Effective date: January 18, 2021   Flight TLV Ltd. and its affiliates (“us”, “we”, or “our”) respects your privacy and takes your personal data seriously. Please read the following to learn more about our Privacy Policy (“this Policy “). This Policy applies to the Pilots.co.il website (the “Website”) and the online Courses and events you can register to through the Site the “Course(s)”).   Contents:

1. What personal data we collect, How and How is it Being Processed
2. How we share your personal data
3. Data transfers and global processing
4. Data Subject Rights
5. Cookies and Similar Technologies
6. Security of Processing
7. Data Retention
8. Changes to This Privacy Notice
9. General

 

1. What Personal Data We Collect, How, and How is it Being Processed
   • The following table describes what personal data we collect through the Website, including through the Courses and for what purposes it may be processed:

Instance in which data is collected	Categories of personal data that are processed	Purposes of processing	Legal basis for processing (under GDPR)	Category of data collected for CCPA purposes (relevant for California residents only)
When you fill out contact forms on the website	First and last name, telephone number, email address.	To contact you and schedule your online Course To contact you occasionally with marketing communications regarding Company’s services and products, subject to applicable laws (for example, where required, subject to your consent). To reply to you and address your questions and requests	Consent (Article 6(1)(a))	Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers (collectively “Identifiers”). Professional or employment-related information.
Data that you provide passively (by using the website, by navigating the screens, clicking on buttons etc.) information . This data is collected using third party services by means of placing cookies or web beacons. For more information, please look at the Cookies section.	Your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.	To improve, modify and update services and content offered on the website. To monitor and ensure the orderly and proper operation and development of the Website and associated services. To improve and customize the user experience and the content that is presented on the Website.	Our legitimate business interest (Article 6)1)(f))	Internet or other electronic network activity information, including, but not limited to, Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
Information that you provide to us when making a purchase through the Website	First and last name, Phone number, email address	To process your registration to an online Course or other event as available through the Website, to send you invoices or other confirmations, to coordinate any changes or support any requests related to your purchase	Contract (Article  6(1)(b))	Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers (collectively “Identifiers”). Professional or employment-related information.
As part of your participation in the Course	Information regarding your attendance in the Course classes	In order to allow you to complete any missed lessons and catch up with the curriculum	Contract (Article  6(1)(b))

 

• In some cases, you may be able to opt not to disclose your personal data to Company. However, not providing Company with certain data may mean that we cannot provide you with certain functionalities or respond to an issue that you have raised.
• In addition to the above uses of your personal data, we will also process your personal data for the following purposes:
• We use all of the above personal data to operate, maintain, and provide to you with the Website and Course features and functionality and to provide you with the services as requested by you.
• To prevent, detect and fight fraud or other illegal or unauthorized activities
• To ensure legal compliance – from our side (to legal requirements that apply to us and to our obligations under the Terms of Use) and from your side (Compliance with laws applicable to you and with the Terms of Use)
• We will not use your Personal Data for any personal profiling and automated decision making based on such profiling.
• We limit access by our employees to your information only to those who were specifically authorized by the Company to access your information, as part of their job.
• We use anonymized, aggregate data, in order to gain insight on how you and other users use the Platform and Services and try and improve our Platform and Service, as well as to plan our marketing and advertisements.
• All of the above processing is based on our legitimate business interest (GDPR Article 6(1)(f), except for the last point which is partially based on our legitimate business interest (concerning compliance with terms of use) and partially is processing that is necessary to comply with legal obligations that apply to us (GDPR Article 6(1)(c).

 

2. How we Share Your Personal Data

 

• No Sale to Third Parties. We do not, and will not, sell any of your personal data to any third party for advertising, marketing or any other purpose – including your name, address, email address or credit card information. We want to earn and maintain your trust, and we believe this is absolutely essential in order do that.
• Service Providers: we employ other companies and people to perform tasks on our behalf and need to share your information with them in order to provide the Services. The categories of third party recipients of the Personal Data from us are as follows: Cloud hosting services, simulator engine provider, communication services to the simulator and course platform, billing, processing payments, email campaign automation, marketing automation, social media advertisement (on our behalf, not for transfer to third parties advertisement or marketing purposes), CRM platform, analytics tools providers, web page building tools, cloud services, support and maintenance operation tools. Our service providers do not have any right to use your personal information collected from our Website beyond what is necessary for the purpose of facilitating our provision of the Website and Courses.
• Compliance with the Law: We may disclose your information if we believe it’s necessary in order to comply with the law, such as to comply with a subpoena, regulation or legal request, respond to a government request, to address fraud or security issues, to protect the safety of any person, to enforce our agreements with you; to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing or to protect our own rights or property. If you are located in the EU, we may only do so based on legal requirements specified above of EU authorities. This includes sharing such information with our legal counsels.
• Business Transfers: If we are in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be transferred as part of that transaction to a successor in interest and to the applicable legal authorities as well as legal counsels and other professional counsels involved such as accountants, and other officers of the government or of the applicable judiciary instance.
• Anonymized Information: We may provide third parties (for their needs, including advertising and tracking) with aggregated but anonymized information and analytics about our customers however, before we do so, we will make sure that it does not identify you.

3. Data Transfers and Global Processing
   • The website may be operated in countries other than your own location, and your personal data may be accessed and/or processed from and/or transferred to countries other than your own location. We may do this where data is accessed/processed:
   • by Company and its affiliates for operational, administrative, compliance purposes or customer support teams in our various locations.
   • By our service providers, for the purposes we specified under the section “Service Providers”.
   • The safeguards we deploy for performing such transfers across boundaries:
   • If you are located outside of Israel, and choose to provide information to us, please note that we transfer the data, including personal data, to Company headquarters located Israel and process it there. Any transfers to Israel may be made on the basis of an adequacy decision made by the European Commission.
   • Model Clauses. With some of our processors, we use standard contractual clauses approved by the European Commission that are binding standards of processing of personal data committed to contractually by third parties processing information for us and on our behalf.
   • In the absence of an adequacy decision or Model Clauses, and in the absence of any other right to transfer your data, your consent shall serve as the basis for such transfer. By accessing and using the website, you agree and understand that your information may be transferred from the EEA or other countries in which you may be using or accessing the website, to other jurisdictions outside your own location (including outside the EEA). The transfer will be to such third parties as described under “Service Providers and Third Parties”.
   • Company t will take steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
   • Currently we process data in the US Israel and the EU.

 

4. Data Subject Rights
   • It is your responsibility to ensure that all personal data submitted to Company is correct. Company would like to make sure you are fully aware of all of your data protection rights. Depending on your location and on the laws that are applicable to you, you may be entitled to some or all of the following rights:
   • The right to access– You have the right to request Company for copies of your personal data, which includes the right to obtain confirmation as to whether or not personal data concerning you are being processed and, where that is the case, access to the personal data and the purposes of the processing; categories of personal data concerned; recipients or categories of recipient to whom the personal data have been or will be disclosed; where possible, the envisaged period for which the personal data will be stored; the existence of the right to request rectification or erasure of personal data or restriction of processing of personal data or to object to such processing; the right to lodge a complaint with a supervisory authority; where the personal data are not collected from the data subject, any available information as to their source; the existence of automated decision-making, including profiling; the appropriate safeguards relating to the transfer of your personal data outside the EEA,. We may charge you a small fee for this service under certain conditions.
   • The right to rectification– You have the right to request that Company correct any information you believe is inaccurate. You also have the right to request Company to complete the information you believe is incomplete.
   • The right to erasure– You have the right to request that Company erase your personal data, under certain conditions.
   • The right to restrict processing– You have the right to request that Company restrict the processing of your personal data, when: (a) you contest the accuracy of your personal data, for a period allowing Company to verify the accuracy of said data; (b) if you believe personal data has been unlawfully processed and you wish to restrict processing rather than delete it; (c) Company no longer needs the personal data but you require to keep it in order to establish, exercise or defend a legal claim; or (d) you have exercised your right to object the processing (below) for a period allowing Company to consider whether your legitimate grounds override those of Company.
   • The right to object to processing– You have the right to object to the processing of your personal data at any time – this means you have the right to stop or prevent Company  from processing your personal data (it could be in relation to part or all of your personal data, and for part or all of the processing purposes). When relating to processing for marketing purposes, you have an absolute right to object; while for other purposes, the existence of the right depends on what lawful basis the processing relies on.
   • The right to data portability– You have the right to request that Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.
   • If allowed by applicable laws, you have the right to withdraw your consent at any time when Company processes your personal data based on your consent on any of these rights. However, withdrawal does not affect the legitimacy and effectiveness of how we process your personal data based on your consent before the withdrawal is made; nor does it affect any data processing based on another lawful bases other than your consent.
   • You may exercise these rights to the extent these rights apply to you by emailing Company to: [email protected] or use any of the contact information listed below. We will undertake to respond to your request within the applicable time frame prescribed by applicable law. Although we will make reasonable efforts to accommodate your requests, in some circumstances we may deem your request unfounded or not eligible under applicable law. In such instances we reserve the right to refuse your request. We shall require, as pre-requisite to fulfilling any request, to verify your identity which we may do by asking you to provide certain information or identification to ensure that all data subjects’ privacy is protected.
   • If you think that the way we process your personal information does not comply with applicable data protection laws, you are of course invited to contact us and we will consider your request, but in any event you may contact the relevant competent data protection authority. You can obtain the contact information for all of the EEA data protection authorities at https://edpb.europa.eu/about-edpb/board/members_en.

 

5. Cookies & Similar Technologies
   • A cookie is a small text file that is stored in your web browser that allows Company or a third party (such as third-party service providers) to recognize you. Cookies can either be session cookies or persistent cookies. A session cookie expires automatically when you close your browser. A persistent cookie will remain until it expires, or you delete your cookies.
   • Cookies that we may use can generally be categorized as follows:
     • Necessary Cookies: These cookies are necessary to load the website or to allow users to use website’s certain features.
     • Analytics Cookies: These cookies track information about how the website is being used so that we can make improvements and report on our performance.
     • Preference Cookies: These first party cookies store your website preferences.
     • Marketing Cookies: These are usually third party cookies by advertising platforms or networks in order to: (i) deliver ads and tracks ad performance, and (ii) enable advertising networks to deliver ads that may be relevant based upon your activities.
   • We may use additional tracking technologies to help understand user activities and preferences. For example, we may use web beacons (also known as clear gifs, pixel tags or web bugs) to track user activities and communicate with cookies You cannot opt out of web beacons used in webpages, but you can limit their use by opting out of the cookies they interact with. You can opt out of web beacons used in emails by setting your email client to render emails in text mode only.
   • We use the following cookies and other tracking technologies. We will update this list from time to time depending on the cookies we will be using.  

Name of cookie	Source (if third party cookies)	Purpose  – what this cookie is doing	Expiration (lifetime of cookie)	advertisement
viewed_cookie_policy	local	The cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data.	11 months	advertisement
cookielawinfo-checkbox-necessary	local	This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category “Necessary”.	11 months	advertisement
cookielawinfo-checkbox-non-necessary	local	This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category “Non Necessary”.	11 months	advertisement
test_cookie	local	This cookie is set by doubleclick.net. The purpose of the cookie is to determine if the users” browser supports cookies.	11 months	advertisement
__cfduid	cloud flare	The cookie is used by cdn services like CloudFare to identify individual clients behind a shared IP address and apply security settings on a per-client basis. It does not correspond to any user ID in the web application and does not store any personally identifiable information.	29 days 23 hours 59 minutes	analytics
_wcml_appointment_currency	local	No description	23 hours 59 minutes	analytics
PHPSESSID	local	This cookie is native to PHP applications. The cookie is used to store and identify a users” unique session ID for the purpose of managing user session on the website. The cookie is a session cookies and is deleted when all the browser windows are closed.	session	analytics
wp-wpml_current_language	local	No description	23 hours 59 minutes	analytics
_gcl_au	google	This cookie is used by Google Analytics to understand user interaction with the website.	2 months 28 days 23 hours 59 minutes	analytics
_ga	google	This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of site usage for the site”s analytics report. The cookies store information anonymously and assign a randomly generated number to identify unique visitors.	1 years 11 months 28 days 23 hours 59 minutes	functional
_gid	google	This cookie is installed by Google Analytics. The cookie is used to store information of how visitors use a website and helps in creating an analytics report of how the wbsite is doing. The data collected including the number visitors, the source where they have come from, and the pages viisted in an anonymous form.	23 hours 59 minutes	functional
_gat_UA-121842375-1	google	No description	1 year	functional
li_sugr	local	No description	2 months 28 days 23 hours 59 minutes	necessary
lang	local	This cookie is used to store the language preferences of a user to serve up content in that stored language the next time user visit the website.	session	necessary
bcookie	linkedin	This cookie is set by linkedIn. The purpose of the cookie is to enable LinkedIn functionalities on the page.	1 years 11 months 29 days 11 hours 37 minutes	necessary
lissc	linkedin	This cookie is provided by LinkedIn. This cookie is used for tracking embedded service.	11 months 29 days 23 hours 59 minutes	necessary
lidc	linkedin	This cookie is set by LinkedIn and used for routing.	23 hours 59 minutes	necessary
_fbp	facebook	This cookie is set by Facebook to deliver advertisement when they are on Facebook or a digital platform powered by Facebook advertising after visiting this website.	2 months 28 days 23 hours 59 minutes	non-necessary
fr	facebook	The cookie is set by Facebook to show relevant advertisments to the users and measure and improve the advertisements. The cookie also tracks the behavior of the user across the web on sites that have Facebook pixel or Facebook social plugin.	2 months 28 days 23 hours 59 minutes	other
UserMatchHistory	linkedin	Linkedin – Used to track visitors on multiple websites, in order to present relevant advertisement based on the visitor”s preferences.	29 days 23 hours 59 minutes	other
bscookie	linkedin	This cookie is a browser ID cookie set by Linked share Buttons and ad tags.	1 years 11 months 29 days 11 hours 37 minutes	other
YSC	youtube	This cookies is set by Youtube and is used to track the views of embedded videos.	session	other
VISITOR_INFO1_LIVE	youtube	This cookie is set by Youtube. Used to track the information of the embedded YouTube videos on a website.	5 months 26 days 23 hours 59 minutes	other
IDE	google	Used by Google DoubleClick and stores information about how the user uses the website and any other advertisement before visiting the website. This is used to present users with ads that are relevant to them according to the user profile.	1 years 23 days 23 hours 59 minutes	performance
GPS	youtube	This cookie is set by Youtube and registers a unique ID for tracking users based on their geographical location	29 minutes	Type

   

• We may set cookies that monitor links to our website that we send to you (if you have consented to receiving emails from us). These cookies are used to track visitors to our website sourced from these emails. To avoid these types of cookies, please follow the explanation below on how to change your browser cookies settings.
• In addition we may use a tracking technology (pixels) in emails to understand how often our emails are opened and clicked on by our customers. If you do not wish this tracking to be effected, please change your email software or service (such as outlook, Gmail etc.) settings to not automatically download images (to the extent it is not already your default) In some instances, depending on your email or browser settings, cookies in an email may be automatically accepted (for example, when you have added an email address to your address book or safe senders list). Please refer to your email browser or device instructions for more information on this.
• You can change your browser’s settings to delete cookies that have already been set and to not accept new cookies. To learn more about how to do this, visit the help pages of your browser. Some useful information can also be found here: https://www.allaboutcookies.org/ Please note, however, that if you delete cookies or do not accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.

6. Security of Processing
   • We use appropriate physical, management, and technical measures to protect your data from unauthorized access, disclosure, use, modification, damage, or loss.
   • For processing payments we use service providers that provide SSL security and comply with PCI-DSS standard which is a common standard worldwide for online payments. We also provide training on security and privacy protection for employees to raise their awareness of personal data protection. However, please note that no security measure is perfect, therefore, you should take special care in deciding what information you disclose.
7. Data retention
   • We will retain your personal data for no longer than is necessary for the purposes stated in this Policy, unless otherwise extending the retention period is required or permitted by law or subject to our retention policies as may be in place from time to time. The data storage period may vary with scenario, product, and service.
   • The standards Company  uses to determine the retention period are as follows: the time required to retain personal data to fulfill business purposes, including providing products and services; maintaining corresponding transaction and business records; controlling and improving the performance and quality of the website; handling possible user queries or complaints and locating problems; whether the user agrees to a longer retention period; and whether the laws, contracts, and other equivalencies have special requirements for data retention.
8. Changes to This Privacy Policy
   • We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We may notify you through different channels, for example, posting a notice on our website or sending you direct notification.
   • You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
9. General
   • If you have any questions or suggestions, to exercise any of your rights, or if you have any other questions or complaints about our use of your personal data and your privacy please contact our data protection officer at [email protected].
   • Where your personal data is processed by Company in accordance with this Privacy Policy, Flight TLV Ltd. Of Rachel ve Shmuel Idelson st. 3A, Tel Aviv, Israel is the controller of the related personal data.