Data Privacy Statement

We greatly appreciate your interest in our company. Data protection is of particular importance to the management of EDUCADEMY GMBH. The use of the internet pages of EDUCADEMY GMBH is generally possible without any indication of personal data. However, if a data subject wants to use special services of our company through our website, personal data processing may become necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain consent from the data subject. The processing of personal data, such as the name, address, email address, or telephone number of a data subject, is always done in accordance with the General Data Protection Regulation and in compliance with the country-specific data protection regulations applicable to EDUCADEMY GMBH. Through this data privacy statement, our company wants to inform the public about the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, data subjects are informed, by means of this data privacy statement, of their rights. EDUCADEMY GMBH, as the data controller, has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, internet-based data transmissions may have security gaps, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us via alternative means, such as by phone.

1 Definitions

The data privacy statement of EDUCADEMY GMBH is based on the terminology used by the European Directive and Regulatory Authority when adopting the General Data Protection Regulation (GDPR). Our data privacy statement should be easy to read and understand for the public, as well as for our customers and business partners. To ensure this, we would like to explain the terms used in advance. In this data privacy statement, we use, among other things, the following terms:

· a) Personal Data

Personal data refers to all information relating to an identified or identifiable natural person (hereinafter referred to as the “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more specific factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

· b) Data Subject

A data subject is any identified or identifiable natural person whose personal data is processed by the data controller.

· c) Processing

Processing refers to any operation or set of operations that is performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment, or combination, restriction, erasure, or destruction.

· d) Restriction of Processing

Restriction of processing involves marking stored personal data with the aim of limiting their processing in the future.

· e) Profiling

Profiling means any form of automated processing of personal data consisting of using those personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

· f) Pseudonymization

Pseudonymization means the processing of personal data in a way that the data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

· g) Data Controller

Data controller refers to a natural or legal person, authority, agency, or other body that determines the purposes and means of processing personal data. If the purposes and means of such processing are determined by Union law or the law of the Member States, the data controller or the specific criteria for its nomination can be provided for by Union law or the law of the Member States.

· h) Processor

Processor refers to a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller.

· i) Recipient

Recipient refers to a natural or legal person, public authority, agency, or another body, to which personal data are disclosed, whether a third party or not. However, authorities that may receive personal data in the framework of a particular inquiry in accordance with Union law or the law of the Member States are not considered recipients.

· j) Third Party

Third party refers to a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

· k) Consent

Consent means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2 Name and Address of the Data Controller

The data controller in terms of the General Data Protection Regulation, other data protection laws applicable in Member states of the European Union, and other provisions related to data protection, is: EDUCADEMY GMBH Mühlenstraße 128c 40668 Meerbusch Germany Tel.: +49 176 806 77 671 Email: info@aircademy.com

3 Cookies

The internet pages of EDUCADEMY GMBH use cookies. Cookies are text files that are stored on a computer system via an internet browser. Many websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which internet pages and servers can be assigned to the specific internet browser in which the cookie was stored. This allows visited internet sites and servers to differentiate the individual browser of the data subject from other internet browsers that contain other cookies. A specific internet browser can be recognized and identified using the unique cookie ID. By using cookies, EDUCADEMY GMBH can provide users of this website with more user-friendly services that would not be possible without the cookie setting. Using a cookie allows the information and offers on our website to be optimized for the user. As mentioned above, cookies allow us to recognize the users of our website. The purpose of this recognition is to make it easier for users to utilize our website. The user of a website that uses cookies, for example, does not have to enter access data each time the website is accessed because this is taken over by the website and the cookie stored on the user’s computer system. Another example is the cookie of a shopping cart in an online shop.

4 Collection of General Data and Information

With each visit to the website of EDUCADEMY GMBH by a data subject or an automated system, a range of general data and information is collected. These general data and information are stored in the server’s log files. The following data may be collected: (1) types and versions of browsers used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-webpages accessed by an accessing system on our website, (5) the date and time of access to the website, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) other similar data and information that serve to avert threats in the event of attacks on our information technology systems. EDUCADEMY GMBH does not draw any conclusions about the data subject when using this general data and information. Rather, this information is needed to (1) correctly deliver the contents of our website, (2) optimize the contents of our website and its advertising, (3) ensure the continued functioning of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for prosecution in the event of a cyberattack. These anonymously collected data and information are therefore evaluated by EDUCADEMY GMBH both statistically and with the aim of increasing data protection and data security in our company to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data from the server log files are stored separately from all personal data provided by a data subject.

5 Registration on Our Website

The data subject has the possibility to register on the website of the data controller by providing personal data. The specific personal data transmitted to the data controller for registration is determined by the respective input mask used for registration. The personal data provided by the data subject is collected and stored solely for internal use by the data controller and for its own purposes. The data controller may arrange for the transfer to one or more processors, such as a parcel service provider, who will also use the personal data for internal purposes, which can be attributed to the data controller. When registering on the website of the data controller, the IP address assigned by the Internet service provider (ISP) of the data subject, as well as the date and time of registration, are also stored. The storage of this data takes place in order to prevent the misuse of our services and, if necessary, to enable the investigation of committed offenses. In this respect, the storage of this data is necessary to secure the data controller. In principle, there is no disclosure of this data to third parties unless there is a legal obligation to pass on or the passing on serves the purpose of criminal prosecution. The registration of the data subject, with the voluntary provision of personal data, is intended to enable the data controller to offer the data subject content or services that may only be offered to registered users due to the nature of the matter. Registered persons are free to modify the personal data given during registration at any time or to have it completely deleted from the data controller’s database. The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. Furthermore, the data controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. The entirety of the data controller’s employees are available to the data subject in this respect as contact persons.

6 Subscription to Our Newsletter

On the website of EDUCADEMY GMBH, users are given the opportunity to subscribe to our company’s newsletter. The personal data that is transmitted to the data controller when ordering the newsletter is determined by the input mask used for this purpose. EDUCADEMY GMBH regularly informs its customers and business partners about the company’s offers through a newsletter. The newsletter of our company can only be received by the data subject if (1) the data subject has a valid email address and (2) the data subject registers for newsletter delivery. A confirmation email will be sent to the email address first entered by a data subject for newsletter shipping for legal reasons using the double opt-in procedure. This confirmation email is used to check whether the owner of the email address as the data subject has authorized the receipt of the newsletter. When registering for the newsletter, we also store the IP address assigned by the Internet service provider (ISP) of the data subject’s computer system at the time of registration, as well as the date and time of registration. The collection of this data is necessary in order to be able to trace the (possible) misuse of an email address of a data subject at a later date and, therefore, serves the aim of the legal protection of the data controller. The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. Subscribers to the newsletter may be informed by email, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for the newsletter, may be revoked at any time. For the purpose of revocation of consent, there is a corresponding link in each newsletter. Furthermore, it is also possible to unsubscribe from the newsletter on the website of the data controller or to inform the data controller in another way.

7 Newsletter Tracking

The newsletters of EDUCADEMY GMBH contain so-called tracking pixels. A tracking pixel is a miniature graphic embedded in emails sent in HTML format to enable log file recording and analysis. This allows for a statistical evaluation of the success or failure of online marketing campaigns. Through the embedded tracking pixel, EDUCADEMY GMBH can recognize whether and when an email was opened by a data subject and which links contained in the email were accessed by the data subject. Personal data collected via these tracking pixels in the newsletters are stored and analyzed by the data controller to optimize newsletter distribution and better tailor the content of future newsletters to the interests of the data subject. This personal data is not shared with third parties. Data subjects are entitled to revoke their separate consent given through the double-opt-in procedure at any time. After revocation, this personal data will be deleted by the data controller. Unsubscribing from the newsletter is automatically interpreted as a revocation by EDUCADEMY GMBH.

8 Contact Option via the Website

The website of EDUCADEMY GMBH, due to legal regulations, contains information that enables rapid electronic contact with our company and direct communication with us, including a general email address. If a data subject contacts the data controller via email or a contact form, the personal data provided by the data subject is automatically stored. Personal data voluntarily provided by a data subject to the data controller is stored for the purpose of processing or contacting the data subject. This personal data is not disclosed to third parties.

9 Routine Erasure and Blocking of Personal Data

The data controller processes and stores the personal data of data subjects only for the period necessary to achieve the storage purpose or as far as granted by the European legislator or other legislators in laws or regulations to which the data controller is subject. If the storage purpose is not applicable or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data is routinely blocked or deleted in accordance with legal requirements.

10 Rights of the Data Subject

· a) Right to Confirmation

Every data subject has the right, as granted by the European legislator, to obtain from the data controller confirmation as to whether or not personal data concerning them are being processed. If a data subject wishes to avail themselves of this right to confirmation, they may contact an employee of the data controller at any time.

· b) Right to Information

Every data subject affected by the processing of personal data has the right, granted by the European legislator, to obtain at any time from the data controller free information about the personal data stored about them and a copy of this information. Furthermore, the European legislator has provided the data subject with the following information:

- The purposes of the processing
- The categories of personal data that are processed
- The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations
- If possible, the planned duration for which the personal data will be stored, or, if this is not possible, the criteria for determining this duration
- The existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, 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: All available information as to their source
- The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject

Furthermore, the data subject has a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject also has the right to obtain information about the suitable safeguards relating to the transfer. If a data subject wishes to exercise this right to information, they can contact an employee of the data controller at any time.

· c) Right to Rectification

Every data subject affected by the processing of personal data has the right granted by the European legislator to request the immediate rectification of inaccurate personal data concerning them. Furthermore, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary statement. If a data subject wishes to exercise this right to rectification, they can contact an employee of the data controller at any time.

· d) Right to Erasure (Right to be Forgotten)

Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller the erasure of personal data concerning them without undue delay, where one of the following grounds applies and to the extent that the processing is not necessary:

- The personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed.
- The data subject withdraws consent to which the processing is based according to Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR, and where there is no other legal ground for the processing.
- The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
- The personal data was unlawfully processed.
- The erasure of personal data is necessary for compliance with a legal obligation in Union or Member State law to which the controller is subject.
- The personal data has been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

If one of the above reasons applies and a data subject wishes to request the erasure of personal data stored by EDUCADEMY GMBH, they can contact an employee of the data controller at any time. The employee of EDUCADEMY GMBH will arrange that the erasure request is complied with immediately. Where personal data has been made public by EDUCADEMY GMBH and our company is obliged pursuant to Article 17(1) to erase the personal data, EDUCADEMY GMBH, taking account of available technology and the cost of implementation, will take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employee of EDUCADEMY GMBH will arrange the necessary in individual cases.

· e) Right to Restriction of Processing

Every data subject affected by the processing

· h) Automated individual decisions, including profiling

Every data subject has the right granted by the European legislator not to be subject to a decision based solely on automated processing — including profiling — which produces legal effects concerning him or her or similarly significantly affects him or her, as long as the decision (1) is not necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests or (3) is made with the data subject’s explicit consent. Where the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is made with the data subject’s explicit consent, the EDUCADEMY GMBH shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view, and to contest the decision. If the data subject wishes to exercise the rights concerning automated individual decisions, he or she may, at any time, contact any employee of the data controller.

· i) Right to withdraw data protection consent

Every data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time. If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of the data controller.

11 Data protection provisions about the application and use of Facebook

The data controller has integrated components of the Facebook company on this website. Facebook is a social network. A social network is a place for social meetings on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences, or enable the Internet community to provide personal or business-related information. Facebook allows social network users to create private profiles, upload photos, and connect via friend requests. The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. If a person lives outside the United States or Canada, the data controller is the Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. Each time one of the individual pages of this website is called up, which is operated by the data controller and on which a Facebook component (Facebook plug-in) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding Facebook component from Facebook. An overview of all the Facebook Plug-ins can be accessed at https://developers.facebook.com/docs/plugins/?locale=en_US. During the course of this technical procedure, Facebook is made aware of what specific sub-site of our website was visited by the data subject. If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to our website by the data subject and for the entire duration of their stay on our Internet site which specific sub-site of our Internet page was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our website, e.g., the “Like” button, or if the data subject submits a comment, then Facebook matches this information with the personal Facebook user account of the data subject and stores the personal data. Facebook receives information via the Facebook component that the data subject has visited our website whenever the data subject is logged in at the same time on Facebook at the time of the call to our website; this takes place regardless of whether the data subject clicks on the Facebook component or not. If such a transmission of information to Facebook is not desirable for the data subject, then he or she may prevent this by logging off from their Facebook account before a call-up to our website is made. The data protection guideline published by Facebook, which is available at https://www.facebook.com/about/privacy/, provides information about the collection, processing, and use of personal data by Facebook. In addition, it is explained there what setting options Facebook offers to protect the privacy of the data subject. To prevent data protection breaches, there are also some useful applications that allow the data subject to block data transmission to Facebook.

12 Data protection provisions about the application and use of Google Analytics (with anonymization function)

The data controller has integrated the Google Analytics component (with anonymization function) on this website. Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising. The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA. For the web analytics through Google Analytics, the data controller uses the application “_gat._anonymizeIp”. By means of this application, the IP address of the Internet connection of the data subject is abridged by Google and anonymized when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area. The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, among other things, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us. Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the data controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks and subsequently create commission settlements. The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs. Furthermore, the data subject has the possibility of objecting to a collection of data that is generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript, that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons. Additional information and the applicable data protection provisions of Google may be retrieved at https://www.google.com/intl/en/policies/privacy/ and at http://www.google.com/analytics/terms/us.html. Google Analytics is further explained at https://www.google.com/intl/en_us/analytics/.

13 Data Protection Policy for the Use of Google+

The data controller has integrated Google+ buttons as a component on this website. Google+ is a so-called social network. A social network is an online meeting place, a virtual community operated on the internet that allows users to communicate and interact with each other. A social network can serve as a platform for the exchange of opinions and experiences or enable the Internet community to provide personal or company-related information. Google+ allows users of the social network to create private profiles, upload photos, and connect through friend requests. The operator of Google+ is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA. Whenever an individual accesses a page of this website that has a Google+ button integrated, the web browser on their information technology system is automatically prompted by the respective Google+ button to download a display of the corresponding Google+ button from Google. During this technical process, Google is informed about which specific subpage of our website is visited by the individual. More information about Google+ can be accessed at https://developers.google.com/+/. If the individual is simultaneously logged into Google+ when they visit a page on our website, Google will recognize with each visit to our website by the individual and throughout the duration of their stay on our website, which specific subpage of our website was visited by the individual. This information is collected through the Google+ button and is associated with the individual’s respective Google+ account. If the individual clicks one of the Google+ buttons integrated on our website and thereby gives a Google+1 recommendation, Google assigns this information to the individual’s personal Google+ user account and stores this personal data. Google stores the Google+1 recommendation from the individual and makes it publicly available in accordance with the terms accepted by the individual. A Google+1 recommendation made by the individual on this website will be stored and processed together with other personal data, such as the name of the Google+1 account used by the individual and the photo stored in other Google services, such as search engine results from the Google search engine, the individual’s Google account, or other places, such as websites or advertisements. Furthermore, Google is able to link the visit to this website with other personal data stored on Google. Google records this personal information to improve or optimize the various services provided by Google. Google receives information through the Google+ button that the individual has visited our website whenever the individual is logged in to Google+ at the same time as they access our website; this occurs regardless of whether the individual clicks on the Google+ button or not. If the individual does not wish to transmit personal data to Google, they can prevent such transmission by logging out of their Google+ account before accessing our website. Further information and Google’s privacy policy can be found at https://www.google.com/intl/en/policies/privacy/. Additional information from Google regarding the Google+1 button can be found at https://developers.google.com/+/web/buttons-policy.

14 Payment Method: Privacy Policy for PayPal as a Payment Method

The data controller has integrated components from PayPal on this website. PayPal is an online payment service provider. Payments are processed via so-called PayPal accounts, which represent virtual private or business accounts. PayPal also has the option of processing virtual payments through credit cards if a user does not maintain a PayPal account. A PayPal account is managed via an email address, which is why there are no classic account numbers. PayPal makes it possible to trigger online payments to third parties or to receive payments. PayPal also assumes trustee functions and offers buyer protection services. The European operating company of PayPal is PayPal (Europe) S.à.r.l. & Cie. S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg, Luxembourg. If the individual selects “PayPal” as the payment option during the ordering process in our online shop, data of the individual will be automatically transmitted to PayPal. By selecting this payment option, the individual consents to the transfer of personal data required for payment processing. The personal data transmitted to PayPal is usually first name, last name, address, email address, IP address, telephone number, mobile phone number, or other data required for payment processing. The processing of the purchase contract also requires such personal data, which are in connection with the respective order. The transmission of data is intended for payment processing and fraud prevention. The data controller will transfer personal data to PayPal, in particular, if there is a legitimate interest in the transfer. The personal data exchanged between PayPal and the data controller for the processing of the data will be transmitted by PayPal to economic credit agencies. This transmission is intended for identity and creditworthiness checks. PayPal may also share personal information with affiliates and service providers or subcontractors to the extent necessary to fulfill contractual obligations or to process the data on behalf of the data controller. The individual has the possibility to revoke their consent for the handling of personal data at any time from PayPal. A revocation does not have any effect on personal data that must be processed, used, or transmitted in accordance with (contractual) payment processing. PayPal’s current privacy policy can be found at https://www.paypal.com/en/webapps/mpp/ua/privacy-full.

15 Payment Method: Privacy Policy for Paydirekt as a Payment Method

The data controller has integrated components from Paydirekt on this website. Paydirekt is an online payment method provided by German banks and savings banks. It is operated by paydirekt GmbH. In order to register for paydirekt for the first time, customers need a checking account with a participating bank or savings bank with online banking access. Paydirekt allows for initiating online payments to third parties. Paydirekt is not a third-party provider but an additional function of the checking account. The payment is processed directly via the buyer’s checking account and sent to the seller’s account. The operating company is paydirekt GmbH, Hamburger Allee 26-28, 60486 Frankfurt, Germany, datenschutz@paydirekt.de. If the individual selects “paydirekt” as the payment option during the ordering process in our online shop, data of the individual will be automatically transmitted to paydirekt. By selecting this payment option, the individual consents to the transfer of personal data required for payment processing. The personal data transmitted to paydirekt is usually first name, last name, address, email address, IP address, telephone number, mobile phone number, or other data required for payment processing. The processing of the purchase contract also requires such personal data, which are in connection with the respective order. The transmission of data is intended for payment processing and fraud prevention. The data controller will transfer personal data to paydirekt, in particular, if there is a legitimate interest in the transfer. The personal data exchanged between paydirekt and the data controller for the processing of the data will be transmitted by paydirekt to economic credit agencies. This transmission is intended for identity and creditworthiness checks. Paydirekt may also share personal information with affiliates and service providers or subcontractors to the extent necessary to fulfill contractual obligations or to process the data on behalf of the data controller. The individual has the possibility to revoke their consent for the handling of personal data at any time from paydirekt. A revocation does not have any effect on personal data that must be processed, used, or transmitted in accordance with (contractual) payment processing. The current privacy policy of paydirekt can be found at https://www.paydirekt.de/agb/medien/paydirekt_Datenschutzinformationen.pdf.

16 Payment Method: Privacy Policy for Sofortüberweisung as a Payment Method

The data controller has integrated components from Sofortüberweisung on this website. Sofortüberweisung is a payment service that enables cashless payment for products and services on the internet. Sofortüberweisung represents a technical process through which the online retailer immediately receives payment confirmation. This allows the retailer to deliver goods, services, or downloads to the customer immediately after the order. The operator of Sofortüberweisung is SOFORT GmbH, Fußbergstraße 1, 82131 Gauting, Germany. If the individual selects “Sofortüberweisung” as the payment option during the ordering process in our online shop, data of the individual will be automatically transmitted to Sofortüberweisung. By selecting this payment option, the individual consents to the transfer of personal data required for payment processing. During the purchase process via Sofortüberweisung, the buyer transmits the PIN and TAN to Sofort GmbH. After a technical check of the account balance and retrieval of further data to check account coverage, Sofortüberweisung initiates a transfer to the online retailer. The execution of the financial transaction is then communicated to the online retailer automatically. The personal data exchanged with Sofortüberweisung includes first name, last name, address, email address, IP address, telephone number, mobile phone number, or other data required for payment processing. The data transfer serves the purpose of payment processing and fraud prevention. The data controller will transfer personal data to Sofortüberweisung even if there is a legitimate interest in such transmission. Personal data exchanged between Sofortüberweisung and the data controller may be transmitted to credit agencies. This transfer is intended for identity and creditworthiness checks. Sofortüberweisung may also share personal data with affiliated companies and service providers or subcontractors to the extent necessary to fulfill contractual obligations or if the data is to be processed on behalf of the data controller. The individual has the option to revoke their consent for the handling of personal data at any time with Sofortüberweisung. Such a revocation does not affect personal data that must be processed, used, or transmitted in accordance with (contractual) payment processing. The applicable privacy policy for Sofortüberweisung can be accessed at https://www.sofort.com/ger-DE/datenschutzerklaerung-sofort-gmbh/.

17 Data Protection Policy for the Use of the AIRCADEMY App

The software provider for the AIRCADEMY APP is the company SilkCode GmbH, Luisenstraße 62, D-47799 Krefeld, Tel. 02151 60773-70, Fax 02151 60773-99, info@silkcode.de, www.silkcode.de.

17.1 General

The software provider takes the protection of users’ personal data as well as the obligation to provide information to them very seriously and strictly adheres to the legal provisions of data protection law. This statement provides an overview of how the provider ensures this protection and what type of data is collected for what purpose. Further questions regarding data protection should be directed to the provider.

17.2 Collection of Personal Data

The access data provided by the provider for using the software and the publications available within the software (login data), as well as the personal data voluntarily provided by the user for registration purposes, constitute personal data. These are stored by the provider on a server in Germany without a time limit. Personal data is processed solely in accordance with the legal provisions of the European Union, in accordance with the General Data Protection Regulation (GDPR) dated May 25, 2018, to protect natural persons with regard to the processing of personal data and the free movement of such data.

17.3 Purpose of Data Collection – Access Data (Login Data)

The storage of access data (login) is for the purpose of providing copyrighted content of the publications to the user. The provision of publications can apply to multiple devices and platforms on a user-specific basis. The provider defines the number of permissible devices and associates this information with the access data.

17.4 Purpose of Data Collection – Registration, Setting Up a Cloud Account

Users are provided with the opportunity to enhance the publications provided by the software with their own annotated bookmarks and annotations in the form of texts, images, photos, audio comments, PDF data, and web links. These bookmarks and annotations are initially stored locally on the user’s mobile device in the native apps and are not transmitted to the provider. Therefore, they are generally only available on the mobile device where the bookmarks and annotations were created. If a browser-based application is used, local use of bookmarks and annotations is not possible as the application only operates online. Therefore, users must register in the browser-based application before creating annotations and bookmarks. Users must also register if they wish to use the locally created annotations and bookmarks on other platforms (another native app or browser-based application) without having to create them again. Registration involves transferring the created annotations to a server operated by the provider in Germany. Additionally, registration allows the user to recover bookmarks and annotations in the event of reinstallation and transfer them to exchange sites for “loose-leaf products.” The use of the registration function is generally voluntary for users. To synchronize devices, user registration is required by providing a personal email address and a user-defined password in the “Cloud Account” section. The synchronization of devices is done through a double-opt-in process, where the user must separately confirm the email address and password entered during registration. The user-defined password is stored on the server in encrypted form. Unauthorized access to registration data is not possible. An internet connection is required for synchronization. During synchronization, the provider centrally stores bookmarks and/or annotations related to the corresponding publication and registration data. Upon uninstallation of the software, locally stored annotations and bookmarks are deleted from the user’s device. Data transferred to the server through registration remains unaffected by this deletion. Alternatively, users can use the access to an existing social media account for registration instead of creating their own cloud account. These access data are exclusively held by the social media service provider and are not transmitted to the provider. There is only a verification process between the access data entered by the end customer and the data stored by the social media service provider.

17.5 Consent for the Storage of User-Related Data

Users agree to the storage of both their access data and the registration data voluntarily transmitted during synchronization by the provider, as well as the data for the provision and maintenance of the services described in points 3 and 4, and for the collection of statistics on the use of the software and associated publications. Specifically, the following data is stored for this purpose: – Time of consent – Device identifier of the mobile device (iOS and Android platforms). For iOS, the operating system used and the operating system version are also stored. – In the case of using a browser-based application, only the type and version of the browser are stored, but not the computer’s operating system and device type. – Statistics on loading and reading publications: When and how often documents and pages are loaded and read on various platforms. It also records which external links a user accesses from a publication and when. Storage and evaluations are anonymized. They serve to ensure the operation and security of the application and to optimize the offering for the user. Additionally, information about accessed resources is stored on the server. This storage includes software technical error logs (log files) in case of software errors. There are no further analyses for the purpose of personalized advertising, nor are user profiles created.

17.6 Analysis Tools

Further analyses or the use of third-party analysis tools do not take place.

17.7 Access to Microphone, Camera, or Gallery

Access to the microphone, camera, or gallery is only granted on iOS platform devices or when using a browser-based application with the prior consent of the user. For Android devices, the user is asked for such consent before installing the app.

17.8 Location-Based Data / Third-Party Services

Location-based data is not collected, and other third-party services are not used.

17.9 Social Plugins

The software allows the user to share content with other users via email or social networks. This does not automatically establish a direct connection to social networks. Instead, the user must log in to the respective social networks themselves. Storage of any necessary login data for this purpose in the provider’s app/application does not occur.

17.10 Links to URLs of Other Providers

The content offered in the software may include links to URLs of other providers. The provider of the linked page is solely responsible for illegal, incorrect, or incomplete content and, in particular, for damages resulting from the use or non-use of such information. The provider who merely refers to the respective publication via links is not liable.

17.11 Disclosure of Personal Data

In principle, user-specific data is not shared with third parties, whether for business, advertising, or any other purposes. It is solely stored and used by the provider. The provider also takes technical measures to prevent breaches by hackers or other illegal methods of data acquisition. However, the provider cannot provide a 100% guarantee to prevent illegal data sharing, and no liability can be assumed for any resulting damages.

17.12 Processing of Data Outside the European Union / Server Location

The processing of personal data within and outside the European Union strictly follows the provisions of the GDPR (General Data Protection Regulation) of the European Community to provide adequate guarantees for the protection of privacy, fundamental rights, and freedoms of individuals. Personal data is stored on a server operated in Germany.

17.13 User’s Rights

A user has the right at any time to request information, free of charge, about the personal data stored about them and the purpose of data collection. In addition, the user has the right to correct incorrect data, block, and delete their personal data, as far as no legal retention obligations oppose this. This does not happen automatically but through written communication from the user to the provider. Revoking the storage of personal data leads to the unavailability of certain functions and services of the software, either entirely or partially. —

18 Data Protection Policy for the Use of AIRCADEMY Online Trainer and Online Examination Platforms

18.1 Collection and Processing of Personal Data

When you visit the AIRCADEMY Trainer or AIRCADEMY Examination, our web server logs your abbreviated IP address and the internet address of the page from which you access it, as well as the date and time of access, your browser type and operating system, and the number of bytes transferred during the connection for establishing and maintaining the internet connection and for statistical purposes. When you log in for online registration and examination, further data is stored to process your registration and conduct the examination. This data includes your name, possibly your candidate number, and the type of examination. For XML imports, additional information such as your date of birth, place of birth, street, house number, postal code, city, and the examination result (although not imported, just stored for database export) may be kept. Additionally, for error handling of error messages, we store your IP address, the accessed page, the login processes, and the browser and operating system you used. Some information is stored as “session cookies” on your PC during a session. These are valid for one session only and are deleted upon ending a session. EDUCADEMY GMBH uses your data exclusively for the services you have requested. Data is stored on a server within the European Union in accordance with the applicable data protection regulations. Data transmission is encrypted.

18.2 Security

We treat your data confidentially and in strict accordance with legal provisions. The personal data provided during registration is not disclosed to third parties and is not accessible to third parties. We implement technical and organizational security measures to protect data managed by us against accidental or deliberate manipulation, loss, destruction, or access by unauthorized persons. You have the right to access your stored data at any time. You can change, supplement, or withdraw it at any time. To protect your personally stored data against unauthorized access and misuse, we have taken extensive technical and operational security measures. Our security procedures are regularly reviewed and adapted to technological progress. Communication between your computer, the test computer, and our web server is encrypted using recognized encryption methods (Secure Socket Layer technology, SSL) if your browser supports SSL.

18.3 Information

Upon written request to EDUCADEMY GMBH, Schlesier Weg 7, 32805 Horn-Bad Meinberg, Germany, we will inform you about the data we have stored about you (e.g., name, address). —

19 Legal Basis for Processing

Article 6(1)(a) GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1)(b) GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1)(c) GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data, or other vital information would have to be passed on to a doctor, hospital, or other third parties. Then the processing would be based on Art. 6(1)(d) GDPR. Finally, processing operations could be based on Article 6(1)(f) GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

20 Legitimate Interests in Processing Pursued by the Controller or a Third Party

If the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is the conduct of our business in favor of the well-being of all our employees and the shareholders.

21 Period for Which Personal Data Will Be Stored

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

22 Legal or Contractual Requirements for the Provision of Personal Data; Necessity for the Conclusion of the Contract; Obligation of the Data Subject to Provide the Personal Data; Possible Consequences of Failure to Provide Such Data

We clarify that the provision of personal data is partly required by law (e.g., tax regulations) or can also result from contractual provisions (e.g., information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with them. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact one of our employees. Our employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and the consequences of non-provision of the personal data.

23 Existence of Automated Decision-Making

As a responsible company, we do not use automatic decision-making or profiling.