We, Lufthansa Aviation Training GmbH (hereinafter also referred to as “LAT GmbH” or “we”, or “us”), would like to provide you with information on how we process your personal data when you use our website www.interpersonal-competence-training.com (“website”).
Should you have any further questions regarding data protection in connection with our website or the services offered on it, please contact our data protection officer:
Lufthansa Group Data Protection Officer
Dr. Barbara Kirchberg-Lennartz
Deutsche Lufthansa AG
2. Scope, Purpose, and lawful Basis of processing personal Data
We collect and use personal information directly from our users or from other sources (as described below) in the following situations:
2.1. Use of the Website and Creation of Log Files
When users visit our website, our system automatically collects data and information about the computer accessing our website each time our website is accessed. In the process, the following data (“technical information”) is collected:
(1) Information about the type and version of browser used
(2) The user’s operating system
(3) The user’s internet service provider
(4) The user’s IP address
(5) The date and time the website was accessed
(6) Websites from which the user accessed our website
(7) Websites and files that were accessed by the user’s system from our website, as well the following information: the method of access and protocol
(8) The size of the file/page accessed
This data is also saved in our system’s log files. This data is not stored together with any other personal data about the user. We collect and use this technical information for purposes of (network) security (e.g. to combat cyberattacks), marketing, and to better understand the requirements of our users, as well as to continuously improve our website and enable the respective user to access the website from their computer. This information is stored in log files to guarantee the website’s functionality. In addition, we use the data to optimize our website and to ensure the security of our information technology systems. We do not process the data collected in this context for marketing purposes. The lawful basis for the temporary storage of data and log files is article 6(1)(f) of the GDPR.
2.1.2. Tracking Tools
We use the following tracking and marketing tools (including for remarketing) on our website:
The legal basis for the use of the aforementioned tools is our legitimate interest pursuant to article 6(1)(f) of the GDPR for the purposes of increasing the efficiency of our website and our marketing activities (including direct marketing).
Further information about the individual tools can be found in the Annex/Tracking Tool Policy.
2.2. Use of the Services offered on our Website
We offer a wide range of services on our website. In order to provide these services, we must collect and process personal data from users or our customers.
2.3. Processing personal Data on the Basis of our legitimate Interests
In the event that article 6(1)(f) of the GDPR is our legal basis for processing, in addition to the purposes listed above, our legitimate interests include:
- Protecting the company from material or immaterial damage
- Professionalization (of our products and services)
- Cost optimization (cost control and cost minimization)
2.4. Further Obligations to process Data
Insofar as we are legally obligated to do so, we also process personal data in order to comply with our obligation to retain data as set forth in applicable commercial or tax law or to meet security requirements (e.g. section 7 of the Luftsicherheitsgesetz (LuftSiG), German aviation security act). Further information about retention periods can be found under Duration of Data Processing.
2.5. Obligation to provide personal Data
In order to meet statutory or contractual requirements, we have marked the respective fields in the forms on our website that must be filled out so that we can perform the requested contract or service.
3. Duration of Data Processing
Your personal data will be erased as soon as it is no longer required for the aforementioned purposes. In this context, personal data may be stored for the period of time during which legal claims can be asserted against Lufthansa Aviation Training GmbH (statutory limitation period of three to thirty years). In addition, personal data is stored to the extent and for as long as Lufthansa Aviation Training GmbH has a legal obligation to do so. Corresponding documentation and retention obligations result from Germany’s Commercial Code, tax code, and money-laundering act, among others. Based on the aforementioned laws, data can be stored for a period of up to 10 years.
4. Right to object pursuant to Article 21 of the GDPR
You have the right to object, at any time, on grounds relating to your particular situation, to the processing of personal data concerning you, which is based on point (e) or (f) of article 6(1) of the GDPR, including profiling based on those provisions.
If you make such an objection, the controller will no longer process your personal data unless the controller can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.
Where personal data is processed for direct marketing purposes, you have the right to object, at any time, to the processing of your personal data for the purpose of such marketing; this also applies to profiling insofar as it is conducted in conjunction with such direct marketing.
If you object to the processing of your personal data for direct marketing purposes, we will cease to process your personal data for this purpose.
In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications.
Where personal data is processed for scientific or historical research purposes or statistical purposes pursuant to article 89(1) of the GDPR, you have, on grounds relating to your particular situation, the right to object to the processing of your personal data unless the processing is necessary for the performance of a task carried out for reasons of public interest.
5. Disclosure of personal Data to Third Parties
In order to be able to offer you our products and services based on our contractual obligations or in accordance with our legitimate interests, we may have to disclose your personal data to third parties within or outside the Lufthansa Group. These recipients can be categorized as follows:
In this context, personal data may be transferred to third countries or international organizations. For your protection and the protection of your personal data, such data transfers are subject to appropriate safeguards pursuant to and in accordance with the applicable legal requirements (in particular application of EU standard contractual clauses) or an adequacy decision adopted by the EU Commission (article 45 of the GDPR).
Information about EU standard contractual clauses can be found here: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:039:0005:0018:EN:PDF. The EU Commission provides information on its adequacy decisions at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en#dataprotectionincountriesoutsidetheeu.
You can also request a copy of the security measures we implement by sending an e-mail to dsb(at)dlh.com. In addition, we are legally obligated to disclose personal data to German and international authorities pursuant to article 6(1)(c) of the GDPR in conjunction with local and international regulations and agreements.
international authorities pursuant to article 6(1)(c) of the GDPR in conjunction with local and international regulations and agreements.
6. Rights of the Data Subject
Ensuring our processing operations are fair and transparent is extremely important to Lufthansa Aviation Training GmbH. For this reason, it is important to us that you, as the data subject, can exercise the following rights, in addition to the right of objection, if the respective legal requirements are met:
- Right of access pursuant to article 15 of the GDPR;
- Right to rectification pursuant to article 16 of the GDPR; Right to erasure (“right to be forgotten”) pursuant to article 17 of the GDPR;
- Right to restriction of processing pursuant to article 18 of the GDPR;
- Right to data portability pursuant to article 20 of the GDPR
To exercise your rights, simply send an e-mail to dsb(at)dlh.com. In this case, we would like to point out that in order to process your request and to identify you, we will process your personal data in accordance with article 6(1)(c) of the GDPR.
In addition, you have the right to lodge a complaint with a supervisory authority. The supervisory authority responsible for Lufthansa Aviation Training GmbH is:
Bayerisches Landesamt für Datenschutzaufsicht (BayLDA, Bavarian data protection authority)
Promenade 27 (Schloss)
If you have given us your consent to process your personal data, we hereby inform you that you have the right to withdraw this consent at any time.
If you have given your consent on this website, please visit the page where you originally gave your consent, or log in with your LH iD to withdraw your consent in the settings.
In all other cases or if you have any difficulties withdrawing your consent on this website, you can send an e-mail to dsb(at)dlh.com.
Please note that the withdrawal of consent only applies to the future and does not affect the lawfulness of processing based on consent before its withdrawal. In certain cases, we may be authorized to continue processing your personal data on another legal basis – such as to fulfil a contract – despite your withdrawal.