Effective date: July 8,
1.1 At CAE, your privacy is important to us. This
statement sets out our privacy practices with respect to the collection, use
and disclosure of personal information with respect to the use and access to
the elearning content of the bombardieratp.cae.com website (the “Application”).
1.2 The Application may contain links that take you to third
party web sites or applications and may also host courseware delivered by third
parties. This privacy statement does not extend to the data collection
practices of third parties and CAE does not assume any responsibility for the
privacy practices, policies or actions of third parties. You should read the
individual privacy policies and/or legal notices of third parties and make an
informed decision as to whether or not you wish to use their content or sites
based on their privacy practices.
Personal data means data or
information about an identifiable person, recorded in any form. When you
interact with us on our Application, you may be asked to provide and disclose
personal data such as your name, e-mail address and mailing address, telephone
number and other similar contact information, as the case may be. Furthermore,
for courses managed by CAE, CAE processes your training performance &
CAE processes your personal data
to provide you with the requested training services effectively, or to enable
you to use certain features of Application, and to comply with applicable laws.
The training for which you access the
Application may be under your or your employer's training contract with CAE,
for which you are considered the ultimate beneficiary of the training services,
therefore, the processing of your personal information is deemed to be in your
interest also. The processing is supported by means of analytical procedures.
In relation to this
processing of personal data, the purpose includes:
facilitate or improve your training;
• to perform various analyses and
research, and to create various dashboards and databases of instructor and
trainee performance data. Such data may be provided to your employer and
(subject to the data being anonymous, or rendered anonymous) to other air
operators, aviation authorities or aviation trade associations;
• to carry out, manage and/or maintain
our relationship with you and to manage communications and other dealings. In
this respect your personal data is shared with affiliated companies;
invoice and process payments;
respond to inquiries or complaints;
1.5 For the benefit of CAE’s legitimate interests in
rendering quality training services in compliance with applicable legislation,
having duly considered your interests, CAE further processes personal data for
the purpose of:
• to test, develop or improve our
• to inform you about our additional
services for your future benefit (“direct marketing”); and
• to detect, record and deter unruly
behavior and unlawful acts.
CAE will only
process your personal data in accordance with current laws.
The Application may contain
marketing information. CAE may collect information as to which Content you
access. This information is used internally, only in aggregated and anonymized
form, to better serve you and other users by helping CAE manage its
Application, diagnose any technical problems and generally improve the
Application and Content.
1.7 CAE will never disclose, share, sell or lease to any
third party other than our affiliated companies, business and joint venture
partners (“Affiliates”), and to professional subcontractors involved in
the administration or performance of training services (like in connection with
CAE’s training performance grading) or for storage in the cloud, either free of
charge or for remuneration, any personal information that you provide through
this Application, without your permission, unless we are required to do so by
law and except as described in sections
1.8 – 1.10 below.
CAE may disclose personal data to
respond to legal requirements (e.g. regarding audits, inspections or
investigations by, or consultations with, competent authorities), enforce its
corporate policies, respond to claims or protect anyone's vital interests.
Disclosure will be in accordance with the applicable laws and regulations on
personal data protection (“Regulations”).
1.9 If our customer is your employer, then necessary parts
of your personal data will also be made available to your employer.
1.10 Should CAE merge with or be acquired by another
business entity, CAE may share personal data with the other company and its
respective advisors. The acquirer or the new combined entity will be required
to follow this Privacy Statement.
1.11 If you submit an inquiry through this Application, any
personal data you might submit at that time will only be used by employees,
representatives or agents of CAE, its Affiliates or third parties who need to
have access to it in order to respond to your inquiry, to provide the requested
services (including newsletters/marketing), for proper administration
(including storage in the cloud).
1.12 Note that CAE will only share your personal data with
third parties or Affiliates if they are established in a country with an
adequate data protection level (like so-called safe harbor countries) or if
such entity has signed a contract with CAE for processing personal data in
compliance with respective data protection laws. Further information can be
provided by CAE upon request.
1.13 Except as otherwise mentioned herein, CAE shall not
disclose your personal data to any third party without your consent.
1.14 CAE is committed to ensuring that your personal data
is stored securely and only accessible by authorized persons. Your personal
data will only be transferred to other parties in accordance with this Privacy
Statement, following the implementation of appropriate technical and
organizational measures in compliance with the Regulations. Nonetheless, there
are third parties that may unlawfully try to access systems or intercept
transmissions or communications containing personal data. CAE continuously uses
its reasonable efforts in line with industry standards to protect your personal
data but cannot absolutely guarantee that such unlawful actions will not occur.
Consequently, CAE bears no liability for the use that may be made of the
information by any third party. CAE has in place an adequate data breach
1.15 CAE will only store your personal data for the
duration necessary for the Purpose, in connection with the Application, and in
a manner permitted by the Regulations or other applicable laws.
1.16 You - as the individual whose personal data CAE
processes - have the right to request access to your personal data held by CAE,
request (e.g. for transfer to another IT environment) for a copy of such
personal data, and to request to update or correct it. You also have the right
to object to the processing of your personal data by CAE, to request CAE to
restrict its processing or to request to erase it, pursuant to applicable data
protection laws. CAE will respond to all such request in accordance with the
applicable data protection laws.
If you believe that the processing
of your personal data by CAE is not compliant with applicable Regulations or if
CAE does not respond to your requests in a timely or adequate manner, you have
the right to lodge a complaint with the competent authority for the protection
of personal data, in accordance with the data protection laws that apply to
at CAE Inc. c/o Bombardier ATP Training, 8585 Côte de Liesse, St-Laurent H4T 1G6,
CAE reserves the right to change
this Privacy Statement as it sees fit and without prior notice. However, we
will ensure that any change to this statement is in compliance with the
Regulations and posted on this Application. We encourage you to refer back to
this Privacy Statement regularly.
© CAE Inc. 2019. All