PRIVACY POLICY

Art. 13 of Regulation (EU) 2016/679

General Data Protection Regulation

 

With this policy, Leonardo CAE Advanced Jet Training S.r.l., in its capacity as data controller, wishes to inform users visiting the website www.advancedjettraining.com (hereinafter the “Site“) of the policy adopted regarding the protection of personal data, underlining its commitment and attention to the protection of the privacy of users of the Site (the “Users of the Site”).”). Please read our Privacy Policy carefully, which applies both in the case of simple navigation within the Site and in the case of use of related services.

Navigation within the Site is free and does not require any registration, with the exception of some areas in which the User can freely and expressly provide a series of data concerning him or her in order to access specifically identified services (e.g. to request information from the Company). If the visitor intends to provide his/her personal data to access these additional services, he/she can find in this document all the information relating to the processing of his/her personal data pursuant to Regulation (EU) 2016/679 – General Data Protection Regulation (the “Regulation“) and Legislative Decree no. 196 of 30 June 2003 – Personal Data Protection Code (the “Code“), with an indication (by way of example) of the purposes and methods of use of the data, as well as the right to request at any time the deletion of the data or the updating of the same.

We remind Users that personal data is “any information relating to an identified or identifiable natural person“; “any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available,  the comparison or interconnection, limitation, erasure or destruction“.

By accessing the Site, the User declares that he/she has read and understood this Privacy Policy.

Pursuant to and for the purposes of art. 13 of the Regulations, the Company provides the following information.

1. Identity and contact details of the Data Controllers

Leonardo CAE Advanced Jet Training S.r.l. with registered office in with registered office at the Military Base of Decimomannu, SS 196, KM 4, 09034, Villasor (CA) (hereinafter “AJT“, the “Company“) is the Data Controller of the personal data collected through the Site.

2. Types of personal data processed

To access the Site it is not necessary to proceed with any registration. The Site, however, offers some services for the use of which it is essential to provide your data (e.g. to request information from the Company, to send an application, etc.).

Where necessary, the Company will obtain the specific consent of the User to the relevant use of the data.

3. Purpose and legal basis of the processing

Users’ data are collected and processed for purposes strictly related to the use, management and updating of the Site, the services offered within them and their presentation to Users. The specific purposes of data use are set out in detail in this paragraph.

(a) Use and improvement of the services offered by the Site

Users’ personal data will be processed to ensure access to the main areas and functionalities of the Site (e.g. sending requests for information, submitting your application, etc.).

The processing of data related to the provision of the services of the Site and its operation does not require the consent of the Users, as it is necessary for navigation on the Site (and therefore for the execution of a contract with Users as well as to correctly comply with the legal obligations to which the Company is subject – art. 6, paragraph 1,  letters b) and c) of the Regulation).

Likewise, the processing of data for analysis purposes to allow the improvement of the functioning of the Site does not require the consent of the Users, as it is necessary for the pursuit of the legitimate interest of the Company and the Users in the provision of a high quality service (Article 6, paragraph 1, letter f) of the Regulation).

For more information, see. also the point that follows.

 

(b) Request for information

If the user sends the Company a request for information using the dedicated e-mail address, his/her data will be processed to adequately manage the requests received and, where necessary, to contact the Users concerned.

The processing of data for this purpose does not require the consent of the Users, as it is necessary for the execution of pre-contractual measures adopted at the request of the User (Article 6, paragraph 1, letter b) of the Regulation).

 

(c) Recruitment and selection

If the User submits his/her application using the dedicated e-mail address, his/her personal data will be processed to evaluate the application and, if necessary, to contact the User to schedule a job interview or to request more information about the application.

Among the personal data provided when sending the User’s CV, there may be data belonging to “special categories of personal data” (e.g. reasons for exemption from military service, disability status, belonging to protected categories, etc.).

The processing of personal data, including special data, for the purposes of personnel search and selection does not require the consent of the Users, as it is necessary for the execution of pre-contractual measures adopted at the request of the User (pursuant to Article 6, letter b) of the Regulation and the provision of the Guarantor no. 146 of 5 June 2019 “Provision containing the requirements relating to the processing of special categories of data, pursuant to art. 21, paragraph 1 of Legislative Decree no. 101 of 10 August 2018″).

 

4. Processing methods

The processing of Users’ personal data is carried out by archiving them on electronic media, in compliance with current legislation and, in any case, in such a way as to guarantee the security and confidentiality of the data and prevent their unauthorized disclosure or use, alteration or destruction. All information collected is transmitted in a secure connection so as to prevent it from being intercepted by outsiders.

5. Recipients of personal data

The Users’ data will be made known (limited to their respective areas of competence) by personnel expressly authorised by the Company (Article 29 of the Regulation).

Within the scope of the purposes indicated in the diagram below, the Users’ personal data may come to the knowledge of the following third parties:

 

Purpose	Recipients
(a)	(i) entities that provide services related to the management of the Company’s technological infrastructure; (ii) companies in charge of managing or supporting the management of services functional to the proper functioning of the Site.
(b)	(i) entities that provide services related to the management of the Company’s technological infrastructure; (ii) subjects who provide technical and organisational services instrumental to the management of the pre-contractual relationship (e.g. suppliers of management applications and  dedicated software); (iii) legal, tax and accounting advisors.
(c)	(i) entities that provide services related to the management of the Company’s technological infrastructure; (ii) suppliers who carry out activities functional to the establishment of the employment relationship; (iii) companies that provide services functional to personnel search and selection activities.

 

Where necessary, the Company has appointed the recipients of the Users’ personal data as data processors (Article 28 of the Regulation). A list of all data processors can be requested by communication to be sent to the contact details indicated in this Privacy Policy.

Any communication of Users’ personal data will take place in full compliance with the legal provisions of the Regulation and the technical and organisational measures prepared by the Company to ensure an adequate level of security. Users’ personal data will never be disseminated.

 

6. Transfers outside the EU

The Data collected through the Website are generally not transferred abroad, as the processing is carried out through suppliers who use servers located in the European Union (or European Economic Area).

7. Retention period

Users’ data will be stored for the time strictly necessary to pursue the purposes indicated (cf.  paragraph 3) and in compliance with any consents given. At the end of the retention period, the data will be destroyed or anonymized. Specifically, the data will be stored according to the criteria indicated in the following table.

 

Purpose	Preservation
(a)	With reference to the storage times of data relating to connection and navigation within the Site, please refer to the provisions of paragraph 9 below.
(b)	The data will be stored for the time necessary to properly manage the User’s request for information. In any case, Users’ personal data will not be kept for a period longer than  1 year from the request for information.
(c)	The User’s personal data will be kept for the time strictly necessary for the evaluation of his application, and in any case for a time not exceeding the recruitment needs. However, personal data will not be kept for a period longer than one (1) year from receipt, after which the same data will be destroyed.

 

8. Links to other sites

This Privacy Policy is provided only for the Website and not for other websites that may be consulted by the User via links. The Company cannot be held responsible for the personal data provided by Users to external parties or to any websites linked to the Site.

 

9. Analytics and Tracking Tools

The Site uses technical tracking and personalization tools (i.e. to facilitate navigation and use, as well as the choice of language). The following information relates to both the use of “cookies” and other tracking tools that may be used (unless otherwise indicated). For your convenience, we will use the term “cookies” to refer to all different tracking technologies, unless expressly stated otherwise.

9.1 What is a cookie

Cookies are text files that are sent by a web server (i.e. the computer on which the visited website is “hosted”) to the user’s browser (Microsoft Edge, Mozilla Firefox, Google Chrome, Opera, Safari, etc.) and stored on the device, fixed or mobile, used for the user’s browsing. The cookie allows the Site to identify the user’s device, through the information stored on it, each time the user reconnects to the Site through that device.

2. What types of cookies (or tracking tools) does the Site use

The Site uses only cookies and technical or necessary tools, i.e. used in order to ensure navigation and therefore the electronic transmission of data on the network or strictly necessary for the provision of the services provided by the Site and so-called personalization cookies that allow the user’s preferences in the use of the Site to be recorded (limited to the language chosen for viewing the site).

These cookies can be both first-party and third-party and do not require the acquisition of the user’s prior and express consent as they are strictly necessary to provide the service requested by the user of the Site or functional to navigation.

No cookies are used for analysis or user profiling.

3. Deactivating/deleting cookies via web browser

You can deactivate/enable or delete cookies at any time by using the settings of your web browser. In particular, if you do not wish to receive cookies, you can set your browser so that you are warned of the presence of a cookie and thus be able to decide whether to accept it or not; You can also automatically refuse all cookies by activating the appropriate option in your browser. You can also delete specific cookies that have already been stored within your browser, or block specific websites from storing cookies on your computer, or block third-party cookies.

Each browser (Firefox, Chrome, Edge, Safari, Opera, etc.) has its own cookie management methodology: in the settings or preferences panel it is possible to modify/manage the parameters relating to cookies and/or proceed with their deletion. You can also manage your cookie preferences on http://www.youronlinechoices.com.

Please note that the cancellation/refusal to use technical or necessary cookies may compromise the correct use of the Site.

10. Rights of data subjects

By sending a communication to the address available in the Contact section, the User may at any time exercise the rights referred to in Articles 15 to 22 of the Regulation, including knowing what data we are processing, how and for what purposes we use them, modifying the data you have provided us with or deleting them, asking us to limit the use of the data,  request to receive or transmit the data, without prejudice to the possibility of revoking and/or modifying any consents to processing provided.

Where applicable, the User may also always object to the processing of his data carried out for direct marketing purposes or preference analysis.

In the event of exercising one of the rights provided for by the Regulation, the Data Controller reserves the right to verify the identity of the User by requesting the sending of a photocopy of an identity document certifying the legitimacy of the request. Once the identity has been confirmed, the photocopy received will be immediately destroyed.

An exhaustive description of the rights recognized by the legislation is provided at the end of this Policy.

 

11. Complaint to the Supervisory Authority

If a User believes that the processing of his or her violates the provisions of the Regulation, he or she may always lodge a complaint with the Data Protection Authority (www.garanteprivacy.it), or with the Data Protection Authority of the country in which he or she habitually resides, works or the place where the alleged violation occurred.

 

12. Data Protection Officer (DPO)

The Data Protection Officer designated by the Company (Article 37 of the Regulation) can be contacted at the following email address dpo@advancedjettraining.com.

 

13. Revision clause

The Company reserves the right to revise, modify or simply update, in whole or in part, at its sole discretion, in any way and/or at any time, without notice, this Privacy Policy, also in consideration of changes in laws or regulations on the protection of personal data. Changes and updates to the Privacy Policy will be notified to Users as soon as they are adopted and will be binding as soon as they are published on the Site. We therefore ask Users to regularly access the “Privacy” section to check the publication of the most recent and updated Privacy Policy.

 

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Arts. 15 to 22 of the Regulation recognize specific rights including:

 

Rights	Contents
Right to object to processing	You have the right to object to certain types of processing of your personal data, including processing based on our legitimate interest or processing for the purposes of direct marketing or preference analysis.
Right to be informed	You have the right to receive clear, transparent and easily understandable information about how your personal data is used and how you can exercise your rights.
Right of access to personal data	You have the right to access your personal data (insofar as it is processed by us) and to request, at any time, further information about the processing (e.g. what data concerning you is processed, the purpose of the processing, the categories of data concerned, the recipients or categories of recipients to whom the data is transmitted,  the retention period or the criteria used to determine that period).   In this way, the User will become aware and will be able to verify whether the Company is using his personal data in compliance with current legislation on the protection of personal data.
Right to update and modify	You have the right to have your personal data rectified if it is inaccurate or incomplete.
Right to erasure	Also known as the “right to be forgotten”, it allows you to request the deletion or removal of your personal data where there are no compelling reasons for us to retain it.   There is no absolute right to erasure, which must therefore be balanced with the needs of the Company (e.g. the deletion of data that the Company is obliged to retain in order to comply with a legal obligation, a contractual obligation or for the purpose of ascertaining, exercising or defending a right in court may not be requested).
Right to restriction of processing	You have the right to “block” or restrict the further use of your personal data. If the processing has been restricted, we may still retain your personal data, but we may not process it further. In the event of exercising the right, the Company will prepare special lists containing the details of the subjects who have requested to restrict the processing of their personal data, in order to ensure that the restriction is respected.
Right to portability	You have the right to obtain your data in a structured, commonly used and machine-readable format, and to reuse it for your own purposes within the framework of various services.   This right is limited to data collected in the context of entering into or performing a contract with you or on the basis of your consent.