Effective – August 3, 2018
For Alron Aviation, Inc. DBA (doing business as) ‘Sheffield School of Aeronautics’
Table of Contents
- Sheffield’s note of History & Privacy
- Changes to this Privacy Notice, Conditions of Use and Notices
- Personal Information Collected by Sheffield
- Collection Offline
- Collection and use of location data
- Collection of Other Information
- Sharing of Information with third-parties
- Third Party Content
- Third Party Services
- Use of Personal Information
- Uses and Disclosures of Other Information
- Law Enforcement and Protection of Users
- International Data Transfers
- What if data is transmitted internationally?
- Retention of Personal Information
- Application of Generally Accepted Privacy Principles (GAPP)
- Use, retention and disposal
- Quality and Data integrity
- Monitoring & Enforcement
- Employee Training
- Information Security (IS)
- Sheffield School of Aeronautics Human Resources Organizations
- Sheffield School of Aeronautics organizations administering contracts or agreements
- All Sheffield School of Aeronautics organizations using Personal Information
- Security Incidents
- Dispute Resolution
- Choices and Access – Your choices regarding our use and disclosure of your Personal Information
- How you can access, change or suppress your Personal Information
- Retention Period
- Jurisdiction and Cross-Border Transfer
- Right to Revise/ Amend
- Contact Us
Affiliate: A company not specifically part of Sheffield School of Aeronautics but operationally reports into Sheffield School of Aeronautics.
Customer: A person or organization who receives products or services from Sheffield School of Aeronautics.
Disclosing Party: A party that discloses Personal Information to the other party.
Disclosing Party Personal Data: Personal Information disclosed to Sheffield School of Aeronautics.
Employee: Someone who is employed by Sheffield School of Aeronautics either as an Employee or a contract Employee.
This includes any information that does not reveal your specific identity or does not directly relate to an identifiable individual. Other Information includes:
• Browser and device information;
• App usage data;
• Information collected through cookies, pixel tags and other technologies;
• Location data;
• Demographic information and other information provided by you that does not reveal your specific identity; and
• Information that has been aggregated in a manner that it no longer reveals your specific identity.
If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.
Personal Information: Information that specifically identifies an individual (such as an individual’s name, home or other physical address, e-mail address, home or mobile telephone number or other identifier that permits the physical or online contacting of a specific individual) or that is associated with an identifiable person (such as demographic information or information about a person’s activities when such information is linked to personally identifying information), and credit/debit card numbers with expiration dates and security card codes.
We collect, use and disclose these types of Personal Information to provide the requested Services to you, or because we are legally required to do so. If you do not provide the information that we request, we may not be able to provide you with the requested Services.
Processing: Any operation or set of operations performed upon Personal Information, whether automated or manually, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, erasure or destruction.
Security Incident: An incident where the confidentiality of Personal Information within Sheffield School of Aeronautics’ custody has been materially compromised posing a reasonable possibility of harm.
Third Party Service Provider or Vendor: A third party reasonably selected by Sheffield School of Aeronautics to provide services. Examples of Third Party Service Providers include technology service providers, SEO partners, business process outsourcing service providers and call center service providers.
Uses Permitted: Sheffield School of Aeronautics’ use of Personal Information includes:
- Undertaking activities related to Accounts for Products and Services with agreed to terms
- Managing an individual’s relationship with Sheffield School of Aeronautics
- Use within specific Sheffield School of Aeronautics products and/or services
- Improving Sheffield School of Aeronautics products, sites and services (by itself or in combination with data from other Sheffield School of Aeronautics offerings or third parties)
- Risk assessment, information security management, statistical, trend analysis and planning purposes
- Monitoring and recording electronic communications for quality, training, investigation and fraud prevention purposes
- Detection, prevention, investigation and prosecution of Employee crime
- Undertaking normal and reasonable business activities
- Administration and management of Employees (i.e. benefits, use of company assets, salary planning, etc.)
These updates include changes to address the new standards introduced by the European data protection law known as the General Data Protection Regulation (GDPR).
Sheffield’s note of History & Privacy
Since 1948, Sheffield has developed relationships with thousands of professionals seeking FAA certification and hundreds of airlines, based on respect, integrity, and for providing unparalleled training. We’re aware of the trust and confidence you demonstrate when you visit our website and provide us with information. The Privacy Notice below is posted to demonstrate our adherence to the expected privacy practices. We shall treat your information with the same honesty and sensitivity that we have displayed throughout our company’s history.By visiting sheffield.com, you agree to accept the practices described in this Privacy Notice.
Changes to this Privacy Notice, Conditions of Use and Notices:
Personal Information Collected by Sheffield:
Information you give us electronically and/or verbally: Sheffield collects any information which you enter on our web site forms. This information is normally provided when you search, or request school or course information, or apply for enrollment, or when you communicate with any of our departments such as instruction or admissions through our web site, telephone, mail or fax. Examples of the type of information you may supply us with include your name, address, telephone number, credit card information, e-mail addresses, and financial information such as your Social Security number or military ID number or airline employee badge number. Automatic Information collected by us: Whenever you visit our Web site we collect and store information such as “cookies” which remember information about a visitor from one page to the next and from one visit to the next. We collect and analyze the IP address used to connect your computer to the Internet; login; password; computer and connection information such as your browser type and version; operating system and platform; confirmation when you open e-mail that we send you; the URLs which lead you to and around our Web site including the date and time; the pages and or programs you viewed or searched for and the phone number used to call our voice telephone numbers. Your browser allows you to reject cookies and software is available from third parties which will allow you to visit our Web site without providing this information. You are welcomed at our Web site if you use this software but we will not be able to offer you our personalized services.
We collect Personal Information from you offline, e.g., when you attend a related trade shows that Sheffield School is attending, inquire over the phone, or contact customer service
Collection and use of location data
When using Sheffield School of Aeronautics sites, actual location information may be collected and processed. Various technologies are used to determine location, including IP address, GPS, and other sensors that may, for example, provide information on nearby devices, Wi-Fi access points and cell towers. Location data is used in accordance with the section ‘Uses Permitted’, and disclosed in accordance with the section ‘Use, retention and disposal’.
• Through your browser or device. Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
• Through your use of any mobile device App that we make available on iTunes, Google Play, or any similar app store. When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number. We also use the contact information you provide when seeking school and course information.
• Using cookies and other tracking technologies. Technologies such as: cookies, but not beacons, tags, scripts, and similar technologies, are used by Sheffield School of Aeronautics.
• Using pixel tags and other similar technologies. We do notemploy the use of Pixel tags (also known as web beacons and clear GIFs) that may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Services and response rates.
• IP Address. Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.
• Approximate Location. We do not collect the approximate location of your device by, for example, using satellite, cell phone tower or WiFi signals.
• Using Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies. We do not use Flash LSOs and other technologies to, among other things, collect and store information about your use of the Services.
Sharing of Information with third-parties:
We contract with an outside service called Google Analytics to help us better understand your use of our web sites. Google Analytics places cookies on your computer to collect various kinds of information for us related to the use of our websites, so that we may continue to refine and improve the sites and better serve you. We do not allow Google Analytics to collect any credit card, user name or password information, nor are they allowed to use data that they collect for us for any other purpose. Additionally, Google Analytics is required to maintain all the information collected for us in strict confidence.
- Our content may link to third party websites to provide relevant references. We are not responsible for such external content, which may contain separate privacy policies and data processing disclosures.
We may also use and share your Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law, which may include laws outside your country of residence, to respond to requests from public and government authorities, which may include authorities outside your country of residence, to cooperate with law enforcement, or for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
In addition, we may use, disclose or transfer your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
Third Party Services
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
Providing the functionality of the Services and fulfilling your requests.
- To provide you with the Services.
- To respond to your inquiries and fulfill your requests, complete your transactions, and provide you with related customer service.
- To send administrative information to you, such as changes to our terms, conditions and policies
We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
Providing you with our newsletter and/or other marketing materials and facilitating social sharing.
- To send you marketing communications that we believe may be of interest to you based on your information, preferences and interests, including how you use and interact with the Services and any content provided thereon.
- To facilitate social sharing functionality that you choose to use.
We will engage in this activity with your consent or because we have a legitimate interest.
Uses and Disclosures of “Other Information”
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
Law Enforcement and Protection of Users:
We will release personally identifiable information to third parties and organizations when we believe it is appropriate for us to do so to comply with the law. We will also do so to cooperate with law enforcement investigations, comply with court orders or subpoenas, protect the legal rights of us and our users, or when we believe it is needed for fraud protection and/or credit risk reduction.
Our Web site protects the security of certain personal information you transmit to us by using Secure Sockets Layer (SSL) software, which encrypts the information you input during the transmission to us.
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” at the end of the policy.
International Data Transfers
The nature of our operations requires us to transfer and receive data from locations outside of the United States. Sheffield School of Aeronautics is committed to self-certifying under the US-EU Privacy Shield effective immediately.
What if data is transmitted internationally?
Visitors may want to know whether their personal information will be transferred out of their country of origin. Please be aware that when registering or requesting a transaction on Sheffield School of Aeronautics Sites, Sheffield School of Aeronautics reserves the right to transfer the visitor’s personal data to computers in the United States or any other country where Sheffield School of Aeronautics or its affiliates, subsidiaries or service providers maintain facilities. The data protection laws in these countries may be different from, and less stringent than the visitor’s country of residence. By using the Sites or by providing any personal or other information to Sheffield School of Aeronautics, express consent is given to Sheffield School of Aeronautics to conduct such transfers and processing. Sheffield School of Aeronautics takes steps to ensure that the data collected under this Policy is processed according to the provisions of this Policy and the requirements of applicable law wherever the data is located.
Sheffield’s products and services are not intended for or targeted at children under 18. We do not knowingly or intentionally collect information on our website or mobile applications about children under 18.
Retention of Personal Information:
The retention time of the personal data we collect and process varies both due to the requirements of the specific processing activity and due to the requirements imposed by law and/or governmental authorities, including the Federal Aviation Administration (FAA).
Application of Generally Accepted Privacy Principles (GAPP)
Sheffield School of Aeronautics is committed to providing reasonable protection from loss, inappropriate use, or inappropriate disclosure of the Personal Information that is entrusted to the company. In an effort to provide protection that is as consistent as possible for all individuals who provide Personal Information to the company, Sheffield School of Aeronautics has established a privacy program that is based on the Generally Accepted Privacy Principles (GAPP) identified by the Assurance Services Executive Committee (ASEC) of the American Institute of Certified Public Accountants (AICPA) and the Assurance Services Development Board (ASDB) of the Canadian Institute of Chartered Accountants (CICA). These ten principles (covering Management, Notice, Choice and Consent, Collection, Use and Retention, Access, Disclosure to Third Parties, Security for Privacy, Quality, Monitoring and Enforcement) were developed to serve as a universal framework of privacy best practices that companies can use to evaluate their programs and develop sound policies and practices.
- Ensuring that processes have been implemented for the appropriate collection, use, disclosure and retention of personal information in accordance with applicable law and the Generally Accepted Privacy Principles (GAPP).
- Ensuring that privacy plans in compliance with Data Privacy laws and regulations are documented in writing and implemented.
- Provision of guidance, consultation and training regarding privacy issues
- Compliance with privacy plans including:
- Performing monitoring and verifications for compliance with existing privacy plans. Verifications include ongoing monitoring and enforcement of privacy plans.
- Coordination and alignment with Boeing’s Global Privacy Office whenever appropriate
- Follow up on deficiencies or opportunities for improvement. The DPO will maintain verification records and respond to inquiries or complaints.
- Maintenance and assignment of data privacy training materials
- Assurance that reliable methods for dispute resolution and incident response are available and clearly communicated
- Providing support to business owners by assessing products and services to ensure compliance with applicable privacy laws
Use, retention and disposal
Sheffield School of Aeronautics will use an individual’s Personal Information only for Uses Permitted stated herein or in the Product or Service privacy notice and will only be provided to parties with a need to know. Reasonable attempts to use anonymized data will be made prior to disclosure.
When an account is terminated, Sheffield School of Aeronautics will only be entitled to retain Personal Information pursuant to applicable information retention policies. Personal Information will be deleted at the conclusion of the applicable retention policy retention period.
Individuals may request access to Personal Information about them that Sheffield School of Aeronautics holds and be able to correct, amend, or delete that information where it is inaccurate, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated. If an individual would like to have access to Personal Information Sheffield School of Aeronautics holds about them, please email to firstname.lastname@example.org, or write to Sheffield School of Aeronautics, Attention: Eric Morris, 499 NW 70thAve, Suite 110, Plantation, FL, 33317 – USA.
Customer California Privacy Rights – Under California law, Individuals who are California residents are entitled to annually request and obtain information about the Personal Information shared, if any, with other businesses for their own direct marketing. If applicable, the information would include the categories of Personal Information and the names and addresses of those businesses with which Personal Information was shared for the prior calendar year. To make such a request, please send an email to email@example.com. Written requests may be sent to Sheffield School of Aeronautics, Attention: Eric Morris, 499 NW 70thAve, Suite 110, Plantation, FL, 33317 – USA. Please note that not all information sharing is covered under the California law, and only information on covered sharing will be included in any response.
Monitoring and Enforcement
Sheffield School of Aeronautics conducts periodic assessments to ensure compliance with its Data Privacy policies. Relevant discrepancies will be corrected in a timely manner.
Sheffield School of Aeronautics also provides (a) various methods for which each individual’s complaints and disputes can be investigated and resolved, (b) assessments to ensure compliance with policies; and (c) commits to remedy problems arising out of a failure to comply with the principles.
With regard to complaints concerning verification, correction or deletion of any Personal Information collected, or to communicate any questions or concerns regarding this Policy or Sheffield School of Aeronautics’ treatment of Personal Information, please e-mail firstname.lastname@example.org, or by writing to Sheffield School of Aeronautics, 499 NW 70thAve, Suite 110, Plantation, FL, 33317 – USA.
Certain information may also be corrected by using the “Account” and “Profile” section of the Sites. Please note that in certain circumstances, Personal Information may not be able to be removed or changed.
Upon receipt of formal written complaints, it is Sheffield School of Aeronautics’ policy to contact the complainant regarding any concerns. If unable to reach a resolution, various other methods may be used to investigate and resolve the dispute.
Information Security (IS)
IS will implement sufficient and reasonable technical, administrative and logical security controls to ensure the safety and protection of Personal Information. In addition, IS will develop and maintain an effective information security breach notification process.
Sheffield School of Aeronautics Human Resources Organizations
Human Resources will provide and maintain business processes which implement the Notice, Choice and Access principles for Employee Personal Information.
Sheffield School of Aeronautics organizations administering contracts or agreements
Procurement organizations (such as Supplier Management and contracts organizations) will maintain business processes and contractual terms and conditions that help ensure data is transferred in accordance with provisions of this Policy and the requirements of applicable law.
If Sheffield School of Aeronautics or its Affiliates are made aware of any Security incidents, Sheffield School of Aeronautics will review and investigate in accordance with company policies and procedures, as well as any applicable statutes and regulations. Once a Security Incident has been determined to have taken place, Sheffield School of Aeronautics will conduct an investigation to determine root cause and implement reasonable solutions to ensure the safety and security of Personal Information in its custody. Affected individuals will be notified as reasonably practical after a Security Incident has been determined to have taken place unless Sheffield School of Aeronautics or its Affiliate is subject to a legal or regulatory constraint.
Verification, correction or deletion of any Personal Information collected, or to communicate any questions or concerns regarding this Policy or Sheffield School of Aeronautics’ and its Affiliates’ treatment of Personal Information, please e-mail email@example.com, or by writing to Sheffield School of Aeronautics, 499 NW 70thAve, Suite 110, Plantation, Florida, USA. Certain information may also be corrected by using the “Account” and “Profile” section of the Sites. Please note that in certain circumstances, Personal Information may not be able to be removed or changed. Upon receipt of formal written complaints, it is Sheffield School of Aeronautics policy to contact the complainant regarding any concerns.
Your choices regarding our use and disclosure of your Personal Information
We do not give you choices regarding our use and disclosure of your Personal Information for marketing purposes because we do not use your data for marketing purposes, other than for the prospective inquiring student to receive a follow up email from us, usually 1 week to 1 month following your initial receipt of our school/course information from your initial contact with Sheffield School.
You may opt-out from: receiving electronic communications from us: If you do not wish to receive a follow up email from us, you may opt-out by following the emailing us your full name and contact information with a simple text statement of “Unsubscribe” in the e-mail communications to us.
How you can access, change or suppress your Personal Information
You may correct, delete, or update some of the Personal Information associated with a particular account by contacting us at firstname.lastname@example.org. We will respond to your request within a reasonable timeframe.
If you are in an European Economic Area (EEA) country and would like to request to review, suppress, restrict or delete Personal Information that you have previously provided to us, you may contact us at email@example.com. If our collection, use or disclosure of your Personal Information is based upon your consent, you may withdraw that consent (as applicable to future collection, use or disclosure) also by contacting us at firstname.lastname@example.org. We will respond to your request consistent with applicable law.
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or apply a course tuition discount, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion). There may also be residual information that will remain within our databases and other records, which will not be removed. FAA regulations require that we retain your student file and all applicable information provided for the file, for at least 3 years.
We will retain your Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you and provide the Services to you; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is legally advisable (for example, in regard to applicable statutes of limitations, litigation or regulatory investigations).
Jurisdiction and Cross-Border Transfer
The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information is not stored or processed in any country.
You may also contact at us by postal mail or telephone at:
Sheffield School of Aeronautics
499 NW 70th Ave
Plantation, Florida 33317
United States of America