ATSimTest Privacy Policy
Effective as of 25 May 2018
Table of Contents
- Introduction
- About this Policy
- Your rights and your preferences: Giving you choice and control
- How do we collect your personal data?
- What personal data do we collect from you?
- What do we use your personal data for?
- Sharing your personal data
- Data retention and deletion
- Transfer to other countries
- Links
- Keeping your data safe
- Children
- Changes to this Privacy Policy
- How to contact us
1. Introduction
Thanks for using ATSimTest!
At ATSimTest, we want to help you manage your VATSIM career and improve your skills. To do this we provide you with ATSimTest as a voluntary service. That said, your privacy and the security of your personal data is, and will always be, enormously important to us. So, we want to transparently explain how and why we gather, store, share and use your personal data - as well as outline the controls and choices you have around when and how you choose to share your personal data.
That is our objective, and this Privacy Policy (“Policy”) will explain exactly what we mean in further detail below.
2. About this Policy
This Policy sets out the essential details relating to your personal data relationship with ATSimTest. The Policy applies to all ATSimTest services and any associated services (referred to as the ‘ATSimTest Service’). The terms governing your use of the ATSimTest Service are defined in our Terms and Conditions of Use (the “Terms and Conditions of Use”) and the applicable VATSIM Policy documents (including, but not limited to, the VATSIM Code of Conduct, Code of Regulations, and User Agreement).
From time to time, we may develop new or offer additional services. If the introduction of these new or additional services results in any change to the way we collect or process your personal data we will provide you with more information and additional terms or policies. Unless stated otherwise when we introduce these new or additional services, they will be subject to this Policy.
The aim of this Policy is to:
- Ensure that you understand what personal data we collect about you, the reasons why we collect and use it, and who we share it with;
- Explain the way we use the personal data that you share with us in order to give you a great experience when you are using the ATSimTest Service; and
- Explain your rights and choices in relation to the personal data we collect and process about you and how we will protect your privacy.
For information on how to contact us if you ever have any questions or concerns, please see the ‘How to Contact Us’ Section 14 below. Alternatively, if you do not agree with the content of this Policy, then please remember it is your choice whether you want to use the ATSimTest Service and VATSIM in general.
3. Your rights and your preferences: Giving you choice and control
You may be aware that a new European Union law, called the General Data Protection Regulation or "GDPR" gives certain rights to individuals in relation to their personal data. Accordingly, we have implemented additional transparency and access processes in our service to help users take advantage of those rights. As available and except as limited under applicable law, the rights afforded to individuals are:
- Right of Access - the right to be informed of and request access to the personal data we process about you;
- Right to Rectification - the right to request that we amend or update your personal data where it is inaccurate or incomplete;
- Right to Erasure - the right to request that we delete your personal data;
- Right to Restrict - the right to request that we temporarily or permanently stop processing all or some of your personal data;
- Right to Object -
- the right, at any time, to object to us processing your personal data on grounds relating to your particular situation;
- the right to object to your personal data being processed for direct marketing purposes;
- Right to Data Portability - the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and
- Right not to be subject to Automated Decision-making - the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
In order to enable you to exercise these rights with ease and to record your preferences in relation to how ATSimTest uses your personal data, we provide you with access to the following privacy controls:
- The VATSIM Membership Dashboard - allows you to control some of the categories of personal data VATSIM, and we, process about you, and includes a link to the Privacy Policy on VATSIM.net where you can find out more information about how VATSIM and ATSimTest uses your personal data and what your rights are; and,
- The Contact Us page - allows you to request correction, deletion, and access to your personal data by sending a request to us.
If you have any questions about your privacy, your rights, or how to exercise them, please contact us using the ‘Contact Us’ form on the ATSimTest site. We will respond to your request within a reasonable period of time upon verification of your identity. If you are unhappy with the way we are using your personal data you can also contact and are free to lodge a complaint with the German Data Protection Authority (Bundesbeauftragter für den Datenschutz und die Informationsfreiheit) or your local Data Protection Authority.
4. How do we collect your personal data?
We collect your personal data in the following ways:
- When you sign up for the VATSIM Service - when you sign up to VATSIM, they collect certain personal data and provide that data to ATSimTest, so you can use the ATSimTest Service, such as your email address, age group, and country.
- Through your use of the ATSimTest Service - when you use the ATSimTest Service, we collect personal data about your use of the ATSimTest Service, such as what tests you have requested and the results of these tests.
- From third parties - we will receive personal data about you and your activity from Google through use of the Google Analytics service. Note that we do not use Google Analytics if your browser transmits the "Do Not Track" flag to ATSimTest. Please see the documentation of your browser about details on how to enable this feature. You can learn more about how Google Analytics processes your data at https://policies.google.com/technologies/partner-sites.
- Cookies - ATSimTest requires Cookies to work. Cookies are small bits of information that are stored by your browser and re-transmitted to a website to identify a user throughout a session. Although you can disable Cookies in your browser, ATSimTest will not work without them.
We use anonymised and aggregated information for purposes that include testing our IT systems, research, data analysis, improving the ATSimTest Service, and developing new features and functionality within the ATSimTest Service.
5. What personal data do we collect from you?
We have set out in the tables below the categories of personal data we collect and use about you:
Personal data collected when you signed up for the VATSIM Service
| Categories of personal data | Description of category |
|---|---|
| VATSIM Account Data | This is the personal data that is provided by you to VATSIM to enable you to sign up for and use the VATSIM service and use the ATSimTest Service. This includes your name, email address, country and state, age group, controller rating, VATSIM region, division, and VACC membership, and the date you joined VATSIM. This data is provided to us by VATSIM. |
Personal data collected when you use the ATSimTest Service
| Categories of personal data | Description of category |
|---|---|
| Test Data | This is the information that is generated when you request a test to achieve a higher VATSIM rating. It contains your VATSIM ID, the requested test, the date when you requested the test, the test results, and some status information about the progress of your test. |
| Controller Rating | This data is the information about the progress of your rating and achievements obtained by using ATSimTest. |
| Authorization Data | This applies only if you are a VATSIM staff member or ATSimTest staff member. It includes information about your authorization level within ATSimTest. |
6. What do we use your personal data for?
When you use or interact with the ATSimTest Service, we use a variety of technologies to process the personal data we collect about you for various reasons. We have set out in the table below the reasons why we process your personal data, the associated legal bases we rely upon to legally permit us to process your personal data, and the categories of personal data (identified in Section 5 ‘What personal data do we collect from you?’) used for these purposes:
| Description of why ATSimTest processes your personal data (‘processing purpose’) | Legal Basis for the processing purpose | Categories of personal data used by ATSimTest for the processing purpose |
|---|---|---|
| To provide the ATSimTest Service. | Performance of a Contract | Account Registration Data Service Usage Data |
7. Sharing your personal data
We have set out the categories of recipients of the personal data collected or generated through your use of the ATSimTest Service.
Publicly available information
No data collected, processed or generated by ATSimTest will be publicly available.
Personal data shared with third parties
| Shared information | Categories of Recipients | Reason for sharing |
|---|---|---|
| VATSIM account data | VATSIM staff members and ATSimTest staff members | To enable us to provide the ATSimTest service to you |
| Test data | VATSIM staff members and ATSimTest staff members | To enable us to provide the ATSimTest service to you |
We do not share any of your data with anybody outside the VATSIM organisation.
8. Data retention and deletion
We keep your personal data only as long as necessary to provide you with the ATSimTest Service and for legitimate and essential operational purposes, such as maintaining the performance of the ATSimTest Service, and providing staff with a history of your rating progress in VATSIM.
If you request, we will delete or anonymise your personal data so that it no longer identifies you, unless, we are legally allowed or required to maintain certain personal data, including situations such as the following:
Where necessary for our legitimate operation interests such as fraud prevention or to maintain the security of our users.
9. Transfer to other countries
ATSimTest shares your personal data globally with ATSimTest staff and VATSIM staff in order to carry out the activities specified in this Policy. This includes to ATSimTest staff members in all countries where VATSIM is operating, inside and outside of the European Union. Your personal data, therefore, may be subject to privacy laws that are different from those in your country of residence.
Personal data collected within the European Union and Switzerland may, for example, be transferred to and processed by third parties located in a country outside of the European Union and Switzerland. In such instances ATSimTest shall ensure that the transfer of your personal data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organisational measures are in place such as the Standard Contractual Clauses approved by the EU Commission.
For further details of the security measures we use to protect your personal data, please see the ‘Keeping your personal data safe’ Section 11 of this Policy.
10. Links
We may display content that links to third-party websites. We cannot control or be held responsible for third parties’ privacy practices and content. If you click on a third-party advertisement or link, please understand that you are leaving the ATSimTest Service and any personal data you provide will not be covered by this Policy. Please read their privacy policies to find out how they collect and process your personal data.
11. Keeping your personal data safe
We are committed to protecting our users’ personal data. We implement appropriate technical and organisational measures to help protect the security of your personal data; however, please note that no system is ever completely secure. We have implemented various policies including pseudonymisation, encryption, access, and retention policies to guard against unauthorised access and unnecessary retention of personal data in our systems.
Your VATSIM password protects your user account, so we encourage you to use a unique and strong password, limit access to your computer and browser, and log out after having used the ATSimTest Service.
12. Children
The ATSimTest Service is not directed to children under the age of 13 years. However, in some countries, stricter age limits may apply under local law. Please see our Terms and Conditions of Use for further details.
We do not knowingly collect personal data from children under 13 years or under the applicable age limit (the “Age Limit”). If you are under the Age Limit, please do not use the ATSimTest Service, and do not provide any personal data to us.
If you are a parent of a child under the Age Limit and become aware that your child has provided personal data to ATSimTest, please contact us using the ‘Contact Us’ form, and you may request exercise of your applicable rights detailed in the ‘Your rights and your preferences: Giving you choice and control’ Section 3 of this Policy.
If we learn that we have collected the personal data of a child under the age of 13 years, we will take reasonable steps to delete the personal data. This may require us to delete the ATSimTest account for that child.
13. Changes to this Privacy Policy
We may occasionally make changes to this Policy.
When we make material changes to this Policy, we’ll provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the ATSimTest Service or by sending you an email. We may notify you in advance.
Please, therefore, make sure you read any such notice carefully.
14. How to contact us
Thank you for reading our Privacy Policy. If you have any questions about this Policy, please contact us by using the ‘Contact Us’ form on the Privacy Center or by writing to us at the following address:
Frank Bitterlich, Günter Schmidt GmbH, Ben-Gurion-Ring 21, 60437 Frankfurt, Germany
Frank Bitterlich is the data controller for the purposes of the personal data processed under this Policy.
We hope you enjoy ATSimTest!
© Frank Bitterlich.
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