Privacy Policy

1 Definitions

1.1 In this Privacy Policy (Policy):

You, your means in the case of an individual using the Wrighton Aviation Website or purchasing Products and Services through Wrighton Aviation directly or the Wrighton Aviation Website, that individual (such as students and employees of Wrighton Aviation), or in the case of an individual on behalf of another company or other legal entity, then that company or other legal entity.
Wrighton Aviation Website means the online services accessible via wrightonaviation.au
Personal Information means information or an opinion about an identified natural person, or a natural person who is reasonably identifiable.
Privacy Officer means the Privacy Officer, with contact details provided at clause 18.1.
Products and Services means all products and services offered by Wrighton Aviation, including flight training and other flight services offered by Wrighton Aviation from time to time.
Wrighton Aviation, us, we, our mean Wrighton Aviation Pty Ltd ACN 669 010 486 and all legal entities owned or controlled by Wrighton Aviation Pty Ltd ACN 669 010 486 (across any jurisdiction).

2 Introduction

2.1 This Policy sets out how we collect, handle and use information that identifies you, for example: your name, email and address.

2.2 We care about your privacy and have put measures in place to protect you and the information you have entrusted to us.

2.3 We reserve the right to update this Policy from time to time. You can view the latest version of this Policy on the Wrighton Aviation Website at any time.

2.4 We are NOT subject to the privacy laws of the jurisdictions in which we operate, including the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) (Act), as we are a 'small business operator' within the meaning of the Act. Notwithstanding this, we publish this Policy to be transparent about the data we collect and how we hold it.

3 Application

3.1 This Policy applies to Personal Information that we may collect about you in the manner outlined in this Policy. To the extent permitted by law, this Policy does not apply to any information that may be collected by a third party and how that third party may use, handle, store or disclose your Personal Information.

4 Type of Personal Information We Collect

4.1 We may collect, use, store and transfer Personal Information about you, which is generally grouped into one of the following types of data:

your first name, last name, title, address, billing address, email address, username and telephone numbers;
for identification purposes, certified copies of passports or birth certificates, drivers licence or any other document to make up 100 points of identification;
as part of the application for employment process, Personal Information provided in the application form including contact details, employment history, education details, licenses and qualifications;
bank account details, credit card details or other payment information;
information regarding IP addresses, browser type and version, time zone setting, browser plug-in types and versions, cookies, operating system, platform and device type;
your username or password, information about how you use the website and our Products and Services;
your interests, preferences, feedback, communication, opinions and reviews;
information we may receive from third-parties such as business partners, analytics providers and payment providers;
digital media and content such as video, footage and audio.

5 Collection of 'Sensitive Information'

5.1 As part of providing the Services to you, Wrighton Aviation may be required to collect 'sensitive information' from you including:

medical history / health information;
criminal history including criminal history checks; and
financials/credit history.

Wrighton Aviation will only request sensitive information if it is necessary for your employment with us or your enrolment as a student.

5.2 'Sensitive information' is subject to a higher level of privacy protection than other 'personal information' and we will handle this information with additional care, including only collecting it with your consent except in specified circumstances.

6 How Do We Collect Information From You

6.1 We use different methods to collect data from you and about you, including:

direct interactions – you may give us your identity, contact, financial, profile and proof of identity data by creating an account, completing forms or corresponding with us;
interactions you have with other sources – we may receive data from third-parties such as regulatory bodies, other flight training organisations, business partners, and payment providers;
automated technologies or interactions – we may collect information automatically when you visit the Wrighton Aviation Website, including cookies, log files, web beacons, tags and pixels.

6.2 If we receive Personal Information from a third party, we will take reasonable steps to ensure that you have given express or implied consent to the collection of that Personal Information.

7 How Do We Use Your Personal Information?

7.1 We may use your personal data to:

communicate with you;
register you as a new customer/student or create an account;
validate your identity;
provide technical or other support;
enhance, administer and manage the website, Products and Services;
deliver relevant content and measure effectiveness;
protect you;
market to you and make recommendations;
analyse, aggregate and report;
perform a contract with you, manage payments, fees and charges;
improve the Products and Services;
manage our relationship with you;
facilitate internal training and administrative functions;
monitor compliance with regulations;
cooperate with law enforcement agencies and regulatory bodies;
cooperate with stakeholders relating to course completion;
improve our Products and Services and business activities;
celebrate milestones/achievements in your career/study.

8 Whether Giving It Is Compulsory or Voluntary

8.1 Wrighton Aviation will ensure that where possible, any Personal Information requested from you can be provided voluntarily or anonymously. However, due to the nature of aviation and aviation licensing there are circumstances when we will require specific information, for example: Aviation Reference Numbers, Federal Police Checks, medical examination results, and pilot licenses.

8.2 You have the right to decline a request for Personal Information. However, withholding information may result in enrolment applications being declined, access to services being refused, or the course not proceeding.

9 Data Retention

9.1 We will retain your Personal Information for as long as is necessary for a lawful purpose connected to our relationship with you.

9.2 If it is determined that we should not have possession of Personal Information under a relevant law, we will destroy it or ensure it is de-identified.

9.3 We will only collect Personal Information from a third party where it is reasonably necessary for, or directly related to Wrighton Aviation's functions or activities.

10 Do Not Track Settings

10.1 Please note that we do not alter our data collection and use practices when we see a 'Do Not Track' signal from your browser.

11 Storing Your Information

11.1 To offer a consistent service, we may store and manage data electronically or in paper form. Where data is stored electronically, it is done so by a third-party cloud service provider.

11.2 The data that we collect from you may be transferred to and stored on servers in other jurisdictions.

11.3 We will take all steps reasonably necessary to ensure that your Personal Information is secured from misuse, interference, loss, unauthorised access, modification, or disclosure.

11.4 Submission of any Personal Information to us is an acknowledgement that you agree to such use, storage, and disclosure as outlined in this Policy.

12 How We Disclose Your Information

12.1 There may be times when we need to share your Personal Information with third parties. We may share your information with:

any and all of our affiliates;
third parties including business partners, suppliers, subcontractors and financial sponsors;
an approved and authorised RTO for the completion of your course qualifications;
where required to comply with any legal obligation;
Department of Home Affairs;
Australian Transport Safety Bureau;
CASA;
hospitals and other health related clinics and support services;
law enforcement or emergency departments;
various other Government agencies;
applicants under the Freedom of Information Act 1982 (Cth);
other flight training organisations;
an actual or potential buyer in connection with an actual or proposed purchase, merger or acquisition;
other third-parties where we have your consent.

13 When Will We Disclose Personal Information

13.1 Personal Information will only be used or disclosed for purposes related to the Primary Purposes for which it was collected. Exceptions include where the use or disclosure is required to lessen or prevent a serious threat, we suspect fraud or unlawful activity, it is necessary to assist law enforcement, or it is required or authorised by law.

14 International Data Transfers

14.1 We may collect and store Personal Information globally and may transfer, process and store your Personal Information outside of Australia, to wherever we or our third-party service providers operate. We will take reasonable steps to ensure that any third-party service providers engaged outside of Australia do so in accordance with this Policy and any applicable law.

15 Accessing and Correcting Your Information

15.1 You may request access to Personal Information that we hold about you at any time by contacting our Privacy Officer. We will respond within a reasonable time.

15.2 Where permitted by law, we may charge you a reasonable fee for processing your request.

15.3 If you believe the Personal Information we hold about you is incorrect, out of date, incomplete, irrelevant, or misleading, please notify our Privacy Officer.

15.4 If we decline to correct your Personal Information as requested by you, a reason for refusal will be provided.

16 Complaints

16.1 If you believe we have not fulfilled our obligations under any relevant law or have not complied with the terms of this Policy, you can make a complaint in writing to our Privacy Officer.

16.2 We will respond to you within a reasonable period of time to acknowledge your complaint and inform you of the next steps.

17 Unsubscribe

17.1 When it comes to marketing communications, you can ask us not to send you these at any time by following the unsubscribe instructions contained in our communication, or making a request to the Privacy Officer.

18 Contact

18.1 If you have any comments, concerns or questions regarding this Policy or Personal Information that we hold about you, please contact our Privacy Officer:

Email: nick@wrightonaviation.au

Post: Privacy Officer, Turtle Park Airfield, 171 Tedfords Rd, Marian QLD 4753