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Privacy Statement in compliance with EU GDPR
September 2nd 2022


  Dear Customers,

thank you for your kind interest in ATCPrep.comâ„¢, a software developed and licensed by Aviation Media & IT GmbH, Germany (we / us / our).

This privacy statement is a briefing about the personal data you share with us when you visit the ATCPrep.comâ„¢ website or use a ATCPrep.comâ„¢ product and explains how we handle this information, our cookie policy and which traffic tracking tools we use. We operate ATCPrep.comâ„¢ under EU privacy rights jurisdiction.

European General Data Protection Regulation (GDPR) governs this privacy statement. Under GDPR provisions your privacy rights include, not limited to:
  • Right of access (Art. 15 GDPR)
  • Right to rectification (Art. 16 GDPR)
  • Right to erasure (Art. 17 GDPR)
  • Right to object (Art. 21 GDPR)
  • Right to restriction of processing (Art. 18f. GDPR)
  • Right to data portability (Art. 20 GDPR)

If you file a privacy / GDPR request with us, we need to make sure you actually are the respective data subject.



I Personal data
  If you order and use a ATCPrep.comâ„¢ preparation software, you will leave and share a trace of personal information.


1 Contractual data
  If you place an order in the ATCPrep.comâ„¢ shop environment, we may ask for your name, email address, postal address, phone number, payment/credit information or other details. Mandatory information you need to share with us to place an order is highlighted.

Only indispensable payment details will be processed to a payment service provider according to your preferred method of payment. Payment service provider provisions may apply.

In addition to any contractual data you provide us, we collect and save your IP address to run a data comparison and verify your location and/or residence details. This layer of verification is necessary for a legally compliant tax treatment of your order. To the extent required by law, we may also use and analyze other data to verify your location and/or residence details for this purpose, in particular payment data.

If you fail to fulfill contractual payment obligations, we reserve the right to share contractual data with a payment collection agency.

Mandatory fields you need to complete during order process are processed for contractual fulfillment purposes only. We store contractual information from the order process under European customer privacy provisions to provide you customer and product support later on.

We will ask for your consent with the provisions of this privacy statement before we store data. In absense of your explicit consent we will not store or use any personal data beyond fulfillment of our contractual obligations.


2 Licensing data
  If your order includes a ATCPrep.comâ„¢ preparation software we will save and process licensing data, that may differ from contractual data, i.e. licensee`s name, email address and postal address. Mandatory information you need to share with us to license a ATCPrep.comâ„¢ preparation software is highlighted.

If you place the order on behalf of a third party licensee, you need to make sure and assert that you are allowed to submit mandatory licensing data of this individual.

Licensing data are hosted in a separate database in compliance with European customer privacy provisions along with a username and password we assign. We will host an account on the ATCPrep.comâ„¢ website you can access with your username and password credentials to download your ATCPrep.comâ„¢ file.

Hosting licensing data is indispensable to operate the download account and to check user authorization in a first time or follow-up activation of ATCPrep.comâ„¢ preparation software in an automated or support-assisted process.


3 Support data
  If you contact our support desk (i.e. by email or a contact form embedded in our website or your ATCPrep.comâ„¢ preparation software) you will share data and information we only save and process to handle your support request and to touch base with you.


4 Performance data
  Certain editions of ATCPrep.comâ„¢ preparation software support the product feature ATCPrep.comâ„¢ Cloud. ATCPrep.comâ„¢ preparation software may establish a communication protocol with a server within GDPR jurisdiction (ATCPrep.comâ„¢ Cloud) to exchange performance data attributed to your licensing data. This allows you to recover your performance statement in case of a change of your system environment (back-up).

Performance data of the overall ATCPrep.comâ„¢ Cloud user community will be processed, curated and randomized without individual user attribution to provide all users a peer-to-peer benchmark to compare their individual performances against (benchmarking).

ATCPrep.comâ„¢ Cloud participation or non-participation will not effect usability of other features of your ATCPrep.comâ„¢ preparation software. You decide upon initial activation of ATCPrep.comâ„¢ preparation software whether you wish to participate in ATCPrep.comâ„¢ Cloud and upload performance data or not (opt in). You may change these settings later on.


5 Objection
  We are authorized to collect, process, save and use personal data to provide you and access to our services and maintain operation of these services.

We will only share personal data like your email address or phone number with trustworthy third party operations with you explicit consent to do so.

You have the right and object and revoke your consent regarding any aspect of your personal data in a written or electronic notice. Kindly address your objection to the accountable controller:

ATCPrep.comâ„¢ - User Privacy
Aviation Media & IT GmbH
Akazienweg 3
91083 Baiersdorf
Germany

E-mail: support(*at*)atcprep.com

Attention: we will comply with your objection without further notice and delete your personal data from our databases without back-up. Certain services including ATCPrep.comâ„¢ Cloud, future activations of ATCPrep.comâ„¢ preparation software and access to your ATCPrep.comâ„¢ user account will be terminated on grounds of their dependency on user information. Performance data will be lost. Please contact our support desk to request a future activation of your ATCPrep.comâ„¢ preparation software after filing a privacy objection.



II Cookies and Service Providers
  Cookies are very small text files placed on your computer/browser by a web server when you visit certain websites. Cookies are used to store data about user preferences but do not collect personal data. Most internet browsers do accept cookies by default, but allow custom configurations to change these settings and reject cookies.


1 Google Analytics
  This website uses "Google Analytics", a web analytics tool provided by Google LLC.

Responsible entity for users in the EU, the EEA and Switzerland is Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google").

Google Analytics uses cookies that provide insights into your use of our websites. The information collected by these cookies about your use of this website is or can be transferred to a Google server in the USA and kept stored there. We use Google Analytics by application of an anonymized IP address in the process.

With IP anonymization, your IP address will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in in very occasional circumstances the full IP address will be transmitted to a Google server in the USA to be shortened there.

According to Google, the IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

By Google Analytics we can statistically analyze the use of our website for a given time but cannot draw any conclusions about a specific person and their user behavior. We need this information for the continuous improvement of our services and optimization of marketing (purpose).

During your website visit, your user behavior is recorded in "events", such as visiting time, page views, click path, scrolls and interactions. Google Analytics also records your approximate location (region), IP address (in shortened form), technical browser information, internet service provider and referrer URL.

Recipients of the data are or may be
  • Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (as processor pursuant to Art. 28 GDPR).
  • Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA
  • Alphabet Inc, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA

US authorities may obtain access to data stored by Google. The USA is currently considered a third country under EU data and privacy protection laws.

We have entered a processing agreement with Google and fully implemented the strict requirements of the German data protection authorities when using Google Analytics. Google Analytics has committed to the EU standard contractual clauses with regard to an eventual cross-border transfer of data to the USA.

Data stored by Google at user and event level that is linked to cookies, user identifiers (e.g. User ID) or advertising IDs (e.g. DoubleClick cookies, Android advertising ID) is anonymized or deleted after 26 months. For details, please see the following link: https://support.google.com/analytics/answer/7667196?hl=en.

You can prevent the setting of cookies by our website at any time by means of an appropriate setting of the internet browser used and thus permanently object to the setting of cookies. Such a setting of the internet browser used would also prevent Google from setting a cookie on your system. In addition, a cookie set by Google Analytics can be deleted at any time via the Internet browser or other software programs.

Furthermore, you have the option to object to and prevent the collection of data generated by Google Analytics and related to a use of this website as well as the processing of this data by Google.

To do so, you must download and install a browser add-on under the link https://tools.google.com/dlpage/gaoptout?hl=en. This browser add-on tells Google Analytics via JavaScript that no data and information about visits to internet pages may be transmitted to Google Analytics. The installation of the browser add-on is considered by Google as an objection.

Further information and the applicable Google privacy policy can be obtained at https://policies.google.com/privacy?hl=en


2 1&1 WebAnalytics
  We use 1&1 WebAnalytics, a website traffic tracker provided by 1&1 Internet SE, Elgendorfer Str. 57, 56410 Montabaur, Germany.

1&1 WebAnalytics collects and processes the following data aspects without gathering personally attributable user information:
  • Referrer (the site you arrive from)
  • Browser information
  • Operating system
  • Device
  • Time
  • IP-Address (randomized)


3 SCA Compliance in Online Payments
  Effective September 14th 2019 an additional authentication layer is mandatory for online payments within the EU ("Strong Customer Authentication", SCA).

If you pay for our products or services using a credit card, supplemental personal data may be collected in addition to your name and credit card number and forwarded to our external payment service provider

BS PAYONE GmbH
Daniel-Goldbach-Straße 17 - 19
40880 Ratingen
Germany

and its contract credit card companies Mastercard and Visa to be further processed and stored once you submit this data.

If your credit card is activated for secure payment using the strong authentication procedures Mastercard SecureCode®, Mastercard IdentCheck®, Verified® by Visa or other 3D-Secure-procedures this may extend to included but not limited to address data, mobile phone numbers, e-mail addresses, the answer to a security question or a code you chose. This information and data is transmitted encrypted.

By making your payment, you consent to the submission of this data also to third countries outside EU legislation, such as the United States or Switzerland, for payment processing purposes. Special conditions and procedures for the use of the above-mentioned strong authentication methods of the external payment service provider BS PAYONE GmbH and its contract credit card companies apply, especially the Information on data processing by BS PAYONE GmbH for end customers (card holder/user) according to Art. 14 GDPR.


4 Adequacy Decision
  The EU Commission decided on July 10th 2023 that personal data in the United States are regulated by an adequate level of protection as in the European Union (so-called "adequacy decision", Art. 45 GDPR). This adequacy decision covers data transfers to US companies that have certified themselves with the US Department of Commerce. Data transfers to these US companies are made with explicit reference to the adequacy decision.


September 12th 2023 - Aviation Media & IT GmbH