Privacy policy 

Effective from February 11th, 2024

1. GENERAL INFORMATION ABOUT PRIVACY POLICY

The company VictorOne, services in aviation, d.o.o. is responsible for the protection of personal data (hereinafter the service). This document explains how and why your personal data is processed, where “you” or “customer” refers to the person, company or organization who uses the services of “VictorOne”, “we” or “our” refers to the company VictorOned.o.o. that provides the services.

VictorOne d.o.o., services in aviation, located at Mestni trg 10, 1000 Ljubljana, Slovenia, with identification number 931049500 and tax number 33120668, is data controller responsible for the collection, use, disclosure, retention of your personal information in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679), and on the Personal Data Protection Act, Official paper of the Republic of Slovenia, no. 163/22 – official consolidated text (ZVOP-2).

The services we offer include accompanying service activities in air transport.

Victorone d.o.o. keeps personal data in such a way that data is not disclosed to person who are not entitled to it.

2. WHAT TYPES OF PERSONAL DATA WE COLLECT AND PROCESS

Personal data, or personal information, means any information about an individual from which that person can be identified, directly or indirectly.

We collect and process the following data relating to you: name, nationality, date of birth, residence, tax residency, tax number, bank details, bank account and all other valid documents (valid licenses, etc.). For verification purposes: any document you submit to us for verification of personal data. These are mainly copies of government-issued documents together (eg document number, date of issue, issuer and validity) and digital. We also collect and process when you use our services, web cookies, individual geolocation data and social network data.

3. HOW IS YOUR DATA COLLECTED

We collect personal data in various ways, namely: when you fill out forms, upload documents, when you communicate with us by post, phone, e-mail, mobile application, website, video call or otherwise.

4. HOW WE USE YOUR DATA

We will use your personal data in the following circumstances:

• Due to the implementation of the contract that we will conclude or have concluded with you.
• In enrolling for Language Testing Body SI.LTB.001 services
• To comply with our legal obligations.
• When it is in our legitimate interests.
• If you have provided express consent for specific personal data and its intended use.

Below we state which personal data we will process, the purpose and the basis on which we refer.

• Explanation of legal basis

In accordance with the legal basis in the management and administration of our services, these also concern:

• Ensuring that our services are improved for you (e.g. by determining your satisfaction with our services).
• Promotion of our services, especially the transmission of advertisements or offers that we can send to you via e-mail or through other channels that we use.
• Detection and prevention of property damage or financial loss.

In order to protect legal claims and maintain our internal records and controls, we process data for a period of 5 years after which they are arcived in relation to claims that are asserted by the end of the statute of limitations. In the case of legal, administrative or other proceedings, we process your personal data for the period necessary for the duration of such proceedings and for the remainder of the limitation period after its completion.

Compliance with legal obligations means processing your personal data when this is necessary to fulfill the legal obligations to which we are bound.

Identification and contact data, your settings are stored on the basis of legitimate interest, which means without your express of consent.

• Profiling and automated decision-making

Some of our processes may include profiling, automated processing and automated decisions.

To improve your user experience or we may use automated individual decision-making, e.g. to verify your personal documents or to confirm the accuracy of the information you have submitted to us.

• Change of purpose

We will only use your personal data for the purposes for which we collected them. In the event that we need to use your personal data for a purpose for which we did not collect it, we will notify you and provide a legal basis for action.

5. STORAGE AND SECURITY OF YOUR INFORMATION

Your personal data is collected and processed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and the annulment of Directive 95/46/EC (General Data Protection Regulation). First of all, they are stored and processed only within the European Economic Area (EEA).

For the data we collect, we use a major and reliable service provider that complies with ISO 27001. We also use technical measures to safeguard and protect your data, including but not limited to:

• end-to-end encrypted communication,
• encryption of the database,
• regular backups,
• secure storage of authentication data,
• limiting access rights.

Only our employees and contract partners have access to your personal data. Your personal data will be processed only according to our instructions, and they are bound by the duty of confidentiality.

• Data storage

 The retention period of your personal data depends on the purpose for which we collected it. After the processing purpose is fulfilled and if we have no legal basis for storage and processing, they are deleted, destroyed or anonymized.

6. TO WHOM WE DISCLOSE YOUR DATA

The following persons can access your personal data: our employees and contractual partners who participate in the smooth operation of our services.

We share your personal data with:

• Bristol Groundschool (BGS) to store and process data we receive from you in the cloud.
• Aviationexam and ATPL Questions for account activation
• Apple Inc. and Google LLC to enter push notifications.
• Moodle Experts for customer support and notifications.
• Revolut for providing payment services

VictorOne d.o.o. may also provide personal data to third parties, in the event that this is required by law. These are mainly: the Financial Administration of the Republic of Slovenia, the police, the court, etc.

We may also disclose personal data to our business partners, subsidiaries, or in the event that this would be required in the implementation of the contract with our contractual partners.

• External services

The Website may include links to third-party websites, plugins, channels or third-party applications. If you click or enable these links, you may allow third parties to collect or share information about you. We do not control these third parties and are not responsible for their privacy statements. After you leave our app or website, we advise you to read the privacy statement of each website or app you visit.

7. WHAT RIGHTS YOU HAVE REGARDING YOUR DATA

Personal data protection legislation gives you the following rights:

• The right to access your personal data that we hold.
• The right to correct inaccurate, incorrect or outdated personal data.
• The right to delete your data when they are no longer needed for the purpose for which they were collected, or if they are no longer subject to legal obligations to which we are bound.
• The right to request that we stop processing some of your personal data, such as personal data processed for direct marketing purposes. You also have the right to object solely to the automated processing and profiling of activities based on our legitimate interests.
• The right to request that we restrict the processing of your personal data, e.g. in the following cases, if you dispute the accuracy of the data, if the individual has filed an objection regarding data processing, etc.
• The right to request the export of your personal data.
• If you have consented to the collection and processing of personal data by us, you may revoke this consent at any time.

We have to provide you with the requested information free of charge and we try to answer it as soon as possible. The company VictorOne d.o.o. is obliged to respond to your requests without undue delay, or within one month at the latest. It may happen that we will ask you for certain information that will help us confirm your identity and thereby guarantee you the right to access your personal data.

When requests are clearly unfounded, excessive or repetitive, we may refuse to act on the request. For the smooth operation and offering of services, it is crucial that personal data is accurate, so please notify us in time of any changes.

• Complaint

In relation to the collection and processing of your personal data, you have the right to file a complaint, for the resolution of which the competent supervisory authority the information commissioner (https://www.ip-rs.si/en/) is responsible. Nevertheless, we would like the opportunity to handling of your complaints, you can contact us via post or email listed below.

8. UPDATE OF GENERAL INFORMATION

We reserve the right to make changes to this document to ensure compliance of our services with personal data protection regulations.

9. CONTACT

More detailed information or a complaint can be sent to the e-mail info@victorone.eu or by mail to VictorOne d.o.o., Mestni trg 10, 1000 Ljubljana, Slovenia. All messages must be in Slovenian or English.