Data protection policy

This document aims to explain how Flight Operations Academy GmbH (hereafter also referred to as
“we” or “us”) collects, processes, and protects personal data that you provide when communicating
with us through any media, including but not limited to Flight Operations Academy GmbH’s online
service request form, chat, phone, emails, and texts.
This information must be provided by the General Data Protection Regulation (article 13; Regulation
(EU) 2016/679 of the European Parliament and of the Council of 27 April 2016).
Please note that Flight Operations Academy GmbH does not carry out any automated decision-
making.

1. IDENTITY AND CONTACT DETAILS OF THE CONTROLLER

The data controller is International Flight Operations Academy GmbH, with a registered office at
Oberdorf 26, 4314 Zeiningen, Switzerland.
For any data protection concerns, don't hesitate to contact Vincent Incammicia at the address
vincent@theifoa.com or call +41 78 227 3103

2. PURPOSES AND LEGAL BASIS FOR THE PROCESSING

International Flight Operations Academy GmbH collects personal data for the following purposes:
a. To provide our services to you
This is the main reason why we need to collect personal data. We need information about you to
answer service requests (made with our online form, by phone, or WhatsApp), make service
proposals, draft and conclude service level agreements, send invoices, and organize and follow up
services.
In this regard, the collection of personal data is a contractual requirement and not a statutory one. It
is a condition to enter into any contract with Flight Operations Academy GmbH. If you fail to provide
the required data, it can be impossible to conclude a contract, and International Flight Operations
Academy GmbH will be unable to provide the requested services.
For this purpose, the legitimate ground for personal data collection is the necessity to process
personal data to enter into a contract with us.
b. To improve your customer experience
We process your personal data to improve our services. This includes tailoring our services to your
needs and preferences, facilitating the use of our website by analyzing the browsing history of its
users, and sending promotional content by post, email, WhatsApp, or online advertisements.
Suppose you have requested or used our services and provided personal data to International Flight
Operations Academy GmbH in this context. We may use your contact details to send you marketing
emails about similar services unless you have opted out. You can opt-out anytime by clicking
“unsubscribe” in promotional emails or contacting us at the address above.

For this purpose, the legitimate ground for personal data collection is International Flight Operations
Academy GmbH’s legitimate interest in offering better services.
c. To comply with the law
In some cases, we are legally required to collect some personal data. This is the case when banks
conduct anti-fraud checks or in the event of a formal request by a government entity.
For this purpose, the legal ground for personal data collection is compliance with a legal obligation.

3. TYPE OF INFORMATION COLLECTED

Collected personal data includes:
- Contact details, such as name and surname, phone number, email address, and physical address;
- Personal details, such as family members, personal preferences, and pets;
- Travel information, such as passport details, aircraft, departure location, destination, and time of
your flights;
- Bank details when a credit card is used to book or pay for our services;
- Usage Data includes information history of your use of Flight Operations Academy GmbH’s services
and website.

4. RECIPIENTS OF THE PERSONAL DATA

The employees of International Flight Operations Academy GmbH process collected data. The
number of employees accessing your data is limited to those needing assistance for the intended
activity.
In addition, under the circumstances listed below, we will share your personal data with the
following people:
- When a service agreement is concluded with you: People whose intervention is mandatory to
perform the contract (i.e., operators, terminal airport staff…);
- When we need to store your data: Cloud storage providers;
- When we communicate by e-mail with you: Email services providers;
- When you use our website: Analytic tools and the website’s IT developers;
- Upon payment, when we are asked to provide information against fraud: Banks;
- When you book or pay with a credit card: E-payment interface provider and payment service
providers;
- When you use our chat: Chat service provider.

5. PERSONAL DATA TRANSFER TO A THIRD COUNTRY

Depending on the service you ask for, your personal data may be transferred to a country outside of
the EU (a third country). This can be the case if you wish to travel to or from such a third country, if
you stay in such a third country when data is transferred to or from International Flight Operations
Academy GmbH, or if the provider or partners chosen is based in a third country.
In all of the above situations, the transfer is based on the necessity to process personal data to enter
into a contract with you.

6. STORAGE PERIOD OF THE PERSONAL DATA

Personal data are stored as long as necessary to fulfill the purposes set out here above. This means
that data will generally be stored for the time needed for the performance of the contract and
possible future agreements with Flight Operations Academy GmbH. Some personal data will be
stored longer to comply with legal obligations, such as tax purposes.
7. CONFIDENTIALITY AND SAFETY MEASURES

The information is securely stored systematically, ensuring that nobody outside International Flight
Operations Academy GmbH can access it.
Each new employee receives training in data protection to know how to handle our customers’
personal data.

8. YOUR RIGHTS

Under the General Data Protection Regulation, you have the following rights:
a. Right to request access to personal data (art. 15 of the Regulation)
This right allows you to ask Flight Operations Academy GmbH if you want to know and see what
personal data we store about you.
b. Right to request rectification of personal data (art. 16 of the Regulation)
If some personal data we hold about you needs to be corrected, you can ask Flight Operations
Academy GmbH to rectify it.
c. Right to request the erasure of personal data, also referred to as the “right to be forgotten” (art.
17 of the Regulation)
This right allows you to ask us to suppress personal data under specific circumstances; for example,
the personal data are no longer necessary concerning the purposes for which they were collected,
when processing is based on consent, and you withdraw your consent, or when your personal data
have been unlawfully processed.
d. Right to restrict the processing of personal data (art. 18 of the Regulation)
You can ask Flight Operations Academy GmbH to restrict the processing of your personal under
specific circumstances. It is the case when you exercise the right of rectification – you can ask for a

restriction of the processing while we verify the accuracy of the concerned data. You can also
exercise this right when the processing is unlawful instead of asking for erasure (see right no. 3
above). Restriction of processing can as well be requested when we no longer need the personal data
for processing but you require them for legal claims.
e. Right to object to the processing of personal data (art. 21 of the Regulation)
When your data is used to improve our services or direct marketing, you can object to the
processing. Concerning promotional emails, you can opt-out by clicking on “unsubscribe” in the
emails or by contacting us at the address displayed here under.
f. Right to data portability (art. 20 of the Regulation)
This right enables you to receive the personal data concerning yourself, which you have provided to
Flight Operations Academy GmbH, in an easily readable format and transmit those data to another
data controller.
g. Right to complain with a supervisory authority.
This right enables you to address a complaint to the competent supervisory authority of the member
state.
If you want to exercise any of rights (a)-(g) listed above, or if you have any inquiry about data
protection, please send your request to Vincent Incammicia at the following email address:
vincent@theifoa.com
Zeiningen, 28 February 2023

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