1 Definitions
1.1 In this Privacy Policy (Policy):
(a) 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 using the Wrighton Aviation Website or purchasing Products
and Services through Wrighton Aviation directly or the Wrighton Aviation
Website, then that company or other legal entity.
(b) Wrighton Aviation Website means the online services accessible via the following
website:
(c) Personal Information means information or an opinion about an identified
natural person, or a natural person who is reasonably identifiable.
(d) Privacy Officer means the Privacy Officer, with contact details provided at clause
18.1 .
(e) 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.
(f) 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. Although we will not provide
notice of the changes to you, 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.
2.5 In this Policy we set out:
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(a) the types of information that we may collect; and
(b) how that information will be used, handled, stored and disclosed.
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 or as otherwise set out in this
Policy, 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 about you
4.1 We may collect, use, store and transfer Personal Information about you, which
information is generally grouped into one of the following types of data:
(a) your first name, last name, title, address, billing address, email address, username
and telephone numbers;
(b) for identification purposes, we may collect certified copies of passports or birth
certificates, drivers licence or any other document to make up 100 points of
identification, as per the student enrolment application process;
(c) as part of the application for employment process for employees, we may collect
Personal Information that:
(i) has been provided in the application form which may include; contact
details, employment history, education details, licenses and qualifications,
and this may include personal information about you gathered from
curriculum vitaes, tender documents or any other documents required for
the normal operations of the flight school;
(ii) identifiers (such as tax file number and business number), citizenship and
residency details, details regarding and information provided by your
referees, details regarding and information provided by your guarantor(s)
and business partner(s), results of any pre-employment or profile tests,
employment history, education history, identity documents and next of
kin details; and
(iii) interviews, student/staff briefings or general conversation;
(d) to the extent required by law or by any third party payment processor that we
may use, your bank account details, credit card details or other payment
information;
(e) information regarding the IP addresses used to connect your computer to the
Internet, browser type and version, time zone setting, browser plug-in types and
versions, cookies, operating system, platform and type of device;
(f) your username or password from the Wrighton Aviation Website, information
about how you use the Wrighton Aviation Website and our Products and Services,
as well as details regarding purchases or orders and payments made by you to us,
including transactions, payment history and business activities;
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(g) your interests, preferences, feedback, communication, opinions and reviews
about any of our Products and Services, as well as information regarding your
preferences in receiving marketing and communication from us;
(h) subject to clause 9.2 , information we may receive from third-parties such as:
(i) business partners, sub-contractors in technical and delivery services,
advertising networks, analytics providers and search information
providers, third party applications that plug into the Products and Services
and payment providers or merchants;
(ii) information collected from third parties about you that are the subject of
reports of misconduct made to Wrighton Aviation or information
collected from third parties relating to compliance issues, information
collected from airlines to whom the individual is contracted to or enrolled
through, or any other statutory purposes.
(i) 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 as defined under section 6(1) of The Privacy Act 1988
(Cth). Wrighton information may require the following sensitive information from you:
(a) medical history / health information;
(b) criminal history including criminal history checks; and
(c) financials/credit history.
however; Wrighton Aviation will only request the sensitive information listed in clause 5.1
if it is necessary for your employment with us or your enrolment as a student, and this
may also include information received from third parties (previous employers and
referees etc).
5.2 ‘Sensitive information’ is subject to a higher level of privacy protection than other
‘personal information’ and we will handle this information in the following ways:
(a) we will only collect sensitive information with your consent, except in specified
circumstances;
(b) subject to clause 5.3 , we will not use or disclose the sensitive information for a
purpose other than that which it was required to be collected (for example, use in
direct marketing or by disclosing it to our related bodies corporate, as defined
under the Corporation Act 2001 (Cth)). We will only use the sensitive information
for the purpose for which it was collected and within your reasonable
expectations.
5.3 We will not process and use sensitive information for a purpose other than the purpose
for which it was collected, unless:
(a) you are adequately informed of the use before giving consent;
(b) you give consent voluntarily;
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(c) the consent is current and specific;
(d) you have the capacity to understand and communicate your consent; or
(e) as otherwise required or authorised by or under an Australian law or a
court/tribunal order.
6 How do we collect information from you
6.1 We use different methods to collect data from you and about you, including:
(a) (direct interactions) – you may give us your identity, contact, financial, profile and
proof of identity data by creating an account with us, completing paper copy or
online forms or corresponding with us;
(b) (interactions you have with other sources) – subject to clause 9.2 , we may
receive identity, contact, financial, transaction, usage, marketing and
communications data from third-parties such as regulatory bodies, other flight
training organisations, business partners, sub-contractors in technical and delivery
services, advertising networks, analytics providers and search information
providers, third party applications that plug into the Products and Services and
payment providers or merchants;
(c) (automated technologies or interactions) – we may collect information
automatically when you visit the Wrighton Aviation Website, for example your IP
address and device type or details of what pages you looked at and what links you
clicked on. This information is useful for us to improve the value of our Products
and Services to you. We may use the following technologies to collect technical
and third-party data:
(i) “cookies” are data files that are placed on your device or computer and
often include an anonymous unique identifier. For more information
about cookies, please see: https://allaboutcookies.org;
(ii) "log files” track actions occurring on the Wrighton Aviation Website, and
collect data including your IP address, browser type, Internet service
provider, referring/exit pages, and date/time stamps; and
(iii) “web beacons”, “tags”, and “pixels” are electronic files used to record
information about how you browse the Wrighton Aviation Website and
Products and Services.
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. If it is determined that we are unable to have possession of the Personal
Information under a relevant law, we will destroy the Personal Information or ensure that
it is de-identified.
6.3 If we receive Personal Information from any third party, we will take reasonable steps to
ensure that before we collect the information:
(a) we are satisfied that you would reasonably expect us to obtain the Personal
Information;
(b) you have authorised the collection of that Personal information; and
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(c) that the Personal information is accurate.
7 How do we use your personal information?
7.1 We may use your personal data to:
(a) communicate with you;
(b) to register you as a new customer/student or create an account with us;
(c) to validate your identity;
(d) to provide technical or other support to you;
(e) to enhance, administer and manage the Wrighton Aviation Website, Products and
Services and develop new ones to administer and protect our business and the
Wrighton Aviation Website;
(f) to deliver relevant Wrighton Aviation Website content and measure or
understand the effectiveness of the Wrighton Aviation Website and to ensure the
proper function of the Wrighton Aviation Website and online software;
(g) to protect you;
(h) to market to you including a newsletter (if we choose to) and make suggestions
and recommendations to you about goods, services or promotions that may be of
interest;
(i) to analyse, aggregate and report;
(j) to perform a contract with you and provide you with the Products and Services,
including flight training and other flight services, manage payments, fees, and
charges, perform fraud checks and collect and recover money owed to us;
(k) to improve the Products and Services or businesses that we undertake;
(l) to maintain a record in the event of any Product and Service or warranty request;
(m) to manage our relationship with you which may include, notifying you about
changes to our terms of this policy, asking you to leave a review or take a survey,
engaging with you in relation to any support request or communication that you
may submit;
(n) to facilitate internal training and fulfil all administrative functions required to
complete aviation courses, to ensure the effective delivery of Products and
Services and to manage complaints, alleged misconduct, professional
development requests, and other forms/procedures within the scope of the
school or business, whether initiated by us or you;
(o) to monitor compliance with regulations and to identify, investigate and take
action in relation to the contravention of those regulations;
(p) to cooperate with domestic and foreign law enforcement agencies and other
regulatory bodies;
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(q) co-operate with various stakeholders directly relating to the successful
completion of your course, such as a registered training Organisation (RTO);
(r) to improve our Products and Services and business activities we undertake; and
(s) in order to celebrate certain milestones/achievements in your career/study, we
may ask you to take part in other photographic opportunities for the Wrighton
Aviation literature, or for publishing aforementioned achievements on social
media, the Wrighton Aviation Website or other marketing material;
(the Primary Purposes).
7.2 Where we collect Personal Information, we will only process the information for the
Primary Purpose where:
(a) we have legitimate interests to process the personal data and they are not
overridden by your rights;
(b) it is in accordance with a legal obligation; and
(c) we have your consent.
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. You do not have to provide us with
the personal data we request, but this may mean that you cannot use some parts of our
Wrighton Aviation Website, Products and Services, and this includes enrolment as a
student. However, due to the nature of aviation and aviation licensing there are
circumstances when we will not be able to allow this, for example:
(a) Aviation Reference Number – An aviation reference number (ARN) is similar to a
customer number and this will be required to complete most of our application
forms;
(b) students and some staff will be required to obtain a Federal Police Check;
(c) the results from aviation medical examinations;
(d) pilot licenses;
(e) previous and current student records or assessments;
(f) pilot log books;
(g) course enrolment forms; and
(h) employee wages and superannuation entitlements.
8.2 As stated in clause 8.1 , you have the right to decline a request for Personal Information.
However, if information is withheld the following consequences might apply:
(a) if a person’s identity cannot be adequately substantiated an enrolment
application may be declined;
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(b) necessary documents and licenses required to become a pilot can be refused;
(c) withholding information may be interpreted as a breach in safety obligations
therefore flying may be refused;
(d) access to Wrighton Aviation services and facilities may be refused;
(e) necessary CASA requirements for flying may be declined;
(f) the course may not proceed;
(g) we may not be able to adequately investigate or resolve complaints/misconduct
made by individuals;
(h) wages/superannuation may not be able to be paid; and
(i) employment may not be able to be offered to an individual.
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 or for the Primary Purposes.
9.2 If it is determined that we should not have possession of Personal Information under a
relevant law, we will destroy the Personal Information or ensure that the Personal
Information 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 as outlined
in clause 7 of this policy.
10 Do Not Track Settings
10.1 Please note that we do not alter our Wrighton Aviation Website 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 to you, 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 that may store your Personal Information (or a backup of your Personal
Information) in a data centre or an online cloud service, as determined by the third-party
provider from time to time.
11.2 The data that we collect from you may be transferred to and be stored to these servers or
subject to clause 14 , processed by staff operating in other jurisdictions or who work for
Wrighton Aviation.
11.3 We will take all steps reasonably necessary to ensure that your Personal Information is
secured from misuse, interference, loss, unauthorised access, unauthorised modification,
or unauthorised disclosure. Any Personal Information will be handled in accordance with
this Policy and the Act. Despite using all steps reasonably necessary, the transmission of
information through the internet is not completely secure.
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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.
12.2 We may share your information with:
(a) any and all of our affiliates;
(b) third parties including business partners, suppliers, subcontractors and financial
sponsors;
(c) an approved and authorised RTO for the completion of your course qualifications;
(d) where we are required to disclose your information in order to comply with any
legal obligation, to enforce any agreements; or to protect the rights, property, or
safety of us and our students, customer, or others. This includes, where relevant,
exchanging information with organisations for the purposes of fraud protection
and credit risk reduction;
(e) Department of Home Affairs;
(f) Australian Transport Safety Bureau;
(g) CASA;
(h) hospitals and other health related clinics and support services;
(i) law enforcement or emergency departments such Fire, ambulance, SES;
(j) various other Government agencies (Taxation office, Foreign regulators etc);
(k) Applicants under the Freedom of Information Act 1982 (Cth);
(l) other flight training organisations;
(m) an actual or potential buyer (and its agents and advisors) in connection with an
actual or proposed purchase, merger or acquisition of any part of our business;
and
(n) other third-parties where we have your consent, including your implied consent
given where disclosure is required for the performance of a contract with you.
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 and is relevant to you. Wrighton Aviation will obtain
consent from you where appropriate and necessary. Exceptions to this include where:
(a) the use or disclosure is required to lessen or prevent a serious and imminent
threat to an individual’s life, health or safety, or to public health and safety;
(b) we suspects fraud or unlawful activity;
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(c) the use or disclosure is necessary to assist a law enforcement agency or
government regulatory body in its law enforcement functions or investigations; or
(d) the use or disclosure is required or authorised by or under law.
14 International Data Transfers
14.1 We may collect and store Personal Information globally from each jurisdiction we operate
in and from each legal entity that is owned or operated by us in different international
jurisdictions and may transfer, process and store your Personal Information outside of
Australia, to wherever we or our third-party service providers operate for the Primary
Purposes. We will take reasonable steps to ensure that any third-party service providers
engaged outside of Australia to process and store your Personal Information, 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 (using the details set out in clause 18 of this Policy.) We will
respond to any such request for access to Personal Information within a reasonable time
and will provide you access to the Personal Information that we hold relating to you
unless we are authorised not to do so by law.
15.2 Where permitted by law, we may charge you a reasonable fee for processing your request
to access your Personal Information and should we decline you access to your Personal
Information, a written explanation will be provided setting out the legal reasoning for
doing so (except to the extent that it would be unreasonable to do so having regard to the
grounds for refusal). Examples include, but are not limited to, if the information doesn’t
exist, cannot be located, the information may involve an unwarranted breach of someone
else’s privacy, or releasing it may pose a serious threat to someone else’s safety.
15.3 If upon receiving your Personal Information, or at any other time, you believe the
Personal Information that we hold about you is incorrect, out of date, incomplete,
irrelevant, or misleading, please notify our Privacy Officer (using the details set out in
clause 18 of this Policy.) We will take reasonable steps in the circumstances to ensure,
having regard to the lawful purpose that it was collected, to ensure that the information is
accurate, up to date, complete and not misleading.
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, or you would like to appeal a decision made by us
in relation to your Personal Information, you can make a complaint in writing to our
Privacy Officer, using the contact details set out in this Policy.
16.2 We will respond to you within a reasonable period of time (or where a period is specified
by any law, that period) to acknowledge your complaint and inform you of the next steps
we will take in dealing with your complaint.
17 Unsubscribe
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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, using the contact details as outlined in clause 18
of this Policy.
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 by email to
nick@wrightonaviation.au or by post at:
Privacy Officer
64 Victoria Street
Mackay, QLD, 4740
