Privacy Information Notice - Airbus Flight Academy

Airbus SAS (also known as“we” or “us”) appreciates your interest in the Airbus Pilot Cadet Training Programme.

The Airbus Pilot Cadet Programme has been designed to allow someone with no flying experience to undergo the Airline Transport Pilot integrated licence with a view to becoming a commercial airline pilot. The Airbus programme is delivered via a network of Airbus standardised & approved flight school members: the Airbus Flight Academy network.

The registration and assessment process can include different steps:

• First contact for information
• Assessment / Screening phase (online and on site)
• Selection and onboarding in the AIrbus Pilot Cadet Training Programme

Your privacy is important to us and we want you to feel comfortable when contacting Airbus or when applying for the AIrbus Pilot Cadet Training Programme, jointly managed and operated with a partner Flight School.

Airbus is committed to protecting the rights of individuals in line with the General Data Protection Regulation (reference EU2016/679) of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (hereinafter referred as : “GDPR”) as well as each applicable national Personal Data protection laws and regulations (collectively referred as “Data Protection Laws and Regulations”). The protection of your privacy and Personal Data is an important concern to which we pay special attention throughout the Airbus Pilot Cadet Training Programme processes.

However, the assessment and/or onboarding steps might include links to specific applications with associated privacy information notice. In this event, we encourage you to carefully read such privacy policies.

This Privacy Notice will inform you of the Personal Data we collect when you contact Airbus for further information on the Airbus Pilot Cadet Training Programme via the relevant contact form on the Airbus Services website or via our generic email address as well as during the Screening assessment and the Airbus Pilot Cadet training delivered in the relevant Flight School partner; how we use and disclose your Personal Data; how you can control the use and disclosure of your Personal Data; and how we protect your Personal Data.

Personal Data is information that can be used to identify a person either directly or indirectly (hereinafter referred as “Personal Data”). This definition covers a wide range of data enabling the identification of an individual.

The Personal Data we might process depending on how far you will go in the Airbus Pilot Cadet Training Programme under this Privacy Notice are as follows:

• Identification data (including full name, address, postal code, city, country of residence, nationality, telephone number, email address, date of birth)
• IT data (Digital activity data (e.g. IP address, MAC address, logs account information such as role and permissions, settings and preferences, login, password)
• Professional data (including assessment test results if applicable, candidate number, Approved Training Organisation center name, PPL Licence number (if applicable))

We may collect this Personal Data cumulatively:

• Directly from you by email and/or by filling the Airbus Pilot Cadet Training Programme contact form in Airbus services.com and/or any information provided when accessing any screening or training tools.
• Indirectly from the company for which you are working for or from Flight School partners that you have contacted to enter into the Airbus Pilot Cadet Training Programme.

By submitting the contact form through Airbus services.com website, by sending email to Airbus and/or by entering into Airbus Pilot Cadet Training Programme for the screening phase (online or onsite) or for undergoing the training program within the Flight School partner, Airbus and the relevant Flight School partner might collect and process your Personal Data for the following purposes depending on how far you will go in the Airbus Pilot Cadet Training Programme (hereinafter referred as: the ‘Purposes’):

• To communicate with you regarding your interest in the Airbus Pilot Cadet Training Programme services, including responding to your request for information and/or for assistance during the Programme. We could possibly use your e-mail address and postal address as well to inform you about Airbus Pilot Cadet Training Programme news, next events, screening sessions, new flight school opening, products, promotional offers and occasional offers by partners third parties we think might interest you. If you do not wish to receive those offers, you can unsubscribe at any time by sending “Unsubscribe” or clicking on the link “Unsubscribe” at the bottom of every emails.
• To comply with Approved Training Organisation requirements in order to assess your skills, competences, qualifications and your eligibility for the Airbus Pilot Cadet Training Programme (if applicable) in the course of the screening assessment phase.
• For Legal compliance. We use your Personal Data to comply with applicable legal obligations, including responding to an authority or court order or discovery request.
• To protect us and others. Where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of policies, terms, and other policies.
• For Website Browsers / Administration. We may use your Personal Data for administrative and account management purposes, to implement and maintain security, anti-piracy, fraud prevention, and other services designed to protect you, our partners and us; and to enforce our policies, directives and processes.
• For Research and development. We may use your Personal Data for research and development purposes, including improving our websites, applications, training services, and customer experience and for other research and analytical purposes dedicated to improving our products, services, businesses, operations and processes.

We will use your personal information for the above Purposes only, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose (for preserving particular evidence under the applicable Data Protection Laws and Regulations, or in the context of legal statutes of limitation for example). If we need to use your Personal Data for an unrelated purpose, we will notify you prior to this before further Personal Data processing and provide you the relevant privacy information notice.

As a responsible company, we need a lawful basis for collecting and/or processing your Personal Data in accordance with the provisions set out in the GDPR and the relevant applicable Data Protection Laws and Regulations. The legal basis for processing your Personal Data under this Privacy Notice are:

For Cadets joining the Airbus Cadet Pilot Training Programme at their own initiative:

As a result of your consent during the screening phase.

When you have consented to the processing of your Personal Data by us for the Airbus Pilot Cadet Training Programme in particular to be part of the screening phase, via the Airbus services.com Website and/or further online and onsite screening tools, you can withdraw consent at any time by following the instructions provided in the application process or by contacting us at dataprotection@airbus.com. For further information on the right of withdrawal, please see below Section “How to exercise your rights and/or contact Airbus in respect of your Personal Data?”

When you have consented to the processing of your Personal Data by us for assessing your skills; competences and qualifications in the course of training services delivery, you can withdraw consent.

For further information on the right of withdrawal, please see below Section “What are your rights and how to exercise them?”

For the duration of the training contract if selected further to the screening phase.

Description : at the end of the screening phase if selected, the related flight school partner and you will enter into a dedicated training contract to cover the training program phase.

Within the scope of a legitimate interest.

• For Information, system, network and cyber security within Airbus.
• For fraud detection and prevention and investigation of criminal acts.
• For Compliance with foreign law, law enforcement, court and regulatory bodies’ requirements.

For Cadets joining the Airbus Cadet Pilot Training Programme at your company’s initiative:

Within the scope of a legitimate interest.

Taking into account the minimum privacy impact for you, the processing of your personal data is necessary for the following legitimate interest:

• For the screening performance and delivery of appropriate training services as agreed with the company for which you are working for
• For fraud detection and prevention and investigation of criminal acts
• For Compliance with foreign law, law enforcement, court and regulatory bodies’ requirements
• For Information, system, network and cyber security within Airbus
• For Communications, marketing and intelligence

For all Cadets:

On the basis of Airbus’/Flight School legal obligations

Airbus, like any other company, is subject to legal obligations and regulations. In some cases the processing of your Personal Data will be necessary for Airbus in order to comply with local aviation authority regulations, notably EASA Part FCL.

We may disclose your Personal Data to the following recipient(s) on a strict need to know basis and for the Purposes as outlined in this Privacy Notice:

• Airbus and its affiliates;
• Authorised persons working for or on behalf of Airbus and/or the relevant Flight School partners, including our agents, service providers and advisers providing the screening tools and/or training tools.
• Other authorised third parties in connection with any merger, reorganisation, a sale of some or all Airbus assets, or a financing or acquisition of all or a portion of our business by another company.
• Law enforcement or government or public authorities or other legal processes to comply with applicable law, or in response to any subpoenas, court orders, or to establish or exercise our legal rights or to defend against legal claims.

Airbus processes your Personal Data mostly in the EEA and UK. On occasion Personal Data is transferred to the relevant recipients as described in Section “Who will receive your Personal Data?”, on a need-to-know basis, including entities outside the EEA when the applicants or the Cadet is affiliated to a non-EEA aviation authority and/or to an non-EEA Flight School partner (such as Mexico) and/or when the applicants or Cadet will access to screening tools where the data are mostly stored in UK.

This transfer is subject to appropriate safeguards, within Airbus through the legal framework of our Binding Corporate Rules, that can be found on our website www.airbus.com or viewed here Airbus BCR's or through alternative contractual frameworks (so called Standard Contractual Clauses) or relevant adequacy decision where the relevant data recipients as defined in Section “Who will receive your Personal Data?” is engaged to help us.

Our Binding Corporate Rules allow us to transfer Personal Data within our international organisation for Airbus daily business activity and internal organisation, and they include a list of countries where Airbus Affiliates having signed the BCR and which might have access to your Personal Data if relevant.

Australia, Belgium, Brazil, Canada, Chile, China, Colombia, Denmark, Finland, France, Germany, Hong Kong, Hungary, India, Indonesia, Ireland, Italy, Japan, Kazakhstan, Malaysia, Mexico, Morocco, Netherlands, New Zealand, Nigeria, Norway, Oman, Philippines, Poland, Qatar, Romania, Russia, Saudi Arabia, Singapore, Slovakia, South Africa, South Korea, Spain, Switzerland, Taïwan, Thailand, Tunisia, Turkey, United Kingdom, United Arab Emirates, Uruguay, United States of America.

We process and store your Personal Data for what relates to professional data and regulatory requirements for aviation training for at least 5 (five) years for flight training from the date of our last interaction with you in accordance with the GDPR or any local data protection laws requirements or as long as it is required to meet our contractual and statutory and regulatory obligations. For any data not relevant to keeping track of training performed as per regulatory requirement, your Personal Data will be stored for maximum two (2) years and then be deleted or archived.

We use technical and organisational security measures in order to protect the Personal Data we have under our control against accidental or intentional manipulation, loss, destruction and against access by unauthorised persons. Our security procedures are continually enhanced as new technology becomes available.

Under some circumstances provided by law, you may at any time exercise your data protection rights as listed below by contacting us at the contact details in section “How to exercise your rights and/or contact us in respect of your Personal Data?”:

• Right to access/obtain a report detailing the information held about you: You have the right to obtain confirmation as to whether or not your Personal Data is being processed by Airbus and if so, what specific Personal Data is being processed.
• Right to correct Personal Data: You have the right to change any inaccurate Personal Data concerning you.
• Right to be forgotten:  In some cases, for instance, when the Personal Data is no longer necessary in relation to the Purposes for which they were collected, you have the right for your Personal Data to be erased.
• Right to restrict the processing of your Personal Data: You have the right to restrict the processing of your Personal Data by Airbus, for instance when the processing is unlawful and you oppose the erasure of your Personal Data. In such cases, your Personal Data will only be processed with your consent or for the exercise or defense of legal claims.
• Right to data portability: You have the right to receive the Personal Data concerning you in a structured, commonly used and machine-readable format and/or transmit those Personal Data to another data controller.
• Right to object: In some cases defined in law, you may ask us to stop processing your Personal Data.
• Right to withdraw consent: Where your consent is required, you may at any time withdraw such consent by contacting us at the contact details in section “How to exercise your rights and/or contact Airbus in respect of your Personal Data?”. However, please note that if you withdraw your consent, you may not be able to access and use certain information, features or services as described in section “Are you obliged to provide your Personal Data?”.
• Right to get information about the main characteristics of the logic involved in the automated decision-making process, except when those main characteristics are secrets protected by law.

If you want to exercise your rights or if you are unhappy with the way in which your Personal Data has been processed or should you have questions regarding the processing of your Personal Data, you may refer in the first instance to the Airbus Data Protection Officer, who is available, at the following email address:

dataprotection@airbus.com or you can write to the address below:

Airbus SAS, Head of Data Protection, 2 rond-point Emile Dewoitine 31700  Blagnac cedex. France.

In case of doubt of your identity, we may ask you to justify it by enclosing a copy of any identity document.

Under certain circumstances, when some Personal Data is necessary to offer training services or to comply with legal obligations, any failure to provide the requested Personal Data may result in us not being able to fulfil our legal obligations or to achieve the expected results and thus to provide the relevant services.

Profiling might occur

• when we process your Personal Data to assess your eligibility for an AIrbus Pilot Cadet training programme and thus evaluate your skills, competences and qualifications and whether you fulfill the necessary prerequisites to enter a given course.
• to keep you properly aware as per needs identified providing you the right information we think might interest you.

As a matter of principle, we do not use fully automated decision-making processes. The final decision being taken through human intervention. In the event that we should use such processes, we will advise you in advance.

If you remain unsatisfied, then you have the right to apply directly to a Data Protection Supervisory Authority. Listed below are the four main European countries where Airbus operates and the relevant Supervisory Authority.

FRANCE:CNIL: Supervisory Authority France

GERMANY: Each federal state has its own Data Protection Authority that can be found under the following link: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html

SPAIN:   AEPD: Supervisory Authority Spain

UK: ICO: Supervisory Authority UK

In addition to the information provided above, The following section is made specifically pursuant to the California Consumer Privacy Act of 2018 (“CCPA”).

We don’t sell your personal information to third parties and we will not sell your personal information to third parties unless provided otherwise by a specific privacy notice. We do not discriminate against California residents who exercise their CCPA privacy rights. To exercise your California privacy rights please refer to the section “How to exercise your rights”.

Please refer to the cookies policy inserted in our general privacy notice.

Airbus will update this Privacy Notice from time to time in order to reflect the changes in our practices and services and also to remain compliant to Data Protection Laws and Regulations. We will inform you of any substantial modification in how we process your Personal Data.