The following information applies to our website www.rwl-flight.de and to our pages on Facebook and Instagram.
- Controller under data protection laws
RWL German Flight Academy GmbH
Managing director: Jens Küper
Am Flughafen 20
41066 Mönchengladbach
Tel.: +49 2161 68900
Fax: +49 2161 689090
Email: info@rwl-flight.de
Website: www.rwl-flight.de
- Scope of the processing of personal data, legal basis for the processing of personal data, duration of storage/deletion
The protection and security of your data is extremely important to us. We apply technical and organisational measures to secure our website and other systems against loss, destruction, access, alteration and/or distribution of your details by unauthorised persons. To protect the transfer of personal data, this website uses SSL encryption, which you can recognise by the string https in the browser line.
- Data collection when visiting our website
You can visit our website without giving us your name.
However, whenever you access our website, our provider’s server, which is responsible for processing our data for hosting and for displaying the website, will automatically store data about your visit temporarily in a log file.
The following data is retrieved and stored:
- Date and time of access
• URL of the referring website
• Retrieved file
• Quantity of data sent
• User’s browser type and version
• User’s operating system
• User’s IP address
No personal user profiles are created.
The purpose of data processing is to ensure a smooth connection on the website and to make it easier for users to use the site.
The legal basis for this temporary data processing is Article 6(1) lit. f, GDPR. Our legitimate interest follows from the stated purpose of providing the website for users for retrieval.
Data is deleted as soon as it is no longer required for the purposes for which it was collected. When data is collected for the provision of the website, it will be deleted after 7 days at the latest.
- Cookies
We use cookies on our website, which are small text files that are placed on the user’s device. Cookies are placed so user information can be collected and processed. Information is stored in the cookies depending on the user’s device.
Further information can also be obtained from the Cookie-Banner.
- a) Technically required cookies
We use the following technically required cookies:
aa)
We use the WordPress plug-in “Borlabs Cookie” to collect and manage consents and revocations. A cookie is set when consent is given to use cookies. The cookie will remain in place for one year. The legal base for the use of the cookie is Article 6(1), sentence 1 lit. f, GDPR. The purpose of the use is to able to document your consent. Our legitimate interest is based on economic viewpoints and the stated purpose of the use of the cookie.
bb)
We use the device PixelRatio cookie for a better display on your device. This cookie records the pixel ratio of your device. If your screen resolution is a retina or Hi-DPI screen, the web page may offer higher resolution graphics. The cookie will remain in place for 6 days. The legal base for the use of the cookie is Article 6(1), sentence 1 lit. f, GDPR. Our legitimate interest is based on economic viewpoints and the stated purpose of the use of the cookie.
cc)
We also use the PHPSESSID cookie. This cookie is native to PHP applications. The cookie is used to store and identify a user’s unique session ID in order to manage the user session on the website. The cookie is a session cookie, and is deleted when all the browser windows are closed. The legal base for the use of the cookie is Article 6(1), sentence 1 lit. f, GDPR. Our legitimate interest is based on economic viewpoints and the stated purpose of the use of the cookie.
- b) Cookies for usage analysis
Cookies and similar technologies that are used for analysis purposes are only used with your consent. The legal basis for processing data is Article 6(1), sentence 1 lit. a, GDPR.
Google Analytics
We use Google Analytics, a web analysis service of Google LLC (1600 Amphitheatre Parkway Mountain View, CA 94043, USA; referred to in the following as “Google”). Google uses cookies, which are test files that are stored on the browser of the person using our website.
Google sets the following cookies:
| Name | Purpose | Storage period |
| _ga | Analysis cookie to differentiate between users in order to collect data on the number of visits and the user journey. | 2 years |
| _gid | Analysis cookie to differentiate between users in order to collect data on the number of visits and the user journey. | 1 day |
| _gat | Analysis cookie to differentiate between users in order to collect data on the number of visits and the user journey. | 1 day |
The information created by the cookie regarding the use of our web pages is passed on to a Google server.
We have activated IP anonymisation in the use of Google Analytics. This means that Google abbreviates the IP addresses of users of our website within member states of the European Union or other states of the agreement of the European Economic Area. Only in exceptional cases will the full IP address be passed on to a Google server in the USA, and stored and abbreviated there.
Google is certified under the Privacy Shield Agreement. This guarantees that European data protection rights are observed (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use the provided information to evaluate the usage of our website, to produce reports on activities on our website and to provide us with services associated with use of the website and of the Internet. It is possible to create pseudonymous user profiles of the users. The IP address transferred by your browser will not be combined with any other Google data.
If you have not consented to the use of Google cookies, your details will not be collected by Google Analytics.
You can also revoke your consent at any time in the Cookie-Banner.
You also have the option of preventing the data created by the cookie and based on your usage of the online offer from being passed on to Google and the processing of this data by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de
If using a browser on a mobile device, you can click on the following link to set an opt-out cookie. Please note that this cookie will only work for this website and this browser. If you delete cookies, you will have to click on the link again: Google Analytics deaktivieren
For more information, refer to the following links:
https://www.google.com/intl/de/policies/privacy/partners
https://policies.google.com/technologies/ads?hl=de
https://policies.google.com/privacy?gl=DE&hl=de
https://support.google.com/analytics/answer/6004245?hl=de
You can also always set your browser to notify you when cookies are placed so you can decide in each individual case or generally which cookies to accept and which to reject. You can find out more about the options for setting cookies in your browser menu. If cookies are refused, use of our website may be limited.
- c) Integration of third-party content and services
We also include third-party services on our site. This content will initially be blocked if you have not consented to the storage of external cookies.
Instagram
On our website we have integrated a plug-in of Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA (“Instagram”). You can recognise the plug-in by the “Instagram button” on our website.
The external cookie is set once you give your consent, and the Instagram content is made visible. The cookie is deleted at the end of the session. The legal basis for processing the data is Article 6(1), sentence 1 lit. a, GDPR. You may revoke your consent at any time for the future.
If you click on the “Instagram button” while you are logged in to your Instagram account, you can link the content of our pages to your Instagram profile. This allows Instagram to assign the visit to our pages in your user account. We do not know what data is transmitted to Instagram or how Instagram uses this data. For more information, see Instagram’s privacy policy: https://instagram.com/about/legal/privacy
You can also revoke your consent at any time in the Cookie-Banner.
- Data processing when using the contact form / email / telephone numbers
Anyone may seek voluntary contact with us using the email addresses, telephone numbers and contact form provided. If you contact us, we will process the personal details you provide (such as your email address, name, phone number if provided and any other data you provide). If you contact us, you do so voluntarily. It is not possible to converse with you without the provision and the processing of the personal data.
The data will only be used for processing your enquiry.
The legal basis for processing the data that is provided in the process of contacting this site is Article 6(1), sentence 1 lit. f, GDPR. Our legitimate interest results from wanting to enable you to contact us and being able to answer your enquiry. If the enquiry is aimed at the conclusion of a contract, then the additional legal basis for processing is Article 6(1), sentence 1 lit. b, GDPR. After processing the enquiry, the data may need to be processed under Article 6(1), sentence 1 lit. c to comply with fiscal requirements.
The data will be deleted when the enquiry has been completely processed unless we are obliged to retain it for longer in order to comply with fiscal and/or legal requirements (e.g. as per German Commercial Code, HGB; German Penal Code, StGB or the Regulation of Taxation, AO; generally up to 10 years).
If a job application is submitted in response to an advertisement, the application documents will be deleted or destroyed as soon as the application process is concluded.
If an enquiry results in the conclusion of a contract, our customers will receive further information on the scope of the personal details being processed.
- Data processing when registering for events and exams
The following data will be collected when registering for an exam/test or event: first and last names, address, email address and telephone number.
We use this data exclusively for processing and completing the event or exam. Data must be processed in order for the contract to be fulfilled. The legal basis for processing data is Article 6(1), sentence 1 lit. b, GDPR. Without data, it would not be possible to conclude or execute the contract. After the event or exam, the data may need to be processed under Article 6(1), sentence 1 lit. c in order to comply with fiscal requirements. For the sake of balancing interests, under the terms of Article 6(1), sentence 1 lit. f, GDPR, we may also process your data beyond the actual fulfilment of the contract and legal retention obligations so we are able to defend ourselves in the event of any claims being asserted.
The data will be deleted on conclusion of the event or exam unless we are obliged to retain it for longer in order to comply with fiscal and/or legal requirements (e.g. as per German Commercial Code, HGB; German Penal Code, StGB or the Regulation of Taxation, AO; generally up to 10 years). We may store your data as proof for the period during which claims may be asserted against us.
To arrange dates for events and book exam dates, we sometimes use the services of SimplyBook.me Ltd., 21 Karaiskaki Str., Oasis Center, 3032 Limassol, Cyprus. The corresponding order processing contract has been concluded.
Further information on SimplyBook.me is available at:
https://simplybook.me/de/booking-system-security
https://simplybook.me/de/policy
If you decide to pay using PayPal, we will pass the details required for the payment process (e.g. first name, last name, address, telephone number, IP address, email address, invoice amount and taxes in percent, invoice information) on to PayPal (Europe) S.à.r.l. & Cie., S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg.
Please note that PayPal may carry out credit checks and pass on your personal details to credit agencies. PayPal has a legitimate interest in this transfer in order to determine the probability of default and so decide on the provision of the payment method. The legal basis is derived from Article 6(1), sentence 1 lit. f, GDPR.
As well as checking the address, PayPal also collects and uses information on the buyer’s previous payment behaviour and the probability values of this behaviour in the future. PayPal’s calculation of these scores is carried out on the basis of a scientifically recognised mathematical statistical method. PayPal also uses your address details. Should it become apparent after the calculation that your creditworthiness is not given, PayPal will inform you of this immediately.
You can revoke your consent to PayPal’s use of the personal details at any time. However, PayPal may also be entitled to process, use and transmit the personal details if this is necessary and/or legally required for the contractual processing of the payment by PayPal’s services.
For further information, see PayPal’s privacy policy at the following link: https://www.paypal.com/de/webapps/mpp/ua/privacy-full
- Data processing when registering for the graduate catalogue
Graduates of RWL German Flight Academy GmbH may register on the website www.rwl-flight.de for registration in a catalogue of graduates.
In the first step, the graduate is to enter his or her name and an email address on the website. RWL German Flight Academy GmbH will send an individual activation link to the address provided for the graduate’s individual profile page which they may complete either directly or at a later time. The graduate may also login with the email address and password at any time and make changes.
The details provided are not available to the public, and are only available to the graduate via the login area and to staff at RWL German Flight Academy GmbH. In order to prevent misuse, RWL German Flight Academy GmbH reserves the right to check the profile entries.
The following of the graduate’s details will be obtained and stored in the catalogue: first and last names, time of completion of training at RWL German Flight Academy GmbH, telephone number, email address, status of occupation, status of current applications, number of completed theory and practical exams.
Graduates must keep their accounts up to date.
RWL German Flight Academy GmbH logs the time every time a graduate logs in to his or her account.
The data is used by RWL German Flight Academy GmbH in response to enquiries from airlines in order to make it easier to negotiate for positions for graduates. Airlines do not have direct access to the graduates’ catalogue. Data will only be passed on with the explicit approval of the graduate.
As you have given your consent to the data being processed in the graduates’ catalogue, the legal basis for processing the data is Article 6(1), sentence 1 lit a, GDPR.
The data in the graduates’ file will be deleted if and when a graduate revokes their consent or if they do not log in to their account for over a year.
III. Data processing on social media fan pages (Facebook and Instagram)
We maintain what are known as fan pages with Facebook and Instagram. Both are social networks of Facebook Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland (“Facebook”).
These sites are operated jointly with Facebook.
We are responsible for processing the data that you share directly with us via the pages. When our fan pages are visited, we collect all the data and content that is communicated to us there. If you also have a Facebook or Instagram account we will, of course, see your profile there with your name and the shared content.
Joint responsibility for data processing arises during the analysis of its use (known as page insights). Facebook collects the usage behaviour of visitors to the pages with cookies and similar technologies every time a visitor take action on the pages. Based on this, we receive statistics from Facebook on the use of the pages. For instance, we are informed of the likes, comments, interactions and information regarding visitors. The legal basis for this data processing is Article 6(1) lit. f, GDPR. Our legitimate interest is to learn more about the use of our pages.
Further information on the page insights can be found here:
https://www.facebook.com/legal/terms/page_controller_addendum
https://www.facebook.com/legal/terms/information_about_page_insights_data
Facebook also processes the data for its own purposes. We have no influence on this. Facebook processes the data to generate statistics. This is also done for its own advertising purposes. Facebook adheres to the EU-US Privacy Shield for any personal details that are transferred to the USA. Further information is available here: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC
The legal basis for the operation of the fan pages is Article 6(1) lit. f, DSGVO. The purpose is to share information with interested parties and our customers and to be able to communicate with you there. This is also the legitimate interest.
You can see your rights at the end of this privacy statement.
You also have certain rights with regard to Facebook. If you wish to assert them, you can contact Facebook directly. Of course, you will also have our support in this instance.
For further information on Facebook’s data processing operations, please see:
https://www.facebook.com/about/privacy/
https://instagram.com/legal/privacy/
- Rights of the data subject
As the data subject, provided the relevant conditions are met, you have
- the right to information on the personal details that we process about you (Article 15 GDPR),
• the right to rectification of processing (Article 16 GDPR),
• the right to deletion of processing (Article 17 GDPR),
• the right to restrict processing (Article 18 GDPR),
• the right to information (Article 19 GDPR),
• the right to data portability (Article 20 GDPR),
• the right to object to processing (Article 21 GDPR; see also highlighted below),
• the right of appeal against a supervisory authority (Article 77 GDPR with Section 19 Federal Data Protection Act).
If the processing of the data is based on your consent, under the terms of Article 7(3) GDPR
you have the right to revoke your consent at any time without this affecting the lawfulness of the processing based on consent before its revocation.
If you wish to revoke your consent, simply notify info@rwl-flight.de
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Right to revoke to Article 21 GDPR
a) Right to object in an individual case
You have the right, for reasons arising from your particular situation, to object to the processing of the data concerning you resulting from Article 6(1) lit. e, GDPR (Data processing in the public interest) or Article 6(1) lit. f, GDPR (Data processing on the basis of a balancing of interest); this also applies to any profiling based on these definitions.
b) Right to object to the processing of data for advertising purposes.
If your personal details are processed for the purposes of direct advertising, you have the right to object at any time to the processing of your personal data for these purposes; this also applies to any profiling associated with such direct advertising. If you object to processing for the purposes of direct advertising, we will no longer use your personal data for these purposes.
If you wish to object to the processing, simply notify info@rwl-flight.de
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IV. Changes to the privacy statement
We will amend our privacy policy if this becomes necessary in line with the further development of our offer on these pages and/or resulting from changes in the law. The current version of our privacy policy is available on our website.
At: August 2020