Effective date: February 14 , 2023
AXES ATARAH S.R.L. (“us”, “we”, or “our”) operates the https://aviothic.ro/ website (the “Service”).
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.
About this Policy
Personal data we collect about you
These tables set out the categories of personal data we collect and use.
Information you provide to us when you sign up for the Services, update your account, or use the Services
|User Data & Identifiers||Personal data that we need to create your account and that enables you to use the Services.|
The specific types of information we collect will depend upon the Services you use, how you use them, and the information you choose to provide. The types of data we collect directly from you includes name, alias, email address, postal or billing address, zip code, account name, phone number, social media profiles, or other similar identifiers.
|Payment Information||If you sign up for free courses or to purchase courses, we collect certain data about your purchase (such as your name, billing address, and ZIP code) as necessary to process your order and which may be saved to process future orders. The exact personal data collected and used will vary depending on the payment method.|
You must provide certain payment and billing data directly to our payment service providers, including your name, credit card information, billing address, and ZIP code. Aviothic does not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.
|Instructor Payment Information||If you are an Aviothic Instructor, you can provide your payment account to the Services to receive payments through our third party service providers. When you provide a payment account, we collect and use certain information, including your payment account, name of the account holder, email address , physical address, or other data necessary for us to send payments to your account. In some instances, we may collect ACH or wire information to send payments to your account. In order to comply with applicable laws, we also work with trusted third parties who collect tax information as legally required. This tax information may include residency information, tax identification numbers, biographical information, and other personal information necessary for taxation purposes.|
|Other Information||Additional data you may choose to give us includes:|
– demographic information such as your gender or other information;
– user-generated content you provide to us, such as when you upload a project, upload courses and other educational content, leave a course review, ask or answer a question, or otherwise participate in a public discussion forum;
– information you provide when you participate in a survey or research study, including testimonials;
– participation in promotions, sweepstakes or contests, or other marketing promotions;
– Information you provide when you communicate with our customer support team; and
Information about others, including email address, for referral invitations.
Information automatically collected through your use of the Services
|Usage Data||When you use our Services, we collect and analyze:|
– technical data such as your IP address, browser types, browser language, operating system, software and hardware attributes (including device IDs), online identifiers such as – cookie data, referring and exit pages, and URLs;
– site usage patterns such as the number of clicks, mouse movements, scrolling, and time spent on a page;
– navigation data such as pages viewed and the order of those pages, date and time of use, session duration, and error logs;
– learning data such as content or courses watched, total minutes watched, and categories of courses you search for; and
– Other similar information.
We may use third-party providers to log your activity. This provides us with a set of data and a session replay of your activity on Aviothic. Third-party providers capture and analyze your usage data to help us make your Aviothic experience better.
|General (non-precise) location||Your general location includes country, region, or state. We may learn this from technical data (e.g. your IP address, language setting of your device) or payment currency.|
Information collected from partners and other third parties
|Third Party Services||If you link, connect, or login to the Services with a third party service (e.g. Google, Facebook, Instagram…), you direct the service to send us information such as your registration and profile information as controlled by that service or as authorized by you via your privacy settings at that service.|
|Payment partners||If you choose to pay through third parties or by invoice, we may get data from our payment partners. This allows us to send you invoices or process your payments.|
These sources vary over time, but could include:
– security service providers who provide us with information to secure our systems, prevent fraud, and help us protect the security of Aviothic accounts;
– payment service providers who provide us with payment or balance information, or updates to that information, based on their relationship with you;
– online and offline data providers, from which we obtain aggregated demographic, interest-based, and online advertising related data;
– publicly-available sources such as publicly available posts on social media platforms and information available through public databases associating IP addresses with internet service providers; and
– advertising or marketing partners from whom we receive inferences (i.e., their understanding) of your interests and preferences.
We may also receive additional information such as demographic and statistical information from third parties, including business partners, marketers, researchers, analysts, and other parties that we may attribute to you based on your assignment to certain statistical groups. We use this information to supplement the information that we collect directly from you in order to derive your possible interests, provide more relevant experiences for you, and improve our products, analytics, and advertising.
How we use the Personal Data we collect about you
We may use the information we collect about you for various purposes, including to provide, analyze, administer, enhance, and personalize the Services and marketing efforts, to process your subscription and your payments, to communicate with you on these and other topics, to evaluate and improve the Services, and to comply with legal obligations. For example, we use such information to:
- Create and manage your accounts and profiles;
- Personalize your content on the Services–this includes providing you access to your saved courses and course watch history, and providing course recommendations;
- Provide users and Instructors with features and functionality, including to facilitate participation in our content, courses and lessons; issue completion certificates, badges, or other credentials; or to facilitate social or community features, such as by identifying and suggesting connections with other users or Instructors of the Service and providing discussion boards, chat, or messaging functionality;
- Provide Instructors with information related to student engagement and minutes watched, referral earnings, and other analytical data to pay Instructors appropriately;
- Manage student and Instructor referrals;
- Secure our systems, prevent fraud, and help us protect the security of Aviothic accounts;
- Prevent, detect, and investigate potentially prohibited or illegal activities, including fraud, and to enforce our Terms of Service;
- Analyze and understand our audience (including to understand demographic patterns related to our community), improve our service (including our user interface experiences and service performance), and optimize content selection, algorithms, and delivery;
- Communicate with you concerning the Services so that we can send you news about Aviothic or our third party partners, details about new features and content available on Aviothic, special offers, promotional announcements, consumer surveys, and to assist you with operational requests such as password reset requests;
- Fulfill contractual obligations with third parties;
- Complete corporate transactions; and
- Fulfill any other purpose at your direction.
Disclosing your Personal Data
Affiliates and Subsidiaries
To support us in providing, integrating, promoting, and improving the Services, we may share personal information within our corporate family of companies that are related by common ownership or control.
With Your Consent or at Your Direction
Where you provide consent, we share your information as described at the time of consent, such as when authorizing a third-party application or website to access your Aviothic account or participating in promotional activities by Aviothic partners or third parties.
To facilitate interactions between our Instructors and users, we share with Instructors data that we have about users concerning educational content users access or request information about, so Instructors can improve their content for you and other students. This data may include things like your country, browser language, operating system, device settings, the site that brought you to Aviothic, and certain activities on Aviothic, like how many minutes you have watched.
Depending on your settings, your shared content and profile data may be publicly viewable, including to other students and Instructors. If you leave a review, ask a question, or post on a discussion board, your information (including your name) may also be publicly viewable. Note that within the Services, all discussion boards, groups, or other public forums available to participants are publicly visible to other participants. Accordingly, please take care when using these forums and do not post confidential or proprietary information through those features.
- Payment processors
- Fraud prevention service providers
- Providers of advertising services
- Ad networks and marketing tools
- Analytics service providers
- Engineering and development tools
- Staff augmentation and contract personnel
- Hosting service providers
Other Third Parties
We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:
- Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services), such as when users and Instructors interact through the Services;
- Social media services (if you interact with them through your use of the Services);
- Business partners who you access through the Services or that we engage to offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
We may offer joint promotions or programs that, in order for your participation, will require us to share your information with third parties. In fulfilling these types of promotions, we may share your name and other information in connection with fulfilling the incentive. Please note that these third parties are responsible for their own privacy practices.
From time to time, we may share aggregated or anonymous information about use of the Services, such as by publishing a report on usage trends.
Protection of Aviothic and others
We also share Personal Data when we believe it is necessary to:
- Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies;
- Protect us, our business, our users, and others, for example to enforce our terms of service, prevent spam or other unwanted communications, and investigate or protect against fraud;
Maintain the security of our products and services.
Legal Bases for Use of Your Information
We process Personal Data for, or based on, one or more of the following legal bases:
Performance of a Contract
We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties: first and last name, email address, location information, IP address, and your activity on the Services, including course usage information and community interaction data. Examples of these legitimate interests include: operation and improvement of our business, products, and services; personalization of web content on the Services; analyzing the use of the Services; marketing of our products and Services; provision of customer support; protection from fraud or security threats; compliance with legal obligations; and completion of corporate transactions.
In some cases, we process Personal Data based on the consent you expressly grant to us prior to the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you prior to the point and time of collection.
Other Processing Grounds
From time to time, we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
Retention of Your Information
We will retain your Personal Data for as long as your account is active or as needed to provide you services and to maintain a record of your transactions for financial reporting purposes. We will also retain and use your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Protection of Your Information
Aviothic takes technical and organizational security measures that are designed to safeguard Personal Data. However, no online activity is ever fully secure or error-free. While we strive to protect your information, we cannot guarantee that your Personal Data is absolutely secure. Please keep this in mind when disclosing any information to Aviothic.
Please recognize that protecting your Personal Data is also your responsibility. We urge you to take every precaution to protect your information when you are on the Internet, or when you communicate with us and with others through the Internet. Change your passwords often, use a combination of letters and numbers, and make sure you use a secure browser. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account might have been compromised), or if you suspect someone else is using your account, please let us know immediately by contacting us as indicated in the Contact section.
We use these technologies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences. Cookies are small text files that are placed on your computer or mobile device when you visit a site that enable us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv) enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions.
As we adopt additional technologies, we may also gather information through other methods. Please note that you can change your settings to notify you when a cookie is being set or updated or to block cookies altogether. For more information, please consult the “Help” section of your browser (e.g., Internet Explorer; Microsoft Edge; Google Chrome; Mozilla Firefox; or Apple Safari). Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Services.
The Services are not directed to children whose age:
- is under the age of 16 years;
- makes it illegal to process their personal data; or
- requires parental consent to process their personal data.
If you’re a parent of a child under the age of 16, as applicable, and become aware that your child has provided personal data to Aviothic, please contact us. If we learn that we’ve collected the personal data of a child under the age of 16, as applicable, we’ll take reasonable steps to delete the personal data. This may require us to delete the Aviothic account for that child.
Your rights vary depending on the laws that apply to you, but may include:
- The right to know whether, and for what purposes, we process your Personal Data;
- The right to be informed about the Personal Data we collect and/or process about you;
- The right to learn the source of Personal Data about you we process;
- The right to access, modify, correct, and delete Personal Data about you;
- The right to know with whom we have shared your Personal Data, for what purposes, and what Personal Data has been shared (including whether Personal Data was disclosed to third parties for their own direct marketing purposes);
- The right to withdraw your consent, where processing of Personal Data is based on your consent; and
- The right to file a complaint with a supervisory authority located in the jurisdiction of your habitual residence, place of work, or where an alleged violation of law occurred.
We may reject requests that are unreasonable or not required by law, including those that would be extremely impractical, could require disproportionate technical effort, or could expose us to operational risks such as free trial fraud. We may retain information as required or permitted by applicable laws and regulations, including to honor your choices, for our billing or records purposes, and to fulfill the purposes described in this Privacy Statement. We take reasonable measures to destroy or de-identify personal information in a secure manner when it is no longer required.
We currently do not collect household data. If all the members of a household make a request under this Policy, we will respond as if the requests are individual requests.
Please note, if you do not have a Aviothic account we will not have enough information about you to verify your requests under this Policy, as we do not keep sufficient information necessary to reidentify and link you to a prior visit to Aviothic where data may have been collected. As such, we will be unable to verify and honor your requests. You may make a verifiable consumer request related to your personal information twice per 12-month period.
If you are a California consumer, please see our California Consumer Privacy Act (CCPA) Privacy Notice European Union and UK Privacy Rights by clicking here or simply scrolling down.
In some jurisdictions, you can request that your personal information be deleted. Please note that if you request deletion of your personal information, or if your account is suspended, terminated, or voluntarily closed:
- We may retain your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a Aviothic account for fraud or safety reasons, we may retain information from that account to prevent that member from opening a new account in the future.
- We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep information for tax, legal reporting, and auditing obligations.
- Some copies of your information (e.g., log records) will remain in our database, but are disassociated from personal identifiers.
- Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
Requests Made Through Agents
You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.
Your Nevada Privacy Rights
Nevada law permits our users who are Nevada consumers to request that their personal data not be sold (as defined under applicable Nevada law), even if their personal data is not currently being sold. Requests may be sent to firstname.lastname@example.org and are free of charge. Please include “Opt-Out Request Under Nevada Law” in the subject line and body of your message.
Your European Union and UK Privacy Rights
In addition to the above-listed rights, European Union and UK privacy law provides individuals with enhanced rights in respect of their Personal Data. These rights may include, depending on the circumstances surrounding the processing of Personal Data:
- The right to object to decisions based on profiling or automated decision-making that produce legal or similarly significant effects on you;
- The right to request restriction of processing of Personal Data or object to processing of Personal Data carried out pursuant to (i) a legitimate interest (including, but not limited to, processing for direct marketing purposes) or (ii) performance of a task in the public interest;
- In certain circumstances, the right to data portability, which means that you can request that we provide certain Personal Data we hold about you in a machine-readable format; and
- In certain circumstances, the right to erasure and/or the right to be forgotten, which means that you can request deletion or removal of certain Personal Data we process about you.
We may send promotional emails from time to time. If you are located in the EU, we will not send promotional emails without your consent. You can opt-out of receiving promotional emails from us at any time by clicking on the unsubscribe link in the emails. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or our ongoing business relations. In addition, if you downloaded our app and opted-in to receive push notifications on your device, you can opt-out at any time by adjusting the permissions in your device or uninstalling our app.
Cookies and Web Tracking
Consult our Cookie Notice for more information about how to control and/or opt out of certain web tracking technologies.
California Consumer Privacy Act (“CCPA”) Privacy Notice
Personal Information We Collect
We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“CCPA personal information”). We have collected the following categories of CCPA personal information from consumers within the last twelve (12) months:
|Category||Personal Data Collected|
|Identifiers||First name, last name, postal address, unique personal identifier, online identifier, IP address, email address, alias, state, city, country, phone number, account name, social media profiles, or other similar identifiers|
|California Customer Records Personal Information categories||First name, last name, postal address, credit card number, debit card number, or any other financial information.|
If you are an instructor, you can link your PayPal, Stripe, or other payment account to the Services to receive payments. When you link a payment account, we collect and use certain information, including your payment account email address, account ID, physical address, or other data necessary for us to send payments to your account. In some instances, we may collect ACH or wire information to send payments to your account. In order to comply with applicable laws, we also work with trusted third parties who collect tax information as legally required. This tax information may include residency information, tax identification numbers, biographical information, and other personal information necessary for taxation purposes.
Some personal information included in this category may overlap with other categories.
|Characteristics of Protected Classifications Under California or Federal Law||Age, race, national origin, physical or mental disability, sex (including gender, gender identity, gender expression), sexual orientation, veteran or military status.|
|Commercial information||Records of services purchased|
|Internet or Other Similar Network Activity||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement|
|Geolocation Data||Our online services don’t collect precise geolocation data from GPS sensors. However, we do collect IP addresses from which we can determine your general location.|
|Sensory Data||Video recordings|
|Professional or Employment-Related Information||Employment History, Request for Leave|
Categories of CCPA personal information disclosed for a business purpose
We disclose the categories of CCPA personal information listed below for business purposes.
|Category||Category of Third-Party Recipients|
|Identifiers||Instructors, Payment Processors, Analytics service providers, Ad networks and marketing tools|
|California Customer Records Personal Information categories||Instructors, Payment Processors|
|Characteristics of Protected Classifications Under California or Federal Law||Instructors|
|Internet or Other Similar Network Activity||Analytics service providers, Ad networks and marketing tools, Providers of advertising services|
|Geolocation Data||Analytics service providers, Ad networks and marketing tools, Providers of advertising services|
|Inferences Drawn From Other Personal Information||Analytics service providers|
Sources of CCPA personal information
- Directly from you: For example, when you provide it to us to sign up for a Aviothic account, interact with our customer service, or participate in surveys or marketing promotions, as well as information you provide when you choose to provide taste preferences or account settings (including preferences set in the “Account” section of our website).
- Automatically or indirectly from you: For example, through and as a result of your use of and access to the Services, including through our mobile application.
- Business and marketing partners or service providers: For example, online interactions you may have with our joint marketing partners and event co-sponsors, online identity and fraud verification services, social media sites, and analytics providers.
Your California Privacy Rights
California’s “Shine the Light” law permits users of the Services who are California residents to request certain information regarding its disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please submit a request through our Online Form, email us at email@example.com from the email address that you believe is associated with your Aviothic account, or write to us at the address listed below.
CCPA provides our users who are California residents the following additional rights:
- Right to Know: You have the right to request that we disclose certain information to you about the Personal Data we collected, used, disclosed, and sold about you in the past 12 months. This includes a request to know any or all of the following:
- The categories of Personal Data we have collected about you;
- The categories of sources from which the Personal Data was collected;
- The categories of Personal Data about you we disclosed for a business purpose or sold;
- The categories of third parties to whom the Personal Data was disclosed for a business purpose or sold;
- The business or commercial purpose for collecting or selling the Personal Data; and
- The specific pieces of Personal Data we have collected about you.
- Right to Deletion: You have the right to request that we delete the Personal Data we collected from you and maintained, subject to certain exceptions. Please note that if you request deletion of your Personal Data, we may deny your request or may retain certain elements of your Personal Data if it is necessary for us or our service providers to do so in order to comply with applicable laws and regulations, to honor your choices, for our billing or records purposes, or to fulfill the purposes described in this Privacy Statement.
- Right to Non-Discrimination: You have the right not to receive discriminatory treatment by us for the exercise of any your rights.
- Authorized Agent: You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and we may verify your identity directly.
- AXES ATARAH S.R.L.
- Email address for contact:
- Mailing address:
- Strada Dabuleni, Nr. 8, Municipiul Craiova, Judetul Dolj, Romania