PPL/IR - Europe Privacy Notice
This Privacy Notice explains the basis on which PPL/IR EUROPE LIMITED (‘PPL/IR’, ‘we/us/our’) will collect and process personal data about our members and prospective members (‘you/your’). By becoming a member of PPL/IR, or by attending a PPL/IR event for which sign-up is required, you are accepting and agreeing to the practices set out in this Notice.
Data we hold about You
The only personal data that we hold about you is personal data that you have provided to us or that relates directly to your membership of PPL/IR. We do not obtain personal information about you from third parties. The personal data that you may have provided to us falls within the following categories:
- Your contact information (name, address, telephone number, email) (‘Contact Details’)
- Information about your flying (e.g. flying qualifications, experience, the aircraft you fly, where it is based) (‘Flying Details’)
- Information about your membership (e.g. when you joined PPL/IR; whether your membership is current, which events you have attended) (‘Membership Information’)
- Information about and contained within any forum posts that you have submitted (‘Forum Information’)
- Information that you give us to allow us to meet your needs in relation to events to which you sign up (e.g. timing of your arrival and departure, the identity of those travelling with you, any dietary requirements) (‘Event Information’).
Why we process your information
We will process the information that we hold about you for the following purposes:
- To provide membership services to you, such as sending you copies of the PPL/IR magazine, inviting you to attend events, organising events, and sending you other information that we consider may interest you from time to time.
- To further the aims and objectives of PPL/IR
- For PPL/IR’s internal administrative purposes
- For the purposes of research and/or analysis projects undertaken by PPL/IR from time to time
- To make available to the membership a directory of members
- If you are a lapsed member (subject to our data retention policy – see below) for the purposes of keeping in touch with you
People with whom we share your information
If you are a member of PPL/IR, we share the fact of your membership, your Contact Details with the whole membership through the members-only section of the PPL/IR website. Where you have provided Flying Information, we share this in the same way. A recent technical change to the PPL/IR website will allow you to opt out of sharing any element of your Contact Details and Flying Information with other member via the directory. We also share Contact Details with our third party service providers where necessary to provide a service to you or where reasonably required for our operational purposes (e.g. with the Mailchimp mailing software, which we use from time to time to send you notice and information.
Forum Information is available to the whole membership through the members-only section of the PPL/IR website.
We will occasionally need to share Event Information with event venues and/or caterers. Where we do so, we will limit the information that we share to that reasonable necessary to ensure that the event runs efficiently and that any needs that you identify to us are met.
Apart from the circumstances identified above, we will not share any of your information with third parties unless we are legally obliged to do so, or unless we need to do so for the purposes of a legal defence.
Legal basis of processing
The legal grounds on which we process your data are as follows:
- Where the processing is necessary for us to perform a contract that you are party to, or to take steps at your request prior to entering a contract, that is the ground on which we are processing that data
- Where the processing is necessary for compliance with a legal obligation to which we are subject, that is the ground on which we are processing that data
- Where processing is necessary for the purposes of our legitimate interests, that is the ground on which we are processing that data, provided that your fundamental rights and freedoms which require protection of your data override those legitimate interests (our legitimate interests comprise furthering the aims and objectives of PPL/IR as described on the PPL/IR website)
- If you have given your consent to our processing the data,that is the basis on which we are processing that data
If more than one of the above grounds apply to the processing of data in question, the applicable ground will be the one that is set out first above.
Where the basis on which we process data is that you have consented to the processing, you are entitled to withdraw that consent at any time.
How long we will keep your information
Our data retention and deletion policy is as follows:
- We will keep Contact Information and Membership Information – and continue to process it on the basis and for the purposes described above – until the later of (i) the expiry of three years from the end of the calendar year in which you provided the information to us, and (ii) if you are a lapsed member of PPL/IR, the expiry of three years from the end of the calendar year in which your membership lapsed.
- We will keep Flying Information – and continue to process it on the basis and for the purposes described above – until the expiry of three years from the end of the calendar year in which your membership lapses. Thereafter, we may continue to keep your Flying Information in anonymised form (so that it cannot be recognised as relating in any way to you) for the purposes of statistical research and analysis in furtherance of the aims and objectives of PPL/IR.
- We will keep Forum Information in perpetuity as part of the archive of PPL/IR and for the purposes of education and research (in furtherance of the aims and objectives of PPL/IR).
- We will keep Event Information until the expiry of one week after the event to which the Event Information relates.
Notwithstanding our policy as described above:
- We will delete your Contact Information and Membership Information at any time if you ask us to do so. However, the impact of such a request is that we will no longer be able to provide you with any member services. Consequently, if you make such a request, it will result in your membership of PPL/IR being immediately terminated.
- You may delete your Flying Information through the members only section of the PPL/IR website.
- If you are no longer a member of PPL/IR, we will (on your request) partially anonymise your Forum Information by replacing your name where it appears as ‘poster’ in relation to your forum posts with the moniker ‘An Ex Member’.
Where we store your information
The information that you provide to us will be stored on our computers and servers or those of our service providers. It will not be transferred to a third party outside the European Economic Area ("EEA") unless to a processor acting on our behalf which is either (i) in a country that the European Union has decided has adequate data protection laws in place, or (ii) has provided appropriate data protection safeguards of the sort approved by the European Union and provide effective rights and remedies for you.
Where we have given you (or where you have chosen) a password which enables you to access the members-only parts of the PPL/IR website, you are responsible for keeping this password confidential, and for all use made of your account with such password. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet and the storage of data on servers accessible via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data, and you provide it to us at your own risk.
You have various rights under Data Protection legislation. These include:
- The right to ask us not to process your personal data for direct marketing purposes, even if you have given consent;
- If our processing is based on your consent, the right to withdraw any consent you may have given for our processing of your data – if you exercise this right, we will be required to stop such processing if consent is the sole lawful ground on which we are processing that data;
- The right to ask us for access to the data we hold about you;
- The right to ask us to rectify any data that we hold about you that is inaccurate or incomplete;
- The right to ask us to delete your data in certain circumstances;
- The right to ask us to restrict our processing of your data in certain circumstances;
- The right to object to our processing of your data in certain circumstances;
- In certain circumstances, the right to require us to give you the data we hold about you in a structured, commonly used and machine-readable format so that you can provide the data to another data controller.
You can exercise any of the rights set out above, free of charge, by using any applicable methods set out in our communications with you, or by contacting us by emailing firstname.lastname@example.org. In respect of most of the rights referred to above, your right may be qualified by Data Protection legislation, for example where our processing of data is for the purposes of the establishment, exercise or defence of legal claims. We may therefore not be able or required to fulfil your request, but we will discuss this with You following your request if necessary. Also, we may need more information from You, which we will ask You for following your request. We may ask You to provide further information in order to confirm your identity. Please also note that if you submit unfounded or excessive (for example repetitive) requests to exercise any of these rights, we reserve the right to make a reasonable charge for providing the requested information or taking the requested action, or to decline your request. You also have the right to lodge a complaint with the Information Commissioner’s Office (www.ico.org.uk) if you are concerned that we are not respecting your rights under Data Protection legislation. The Information Commissioner’s Office is the authority in the UK which is responsible for overseeing the application of, and enforcing, Data Protection legislation.