PRIVACY POLICY OF THE APP ICAO4PILOTS

This privacy policy governs the application “icao4pilots” (henceforth referred to as the App) available on Google Play Store and Apple Store for download on mobile devices and owned by ICAO4PILOTS LLC (henceforth referred to as the Company), domiciled at 3785 NW 82ND AVE SUITE 302, Miami, Florida, United States of America. It is also applied to the website www.icao4pilots.com (henceforth referred to as the Website).

The App offers users (henceforth referred to as Customer or Customers, without distinction) the possibility to train and improve as aircraft pilots to apply for the ICAO English Test (International Civil Aviation Organization English test) through diverse functionalities.

This policy is aimed at informing the Company’s Customers about the collection, use and processing of their personal data and the protection of their personal data. The legal basis for the processing of personal data is Customer’s consent. Therefore, by using the App, Customer agrees to accept this privacy policy.

Any information provided by Customers to the Company will be duly protected and will not be communicated, modified or disclosed, except as provided for in this privacy policy. The Company will act, at all times, proactively, in good faith, according to the principles of trust, transparency and personal data protection applicable to the processing of its Customers’ information, adopting appropriate technical and organizational measures to guarantee an adequate processing.

Below, you will find the aspects that you should be aware of for the due protection of your personal information:

1. What information do we collect?

Information provided by You: We receive and collect the information you provide when you sign up and use the App and/or log in the Website and, particularly, your full name, date of birth, email address, country of residence, your picture, your professional level as an aircraft pilot, the aircraft type you are licensed to operate, flight hours and if you have ever done the ICAO English Test and, in that case, the score obtained.

Information about your Facebook account and your Gmail email address: If you opt to log in using your Gmail email address or Facebook account, we can get access to the information contained in such social network and Gmail email address, whose terms of use and privacy policy you have previously accepted. For example: If You choose to associate your App access account to your Facebook account, we will access, if You agree, to information such as your contact list, the use you make of your applications, such as your Likes and your personal data, such as your name, email and profile picture.

Information about payments: In addition, the Company collects the information related to the transactions carried out by Customers regarding the “paid services” offered by the Company. This information is necessary for the appropriate execution of the contract entered into by the Company and Customer, and to allow the rendering of the paid services.

Moreover, when You use the App and/or the Website, we may obtain information about your IP address (Internet Protocol Address) and your Internet provider. Similarly, we may get access to information from other sources, including information about data providers obtained either online or offline. This complementary information may include demographic data and Internet browsing behaviors. We may use this complementary information for purposes in accordance with this privacy policy, such as analyzing and understanding our Customers’ preferences.

The Company will never request information for purposes contrary to this privacy policy to collect personal data that directly or indirectly discloses sensitive data, such as information related to race and ethnic, political opinions, religious, philosophical or moral beliefs, trade union affiliation, health or sexual life.

2. What do we use the information collected for?

The Company uses the information collected from our Customers for the purpose of managing and administrating the functionalities provided by the App and/or the Website, communicating with our Customers, offering services and products, as well as customizing the services provided by the Company.

We also use your personal information for advertising and direct marketing activities, to establish certain profiles for advertising, promotional or commercial purposes, or to determine consumption habits, as long as such personal information is provided by You, obtained with your consent or included in documents that can be accessed by the public.

For example, we may use the information collected to make recommendations about services or products offered by the Company that we consider you may like; to prevent, detect and investigate potentially prohibited or illegal activities, such as fraud; to send emails, automatic notifications or any type of correspondence and advertising related to any service and/or product offered by the Company, promotions and surveys.

Similarly, we use such information to offer new services and/or products and to send administrative, technical, organizational and/or commercial information, in the form of documents or electronically, related to the Company’s activities.

3. Who do we share the information collected with?

The Company does not share or commercialize in any form our Customers’ information, except in the following specific situations.

The Company hires the services of providers and natural or legal persons (henceforth referred to as Third-Parties) to perform certain tasks, such as the development of the App and/or the Website, their updates, implementation and several tasks such as the management of marketing and advertising activities. These Third-Parties will have access to our Customers’ personal information required to perform their tasks, but they cannot use it for other purposes. Moreover, they must process the personal data in accordance with this privacy policy and the legislation in force regarding the protection of personal information, respecting at all times its confidential nature.

In the event Customers’ personal information needs to be processed by Third-Parties, a contract will be entered into with such Third-Parties to establish that such Third-Party may not apply or use the personal data provided for purposes other than those specified in the service contract, or assign it to other persons. The contract must also state that once the services established in the contract are fulfilled, the personal information processed must be destroyed, unless the Company expressly authorizes otherwise in the event of possible future services to be rendered, in which case such personal data may be stored under appropriate security conditions for a period up to two years. Said contracts must contain confidentiality and secrecy obligations that must be assumed by the Third-Parties in relation to the information they may have access to.

In the event the Company or most of our assets are acquired in the future by a Third-Party, our Customers’ personal data will be one of the assets transferred, subject to the obligations acquired under this privacy policy (or such policy as may be in force), unless Customer expressly authorizes otherwise. The same rule will be applied in the event of merger, transformation or split in which the Company is involved.

The Company may disclose Customers’ information in the following situations: (a) When requested by a judicial authority; (b) When the Company has a good-faith belief that this is necessary for the compliance of the applicable law or to file an answer in a valid legal proceeding started by a competent authority (including government agencies); (c) When this is necessary in order to protect our Customers (for instance, to prevent spam or attempts of fraud or to help prevent the loss of any human’s or severe injuries); (d) When this is necessary to operate and maintain the security and integrity of our computer systems; and (e) When this is necessary to protect the Company’s rights and/or assets.

4. What are the principles of protection of your personal data that you should know?

The Company will process our Customers’ personal data in accordance with the following principles related to the protection of personal information:

Property Rights on personal data: It is important that You are fully aware that your personal information exclusively belongs to You and that You have the right to manage and control the use made of your personal information.

Data Quality: The Company uses suitable well-defined technology and staff practices to process your personal data with accuracy and agility. We do not collect information for purposes different from or not compatible with the purposes contained in this privacy policy, nor do we collect information through unreliable or fraudulent means. The information provided by You must be true, adequate, relevant, accurate and not excessive in relation to the purpose for which it was collected. It will be stored making it easy for holders to exercise their rights at all times and it will be updated if necessary. Whenever it is no longer necessary or relevant for the purposes for which it was collected, it will be destroyed through an appropriate personal data deletion policy.

Data Category: No person can be obliged to provide sensitive information. The Company does not collect or process such data category.

Information and Consent in Data Processing: The Company only processes your personal data with your free and express consent and solely for the purposes informed, as allowed by You or in the form permitted by the applicable law. You have the right to oppose any data processing not compatible with this privacy policy and to cancel your user account and unsubscribe from the App at any time.

Security: The Company implements all measures required to maintain the security of our Customers’ personal data, contemplating all internal practical, technical and organizational measures to guarantee the security, integrity and confidentiality of such information, diligently attempting to prevent any unauthorized access to the information, its destruction, use, modification or disclosure. However, due to the current state of technology, the Company cannot fully guarantee that unauthorized access will never occur.

Duty of Confidentiality: The Company and the persons involved in any stage of your personal data processing are obliged to keep it under professional secrecy and absolute confidentiality. Such obligation will remain even after the contractual relationship with the Company is terminated. The person bound by the duty of confidentiality may be relieved from such obligation by judicial resolution and in case of justified reasons related to public safety, the national defense or public health. In this respect, we let You know that the Company keeps your personal data confidential and allows the access to your personal data only to those persons that specifically need it to perform their activities related to the Services we render.

Right to personal image: One of the functionalities of the App allows You to publish your personal image. The right to the image is a truly personal right and considered personal data in relation to which You grant us express authorization for its processing and use in accordance with the provisions established in this privacy policy.

5. What are your rights in order to protect your personal data?

Below you will find your rights in order to appropriately protect your personal data:

Right of access: Any Customer of the Company, holder of personal data, may exercise the right of access to his or her personal information stored in the Company’s database, free of charge.

Right to have personal data rectified, updated and deleted: You have the right to rectification, updating and erasure, free of charge, in relation to your personal information stored in the Company’s database. The Company, if applicable, must proceed to the rectification, updating or erasure of such personal information.

Right of removal or blocking: You may also request for free the removal or blocking of your name and email from the Company’s files or data banks for advertising purposes.

Right to suspend personal data processing activities: You may request the suspension of your personal data processing when you require the rectification or deletion of your personal data stored in the Company’s database until your request is resolved.

Right to data portability: You can request to obtain your whole information stored in the Company’s database or to transfer it to another person responsible for the processing of personal data when it is technically possible.

In order to exercise the aforementioned rights or to withdraw your consent to your personal data processing, please contact us by email: info@icao4pilots.com “Ref: “Privacy Policy. Personal Data. Rights”.

6. What are our rules for minors?

Minors under the age of 17 cannot download or use the App. Any use of the App that is not authorized by the Company made by a minor under 17 is under the exclusive responsibility of his or her parents, legal guardians or representatives, who will be responsible for all acts executed through the App by the minors under their charge.

7. Where is our Customer’s personal data stored?

Our Customer’s personal data is stored on servers of a third-party hired by the Company (Amazon Web Service), which renders the data hosting service in the cloud (Cloud Computing).

The Company complies with the Privacy Shield framework between the European Union and the United States, as well as with the Switzerland-United States Privacy Shield framework, according to the provisions established by the Department of Commerce of the United States of America regarding the collection, use and conservation of personal data transferred from the European Union and Switzerland to the United States. In the event of conflict between the terms of this privacy policy and the principles of the Privacy Shield, the latter will prevail. For more information on the Privacy Shield, visit this website: https://www.privacyshield.gov/

8. What is our cookies policy?

The Company uses cookies and other technologies to store and recover the information on its applications for mobile devices and/or upon access to the Website.

Particularly, the App uses Cookies, this is, small files or folders sent to the Costumer’s device to make their experience efficient by enabling a faster access to the functionalities offered by the App and to store Costumer’s preferences and settings, this is, to customize the services offered.

Like computer browsers, mobile browsers allow to make changes in the options or privacy settings to disable or delete cookies. If You want to modify your privacy options, follow the instructions specified by the developer of your mobile browser. If You do not want a cookie to be installed on your hard disk, You can set your browser not to receive them.

Cookies are only associated to an anonymous user and his or her computer and they do not themselves provide user’s personal data, or read information of your hard disk or read cookie files created by other providers.

9. What definitions apply to this privacy policy?

For the purpose of an appropriate interpretation of this Privacy Policy, You should consider the following definitions:

Personal Data: Any type of information related to natural persons.

Date file, register, base or bank: They refer, without distinction, to an organized set of personal information that may be treated or processed, electronically or not, regardless of their method of formation, storing, organization or access.

Data processing: Systematic operations and procedures, electronic or not, that allow the collection, conservation, ordering, storing, modification, relating, evaluation, blocking, destruction and, in general, the processing of personal data, as well as its assignment to third-parties by means of communications, consultation, interconnection or transfer.

Person in charge of a data file, register, base or bank: Natural or legal person, public or private, owner of a data file, register, base or bank.

Data Owner: Any natural person whose data is subject to processing.

Right of access: The right that allows a data owner to know if he or she is included in a data bank; all his or her personal data included in such data bank; the purpose of the processing and eventual assignees of such information.

Right to have personal data rectified, updated and deleted: These rights allow any person to correct false, wrong, incomplete or incorrect information included in a database.

Right to data portability: The right of a data owner to receive from the person in charge of the processing the personal data provided to said person with his or her consent or the right to have such data transferred to another person in charge of the processing when such information is processed automatically. Portability allows the data owner to transfer or reuse his or her personal data with other companies.

Right to suspend personal data processing activities: The right of a data owner to request the person in charge of a database the suspension of his or her personal data processing until his or her request to rectify or delete the personal data stored in such database is resolved.

Sensitive Data: Personal information affecting the owner´s private sphere that could potentially give rise to illegal or arbitrary discrimination, in particular, regarding race or ethnic origin, political opinions, religious, philosophical or moral beliefs, trade union participation or affiliation, health or sexual preferences.

10. Changes in our privacy policy?

This privacy policy may be modified periodically. The last version will be available at www.icao4pilots.com.

The use of the App and/or the Website after this Privacy Policy has been modified implies the acceptance of such modifications. If You do not agree to them, you may unsubscribe from the App and cancel your account immediately. We will never substantially modify this policy to make it less efficient in terms of personal data protection.

11. How can you contact us?

If You have any question in relation to this Privacy Policy, please contact us by email: info@icao4pilots.com “Ref: “Privacy Policy. Personal Data.” The person in charge of data protection in the Company, responsible for the correct and effective application of this policy, will answer your enquiry.