitive Data of the Data Subjects to the following third parties:

  1. I) ENAC (National Civil Aviation Authority)

p.iva 97158180584 – Viale Castro Pretorio n. 118 – 00185 – Rome (RM) – Italy

  1. II) Zucchetti S.p.A.

VAT number 05006900962 – Via Solferino 1 – 26900 – Lodi (LO) – Italy

III) EBIS S.r.l.

p.iva 06587170728 – Via Nicola De Giosa 54, at the Accademia del Levante – 70121 Bari (BA) – Italy

  1. IV) Facebook Ireland Limited

4 Canal Square – Gran Canal Harbor – Dublin 2 – Ireland

  1. V) Instagram

1 Hacker Way, Manlo Park – CA – 94025 – USA

  1. VI) Linkedin Ireland Limited

Gardner House, 2 Wilton Pl, Dublin 2, Ireland

VII) Whatsapp Ireland Limited

4 Canal Square – Gran Canal Harbor – Dublin 2 – Ireland

VIII) Cirrus Design Corporation

4515 Taylor Circle

Duluth, MN 55811

United States

Even without the prior consent of the interested parties, Professional Aviation Service is authorized to communicate the Personal Data and Sensitive Data of the interested parties if forced to do so by law or by order of the Judicial Authority, including foreign ones.

  1. RIGHTS OF THE INTERESTED PARTY

By virtue of the provisions of the GDPR, the Data Subjects have particular rights with reference to the collection, processing and storage of Personal Data and Sensitive Data.

Interested parties have the right:

– access to Personal Data and Sensitive Data stored by Professional Aviation Service;

– to request that the Personal Data and Sensitive Data stored by Professional Aviation Service be rectified, integrated and updated;

– to request that the Personal Data and Sensitive Data stored by Professional Aviation Service be deleted (this right is subject to limitations and exceptions if there are legitimate reasons to keep such Personal Data and Sensitive Data);

– to request Professional Aviation Service to interrupt or limit the processing of Personal Data and Sensitive Data (this right is subject to limitations and exceptions if there are legitimate reasons to continue the processing of such Personal Data and Sensitive Data regardless of consent) ;

– to lodge a complaint with the Guarantor Authority.

  1. REQUEST FOR ACCESS BY THE INTERESTED PARTY

Interested parties have the right to request information and / or request that the information held by Professional Aviation Service concerning them be deleted without incurring any cost, without prejudice to the provisions of point 9 above. Professional Aviation Service is obliged to provide to the interested parties who request only the information concerning them. Personal Data and Sensitive Data referable to other subjects are excluded from the right of access.

Professional Aviation Service is not allowed to disclose confidential information.

Any request relating to the Personal Data and Sensitive Data collected, processed or stored concerning the Data Subjects must be made in writing. The Data Subject Access Request form can be obtained at the following internet address https://www.garanteprivacy.it/home/modulistica-e-servizi-online

The Data Protection Law allows us to provide a response to such written requests within one calendar month. Excessive requests or simultaneous requests for the same information may imply an administrative burden or be rejected when the Personal Data Protection Law allows it.

  1. METHOD OF EXERCISE OF RIGHTS

To assert their rights, the interested party may, at any time, send the form referred to in point 10 above:

  • by registered letter with return receipt addressed to Professional Aviation Service S.r.l. (VAT number 03657391201), with registered office in Ozzano dell’Emilia (BO), Via Sabbionara n. 5 or, alternatively, an e-mail to the address: privacy@professionalaviation.it

It is understood that, where the access request is submitted by electronic means, the information may be provided in a commonly used electronic format.

  1. CONSENT

Professional Aviation Service is obliged to obtain consent in order to process the Personal Data and Sensitive Data of the Data Subjects. This obligation is, however, subject to limitations and exceptions if there are legitimate reasons for processing such data, in order to support the work of Professional Aviation Service or to comply with legal obligations, regardless of consent. Professional Aviation Service, in the collection of Personal Data and Sensitive Data from the Data Subjects, adopts the necessary measures to notify the Data Subjects about certain topics, which include the purpose of the processing and the methods of access, updating and correction of stored information concerning the Data Subjects.

The consent forms will be provided on paper or electronically.

If they agree, the interested parties must clearly and unambiguously express their consent by signing the appropriate form.

The Data Controller may also submit to the interested parties a consent form equipped with a specific link / QR code that refers to this Information, in which case it is the responsibility of the interested parties to view this information before giving consent to the processing of personal data and sensitive data. . Interested parties also have the right to request a printed copy of this Information from the Data Controller.

  1. UPDATE OF THE PRIVACY POLICY

Professional Aviation Service will update this Privacy Policy over time. Any substantial change that may affect the methods of processing Personal Data and Sensitive Data will be made known on the website or through a specific newsletter.

13 bis. SPECIAL PROVISIONS FOR COVID-19

With regard to the containment measures of the Covid-19 epidemic and the prevention of contagion, Professional Aviation Service, in accordance with the provisions of the law in force from time to time as well as the health protocols adopted, could subject the interested parties who need to access the premises and / or to the Owner’s vehicles and / or aircraft, or in any case referable to the same, for the instantaneous measurement of body temperature using appropriate instrumentation.

In the event that the interested party refuses to undergo such measurement, Professional Aviation Service could legitimately refuse access to the premises and / or vehicles and / or aircraft.

For the same purposes, Professional Aviation Service could collect the results of swabs and serological tests carried out by the interested parties from the interested parties as well as request information on the presence of COVID-19 symptoms. In the event that these tests, even if otherwise named, are positive, Professional Aviation Service is entitled to prevent the interested parties from accessing its premises and / or vehicles and / or aircraft. Equally in the event that the interested party has reported the presence of COVID-19 symptoms.

The data collected will not be recorded except in the event that this is necessary in order to document the reasons that prevented access to the premises and / or vehicles and / or aircraft of Professional Aviation Service as well as if storage is necessary for assert a right of the Data Controller, including any disciplinary measures for the violation of the anti COVID-19 protocols.

Any data collected for the purposes described in this point 13 bis will be deleted at the end of the health emergency, except as provided in the previous paragraph.

The data collected for the purposes indicated above will not be disclosed to third parties unless this is required by specific provisions of the law (eg in the event of a request by the Health Authority for the reconstruction of the supply chain of any close contacts of a subject positive for COVID-19).