Privacy Policy

Lufthansa Aviation Training GmbH processes personal information collected during visits to our Web site in accordance with EU General Data Protection Regulation (GDPR). Furthermore, our privacy policy is based on the privacy guidelines applicable to the entire Lufthansa Group.


Our Web sites may contain links to the Web sites of other providers to whom this privacy statement does not apply.


Lufthansa Aviation Training respects your privacy.

1. Controller

We, Lufthansa Aviation Training GmbH (hereinafter also referred to as “LAT GmbH” or “we”, or “us”), would like to provide you with information on how we process your personal data when you use our website www.lufthansa-aviation-training.com (“website”).

2. Contact Information


Should you have any further questions regarding data protection in connection with our website or the services offered on it, please contact our data protection officer:


Lufthansa Group Data Protection Officer
Deutsche Lufthansa AG (DLH)
FRA CJ/D
60546 Frankfurt
E-mail: datenschutz(at)dlh.de

3. Scope, Purpose, and lawful Basis of processing personal Data

We collect and use personal information directly from our users or from other sources (as described below) in the following situations:

3.1. Use of the Website and Creation of Log Files

When users visit our website, our system automatically collects data and information about the computer accessing our website each time our website is accessed. In the process, the following data (“technical information”) is collected:


(1) Information about the type and version of browser used
(2) The user’s operating system
(3) The user’s internet service provider
(4) The user’s IP address
(5) The date and time the website was accessed
(6) Websites from which the user accessed our website
(7) Websites and files that were accessed by the user’s system from our website, as well the following information: the method of access and protocol
(8) The size of the file/page accessed


This data is also saved in our system’s log files. This data is not stored together with any other personal data about the user. We collect and use this technical information for purposes of (network) security (e.g. to combat cyberattacks), marketing, and to better understand the requirements of our users, as well as to continuously improve our website and enable the respective user to access the website from their computer. This information is stored in log files to guarantee the website’s functionality. In addition, we use the data to optimize our website and to ensure the security of our information technology systems. We do not process the data collected in this context for marketing purposes. The lawful basis for the temporary storage of data and log files is article 6(1)(f) of the GDPR.


3.1.1. Use of Cookies Our website uses cookies.

Cookies are text files that are saved in the user’s web browser or by the user’s web browser on their computer system. If a user visits a website, a cookie may be stored on the user’s operating system. This cookie contains a unique string of characters that uniquely identifies the user’s browser when the user returns to the website. Cookies are stored on the user’s computer and transmitted to our site. As a result, you as the user also have full control over the use of cookies. You can deactivate or restrict the use of cookies by changing the settings in your web browser. Any cookies that have already been saved can be deleted at any time. This can also be carried out automatically. Please note that if you deactivate cookies for our website, you may no longer be able to fully use all of our website’s features.


Lufthansa-aviation-training.com uses the following cookies

  • cookieconsent_status
  • ga_cookies

3.1.2. Tracking Tools

We use the following tracking and marketing tools (including for remarketing) on our website:

Google Analytics (https://www.google.com/analytics/terms/gb.html or https://policies.google.com/?hl=en)

Google Analytics
This website uses Google Analytics, a web analysis service of Google Ireland Limited, (Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland). It includes the use of “Universal Analytics” technology, which makes it possible to assign data, web sessions and interactions on several devices to an anonymised user ID, thus enabling an analysis of a user’s activities across multiple devices.

Google Analytics uses "cookies", which are text files placed on your computer, to allow the website operator to analyze how users use the site. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. However, if IP anonymisation is activated on this website, Google will reduce your IP address within Member States of the European Union or in other states party to the Agreement on the European Economic Area beforehand. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide the website operator with other services related to website and Internet use. Our legitimate interest in data processing also lies in these purposes. The legal basis for the use of Google Analytics is § 15 para. 3 TMG and Art. 6 para. 1 lit. f GDPR. Sessions and campaigns are terminated after a certain period of time. By default, sessions are closed after 30 minutes without activity and campaigns after six months. The time limit for campaigns may not exceed two years. For more information on terms of use and data protection, please visit https://www.google.com/analytics/terms/gb.html or https://policies.google.com/?hl=en.

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by Google by downloading and installing the Browser Add-on. Opt-out cookies prevent the future collection of your data when you visit this website. To prevent Universal Analytics from collecting data across several devices, you must opt-out on all systems used. If you click here, the opt-out cookie will be set: Disable Google Analytics

 

3.1.3. Advertising Cookies

These are the cookies we use:

Meta-Pixel (formerly Facebook Pixel)
To measure conversion rates, this website uses the visitor activity pixel of Facebook/Meta. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. According to Facebook’s statement the collected data will be transferred to the USA and other third-party countries too.
This tool allows the tracking of page visitors after they have been linked to the website of the provider after clicking on a Facebook ad. This makes it possible to analyze the effectiveness of Facebook ads for statistical and market research purposes and to optimize future advertising campaigns.
For us as the operators of this website, the collected data is anonymous. We are not in a position to arrive at any conclusions as to the identity of users. However, Facebook archives the information and processes it, so that it is possible to make a connection to the respective user profile and Facebook is in a position to use the data for its own promotional purposes in compliance with the Facebook Data Usage Policy (https://www.facebook.com/about/privacy/). This enables Facebook to display ads on Facebook pages as well as in locations outside of Facebook. We as the operator of this website have no control over the use of such data.
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. You may revoke your consent at any time.
Insofar as personal data is collected on our website with the help of the tool described here and forwarded to Facebook, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 DSGVO). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Facebook. The processing by Facebook that takes place after the onward transfer is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. The wording of the agreement can be found under:
https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the privacy information when using the Facebook tool and for the privacy-secure implementation of the tool on our website. Facebook is responsible for the data security of Facebook products. You can assert data subject rights (e.g., requests for information) regarding data processed by Facebook directly with Facebook. If you assert the data subject rights with us, we are obliged to forward them to Facebook.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European
Commission. Details can be found here:
https://www.facebook.com/legal/EU_data_transfer_addendum and
https://de-de.facebook.com/help/566994660333381.
In Facebook’s Data Privacy Policies, you will find additional information about the protection of your privacy at:
https://www.facebook.com/about/privacy/.
You also have the option to deactivate the remarketing function “Custom Audiences” in the ad settings
section under
https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. To do this, you first have to log into Facebook.
If you do not have a Facebook account, you can deactivate any user-based advertising by Facebook on thewebsite of the European Interactive Digital Advertising Alliance:
http://www.youronlinechoices.com/de/praferenzmanagement/.
 

If you click here, the opt-out cookie will be set: Disable Facebook/Meta

 

Google Conversion-Tracking

This website uses Google Conversion Tracking. The provider of this service is Google Ireland Limited
(“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
With the assistance of Google Conversion Tracking, we are in a position to recognize whether the user has completed certain actions. For instance, we can analyze the how frequently which buttons on our website have been clicked and which products are reviewed or purchased with particular frequency. The purpose of this information is to compile conversion statistics. We learn how many users have clicked on our ads and which actions they have completed. We do not receive any information that would allow us to personally identify the users. Google as such uses cookies or comparable recognition technologies for identification purposes.
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. You may revoke your consent at any time.
For more information about Google Conversion Tracking, please review Google’s data protection policy at:
https://policies.google.com/privacy?hl=en

Bing Universal Event Tracking
This website uses Bing Ads Universal Event Tracking, a conversion tracking service provided by Microsoft (Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA). This service enables us to track activities on our website if you reach our website via a Bing ad. This is done by setting a cookie (small text file) on your device when you click on a Microsoft Bing Ads ad. In particular, Microsoft and we learn the total number of users who have clicked on an ad and reached a previously defined target page. This data is stored by Microsoft for 180 days.
Further information on the usage and data protection guidelines for this product can be found here: https://privacy.microsoft.com/en-us/privacystatement

 

 

3.1.4 Other technologies

We use these other technologies:


Google Tag Manager
We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
The Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other
technologies on our website. The Google Tag Manager itself does not create any user profiles, does not store cookies, and does not carry out any independent analyses. It only manages and runs the tools integrated via it. However, the Google Tag Manager does collect your IP address, which may also be transferred to Google’s parent company in the United States.
The Google Tag Manager is used on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the quick and uncomplicated integration and administration of various tools on his website. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent can be revoked at any time.

 

 


The legal basis for the use of the aforementioned tools is our legitimate interest pursuant to article 6(1)(f) of the GDPR for the purposes of increasing the efficiency of our website and our marketing activities (including direct marketing)


Further information about the individual tools can be found in the Annex/Tracking Tool Policy.

3.2. Use of the Services offered on our Website

We offer a wide range of services on our website. In order to provide these services, we must collect and process personal data from users or our customers.


3.3. Processing personal Data on the Basis of our legitimate Interests

In the event that article 6(1)(f) of the GDPR is our legal basis for processing, in addition to the purposes listed above, our legitimate interests include:

  • Protecting the company from material or immaterial damage
  • Professionalization (of our products and services)
  • Cost optimization (cost control and cost minimization)


3.4. Further Obligations to process Data

Insofar as we are legally obligated to do so, we also process personal data in order to comply with our obligation to retain data as set forth in applicable commercial or tax law or to meet security requirements (e.g. section 7 of the Luftsicherheitsgesetz (LuftSiG), German aviation security act). Further information about retention periods can be found under Duration of Data Processing
2.5. Obligation to provide personal Data
In order to meet statutory or contractual requirements, we have marked the respective fields in the forms on our website that must be filled out so that we can perform the requested contract or service.

4. Duration of Data Processing

Your personal data will be erased as soon as it is no longer required for the aforementioned purposes. In this context, personal data may be stored for the period of time during which legal claims can be asserted against Lufthansa Aviation Training GmbH (statutory limitation period of three to thirty years). In addition, personal data is stored to the extent and for as long as Lufthansa Aviation Training GmbH has a legal obligation to do so. Corresponding documentation and retention obligations result from Germany’s Commercial Code, tax code, and money-laundering act, among others. Based on the aforementioned laws, data can be stored for a period of up to 10 years.

5. Right to object pursuant to Article 21 of the GDPR


You have the right to object, at any time, on grounds relating to your particular situation, to the processing of personal data concerning you, which is based on point (e) or (f) of article 6(1) of the GDPR, including profiling based on those provisions.

If you make such an objection, the controller will no longer process your personal data unless the controller can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.
Where personal data is processed for direct marketing purposes, you have the right to object, at any time, to the processing of your personal data for the purpose of such marketing; this also applies to profiling insofar as it is conducted in conjunction with such direct marketing.
If you object to the processing of your personal data for direct marketing purposes, we will cease to process your personal data for this purpose.

In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications.

Where personal data is processed for scientific or historical research purposes or statistical purposes pursuant to article 89(1) of the GDPR, you have, on grounds relating to your particular situation, the right to object to the processing of your personal data unless the processing is necessary for the performance of a task carried out for reasons of public interest.

6. Disclosure of personal Data to Third Parties

In order to be able to offer you our products and services based on our contractual obligations or in accordance with our legitimate interests, we may have to disclose your personal data to third parties within or outside the Lufthansa Group. These recipients can be categorized as follows:


Service providers:

  • Marketing
  • IT
  • Website Agency


In this context, personal data may be transferred to third countries or international organizations. For your protection and the protection of your personal data, such data transfers are subject to appropriate safeguards pursuant to and in accordance with the applicable legal requirements (in particular application of EU standard contractual clauses) or an adequacy decision adopted by the EU Commission (article 45 of the GDPR).

Information about EU standard contractual clauses can be found here: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:039:0005:0018:EN:PDF.

The EU Commission provides information on its adequacy decisions at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en#dataprotectionincountriesoutsidetheeu.

You can also request a copy of the security measures we implement by sending an e-mail to datenschutz(at)dlh.de. In addition, we are legally obligated to disclose personal data to German and international authorities pursuant to article 6(1)(c) of the GDPR in conjunction with local and international regulations and agreements.

7. Rights of the Data Subject

Ensuring our processing operations are fair and transparent is extremely important to Lufthansa Aviation Training GmbH. For this reason, it is important to us that you, as the data subject, can exercise the following rights, in addition to the right of objection, if the respective legal requirements are met:

  • Right of access pursuant to article 15 of the GDPR;
  • Right to rectification pursuant to article 16 of the GDPR; Right to erasure (“right to be forgotten”) pursuant to article 17 of the GDPR;
  • Right to restriction of processing pursuant to article 18 of the GDPR;
  • Right to data portability pursuant to article 20 of the GDPR
  • Right to object pursuant to article 21 of the GDPR


To exercise your rights, simply send an e-mail to datenschutz(at)dlh.de. In this case, we would like to point out that in order to process your request and to identify you, we will process your personal data in accordance with article 6(1)(c) of the GDPR.


In addition, you have the right to lodge a complaint with a supervisory authority. The supervisory authority responsible for Lufthansa Aviation Training GmbH is:


Bayerisches Landesamt für Datenschutzaufsicht (BayLDA, Bavarian data protection authority)
Promenade 27 (Schloss)
91522 Ansbach
Germany
poststelle@lda.bayern.de

 

8. Disclaimer and Limits of this Privacy Policy

 

The information regarding data protection provided in this Privacy Policy only applies to the processing of data on the website: www.lufthansa-aviation-training.com. Other websites are not covered by this Privacy Policy and provide their own specific privacy policy.