LFTA Asbl, L-1110 Luxembourg, Aviation Générale Nationale (hereinafter “ LFTA”) processes personal data (as defined below) in the course of its activity, which includes in particular those of members of the association and other persons related to LFTA asbl, as well as the personal data of people who browse the Web sites of the LFTA (The “Sites”).
The purpose of this “Privacy Policy” (the “Policy”) is to inform all relevant natural persons (“You” or “Your/Your”) about how LFTA collects and uses such personal data and the means You have to control this use.
1. Scope of this Privacy Policy
This Policy sets out the principles and guidelines for the protection of Your Personal Data (“Personal Data”), which includes Personal Data collected on -or via- its Sites.
LFTA collects Personal Data online (including by e-mail) or offline; This Policy applies regardless of the method of collection or treatment.
The concept of Personal Data refers to any information relating to an identified or identifiable natural person. A person is “identifiable” as long as it can be identified, directly or indirectly, in particular by reference to an identification number or by one or more unique elements of the person.
“Non-Personal Data” refers to information that does not identify a person.
Note to visitors and users of the sites: Your use of the sites and the Personal Data that You will accept to communicate on the sites are subject to the provisions of this Policy and the terms of use Applicable.
2. Data collected
Personal data may include among others:
− Functions;
− Name and Christian name(s);
− Postal Address;
− Electronic Address;
− Telephone Number(s);
Only from students and members:
− Login and password;
− Financial data such as account number, name and address of the holder of the account;
− ID Photo;
And
− Any other Personal Data that may be relevant to the intended purposes set out below.
In any event, the Personal Data collected shall be limited, however, to the data necessary for the intended purposes set out in article 3 below.
Note to visitors and users of the Sites: Certain features of the site can only be used if You communicate to LFTA certain Personal Data when You visit or use the Site. You are free to provide or not some of Your Personal Data. However, if You choose not to provide them, such a decision could prevent the achievement or satisfactory fulfilment of the objectives described in article 3 below, some services and certain features of the Sites may not function properly.
3. Purposes of the collection of Personal Data
Personal data is usually collected for the purposes of the activities of LFTA such as the management of the association or to inform about the activities of the association, or compliance with statutory reporting obligations, as well as other related activities.
LFTA collects and uses Personal Data about You for the purposes of its activities and in particular for the following purposes:
− Allow You to request and obtain information about LFTA and Its activities and LFTA services;
− Allow You to use interactive and personalized Sites;
− Identify Your needs and interests and provide You with the best-suited information and/or services;
− Allow You to interact with other users of the Sites;
− Allow You to register with LFTA as a member or student;
− Allow LFTA to manage and identify its students, members and other persons in connection with LFTA asbl;
− Allow LFTA to manage its transactions with students, members, authorities and suppliers: contributions, contributions to costs, purchases, contracts, orders, invoices, etc.;
− Allow You to register for seminars, webinars or events such as fly-out and rallies;
− Manage Your training, Your licenses and qualifications within LFTA and its associated flying club, Aéro-Sport asbl. This includes monitoring the validity of licenses, qualifications and medical certificates;
− Any other purpose in connection with the activities of LFTA.
LFTA is also likely to use Your email address for administrative purposes.
4. Cookies
Sites may use cookies or other technologies that may collect or store Personal Data. Cookies are text files stored and used to record Personal and Non-Personal Data about You browsing the Sites. Cookies can be permanent (and remain after You log out of the Sites for use during Your subsequent site visits) or temporary (disappear as soon as You log out of sites).
LFTA uses cookies to Improve Your user experience, including:
− Allowing a service to recognize Your hardware, so You won’t have to provide the same information several times in order to perform the same task;
− Recognise the username and password You have already provided so that You do not have to resubmit them on each Web page that would request it;
− Allow You to share the content of Sites with other people on social networks or let these other people know what You are looking at or what You think (e.g. the “Like” button on Facebook).
You can also configure Your browser to consistently deny cookies (including cookies used for audience measurement purposes). However, in this case, some features of the sites may not work properly and You may not be able to access certain parts or services of the sites.
5. Conditions for processing and storing Personal Data
The “processing” of Personal Data includes, among others, the use, preservation, recording, transfer, adaptation, analysis, modification, declaration, sharing and destruction of Personal Data according to what is necessary in terms of circumstances or legal requirements.
All Personal Data collected are kept for a limited period of time depending on the purpose of the treatment and only for the duration provided by the applicable law.
6. Links to websites not controlled by LFTA
Sites may offer links to third party websites that may be of interest to You.
LFTA has no control over the content of third party sites or the practices of those third parties in the protection of Personal Data that they may collect. As a result, LFTA disclaims all responsibility for the processing by these third parties of Your Personal Data. It is Your responsibility to learn about the privacy policies of these third parties.
7. Transfer of Personal Data
In case of access to the Sites from a non-EU country whose legislation on collection, use and transfer of data differs from those of the European Union, we draw Your attention to the fact that by continuing to use the Sites, which are governed by Luxembourgish law, the corresponding terms of use and this Policy You transfer Your Personal Data to the European Union and consent to this transfer.
For the purposes set out in article 3 of this Policy Your Personal Data may be disclosed to affiliates or subsidiaries of LFTA and in particular to its associated flying club Aéro-Sport asbl.
If LFTA was aware that a third-party to which LFTA has provided Personal Data for the purposes set out in article 3 above, uses or discloses Personal Data without complying with this Policy or in violation of applicable law, LFTA would take reasonable measures to prevent or terminate such use or disclosure.
You also have the right to allow or not allow to LFTA to use Your Personal Data for a purpose other than those for which this Personal Data was originally collected, for example to communicate to service providers.
LFTA can also transfer Your Personal Data to the authorities in order to file for flight tests, theoretical examinations and other necessary interventions during pilot training.
LFTA may also be required to transfer Your Personal Data to third parties if the LFTA considers that such a transfer is necessary for technical reasons (for example, for hosting services by a third party) or to protect its legal interests (for example, in case of Sale of assets to a third-party company, change of control or total or partial liquidation of LFTA).
LFTA can also share Your Personal Data with service providers or business partners in case LFTA and the service providers or business partners organize a joint event in which You have committed to participate.
LFTA Can communicate Your Personal Data if the law requires it or if LFTA considers in good faith that such disclosure is reasonably necessary to comply with a legal proceeding (e.g., a warrant, subpoena or other court decision) or to protect the rights, property or personal security of LFTA, our members, students or the public.
8. Right of access and rectification of data
LFTA has set up Personal Data protection systems to ensure that Personal Data are used in accordance with the above intended purposes and to ensure their accuracy and updating.
You have the right to access Your Personal Data. In addition, You have the right to request the rectification, updating or deletion of Your Personal Data. You also have the right to obtain Your Personal Data kept by LFTA.
If You have an account from LFTA as a member or student pilot, You can exercise Your access and rectification rights by logging into Your account. Otherwise, You can exercise Your rights of access and rectification by sending an e-mail to the following address:
dataprotection(at)lfta.lu .
Depending on the extent of the request, LFTA reserves the right to charge the applicant a reasonable amount to cover the costs of access, rectification or deletion operations. LFTA reserves the right to refuse access to Personal Data in the particular cases provided for by applicable laws and regulations.
9. Security and Data Recipients
LFTA ensures to protect and secure the Personal Data that You have chosen to communicate to it, to ensure their confidentiality and to prevent them from being distorted, damaged, destroyed or disclosed to unauthorized third parties.
LFTA has taken physical, electronic and organizational protection measures to prevent unauthorized loss, misuse, access or dissemination, alteration or eventual destruction of such Personal Data. However, despite the efforts of LFTA to protect Your Personal Data, LFTA cannot guarantee the infallibility of this protection because of the inevitable risks that may arise during the transmission of Personal Data.
All Personal Data being confidential, their access is limited to employees, providers and agents of LFTA who need it in the course of carrying out their mission. All persons with access to Your Personal Data are bound by a confidentiality obligation and are subject to disciplinary measures and/or other sanctions if they do not comply with these obligations.
However, it is important that You exercise caution to prevent unauthorized access to Your Personal Data. You are responsible for the confidentiality of Your password and the information contained in Your account. As a result, You should make sure that You close Your session when You are using a shared computer.
10. Conflict resolution
Although the LFTA has taken reasonable steps to protect Personal Data, no transmission or storage technology is completely infallible.
However, LFTA endeavours to guarantee the protection of Personal Data. If You have reason to believe that the security of Your Personal Data has been compromised or abused, You are invited to contact LFTA at the following address: dataprotection(at)lfta.lu .
LFTA can investigate claims concerning the use and disclosure of Personal Data and will attempt to resolve them in accordance with the principles set out in this Policy.
Unauthorized access to Personal Data or misuse may constitute an offence under Luxembourgish law.
11. Contact
If You have any questions about this Policy, to stop receiving information from LFTA or for any request for rectification, addition, update or deletion of Your Personal Data, You can send an e-mail to the following e-mail address: dataprotection(at)lfta.lu .
12. Revisions of the Privacy Policy
This Policy can be updated according to the needs of the LFTA or other circumstances or if the law so requires. We therefore invite You to take regular notice of updates.
15.05.2018