AvA Privacy Policy

  1. Background and Acceptance of this Privacy Policy
  1. AvA and AvA+ are online learning services (Services) offered to end users (You and Your) by Silicon Sky Limited (We, Us and Our).
    1. You can access Our Services:
    1. on applications (Apps) via various operating systems on Your mobile phone or other mobile devices; or
    1. at Our Website https://www.silicon-sky.com (Website).
    1. When You interact with Our Website or Apps, We collect information that, alone or in combination with other information, could be used to identify You (Personal Data).
    1. This Privacy Policy explains:
  2. what Personal Data We collect when You use Our Website/Services (Your Personal Data);
  3. how We may use and share Your Personal Data; and
  4. Your choices concerning how We use Your Personal Data.
    1. This Privacy Policy forms part of Our Terms of Use, which are available at https://www.Silicon-Sky.com/terms/.
    1. By using the Website/ Services, You are providing consent for Us to process Your Personal Data as described in this Privacy Policy.
  • Personal Data That We Collect
  • When You sign up for the Services: You voluntarily give Us Personal Data including Your name and email address.
    • If You buy a subscription or licence for the Services: You may be asked to provide payment information (including payment card number, security code associated with the card, expiry date), to one or more of Our payment service providers.
    • When You use the Services: You may generate learning data such as test answers, learning scores, and progress within a course, which We will collect and store for use solely in connection with the Services.
    • When You complete any “free text” boxes in Our forms: We also collect information that You provide (for example, support requests or survey submissions) and Personal Data disclosed by You on Our forums, blogs and Our other areas of the Services to which You can post information and materials.
  • Automatically Collected Data

When You use the Website/Services, the following information is created and automatically logged in Our systems:

  • Log Data: Information that Your browser automatically sends whenever You visit the Website, or that the Apps automatically send when You use them. Log Data includes Your Internet Protocol (IP) address (so We understand which country You are connecting from when You visit the Website or use the Services etc), browser type and settings, the date and time of Your request, and how You interacted with the Website/Services;
    • Cookies: Information from cookies and other technologies stored on Your device.
    • Device information: Includes type of device You are using, operating system, settings, unique device identifiers, network information and other device-specific information.
    • Usage Information: We collect information about how You use Our Website/Services, such as the types of content that You view or engage with, the features You use, the actions You take, the other users You interact with and the time, frequency and duration of Your activities.
  •  How We Use Your Personal Data

We will use Your Personal Data:

  • To authenticate that You are the registered user; provide You with the Services; process Your transactions and respond to Your requests.
  • For Our Legitimate Business Interests, including:
    • Customising the learning experience and degree of difficulty;
    • Understanding how You interact with Our Website/Services;
    • Adapting Our Website/ Services so that they are presented in the most effective manner for You, and as part of Our efforts to keep Our Website/ Services, network and information systems secure.
    • Conducting analytics to inform Our marketing strategy and to enable Us to enhance and personalise Our communications and the experience We offer to Our users.
    • Conducting or assisting research and prepare scholarly papers. We may share the information We collect in anonymised and de-identified form with researchers who help Us to improve the Website/Service’s learning tools. We may also use such information to publish papers on aviation communication  learning.
    • Marketing. We may send You updates and information about Our new products and services, upcoming events or other promotions or news by email or push notification. Where required by law, We will only send You marketing information if You consent to Us doing so at the time You provide Us with Your Personal Data. You may opt out of receiving such emails by following the instructions contained in each promotional email We send You or by updating Your user settings. We will continue to contact You via email regarding the provision of our Services that you have purchased and to respond to Your requests.
  • Deleting and Amending Your Personal Data

5.1         If You ask Us to delete Your Personal Data or to be removed from Our marketing lists We will only keep the most basic data to identify You and prevent further unwanted processing by Us.

  • We may anonymise, de-identify and/or aggregate the information that We collect (such that it no longer constitutes Personal Data) and use such anonymised, de-identified and/or aggregated data for commercial, statistical and market research purposes, including sharing it with affiliates and business partners.
    • If You need to change or correct Your Personal Data You may do so via your user settings.  

6.                Sharing and Disclosing Your Personal Data

We may share Your Personal Data and other information with certain third parties in the following circumstances:

  • Vendors and Service Providers: To assist Us in providing the Services, Your Personal Data may be shared with third-party providers of hosting, email communication and customer support services, analytics, marketing, advertising (including Amazon Web Services and Google, both certified to the Privacy Shield). Following Our instructions, these third parties may access, process or store Your Personal Data in the course of performing their duties for Us.
    • Business Transfers: If We are involved in a merger, acquisition, financing due diligence, reorganisation, bankruptcy, receivership, sale of all or a portion of Our assets, or transition of a service to another provider, Your Personal Data and other information may be transferred to Our successor or affiliate as part of that transaction.
    • Legal Requirements: If required to do so by law or applicable regulation to:
  • comply with a legal obligation;
  • protect and defend the rights or property of Silicon Sky;
  • act in urgent circumstances to protect the personal safety of users of the Website or the Apps, or the public; or
    • protect Silicon Sky against legal liability.If you give Us specific consent, We may permit other users of the Services to see the profile information You upload to the Services including courses, learning scores and users you are following.

7.            Data Retention

We will keep Your Personal Data for whichever is the longer of:

7.1         as long as reasonably necessary for the purposes described in this Privacy Policy (including whilst We have a Legitimate Business Need to do so); and

7.3         as required by law (e.g. for tax, legal, accounting or other purposes).

8.            Rights Under English Law

  • Data Controller.  Silicon Sky Limited is the Data Controller for Your Personal Data.

8.2         Legitimate Interests means Our interests in conducting Our business, including managing and delivering the best Services to You. This Privacy Policy describes when We process Your Personal Data for Our Legitimate Interests; what these interests are and Your rights. We will not use Your Personal Data for activities where the impact on You overrides Our Legitimate Interests, unless We have Your consent or those activities are otherwise required or permitted by law.

8.3         Your Rights under English law: You have the following rights in relation to Your Personal Data:

  • Right of Access: If We are Processing your Personal Data. You can request a copy of that Personal Data here.
  • Right to Correct: If Your Personal Data is inaccurate or incomplete, You are entitled to ask that We correct or complete it. If We have shared Your Personal Data with third parties as part of Our Legitimate Interest, We will tell them about the correction where possible. If You ask Us in writing, and where possible and lawful to do so, We will also tell You with whom we shared your Personal Data so You can contact them directly.
  • Right to Delete: You may ask us to erase Your Personal Data in some circumstances. If We shared Your data with others, We will alert them to the need for erasure where possible. If You ask Us, and where possible and lawful to do so, We will also tell You with whom We shared Your Personal Data with so You can contact them directly.
  • Right to Restrict processing: You may ask us to restrict or‘block’the processing of Your Personal Data in certain circumstances, such as where You contest the accuracy of the data or object to Us processing it. We will tell You before We lift any restriction on processing. If We shared Your Personal Data with others, We will tell them about the restriction where possible. If You ask Us, and where possible and lawful to do so, We will also tell You with whom We shared Your Personal Data so You can contact them directly.
  • Right to obtain a copy: You have the right to obtain Your Personal Data from Us that You consented to give Us or that was provided to Us as necessary in connection with Our contract with You. We will give You Your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
  • Right to Object: You may ask Us at any time to stop processing Your Personal Data, and We will do so:
    • if We are relying on a Legitimate Interest to process Your Personal Data — unless We demonstrate compelling legitimate grounds for the processing; or
    • if We are processing Your Personal Data for direct marketing.
    • Rights related to automated decision-making and profiling: You have the right to be free from decisions based solely on automated processing of Your Personal Data, including profiling, unless this is necessary in relation to a contract between You and Us or You provide Your explicit consent to this use.
  • Right to withdraw consent: If We rely on Your consent to process Your Personal Data, You have the right to withdraw that consent at any time, but this will not affect any processing of Your Personal Data that has already taken place.
  • Right to lodge a complaint with the data protection authority: If You have a concern about Our privacy practices, including the way We handled Your Personal Data, You can report it to the data protection authority that is authorised to hear those concerns.
  • Changes. We will notify You of changes to the data processing activities described in this Privacy Policy by posting a prominent notice on the Website or the Apps or as otherwise required by law.

9.            Publicly Posted Information

This Privacy Policy shall not apply to any information You post to the public areas of the Website/Services. This includes, but is not limited to, comments on the AvA blog or public forums. Comments posted to public areas may be viewed, accessed, and used by third parties.  

10.         Links to Other Websites

The Website and the Apps may contain links to other websites not operated or controlled by Us, including social media websites and services (Third Party Sites). The information that You share with Third Party Sites will be governed by the specific privacy policies and terms of such Third Party Sites and not by this Privacy Policy. By providing these links We do not imply that We endorse or have reviewed these sites.

11.         Security

We take reasonable administrative and technical steps to protect the Personal Data from loss, misuse and unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the internet is 100% secure. Therefore, while We strive to protect Your Personal Data, We cannot guarantee its absolute security.

12.         Cookies

The Website uses cookies and other technologies to make it easier for You to use the Website/Services during future visits, monitor traffic on Our Website/ Services or Apps and to personalize instructional content. For more information, please refer to Our Cookie Policy.

13.         Changes to Our Privacy Policy

We may change this Privacy Policy at any time and, when We do, We will post an updated version on this page. By continuing to use the Website and the Apps or providing Us with information after We have posted an updated Privacy Policy You consent to the revised Privacy Policy and practices described in it.

14.         Contact Us

If You have any questions about Our Privacy Policy, please contact Us at Privacy@silicon-sky.com