Privacy and cookies policy

date of publication 27.09.2023

We treat your personal data and its protection very responsibly. This Privacy Policy applies to personal data that we process in connection with our business. This document is based on personal data laws, including the provisions of the GDPR (General Data Protection Regulation of 27 April 2016) and the Act on Personal Data Protection of 10 May 2018. This Privacy Policy is subject to change at any time. We will always inform you of changes and provide you with the current version of the document. We cooperate with entities that provide a high level of protection for the personal data we process.
Contact us!	In any matter related to the protection of your personal data you can contact us at: daneosobowe@lotams.com or by phone: + 48 536 360 475.
Controller	The Controller of your personal data processed in connection with our online activities is LOTAMS, i.e. LOT Aircraft Maintenance Services Sp. z o.o. of Warsaw, with registered address at ul. Komitetu Obrony Robotników 45C, 02-146 Warsaw, Poland, entered in the Register of Entrepreneurs of the National Court Register under number KRS 0000352848, kept by the District Court for the Capital City of Warsaw in Warsaw, 14th Commercial Division of the National Court Register, with the share capital of PLN 175,470,063.60, holding Tax Identification Number (NIP): 522-294-67-95 and Industry Identification Number (REGON): 142321116.
What does this Privacy Policy contain?	This Privacy Policy contains information on, among other things, the principles of processing your personal data, the purposes for which we process your data and the legal basis that enables us to do so, the tools we use on the website, as well as the recipients of your data and your rights.

TABLE OF CONTENTS

What data do we process, for what purpose and on what basis?
Your rights related to the processing of personal data
Recipients of personal data
Requirement to provide your personal data
Automated decision-making and profiling
How long do we process your data?
Social media
Newsletter
Withdrawal of consent for data processing
Comments and reviews on the website
Cookies and tools used on the website
META (Facebook) Pixel
Google Analytics
Content from external websites
Server logs
Final provisions

What data do we process, for what purpose and on what basis?

We process your personal data, for example, when you contact us and if you are our customer and purchase our products.

We process the personal data we receive from you for the following purposes and on the following legal bases:

PURPOSE OF PROCESSING	SCOPE OF DATA	LEGAL BASIS
Contact	– e-mail address (first name and surname), information contained in the message – phone number – other data provided by you in your correspondence	The legal basis for such processing is Art. 6.1.a) of the GDPR, which allows us to process data based on consent for the purpose of replying to your message, and Art. 6.1.f) of the GDPR, which allows us to pursue our legitimate interest, which is ensuring efficient and effective communication between the website administrator and the user.
Placing and processing an order for products/services	– first name and surname – address – e-mail address – home address – phone number in addition: – Tax Identification Number (NIP) – details of the conducted business activity Although provision of personal data is voluntary, it is necessary to execute an order.	The legal basis for such processing is: Art. 6.1.b) of the GDPR, which allows us to process data for the purpose of taking steps to enter into an agreement and for the purpose of performing an agreement concluded by placing an order.
Issuing an invoice and fulfilling legal and tax obligations	– details of business activity – first name and surname – address – Tax Identification Number (NIP)	The legal basis for such processing is primarily Art. 6.1.c) of the GDPR, which allows personal data to be processed if such processing is necessary for the controller to comply with its legal obligations.
Consideration of complaints and processing withdrawal from the agreement	– e-mail address – first name and surname – data contained in the complaint – bank account number – home address – phone number	The legal basis for such processing is Art. 6.1.b) of the GDPR, which allows personal data to be processed if it is necessary for the performance of an agreement or taking steps to enter into an agreement, and Art. 6.1.c) of the GDPR, which allows personal data to be processed if such processing is necessary for the controller to comply with its legal obligations.
Marketing objective (newsletter)	1. e-mail address 2. first name	The legal basis for such data processing is primarily Art. 6.1.a) of the GDPR, i.e. your consent to receive commercial information and marketing content from us, and Art. 6.1.f) of the GDPR, which allows personal data to be processed if, by doing so, the controller pursues its legitimate interest (in this case, it is the marketing of own services and products).
Archiving and providing evidence, for the purpose of securing information that can be used to demonstrate facts	– all data listed in table showing data processed by us	The legal basis for such processing is Art. 6.1.f) of the GDPR, which allows the processing of personal data if, by doing so, the controller pursues its legitimate interest (in this case, the controller’s interest is to hold personal data to prove facts related to the use of the website, performance of an agreement, processing of data on a justified legal basis).
Establishment, exercise or defence of legal claims	– all data referred to above	The legal basis for such processing is Art. 6.1.f) of the GDPR, which allows the processing of personal data if, by doing so, the controller pursues its legitimate interest (in this case, the controller’s interest is to hold personal data to establish, exercise or defend against claims lodged by users of the website or third parties or customers).
Website management, use of tools to improve the website and analyse data related to its use	– IP – behaviour on the website	The legal basis for such processing is Art. 6.1.f) of the GDPR, which allows the processing of personal data if, by doing so, the controller pursues its legitimate interest (in this case, the controller’s interest is to act with the intention to optimise the website performance, including content presented on the website, to match the needs of users, improve the controller’s offer).
Use of cookies on the website	– IP – user behaviour on the website	The legal basis for such processing is Art. 6.1.a) of the GDPR, which allows personal data to be processed based on your consent. You give your consent during your first visit to the website.
Management of the controller’s social media profiles	– data related to the use of a particular social media platform	The basis for the processing is the controller’s right under Art. 6.1.f) of the GDPR, i.e. the controller’s legitimate interest to manage the profile on a given platform, and your consent (Art. 6.1.a) of the GDPR), which you give, for example, by joining a group created by the controller on a given platform.
Fulfilment of obligations related to personal data protection (e.g. obligation to create registers and records)	– the scope of the data is defined by law and varies depending on the content of the given legal obligation of the controller	The basis for the processing is Art. 6.1.c) of the GDPR, i.e. it is carried out on the basis of legal provisions which require the processing of personal data.
Posting comments/reviews on the website	– name – e-mail address	The basis for the processing is Art. 6.1.a) of the GDPR, i.e. your consent, which you give to add a comment on our website.

Your rights related to the processing of personal data

Please be advised that you have the following rights related to the processing of your personal data:

If you want to exercise your right, contact us at:

daneosobowe@lotams.com

1. Right of access to information – every person whose data is processed has the right to know what happens to their personal data. Among other things, the Privacy Policy that you read was created for this very purpose.

2. Right of access to personal data – if we, as the controller of your data, receive a request from you for access to your data, we are obliged to provide you with such information. We are obliged to discharge our duties in this regard as a data controller immediately, no later than within a month. If it is not possible to do so within this time limit, we are obliged to inform you at least whether we are processing your data, and once we do so we can extend the time limit for a complete response to your request by two months.

3. Right to rectification of personal data – you can request that the controller of your data rectify incorrect data or supplement any incomplete data.

4. Right to erasure of personal data, the right to be forgotten – you can request us, as the controller of your personal data, to erase it, to inform the person to whom your data has been transferred of its erasure. You also have the right to demand that your personal data that we have made public be subject be erased also by other controllers. As the controller of your data, we are also obliged, at your request, to inform you to which recipients we transferred your data subject to erasure.

5. Right to restriction of processing of personal data – you can request that the processing of your personal data be restricted. This may occur, for example, when you do not agree with the accuracy of the processed data, or when you decide that you no longer need the data for processing purposes.

6. Right to object to the processing of personal data – you can object to your data being processed by the controller.

7. Right to data portability – means that under certain conditions you can request that your data be transferred directly to a designated other controller.

8. Right to lodge a complaint – when you recognise that our processing of your data violates the law, you can lodge a complaint with the President of the Personal Data Protection Office.

9. Right to withdraw consent – where data is processed based on your consent, you have the right to withdraw the consent at any time. The withdrawal of consent does not affect the lawfulness of processing of your personal data before its withdrawal.

Recipients of personal data

Your personal data may be transferred to third parties whose services we use in connection with the operation of https://training.lotams.com and our social media profiles. We carefully select the entities we work with or whose services we use, and always seek to ensure adequate data protection.

Below you will find a list of all the entities whose services we use. They are divided into two groups: the first one includes entities that process data outside the European Economic Area, and the second group is made up of entities that process data outside the European Economic Area (e.g. in the USA).

If personal data is transferred outside the European Economic Area, entities that carry out such processing ensure an adequate level of data protection in accordance with EU standards by, among other things, applying standard contractual clauses adopted by the European Commission.

Processors in the European Economic Area:

Hi GRUPA sp. z o.o. sp. k. with its registered office at ul. Bokserska 2/13, 02-682 Warsaw, Poland, entered in the Register of Entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, 13th Commercial Division of the National Court Register, under number KRS 0000558002, Industry Identification Number (REGON): 361540544, Tax Identification Number (NIP): 9512392829.	Entity that provides IT system maintenance and hosting (maintaining data on a server) services.
Przelewy 24 – PayPro SA (PayPro), with its registered office at ul. Pastelowa 8, 60-198 Poznań, Poland, entered in the Register of Entrepreneurs of the National Court Register kept by the District Court for Poznań Nowe Miasto i Wilda, 8th Commercial Division of the National Court Register, under number KRS 0000347935, holding Tax Identification Number (NIP): 7792369887, with a share capital of PLN 5,476,300.00, fully paid up, and in the register of national payment institutions kept by the Polish Financial Supervision Authority under number UKNF IP24/2014.	Provider of fast online payments.
MailerLite Limited, an Irish registered company at Ground Floor, 71 Lower Baggot Street, Dublin 2, D02 P593, Ireland	Newsletter provider.

Processors outside the European Economic Area:

Google Analytics	Marketing tool.
Facebook – Meta Platforms Ireland Limited (previously: Facebook Ireland Limited)	A social networking website that enables professional and business networking.
Instagram – Meta Platforms Ireland Limited (previously: Facebook Ireland Limited)	A social networking website that enables professional and business networking.
LinkedIn	A social networking website that enables professional and business networking.
Moodle.org	E-learning platform.

Requirement to provide your personal data

Although the provision of personal data is voluntary and depends on your decision, the provision of certain personal data is necessary to meet your expectations regarding the conclusion of an agreement or using our services. If you place an order for a product – the provision of your data is necessary to fulfil your requests related to the agreement.

If you contact us on any matter related to the website, our products or services, the provision of your contact details may be necessary to reply to your inquiry.

If the requirement to provide your personal data arises from the law, it is your obligation to provide your personal data.

Automated decision-making and profiling

We do not use your personal data for automated decision-making that could affect your legal situation or have other similarly significant impact on you.

The tools implemented as part of the website may profile user behaviour in order to improve the website and adjust the content displayed to the user’s preferences, in which case anonymous data (location, age, interests) is mostly analysed.

We use cookies and analytics tools just like any website. In the following section of the Privacy Policy we describe how cookies work and how these operations affect you.

How long do we process your data?

In accordance with applicable laws, we process your personal data only for the period necessary to achieve the defined purpose. After this period, your personal data will be irreversibly deleted or destroyed. The additional year associated with the processing of personal data collected for the performance of an agreement is due to the fact that you may send the notification just before the period of limitation expires.

We process your personal data:

for 3 or 6 years + 1 year	in the case of personal data processed for the purpose of establishment, exercise or defence of legal claims; the decision whether 3 or 6 years apply depends on whether both parties are entrepreneurs;
until an objection is effectively lodged or the purpose of the processing is achieved	in the case of personal data processed based on a legitimate interest of the controller;
until personal data is no longer valid or useful	in the case of personal data processed primarily for the purpose of website administration;
until your consent is withdrawn or no longer useful	in the case of personal data processed based on your consent, unless explicitly indicated otherwise at the time of giving the consent.

Social media

We maintain profiles on social media platforms and our website includes plug-ins for redirecting users to them.

We administer the profile on a given platform and we process your data (first name, surname, alias, other data indicated by you on your profile) mainly for the purpose of managing our profile, building a community and interacting with followers.

The provider of a given social media platform determines the rules applicable to the platform and the rules of data processing for its own purposes, so we encourage you to read the rules and policies of each platform. We do not process personal data collected by social media platforms for their own purposes.

The plugins redirecting to our profiles allow you to connect directly to our profile by clicking on the platform icon. The social media platform may acquire information about your use of our website, particularly when you are logged in as a user of the website.

If you do not want social networks to obtain information about your activities, we recommend logging out of your profiles and using your browser in incognito mode.

On our website you will find plugins that redirect you to our profiles on the platforms indicated below, and we also indicate the privacy policies of the platforms so that you can read them as recommended by us:

Facebook: https://www.facebook.com/profile.php?id=100095177145358

Instagram: https://www.instagram.com/lotams_trainings/
YouTube: https://www.youtube.com/channel/UCPG-diigmuo8aN8zSmc89Hw

LinkedIn: _ https://www.linkedin.com/company/lotams-trainings/about/

Newsletter

Your personal data provided in the newsletter subscription form (first name, surname) is processed for the purpose of sending the newsletter and based on your consent. Remember to confirm your subscription to our newsletter after you receive the first e-mail.

We engage a newsletter provider that ensures the protection of your data, i.e. . MailerLite Limited, an Irish registered company at Ground Floor, 71 Lower Baggot Street, Dublin 2, D02 P593, Ireland (the provider’s privacy policy is available at: https://www.mailerlite.com/legal/privacy-policy) The provider’s system records your activity related to your subscription to our newsletter.

Your personal data will not be transferred to a third country outside the European Union for the purpose of sending the newsletter. Although the provision of personal data in the newsletter subscription form is voluntary, it is necessary for sending you the newsletter based on your consent, as well as for sending you a notice of marketing of our own products or services based on our legitimate interest as the controller (i.e. Art. 6.1.f) of the GDPR) and for the exercise of any legal claims in connection with sending the newsletter.

You will continue to receive our newsletter until you end your subscription or we terminate the newsletter service. If a subscriber is inactive for 1 year, we may stop sending the newsletter, in which case we will remove you from our list of subscribers.

The mechanism for unsubscribing from the newsletter service is not complex and consists of clicking on an active link with the wording Unsubscribe from the newsletter. Once you exercise this right and unsubscribe from the newsletter, your data related to newsletter subscription will be stored for the period necessary to defend against any legal claims. It is our legitimate interest as a data controller.

We may transfer the personal data provided by you when signing up for the newsletter to the following entities: the IT system maintenance and hosting service provider, the e-mail service provider, the newsletter service provider and third parties supporting us in sending the newsletter, with whom we have entered into relevant agreements.

As in any case where we process your personal data, you have the right to access your personal data, to receive its copy, the right to its rectification, erasure, restriction of processing, the right to data portability, the right to lodge an objection and the right to withdraw your consent at any time.

However, remember that if you withdraw your consent to the processing of your personal data, it will not affect the lawfulness of data processing based on consent before its withdrawal.

You also have the right to file a complaint with the President of the Personal Data Protection Office, if you recognise that the processing of your data violates the law. Your personal data will not be processed in an automated manner.

Withdrawal of consent for data processing

If the processing of personal data is based on your consent, you may withdraw that consent at any time – at your discretion. If you would like to withdraw your consent to the processing of your personal data, all you need to do is send an e-mail directly to the controller’s address indicated at the beginning of this document.

If the processing of your personal data was carried out based on your consent, its withdrawal does not mean that the processing of your personal data up to that point was unlawful. In other words, until you withdraw your consent, we have the right to process your personal data and its withdrawal does not affect the lawfulness of the processing prior to such withdrawal.

Cookies and tools used on the website

This website, like many others, uses cookies. Cookies are short pieces of text information stored on the device that you use to view websites. Cookies can be processed by us (“own cookies”, which we use to ensure the proper operation of this website and improve our offer) and by systems of other entities whose services we use (“third-party cookies”). Remember that you have the right to change your cookie settings in your browser or to delete them.

During your first visit to the website, you are shown information related to the use of cookies.

Our website uses the following tracking technologies:

social plugins that redirect users to our social media profiles, referred to above
analytics and marketing tools, such as Google Analytics, META (Facebook) Pixel.
META (Facebook) Pixel

META (Facebook) Pixel is an analytics tool, a piece of code implemented on the website that allows us to address marketing activities to people who have visited our website or are interested in our activities.

The data collected as part of the tool is anonymous (location, gender, age, activity in the internet), but the provider may combine it with data it collected about you during your use of its platform.

META (Facebook) Pixel helps us determine the effectiveness of our ads, reach a specific group of customers and shows their reactions to our activities.

Read more about the tool on the provider’s website:
https://pl-pl.facebook.com/business/help/742478679120153?id=1205376682832142.

Google Analytics

Google Analytics makes it possible to analyse online services and activities. Google Analytics uses cookies, which are stored on your computer and enable an analysis of your use of the website.

You have the option to disable cookies by making the appropriate settings in your browser. However, there is a risk that you will lead to a situation where you will not be able to fully use all of the website’s features.

The data collected as part of the tool is anonymous (location, gender, age, activity in the internet), but the provider may combine it with data it collected about you during your use of its browser and/or services.

We use Google Analytics to analyse the use of the website by its users and to improve the website performance to match users’ preferences. Thanks to the obtained statistics, for example, we can modify our offer.

Detailed information on Google Analytics is available by clicking on the link: https://analytics.google.com/analytics/web/provision/?hl=pl#/provision.

Google declares that it uses data protection and security mechanisms defined by European legislation. Detailed information on data protection by Google is available in the link: https://policies.google.com/privacy?hl=pl.

Content from external websites

On the website we may post content from external websites, such as audiovisual or audio recordings, and such websites may record information about your playback of such content. If you have an account with a particular service, we recommend that you log out of it before playing content on our website, if you do not want the service to know about it.

Server logs

Using our website involves sending requests to the server on which the website is hosted.

Each request to the server is recorded in server logs, which include, for example: the IP address, the date and time of the server, information about the web browser and the operating system you are using.

The data recorded in the server logs is not associated with specific users of the website and is used as support material for administrative purposes.

The contents of the server logs are not disclosed to anyone except persons authorised to administer the server.

Final Provisions

Materials posted on this website are the controller’s own intellectual creation and are subject to legal protection.

Use of the content provided other than the permitted personal use may result in the risk of criminal and civil liability.

If you have any doubts about the legal nature of the provided content or how you can legally use it, please contact us by e-mail (the e-mail address is indicated at the beginning of this document) and we will give you a comprehensive answer.

Also, remember that the provided content is educational and does not constitute or replace individual expert advice.

Finally, we would like to remind you that the content of this Privacy Policy is subject to change, for example when we change a service provider or the scope of functionalities on the website. For your convenience, the date of update of this Privacy Policy is stated at the beginning.

That’s all we have to share with you now.

Thank you for your time.

Privacy and cookies policy

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training@lotams.com

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